Compliance - Digital tools and personal support

Lantero currently partners with around 80 of Sweden’s municipalities. Through this unique insight, we see a clear development: activity within municipal whistleblowing channels is increasing. But what is actually driving this development, how are the incoming cases best managed, and what new administrative challenges are waiting around the corner? We summarize some of the key insights based on a conversation with whistleblowing expert Andreas Wahlström. ### Increased Awareness and Turbulent Periods The fact that more reports are being submitted is primarily due to two things: increased trust and better information. Employees are becoming increasingly aware that these channels exist and trust that they are secure. However, this is not an entirely universal trend; activity varies greatly from one municipality to another. We see a clear link to two specific factors: 1. Focus on Welfare Crime: In municipalities that actively combat corruption and welfare crime, the propensity to report increases. 2. Turbulence and Change: Organizations undergoing a phase of restructuring or turbulence often experience higher pressure in their channels. Experience also shows that municipalities that are engaged and skilled at continuously training their staff receive more—and more relevant—reports. ### Screening and the Need for Investigative Expertise One of the greatest challenges for a municipality is managing the breadth of what is reported. Less than half of the incoming cases actually fall under the strict definition of the Whistleblowing Act. Much of it instead concerns general complaints or personnel matters. Despite this, a large portion of the reports carry significant value for the employer to be made aware of and to follow up on. Once a complex case has been identified, the next challenge arises: the investigation. Conducting an investigation internally can be legally and operationally complicated. A clear trend is therefore that more and more municipalities choose to bring in external expertise to quality-assure the investigative work and guarantee an independent review. ### The New Administrative Challenge: "War of the AI:s” Once a case has been handled, it does not always end there. Awareness among journalists and the public regarding the existence of these channels has increased, which has led to a significant spike in requests to extract documents from the systems. This is largely driven by AI technology. Since reviewers can now use AI to read and summarize vast amounts of text, they do not hesitate to request extensive logs and all available cases. For the already heavily burdened municipal case officers, this creates immense administrative pressure, as confidentiality and harm assessments (skadeprövning) must be carried out promptly and meticulously, since accidental disclosure of sensitive information can have severe consequences. To meet this AI-driven wave of requests, the municipalities themselves have begun implementing AI support in their processes. By allowing an AI to handle the groundwork and flag potential confidentiality risks, administrative time can often be cut by around 80%. This frees up time so that case officers can focus on what only a human can do: the final, qualified harm assessment.

Approximately four years have now passed since the Swedish Whistleblowing Act entered into force for the country's municipalities. This means that the first generation of procured contracts and system solutions is now expiring, which has triggered an intensive wave of contract renewals and direct procurements. Looking back at the past four years, it is clear that much has changed. From being a completely new and untested legal requirement, the field has matured significantly. Here, we summarize the three clearest trends and challenges shaping municipal whistleblowing solutions right now. 1. Higher Quality and the Decline of Clusters When the legislation was first introduced, uncertainty was high. Many municipalities pooled their resources into large clusters for joint procurements, and several attempted to build their own internal solutions. Today, we see a completely different level of confidence in the market. Clearer Specifications: Municipalities have gathered valuable experience. They know exactly what they want, and the procurement specifications are of a significantly higher quality. There is a demand for system solutions with specific functionality, such as integrated login (Single Sign-on) and advanced AI support for masking sensitive information when responding to public records requests. More External Sourcing: Organizations that previously attempted to manage channels entirely internally are now increasingly choosing to seek external assistance, both with the reporting solution and with parts of the case management. Independent Sourcing Replaces Coordination: The tendency to join large clusters has decreased. Because the process has proven to be smooth and uncomplicated, most municipalities now choose to handle their procurements independently. Furthermore, contracts are being signed for significantly longer periods than before (often up to 6 or 7 years), as the cost structure has stabilized and trust in suppliers has grown. 2. Large vs. Small Municipality: Independence in Focus The need for support in the process naturally varies depending on the size of the organization, but interestingly, resources are not the primary deciding factor. The very large municipalities often have the capacity to handle a large part of the case management internally. For other municipalities, it instead comes down to two critical factors: independence and competence. In a smaller municipality, where a case officer might only handle a handful of cases per year, the learning curve is steep and the challenges are completely new each time. Additionally, it is operationally difficult to guarantee a completely independent and impartial internal process. Therefore, external parties are increasingly in demand to step in more actively in the workflow, perform initial assessments, and act as a sounding board or investigator in more complex cases. 3. The Swedish Work Environment Authority Steps Up Inspections After maintaining a relatively passive profile during the initial years, the Swedish Work Environment Authority (Arbetsmiljöverket), as the supervisory authority, has now sharply increased its audits. They conduct regular inspections to review how channels actually function—and there is a clear common thread in what they look for. Right now, the authority’s focus is primarily on the written word. They compare the literal text of the law with the organization's internal policy documents and documented routines. They simply assume that what is written in the organization's guidelines reflects their practice. Sooner or later, the authority will knock on the door of most public actors, and when that happens, the documentation must hold up to scrutiny. How are you preparing? The market has shifted from uncertainty toward standardization and stability. This is highly visible among municipally owned companies—even those with well under 50 employees that are not formally covered by the legal mandate. Many of them still proactively choose to implement external whistleblowing channels, both for the purely business value of capturing useful information and as an important part of their employer branding. Should you receive an inquiry from the Swedish Work Environment Authority, or are you about to renew your current contracts? As a Lantero client, we are always available to provide direct support. We help you prepare accurate responses for the authority and continuously update our documentation and texts based on current practice and experiences from previous supervisory cases.

Every year on June 23rd, we recognize World Whistleblowers Day. The day was established to acknowledge and honor those who blow the whistle on corruption, misconduct, and irregularities, as well as to recognize heroic efforts in defending human rights and democracy. In public debate, being a whistleblower is generally perceived as something highly honorable. In practice, however, it is often a very thankless role, rarely met with goodwill. The whole idea is that you fight for what you believe is right, but in opposition to the prevailing order where you operate. In reality, this also frequently means entering into conflict with your employer, your colleagues, and your superiors. At Lantero, we work with whistleblowers and whistleblowing cases every single day. We know that reported cases often miss the mark. Sometimes they are matters that do not belong in the channel at all, such as issues concerning interpersonal conflicts or leadership. Other times, they stem from a misinterpretation of the circumstances. Those who report are often driven by a strong sense of justice. But just as often as actual violations are brought to light, the report may be based on an overinterpretation or misconstruction of the situation. Whistleblowers tend to be of a personality type that dares to go against consensus, which in certain situations is admirable and valuable. In practice, however, the individual is often perceived as a crank or a troublemaker. We at Lantero constantly remind ourselves of this duality. It is easy to see the troublemaker and focus on cases that perhaps should be handled face-to-face between a couple of colleagues. At the same time, these are the very individuals who are prepared to stand up and sound the alarm when something is genuinely wrong. As professionals working with these issues daily, we tip our hats to this often thankless commitment. Today, let us celebrate our challenging, yet upstanding and vital whistleblowers!