NORWAY Law and Practice Contributed by: Elisabeth Roscher, Geir Sviggum, Tine Vigmostad and Kristin Nordland Brattli, Wikborg Rein Advokatfirma AS
as objectionable in Section 2 A-1 (2), as set out above. Examples of matters that would not nor - mally be considered “objectionable conduct” within the meaning of the Working Environment Act include dissatisfaction about one’s salary, workload, distribution of work or occupational disagreements. Procedure for Notifications An employee may report concerns through various channels, including internally to the employer or a representative of the employer, in accordance with internal reporting procedures, in accordance with relevant reporting obligations or via a health and safety union or legal repre - sentative (Section 2 A-2 of the Working Environ - ment Act). An employee may also report exter - nally to a public supervisory authority or other public authority. In certain (albeit more limited) circumstances, an employee may also report directly to the media or the public. Prohibition Against Retaliation The right to report concerns is safeguarded by way of a prohibition against retaliation. It follows from Section 2 A-4 of the Working Envi - ronment Act that retaliation against an employee or hired worker who notifies their employer or hirer of any objectionable conduct, in accord - ance with the procedure set out above, is pro - hibited. The prohibition against retaliation also applies in cases where the employee or hired worker has signalled their future intention to report; for instance, by providing information about objectionable conduct. In this context, retaliation would include any detrimental act, practice or omission that is a consequence of, or reaction to, the employee or hired worker’s report. Examples of “detrimental acts” include:
• threats, harassment, arbitrary discrimination, social exclusion or other improper conduct; • warnings, change of duties, relocation or demotion; and • suspension, dismissal, summary discharge or disciplinary action. 6.5 Incentives Provided to Whistle- Blowers There are no general financial incentives for whistle-blowers to report bribery or corruption in Norway. However, an employee may, in certain cir - cumstances, have an obligation to notify their employer of objectionable conduct in cases where the employee becomes aware of circum - stances such as (Section 2–3 of the Working Environment Act): • faults or defects that may involve a danger to life or health; • harassment or discrimination in the work - place; or • an employee suffering injury at work or dis - eases believed to be a result of the work or working conditions. Please note that there are also some regulated professions that have an obligation to notify rel - evant authorities of suspicious transactions or activities, such as auditors and employees of financial institutions. There is also an obligation for companies subject to the requirements of the Norwegian Act relat - ing to measures to combat money laundering and terrorist financing of 1 June 2018 No 23 (the “Anti-money Laundering Act”) to report circum - stances giving grounds for suspicion of money laundering or terrorist financing to the authori - ties (Section 26 of the Anti-money Laundering
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