COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report Country Chapter on the rule of law situation in Denmark Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2020 Rule of Law Report The rule of law situation in the European Union
Date: 2020-09-30
Institutions: European Commission, Secretariat-General
Subjects: Denmark, administrative transparency, coronavirus disease, corruption, democracy, epidemic, independence of the judiciary, infringement of EU law, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.9.2020  SWD(2020) 303 final  COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report Country Chapter on the rule of law situation in Denmark Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS  2020 Rule of Law Report     The rule of law situation in the European Union {COM(2020) 580 final} - {SWD(2020) 300 final} - {SWD(2020) 301 final} - {SWD(2020) 302 final} - {SWD(2020) 304 final} - {SWD(2020) 305 final} - {SWD(2020) 306 final} - {SWD(2020) 307 final} - {SWD(2020) 308 final} - {SWD(2020) 309 final} - {SWD(2020) 310 final} - {SWD(2020) 311 final} - {SWD(2020) 312 final} - {SWD(2020) 313 final} - {SWD(2020) 314 final} - {SWD(2020) 315 final} - {SWD(2020) 316 final} - {SWD(2020) 317 final} - {SWD(2020) 318 final} - {SWD(2020) 319 final} - {SWD(2020) 320 final} - {SWD(2020) 321 final} - {SWD(2020) 322 final} - {SWD(2020) 323 final} - {SWD(2020) 324 final} - {SWD(2020) 325 final} - {SWD(2020) 326 final}  
 
 
ABSTRACT 

The  Danish  judiciary  enjoys  a  consistently  high  perceived  level  of  independence  and  some 
steps  have  been  taken  in  2019  to  further  improve  the  framework  for  disciplinary  measures 
and  accountability  of  judges.  The  justice  system  is  characterised  by  a  good  level  of 
efficiency, despite a slight increase of the disposition time in the past years. At the same time, 
stakeholders  have  raised  some  concerns  over  a  lack  of  sufficient  resources  and  some 
challenges  remain  as  regards  the  digitalisation  of  the  judiciary.  Several  initiatives  by  the 
Government  and  the  National  Courts  Administration  aim  to  address  these  challenges, 
including  through  a  project  to  use  digital  tools  to  monitor  the  average  length  of  pending 
cases. 

According to surveys, Denmark is perceived as one of the least corrupt countries in the EU 
and  the  world.  Although  Denmark  has  no  dedicated  anti-corruption  strategy  or  agency  in 
place, it has established an Anti-Corruption Forum that improves coordination for authorities 
to  produce  their  own  anti-corruption-related  arrangements.  Danish  public  institutions  have 
built  a  reputation  for  transparent  administration  and  a  reliable  and  functional  corruption 
prevention  framework.  A  central  aspect  of  the  integrity  system  is  the  low  degree  of 
formalisation of anti-corruption rules on ethics and integrity, with few regulations and control 
measures  to  prevent  corruption,  particularly  for  top  executive  functions.  Denmark’s  track 
record of implementing recent international recommendations, in particular on political party 
funding and oversight of members of Parliament, is limited. 

The national media regulatory authority, the Danish Radio and Television Board, operates in 
an independent manner and has a robust organisational structure. There are no specific laws 
regulating transparency of media ownership but the national Central Business Register could 
be  used  to  access  some  information.  Certain  exceptions  to  the  Access  to  Public 
Administrative  Documents  Act  have  been  introduced,  partly  restricting  the  right  to  access 
information  in  practice.  A  specific  Commission  on  Freedom  of  Expression  has  been  set  up 
with  the  purpose  of  promoting  the  debate  on  the  framework  and  general  conditions  for 
freedom of expression, a freedom which is protected by the constitution and already benefits 
from the robustness of democratic tradition and institutions in Denmark. 

The  system  of  checks  and  balances  is  characterised  by  an  inclusive  process  for  enacting 
legislation  with  a  comprehensive  framework  for  preparing  legislation,  including  the 
consultation  of  stakeholders.  The  Parliamentary  Ombudsman  has  a  well-established  role  in 
ensuring oversight over the decisions of public authorities. Recent campaigns by the National 
Courts Administration aim at raising awareness of the importance of the rule of law and the 
role  of  the  judiciary,  including  through  educational  videos,  curricula  for  teachers  and  a 
dedicated website for journalists. The Danish Institute for Human Rights ensures involvement 
of a broad range of civil society organisations through its Human Rights Council, which has a 
key advisory function. 

1 

 
 
 
I.  JUSTICE SYSTEM  

The  Danish  justice  system  consists  of  24  district  courts,  two  high  courts  (courts  of  appeal) 
and  a  Supreme  Court,  as  well  as  two  specialised  courts1.  The  independent  National  Court 
Administration  is  in  charge  of  the  administration  and  development  of  the  courts,  which 
includes  allocation  of  courts’  budgets  and  management  of  buildings  and  ICT  systems.  The 
independent  Judicial  Appointments  Council2  makes  non-binding  proposals  for 
the 
appointment  of  judges  to  the  Ministry  of  Justice,  who  then  proposes  them  for  formal 
appointment by the executive (the Queen)3. Only one judge is proposed per vacancy by the 
Appointments  Council.  There  have  been  no  cases  where  the  executive  did  not  follow  the 
proposal of the Appointments Council. For transparency, the Judicial Appointments Council 
issues a press release when making their proposal for a vacancy. The Prosecution Service is 
an autonomous institution acting under the supervision of the Ministry of Justice and led by a 
Prosecutor General4. The Law and Bar Society is the independent body governing the legal 
profession and ensuring its independence5.  

Independence  

The  judiciary  enjoys  a  very  high  level  of  perceived  independence.  Overall,  86%  of  the 
general public and 80% of companies consider the independence of courts and judges to be 
‘fairly or very good’, with a notably high percentage of the general public (41%) considering 
independence to be ‘very good’. These figures have overall been stable at a high level since 
2016 for the general public and are similarly consistent for businesses since 20106.  

Several  measures  have  been  taken  to  strengthen  the  accountability  framework  for 
judges  and  its  safeguards.  Two  types  of  disciplinary  measures  for  judges  exist:  court 
presidents can issue a warning to a judge for negligence or carelessness in their performance, 
while the Special Court of Indictment and Revision7 can issue warnings, impose fines and in 
case  of  serious  misconduct,  dismiss  a  judge  or  suspend  them  if  criminal  proceedings  have 

1   The  Maritime  and  Commercial  Court  and  the  Land  Registration  Court.  CEPEJ  (2020),  Study  on  the 

functioning of the judicial systems in the EU Member States.  

2   Members  are  appointed  by  the  Minister  of  Justice  and  consist  of  one  Supreme  Court  and  one  High  Court 
judge proposed by the respective courts, one District Court judge proposed by the Judges Association, one 
lawyer  proposed  by  the  Bar  and  Law  Society  and  two  representatives  of  the  general  public  proposed  by 
Local Government Denmark and the Danish Adult Education Association. 

3   With  the  exception  of  the  president  of  the  Supreme  Court,  who  is  selected  and  appointed  directly  by  the 
Supreme Court according to an internal procedure. In addition, as regards members of the Supreme Court, 
the law sets out a special procedure under which the candidate chosen by the appointments board is vetted by 
judges of the Supreme Court before the appointment is confirmed. 

4    The  Prosecutor  General  is  appointed  by  the  executive  (formally  the  Queen)  on  recommendation  of  the 
Minister of Justice following approval of the Governments’ Recruitment Board and can be dismissed on a 
motivated  recommendation  of  the  Minister  of  Justice  (in  the  latter  case  the  recommendation  is  submitted 
directly to the Queen).  

5   Administration of Justice Act, Section 15.  
6   Figures  44,  46  and  48,  2020  EU  Justice  Scoreboard.  The  level  of  perceived  judicial  independence  is 
categorised as follows: very low (below 30% of respondents perceive judicial independence as fairly good 
and  very  good);  low  (between  30-39%),  average  (between  40-59%),  high  (between  60-75%),  very  high 
(above 75%). 

7   The Special Court of Indictment and Revision is composed of one Supreme Court, High Court and District 
Court  judge  each,  one  lawyer  and  one  professor  of  law,  appointed  by  the  executive  on  nomination  by  the 
judiciary (for the judges-members) and the Bar and Law Society (for the lawyer).  

2 

 
 
                                                 
been instituted against the judge8. Since 2019, a warning given by a court president can also 
be appealed to the Special Court of Indictment and Revision9, adding an additional safeguard 
to  the  system,  which  is  consistent  with  Council of  Europe  recommendations10.  This  reform 
was triggered inter alia by the Judges’ Association, based on a specific case in which a judge 
had received a warning by a President that the judge considered to be unfounded, but had no 
possibility for review. Another relevant development regarding the accountability framework 
for judges is the adoption by the Judges’ Association (in cooperation with the National Courts 
Administration) of interpretative explanatory comments to the ethical  guidelines for judges. 
The  comments,  adopted  in  2019,  further  specify  the  2014  ethical  guidelines  for  judges  by 
providing  concrete  examples  for  their  application.  This  also  replies  to  a  recommendation 
from Group of States against Corruption (GRECO)11. 

The power of the Minister of Justice to issue instructions to the prosecution service in 
individual cases is accompanied by safeguards and not used in practice. According to the 
Administration of Justice Act, the Minister of Justice can issue general guidelines for how the 
prosecution  carries  out  its  tasks,  as  well  as  give  instructions  to  prosecutors  in  individual 
cases, which can include an instruction not to prosecute.12 The instruction must be issued in 
writing, be reasoned, and sent to the Speaker of Parliament in writing.13 In practice, according 
to  the  authorities,  it  appears  that  there  was  only  one  case  of  such  an  instruction  by  the 
Minister  of  Justice,  which  took  place  in  1995,  and  where  the  Prosecutor  General  was 
ineligible to give an instruction due to a conflict of interest. This practice, combined with the 
legal  safeguards  in  place,  appear  to  mitigate  the  risk  to  the  autonomy  of  the  prosecution14. 
Following the recent case law of the Court of Justice of the European Union on the European 
Arrest Warrant15, the existence of this right to instruction has led Denmark to change in 2020 
its procedure for issuing such arrest warrants16. 

8   Decisions  by  the  Special  Court  of  Indictment  and  Revision  can  be  appealed  to  the  Supreme  Court. 

Administration of Justice Act, Section 48-49.  

9   Administration of Justice Act, Section 48a.  
10   Recommendation  CM/Rec(2010)12 of the  Committee of  Ministers of  the  Council of Europe, para 69. See 

also judgment of the Court of Justice of 25 July 2018, LM, C-216/18 PPU, para. 67. 

11   GRECO  Fourth  Evaluation  Round,  recommendation  v,  which  GRECO  now  considers  to  be  implemented 
satisfactorily.  GRECO  Fourth  Evaluation  Round  -  Interim  Compliance  Report,  p.  5.  See  also  ECtHR, 
judgment of 9 January 2013, Oleksandr Volokov v. Ukraine, application n° 21722/11, §§ 175-179. 

12   Administration of Justice Act, section 98(3). Separately, there are cases in which the Minister of Justice must 
by  law  decide  whether  a  case  is  to  be  prosecuted  or  not,  including  for  terrorism-related  offences,  high 
treason and offences against the state, Administration of Justice Act, Chapter 12.   

13   Figure 55, 2020 EU Justice Scoreboard.  
14   According to Recommendation Rec(2000)19 of the Committee of Ministers of the Council of Europe, para. 
13(d),  “where  the  government  has  the  power  to  give  instructions  to  prosecute  a  specific  case,  such 
instructions  must  carry  with  them  adequate  guarantees  that  transparency  and  equity  are  respected  in 
accordance with national law”. As regards the safeguards, para. 13 (points d to e). 

15   Judgment of the Court of Justice of 27 May 2019 in joined cases OG, C-508/18 and PI, C-82/19 PPU. 
16   As of 15 February 2020, the courts are the only authority competent to issue a European Arrest Warrant. Act 
on the Extradition of Offenders, Section 46 and 47. See also the Report by the European Commission on the 
implementation  of  Council  Framework  Decision  of  13  June  2002  on  the  European  arrest  warrant  and  the 
surrender procedures between Member States, p. 5-6. 

3 

 
 
 
 
                                                 
Quality  

Some concerns have been raised over the decreasing expenditure for the justice system. 
Denmark’s  expenditure  on  law  courts  as  a  percentage  of  GDP  is  low  and  has  decreased  in 
past years17. The number of judges per inhabitant is also notably low18. A 2020 report by the 
Association of Judges on ‘The judges’ working conditions’ provides a detailed analysis of the 
workload of judges, highlighting that the number of judges has stagnated and resources have 
slowly been reduced since 2011, while the  caseload has increased19.  In particular, concerns 
have been raised over the decrease in court staff, which places a higher workload on judges. 
In  June  2020,  the  Government  granted  additional  funding  to  the  courts  to  deal  with  an 
increased  backlog  due  to  the  closure  of  courts  during  the  COVID-19  pandemic,  which 
provides for additional posts for judges20.  

Some  initiatives  to  address  outstanding  challenges  regarding  digitalisation  of  the 
judiciary are ongoing. Electronic means for submitting a case and summons online and for 
following the stages of proceedings are available only to a limited degree in courts21. While 
all third-instance judgments are published, this is only partially the case for first- and second-
instance  judgments  and  arrangements  for  machine-readability  of  judgments  are  limited22. 
According  to  information  from  the  National  Courts  Administration,  the  creation  of  a 
comprehensive online database of judgments, including anonymisation of judgments, is under 
preparation for 2021. The National Courts Administration is also implementing a project to 
use digital tools to monitor the average length of pending cases, which aims to help project 
future case handling times23.  

Efficiency 

The justice system handles its caseload efficiently, but the clearance rate has somewhat 
dropped. The estimated time to resolve civil, commercial, administrative and other cases is 
very low, and remains below average for litigious civil and commercial cases at all instances, 
although  it  has  slightly  increased  in  past  years24.  At  the  same  time,  the  clearance  rate  for 
litigious  civil  and  commercial  cases  has  somewhat  decreased  in  past  years,  dropping  from 
102% in 2017 to 95% in 2018 and 94% in 2019. The number of pending cases still remains 
low, in particular for litigious civil and commercial cases25.  

17   Expenditure per inhabitant is at an average level, but has also consistently decreased since 2012. Figures 32 

and 33, 2020 EU Justice Scoreboard.  
18   Figure 35, 2020 EU Justice Scoreboard. 
19   Danish Association of Judges, The judges’ working conditions, p. 5-8.  
20   Communique of Ministry of Justice of 24 June 2020, New judges must relieve the pressure on courts.  
21   Figure 27, 2020 EU Justice Scoreboard.  
22   Figure 28 and 29, 2020 EU Justice Scoreboard.  
23   Input from Denmark for the 2020 Rule of Law Report, p. 10.  
24   No separate data on administrative cases is available.  
25   Figures  5-15,  2020  EU  Justice  Scoreboard.  2019  data  regarding  the  clearance  rate  available  at:  Danish 

Courts, Civil Cases.   

4 

 
 
 
 
                                                 
II.  ANTI-CORRUPTION FRAMEWORK  

The anti-corruption system is to a large extent based on informal rules on ethics and integrity 
as  well  as  social  norms  and  public  scrutiny.  Several  authorities  are  involved  in  preventing 
corruption, promoting good administrative practice and compliance with the legal framework. 
This  includes  amongst  others  the  Financial  Supervisory  Authority,  the  Parliamentary 
Ombudsman and the Auditor General. The Employee and Competence Agency and the Prime 
Minister’s Office have responsibilities with regard to the promotion of integrity among civil 
servants and Ministers. A specialised unit for corruption and foreign bribery cases within the 
State  Prosecutor  for  Serious  Economic  and  International  Crime  has  special  competences  to 
investigate  serious  corruption  cases.  Prevention  of  corruption  is  broadly  regulated  for  civil 
servants, but Denmark currently has no specific law to protect whistle-blowers.  

Denmark  ranks  1st  both  in  the  European  Union  and  worldwide  on  the  Transparency 
International  Corruption  Perception  Index26.  Only  35%  of 
to  a 
Eurobarometer survey consider corruption to be widespread (EU average: 72%) and only 7% 
say that they are personally affected by corruption in their daily life (EU average: 26%). As 
regards  businesses,  16%  of  companies  consider  corruption  to  be  widespread  (EU  average: 
63%)  and  only  5%  of  companies  consider  that  that  corruption  is  a  problem  when  doing 
business  (EU  average:  37%).  25%  of  people  find  that  there  are  enough  successful 
prosecutions  to  deter  people  from  corrupt  practices  (EU  average:  36%)  while  51%  of 
companies  consider  that  people  and  businesses  caught  for  bribing  a  senior  official  are 
appropriately punished (EU average: 31%)27. 

respondents 

The  Danish  Criminal  Code  criminalises  corruption  and  related  offences.  The  criminal 
sanction  in  respect  of  active  bribery  and  passive  bribery28  in  the  public  sector  is  a  fine  or 
imprisonment  of  up  to  six  years  and  in  respect  of  bribery  in  the  private  sector29  a  fine  or 
imprisonment of up to four years. With regard to legal persons, fines can be imposed on legal 
persons in respect of an offence under provisions of the Criminal Code30. In 2018, Denmark 
adopted an amendment of the Penal Code on money laundering, which increases applicable 
penalties (from 6 to 8 years maximum penalty)31. 

Denmark  reviewed  its  overall  approach  to  enforcement  and  created  a  specialised  unit 
for  corruption  and  foreign  bribery  cases  within  the  Special  Prosecutor’s  Office  for 
economic crime (SØIK) in 2014. The Police, the Prosecution Service and a specialised unit 
within the Special Prosecutor’s Office for economic crime (SØIK) are the relevant authorities 
for  investigating  and  prosecuting  corruption.  SØIK  is  a  specialised  prosecution  department 
that  also  functions  as  coordination  body.  The  SØIK  also  hosts  the  national  financial 
intelligence  unit  and  has,  since  2015,  a  unit  for  international  cases,  including  cases 
concerning the bribery of foreign public officials32. Within the police, there has been a recent 
strengthening of procurement procedures and efforts to inform and train police officers on the 
Code  of  Ethics  adopted  in  201533.  A  whistle-blower  system  established  in  2019  allows  the 
reporting  of  criminal  offenses  and  violations  of  administrative  law,  including  conflicts  of 

26   Transparency International (2020), 2019 Corruption Perceptions Index. 
27   Flash Eurobarometer 482 (2019), Businesses’ attitudes towards corruption in the EU. 
28   Criminal Code. Section 122 and section 144. 
29   Criminal Code. Section 299 (2). 
30   Section 306 cf. section 2 
31   Folketinget (the Danish Parliament), act no 711 from 2018. 
32   UNCAC (2017), UNCAC implementation review – country review report of Denmark. 
33   GRECO Fifth Evaluation Round – Evaluation Report. 

5 

 
 
                                                 
interest.  Citizens  can  address  complaints  to  the  Independent  Police  Complaints  Authority, 
which  executes  external  oversight  and  control  of  the  Police  and  Prosecution  service34. 
GRECO  has  however  recommended  that  the  authorities  analyse  the  need  for  introducing  a 
requirement  for  police  officials  to  declare  financial  interests  on  a  regular  basis,  as  well  as 
measures  to  raise  awareness  of  police  staff  of  their  duty  to  report  corruption-related 
misconduct within the police service35. 

Denmark  does  not  have  a  dedicated  entity  for  promoting  integrity  and  preventing 
corruption,  but  rather  several  authorities  with  distinct  tasks.  Whilst  Denmark  does  not 
have  a  dedicated  anti-corruption  agency  or  strategy,  it  has  established  an  Anti-Corruption 
Forum36  which  meets  on  an  ad  hoc  basis  for  authorities  to  improve  coordination  and  share 
information.  Ministries  cooperate and draft  anti-corruption laws.  The Financial Supervisory 
Authority  has  issued  guidance,  manuals  and  instructions  on  ethical  conduct  and  financial 
aspects  of  the  fight  against  corruption.  The  Office  of  the  Auditor  General  audits  state 
institutions  and  examines  the  expenses  mandated  by  Parliament  and  State  Companies.  In 
addition, other authorities such as the Employee and Competence Agency at the Ministry of 
Taxation and the Prime Minister’s Office have tasks related to the promotion of integrity and 
preventing  corruption  related  to  the  management  of  public  administration37.  Denmark’s 
tradition  of  high  ethical  standards  and  transparency  in  public  procedures  has  led  to  few 
formal rules or control measures to prevent corruption, particularly for persons entrusted with 
top  executive  functions,  and  GRECO  has  recommended  to  formulate  rules  that  are  more 
binding38.  

The  Employee  and  Competence  Agency  has  issued  codes  of  conduct  for  civil  servants 
whilst ministers are provided with guidance on integrity matters upon appointment. A 
revised  version  of  the  Code  of  Conduct  in  the  public  sector  published  in  December  2017 
contains rules  on secondary employment and a decorum  requirement  for  public employees. 
The Employee and Competence Agency has published in 2017 the revised “Code of Conduct 
in the Public Sector” and in 2015 the “Code VII – 7 key duties” which set ethical standards 
and  rules  of  conduct  for  public  employees.  To  complement  these,  e-learning  courses  were 
developed  for  all  central  administration  employees.  However,  these  codes  do  not  apply  to 
ministers  who  are  provided  with  a  handbook  with  guidance  on  integrity  matters  upon 
appointment.  Denmark  also  has  no  code  of  ethics  for  parliamentarians  or  top  executive 
functions39,  although  these  are  addressed  in  a  public  letter  to  members  of  Parliament 
informing them of their responsibilities regarding ethical conduct and upholding public trust. 
GRECO has recommended to develop codes of conducts for both members of Parliament and 
members of the Government, in particular as regards conflicts of interest, and to develop an 
overall strategy for integrity of persons with top executive functions40. 

The  Public  Administration  is  bound  by  rules  on  impartiality,  which  entail  a  duty  to 
report any potential conflicts of interests. According to the Public Administration Act, any 

34   GRECO Fifth Evaluation Round – Evaluation Report, p 48. 
35   GRECO Fifth Evaluation Round – Evaluation Report, recommendations xiii and xiv. 
36   Brings together representatives of the Ministry of Justice, the Prosecutor General, the SØIK, the Ministry of 
Foreign  Affairs,  the  Ministry  of  Finance,  etc.  with  the  goal  of  improving  co-ordination  and  information 
sharing between authorities in the context of the fight against corruption. 

37   GRECO Fifth Evaluation Round – Evaluation Report, p. 17. 
38   GRECO Fifth Evaluation Round – Evaluation Report. 
39   A  code  of  conduct  entitled  “Good  Conduct  in  the  Public  Sector",  distributed  to  all  public  servants.  The 

purpose of this publication is to clarify basic duties and responsibilities for public sector employees. 

40   GRECO Fifth Evaluation Round – Evaluation Report, recommendations i, ii and iii. 

6 

 
 
                                                 
person employed by, or acting on behalf of a public administration body, is disqualified from 
being  involved  in  a  particular  case,  which  may  raise  doubts  about  impartiality.  To  avoid 
conflicts  of  interest,  Ministers  are  required  to  give  up  any  (remunerated  or  unremunerated) 
occupation  in  a  private  or  public  company  upon  taking  office41.  This  however  does  not 
include  self-employment,  financial  interests,  honorary  occupations  or  those  associated  to  a 
minister’s political party. Although the Public Administration Act’s provisions are applicable 
to Ministers, it leaves them considerable discretion to report a potential or apparent conflict 
of  interest,  without  providing  much  guidance.  In  addition,  it  does  not  contain  any 
enforceability  measures42.  For  members  of  Parliament,  there  is  no  general  definition  of 
conflict  of  interests  and  the  current  framework  does  not  provide  a  reporting  mechanism. 
GRECO  has  recommended  the  introduction  of  a  requirement  of  ad  hoc  disclosure  when  a 
conflict  may  emerge  in  relation  to  a  matter  under  consideration  in  parliamentary 
proceedings43.  

Whilst  asset  declaration  systems  exist,  these  are  not  systematically  controlled  or 
enforced.  For  members  of  Parliament,  a  regular  public  registration  of  occupations  and 
financial  interests  exists  and  is  subject  to  public  scrutiny  on  the  Parliament’s  website. 
However, GRECO has recommended to ensure standards of conduct are applicable to them, 
where  necessary44.  Whilst  compliance  by  members  of  Parliament  with  the  register  of 
economic interests is generally high, it is not complete45. Similarly, there are no general rules 
regarding  a  duty  to  declare  financial  interests  for  high-level  civil  servants,  although  all 
ministers are required to declare their financial interests on the basis of a standard form to be 
submitted upon entering office and updated annually. The scheme is not based on legislation, 
but successive governments have complied with the regime as if mandatory46. Ministers who 
are also members of Parliament are not part of the Parliament’s declaration scheme. Unlike 
the  regime  in  place  for  members  of  Parliament,  this  scheme  explicitly  includes  certain 
financial interests of spouses and/or partners. However, GRECO has recommended enacting 
these  guidelines  into  legislation,  widening  the  scope  of  declarations  and  introducing 
substantive controls47. 

The  Danish  system  does  not  have  clear  rules  and  guidance  on  how  persons  entrusted 
with top executive functions engage in contacts with lobbyists. There are also no reporting 
or disclosure requirements applicable to those who seek to influence government actions and 
policies. Yet, whilst in all 27 EU Member States, a majority of respondents consider that too 
close links between business and politics in their country lead to corruption, the lowest scores 
were recorded in  Denmark (47%) (EU average:  76%)48. Lobbying in some form or another 
(in particular by interest groups) is an accepted part of the decision-making process, with the 
intention  of  creating  broad-based  support  for  decisions.  Nonetheless,  introducing  rules  and 

41   Pursuant to Article 8 of the Act on Remuneration and Pensions for Ministers. 
42   GRECO Fifth Evaluation Round – Evaluation Report, paragraph 67-69. 
43   GRECO Fourth Evaluation Round – Evaluation Report, recommendation ii. 
44   GRECO Fourth Evaluation Round – Evaluation Report, recommendation iv. 
45   Website Folketinget: https://www.ft.dk/da/medlemmer/medlemmer-uden-registreringer.  
46   The declarations are to include occupations (held currently and in the past 5 years), self-employment with an 
annual  turnover  of  more  than  DKK  50.000  (approximately  EUR  6.700),  corporate  interests  of  more  than 
DKK 50.000 (approximately EUR 6.700) (including current investments), financial agreements with former 
and/or future employers, membership of associations. 

47   GRECO Fifth Evaluation Round – Evaluation Report, recommendations vii, viii. 
48   Special Eurobarometer 502 (2020). 

7 

 
 
                                                 
guidance  for  contacts  with  lobbyists  and  third  parties  seeking  to  influence  governmental 
processes and decisions, and increasing the transparency of such contacts, has been advised49. 

There  are  no  clear  rules  on  ‘revolving  doors’.  In  the  absence  of  a  specific  “cooling  off 
period” policy, there have been several reports of Ministers moving directly into top political 
lobbying  jobs.  Despite  GRECO  recommending  the  introduction  of  rules  to  deal  with  the 
employment of persons  entrusted with  top  executive functions following  the termination of 
their  service  in  the  public  sector,  there  are  currently  no  concrete  plans  to  introduce  such  a 
regulation50.  

There are dedicated mechanisms to protect whistle-blowers but there is no overarching 
legislation.  Denmark  currently  has  no  specific  law  to  protect  whistle-blowers.  However, 
legislation  exists  in  the  financial  sector  as  part  of  the  transposition  of  the  Capital 
Requirements Directive IV51. The Danish business association advises companies to establish 
arrangements  on  a  voluntary  basis  should  they  wish  to  do  so.  In  addition,  there  are  other 
existing systems in place in the public sector or in certain sector specific areas, including the 
external  and  internal  procedures  of  the  Financial  Supervisory  Authority,  a  Danish  Business 
Authority  external  whistle-blower  scheme  regarding  issues  related  to  potential  violation  of 
audit legislation, and a scheme in the area of the European Regional Development Fund and 
the European Social Fund52.  

Political party financing issues have been highlighted in international evaluations, and 
most  recommendations  are  not  yet  implemented.  These  recommendations  include 
addressing  perceived  shortcomings  such  as  the  lack  of  obligations  on  reporting  donations 
above  certain  thresholds,  and  ensuring  independent  monitoring  in  respect  of  the  funding  of 
political parties and electoral campaigns53. Eurobarometer figures show that Denmark is the 
only  country  where  the  proportion  of  respondents  who  agree  that  there  is  sufficient 
transparency and supervision of political party financing decreased since 2013 (41% in 2013, 
to 34% in 2019 (EU average: 32%))54.  

Whilst  repressive  measures  appear  adequately  applied,  there  is  a  lack  of  broadly 
available  statistics  related  to  corruption.  Although  there  have  been  recent  criminal 
convictions for corruption-related crimes55 and important court decisions are published in the 
pay-for-access official judicial journal, Denmark does not publish statistics on foreign bribery 
investigations, and cases commenced or concluded56.  

49   GRECO Fifth Evaluation Round – Evaluation Report, recommendation v. 
50   GRECO Fifth Evaluation Round – Evaluation Report, recommendation vi. 
51   Directive  2013/36/EU  of  the  European  Parliament  and  of  the  Council  of  26  June  2013  on  access  to  the 

activity of credit institutions and the prudential supervision of credit institutions and investment firms. 

52   Most  recently  a  dedicated  whistle-blower  portal  was  set  up  by  the  Danish  Business  Authority  for  alerts 
regarding fraud with coronavirus/covid-19 related compensation schemes (LOV nr 796 af 09/06/2020).   

53   GRECO Third Evaluation Round - Second Compliance Report. 
54   Special Eurobarometer 502 (2020). 
55   Such  as  breaching  rules  on  conflicts  of  interests  and  misuse  of  power,  and  a  number  of  serious  crimes 

investigated in connection with money laundering 

56   Transparency  International  (2018),  Exporting  corruption  –  progress  report  2018:  assessing  enforcement  of 

the OECD anti-bribery convention, p. 43.  

8 

 
 
 
 
                                                 
III.  MEDIA PLURALISM 

The  Constitution  provides  the  overall  framework  for  the  protection  of  the  freedom  of 
expression. The tasks, organisational  structure and rules  of procedure of the national  media 
regulatory authority, the Danish Radio and Television Board, are prescribed in law. There are 
no  specific  laws  pertaining  to  transparency  of  media  ownership  or  allocation  of  state 
advertising.  Access  to  documents  is  regulated  in  the  Access  to  Public  Administrative 
Documents Act of 201457. 

The  Danish  Radio  and  Television  Board  operates  independently.  The  tasks  and 
organisational structure of the independent authority are established in the Danish Radio and 
Television  Broadcasting  Act.  The  media  unit  in  the  Agency  for  Culture  and  Palaces  is  the 
secretariat  of  the  Radio  and  Television  Board.  According  to  the  Board,  they  consider  their 
organisational  structure  to  be  robust,  even  if  some  decisions  have  elicited  strong  political 
interest58.   A very low risk for the independence and effectiveness of the media authority is 
also registered in the latest edition of the Media Pluralism Monitor (MPM 2020). The rules of 
procedure of the Board are set out in an executive order, which has been updated following 
the revision of the Audio-visual Media Services Directive (AVMSD). The Minister appoints 
eight  members  of  the  Board,  including  the  chair  and  vice-chair  for  four  years. 
Reappointments  are  possible.  One  member  is  appointed  by  the  Collaboration  Forum  for 
Listeners  and  Viewers  Organisations  and  one  member  by  the  Association  of  Judges. 
Dismissal  of  the  head/members  of  the  collegiate  body  have  to  follow  the  rules  of  the 
Administration Act. Prior to the decision on dismissal, the member concerned must be heard. 
The decision must be in writing and include an explanation. Furthermore, the member must 
have  the  option  to  file  a  complaint  regarding  the  decision  and  appeal  it  to  a  court.  The 
decisions of the Radio and Television Board cannot be appealed to the Ministry – only to the 
courts.  As  for  all  administrative  decisions,  the  Parliamentary  Ombudsman  can  handle 
complaints with regard to the case management. 

The Danish Press Council (Presse Nævnet) is an independent self-regulating body under 
the  Ministry  of  Justice,  established  by  law59.  It  deals  with  complaints  concerning  the 
Danish mass media and is composed of eight members appointed by the Minister of Justice, 
representing  journalists,  the  public  and  the  editorial  managements  of  the  printed  press  and 
the  vice-chairman  are  appointed  upon 
radio  and 
recommendation  by  the  President  of  the  Danish  Supreme  Court.  The  Press  Council  can 
express its criticism in cases concerning sound press ethics and direct the editor of the media 
in question to publish a reply and/or the decision of the Council. However, it cannot impose a 
sanction or award the complainant a financial compensation60. 

television.  The  chairman  and 

There  are  no  specific  rules  on  transparency  of  media  ownership  or  allocation  of  state 
advertising. State advertising must comply with the general rules in the Radio and Television 
Broadcasting  Act  and  the  secondary  legislation  in  connection  with  the  Act,  based  on  the 
AVMSD.  The  MPM  2020  remarks  that  ownership  above  20%  of  the  shares  has  to  be 
included in the annual accounts in all companies, including media companies, but there are 
no  particular  requirements  for  media  companies.  Danish  media  stakeholders  have  indicated 

57   The Reporters Without Borders’ annual World Press Freedom Index continuously ranks Denmark among the 

best performing countries, currently in the third place. See https://rsf.org/en/ranking. 

58   Written input from the Radio and Television Board, pp. 1 – 2. 
59   The Media Liability Act – Consolidating Act 2018-12-27 no. 1719. 
60   Danish Press Council (Presse Nævnet) website, https://www.pressenaevnet.dk/press-ethical-rules/. 

9 

 
 
                                                 
that  despite  the  lack  of  specific  rules,  they  anyway  consider  the  level  of  the  national 
transparency  of  media  ownership  to  be  rather  satisfactory  in  practice,  notably  through  the 
Central Business Register and when it comes to the owners of the main media outlets61.  

The  right  to  information  is  subject  to  certain  restrictions.  The  Access  to  Public 
Administrative Documents Act, which provides the rules to all public administration bodies 
and  Ministries  on  public  access  to  information  and  documents,  has  been  amended  in  2014, 
subsequently limiting public and journalistic access  to  certain  government  files62. Section 7 
of  the  Act  states  that  anyone  can  request  the  disclosure  of  the  documents  entered  into  or 
created by a public administration body as part of its administrative procedures in connection 
with its activities as an authority. This access, however, is limited with regards to some types 
of cases, documents or information, in particular internal working documents of authorities or 
documents  which  are  being  exchanged  at  a  time  when  a  Minister  needs  the  advice  and 
counsel of his staff63. Stakeholders indicate that the exemptions in cases involving assistance 
and advice to the Minister and communication with members of Parliament in the legislative 
process can have the effect of keeping the basis of some political agreements confidential64. 
The Parliamentary Ombudsman has also found the exception on Ministerial service to have a 
restricting effect on the right to access in practice65. 

Denmark has a strong tradition of freedom of expression. The overall framework for the 
protection of the freedom of expression is found in the Constitution66. The Reporters Without 
Borders’  annual  World  Press  Freedom  Index  continuously  ranks  Denmark  among  the  best 
performing  countries,  currently  in  the  third  place  in  the  world67.  Nevertheless,  in  Denmark 
imprisonment is among the possible sanctions for defamation68. The MPM 2020 regards the 
protection of the freedom of expression to carry very small risks due to the overall robustness 
of  democratic  tradition  and  institutions  in  Denmark.  In  2019  and  2020,  the  Council  of 
Europe’s  Platform  to  promote  the  protection  of journalism  and  safety  of  journalists  did  not 
publish any alert concerning Denmark69. A specific Commission on Freedom of Expression70 
was established in 2017/2018, with the aim to assess the framework and general  conditions 
for  the  freedom  of  expression.  It  delivered  its  report  in  April  2020,  contributing  to  broad 
political discussions regarding the status of freedom of expression in the Danish society71. 

61   Information received in the context of the country visit.  
62   Also  to  be  noted  in  this  context  that  according  to  the  MPM  2020,  the  main  risk  to  the  protection  of 

journalists lies with the fact that the right to information is not explicitly protected in the constitution. 

63   Sections 19 to 33 and Section 35 of the Access to Public Administrative Documents Act. 
64   Sections 24 and 27 (2) of the Access to Public Administrative Documents Act; Information received in the 
context of the country visit and e.g. statements by the Danish Union of Journalists, Open Administration; or 
Danske  Medier.,  Danske  Medier  welcomes  the  publication  of  the  Freedom  of  Expression  Commission's 
report on Thursday.  

65   Section  24  of  the  Access  to  Public  Administrative  Documents  Act.  Annual  Report  of  the  Parliamentary 

Ombudsman (2016), pp. 141-142. 

66   Section 77 of the Constitution. 
67   Reporters without Borders, 2020 World Press Freedom Index.  
68   https://cmpf.eui.eu/wp-content/uploads/2019/01/decriminalisation-of-defamation_Infographic.pdf 
69   Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists 

https://www.coe.int/en/web/media-freedom. 

70   Input from Denmark for the 2020 Rule of Law Report, p. 20. 
71   In line with Recommendation CM/REC(2016)4 of the Committee of Ministers of the Council of Europe on 
the protection of journalism and safety of journalists and other media actors that calls for a comprehensive 
legislative  framework  that  enables  journalists  and  other  media  actors  to  contribute  to  public  debate 
effectively and without fear. 

10 

 
 
                                                 
IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Denmark  has  a  unicameral,  parliamentary  system  of  government,  in  which  both  the 
Government  and members of Parliament  can propose legislation, although draft bills  are in 
general  presented  by  the  Government.  In  the  absence  of  a  constitutional  court,  ex-post 
constitutionality  review  can  be  carried  out  by  all  courts  in  concrete  cases72.  The 
Parliamentary  Ombudsman  provides  oversight  over  decisions  by  public  authorities  and  the 
Danish Institute for Human Rights monitors the respect of fundamental rights.  

The process for enacting legislation involves a comprehensive preparatory process. The 
Ministry of Justice’s legal quality guidelines73 provide detailed instructions on the process for 
preparing  legislation,  including  on  legislative  programming  and  preparatory  steps,  such  as 
potential preparatory commissions and mandatory impact assessments (inter alia of economic 
and  environmental  impact  and  administrative  consequences  for  citizens).  Draft  laws  by  the 
Government  are  generally  published  for  open  consultation  on  a  Government  portal  (for  a 
recommended minimum period of four weeks) and directly sent for external consultation to 
concerned  authorities  and  organisations74.  Draft  laws  also  undergo  a  technical  legislative 
review by the Ministry  of Justice, including  to  ensure conformity  with  international  human 
rights obligations75.  

The  Parliamentary  Ombudsman  plays  a  key  role 
in  providing  oversight  of 
administrative  decisions.  The  Parliamentary  Ombudsman,  elected  by  the  Parliament  after 
each  general  election76,  functions  as  an  appeal  authority  for  administrative  decisions, 
providing  an  assessment  on  the  conformity  of  the  acts  of  public  authorities  with  existing 
legislation  or  good  administrative  practice.  The  Ombudsman  can  act  on  the  basis  of 
complaints or conduct own-initiative investigations. In 2019, the Ombudsman handled 5,368 
complaints,  many  of  which  related  to  questions  of  access  to  public  records,  and  163  own-
initiative  investigations  focussing  on  more  general  issues  affecting  a  larger  number  of 
citizens77. The Ombudsman’s opinions, which can include recommendations to authorities to 
re-open a case or change a decision, are non-binding. According to information from both the 
authorities and the Ombudsman, public authorities generally follow the recommendations in 
practice. In addition to the Ombudsman, the Danish  Institute of Human Rights functions as 
the  National  Human  Rights  Institution  and  was  re-accredited  with  A-Status  by  the  Global 
Alliance of National Human Rights Institutions in 2018.  It also acts as the national equality 
body.  

Civil  society  space  in  Denmark  is  considered  to  be  open78  and  the  civil  society 
organisations are closely involved through a Human Rights Council. The Danish Institute 
for  Human  Rights  involves  a  large  number  of  civil  society  organisations  from  different 
thematic  fields  through  its  Human  Rights  Council,  which  assesses  the  design  and 

72   This happens rarely and there has only been one case in which the Supreme Court decided to disapply a law 

for being incompatible with the Constitution, in the 1999, Tvind case, U 1999.841 H.   

73   Ministry of Justice, Legal Quality guidelines.  
74   See the online platform Hoeringsportalen.  
75   Input from Denmark for the 2020 Rule of Law Report, p. 24.  
76   The Ombudsman can also be dismissed by the Parliament, if they no longer enjoy its confidence.  
77   Parliamentary Ombudsman, 2019 Annual Report, p. 39.  
78   Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed 

and closed.   

11 

 
 
                                                 
implementation of the NHRI’s activities, can recommend new activities and appoints six of 
the 14 members of the board of directors79. 

The  decision-making  process  leading  to  the  suspension  of  courts’  activities  during  the 
COVID-19 pandemic has been subject to debate. Emergency measures in response to the 
COVID-19 pandemic were taken based on an amendment of the Epidemics Law transferring 
the power to adopt decrees to combat the pandemic to the Minister of Health. The law was 
adopted  unanimously  by  Parliament  on  12  March  2020.80  On  the  same  day,  the  National 
Courts  Administrations  announced  that  in  view  of  the  COVID-19  pandemic,  only  the  most 
critical  functions  of  courts  would  be  maintained  and  urgent  and  critical  cases  would  be 
prioritised81. Since then, some debate has emerged as to whether this decision was taken in 
line  with  constitutional  provisions  regarding  the  independence  of  the  courts.  A  study  by 
think-tank Justitia82 argues that the National Courts Administration may have gone too far in 
its guidance given that, based on the Constitution and the Administration of Justice Act, the 
National  Courts  Administration  is  not  empowered  to  make  decisions  on  prioritising  cases 
instead of the courts. In public statements, academics and the Association of Judges have also 
voiced concerns, while acknowledging the extraordinary circumstances which required swift 
action. The Ministry of Justice and the National Courts Administration have contested these 
views83. The Parliament has appointed an independent expert panel, which will examine the 
Government’s overall handling of the pandemic and is expected to present results by the end 
of 2020.  

The  National  Courts  Administration  is  active  in  promoting  the  rule  of  law.  In  recent 
years, the National Courts Administration undertook a series of efforts to promote the rule of 
law, better understanding of the justice system to a variety of target groups and improve the 
user  focus  of  the  justice  system.  This  includes  initiatives  addressed  to  the  general  public, 
through  educational  videos,  to  school  children  through  model  curricula  for  teachers,  to 
journalists  via  a  dedicated  website  and  to  lay  judges,  by  providing  comprehensive 
information materials to them before they start their mandate84.  

79   The  Human Rights  Council includes civil society organisations e.g.  working in the  fields of  the judiciary, 
media  or  refugees  as  well  as  (non-voting  members)  ministries,  pubic  authorities  and  political  parties.  The 
other members of the board of directors are appointed by the Danish universities, the Greenland Council for 
Human Rights and the staff members of the NHRI.  

80   The power to adopt such decrees had previously belonged to committees of health officials and politicians at 
local  level.  The  adoption  of  the  amendment  followed  the  ordinary  legislative  procedure  but  with  three 
hearings condensed in 18h – use of such a fast-tracked procedure can be decided by vote of ¾ of Parliament.  

81   National Courts Administration, Emergency preparedness at the Courts of Denmark: Further information. 
82   Justitia, Rule of Law and COVID-19, pp. 95-104.  
83   Information, Mails cast doubt on whether the closure of the courts was in accordance with the Constitution. 
84   For more information see the website of the National Courts Administration.  

12 

 
 
                                                 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2020 Rule of Law report 
can be found at (COM website). 

Centre  for  Media  Pluralism  and  Media  Freedom  (2020),  2020  Media  pluralism  monitor. 

https://cmpf.eui.eu/media-pluralism-monitor/mpm-2020.  

CEPEJ (2020), Study on the functioning of judicial systems in the EU Member States.  

CIVICUS, Monitor tracking civic space: Denmark. https://monitor.civicus.org/country/denmark/.  

Council of Europe: Committee of Ministers (2000), Recommendation Rec(2000)19 of the Committee 
of Ministers to Member States on the Role of Public Prosecution in the Criminal Justice System.  

Council  of  Europe:  Committee  of  Ministers  (2010),  Recommendation  CM/Rec(2010)12  of  the 
Committee of Ministers to member states on judges: independence, efficiency and responsibilities.  

Council  of  Europe:  Committee  of  Ministers  (2016),  Recommendation  CM/REC(2016)4  of  the 
Committee of Ministers to member States on the protection of journalism and safety of journalists 
and other media actors. 

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 

Denmark. https://www.coe.int/en/web/media-freedom.  

Court of Justice of the European Union, judgment of 25 July 2018, LM, C-216/18 PPU. 

Court of Justice of the European Union, judgment of 27 May 2019 in joined cases OG, C-508/18 and 

PI, C-82/19 PPU. 

Danish Association of Judges (2020), ‘The judges’ working conditions’.  

Danish Courts (2020), Civil Cases, https://domstol.dk/om-os/tal-og-fakta/civile-sager/.  

Danish Government (2020), Input from Denmark for the 2020 Rule of Law Report. 

Danish 

Government 

financial 
https://www.regeringen.dk/media/6607/aftale-om-styrkelse-af-indsatsen-mod-finansiel-
kriminalitet-270319_endelig.pdf.   

Strengthening 

(2019), 

against 

action 

crime. 

Danske  Medier  (1  May  2020).,  Danske  Medier  welcomes  the  publication  of  the  Freedom  of 
Expression  Commission's  report  on  Thursday.  https://danskemedier.dk/aktuelt/journalistik-og-
redaktion/danske-medier-glaeder-sig-over-offentliggoerelsen-af-ytringsfrihedskommissionens-
betaenkning/.  

Danish Union of Journalists, Open Administration. https://journalistforbundet.dk/offentlighedslov.  

European Commission (2020), EU Justice Scoreboard.  

European Commission (2020), Report on the implementation of Council Framework Decision of 13 

June 2002 on the European arrest warrant and surrender procedures between Member States.  

European  Court  of  Human  Rights,  judgment  of  9  January  2013,  Oleksandr  Volokov  v.  Ukraine, 

application n° 21722/11. 

GRECO (2014), Fourth Evaluation Round – Evaluation Report on Denmark on preventing corruption 

in respect of members of parliament, judges and prosecutors.  

GRECO (2019), Third Evaluation Round – Second Compliance Report on Denmark on transparency 

of party funding.  

GRECO  (2019)  Fifth  Evaluation  Round  –  Evaluation  Report  on  Denmark  on  preventing  corruption 
and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law  enforcement 
agencies. 

13 

 
 
GRECO (2020), Fourth Evaluation Round – Interim Compliance Report on Denmark on preventing 

corruption in respect of members of parliament, judges and prosecutors. 

Information (6 July 2020), Mails cast doubt on whether the closure of the courts was in accordance 
the  Constitution.  https://www.information.dk/indland/2020/07/mails-saar-tvivl-hvorvidt-

with 
nedlukningen-domstolene-overensstemmelse-grundloven?lst_mst.  

Justitia (2020), Rule of Law and COVID-19. http://justitia-int.org/retsstaten-og-covid-19.    

Ministry of Justice, Legal Quality guidelines. https://lovkvalitet.dk/.  

Ministry  of  Justice  (24  June  2020),  New 

judges  must  relieve 

the  pressure  on  courts. 

https://www.justitsministeriet.dk/nyt-og-presse/pressemeddelelser/2020/nye-dommere-skal-lette-
presset-paa-domstolene.  

National  Courts  Administration,  Emergency  preparedness  at  the  Courts  of  Denmark:  Further 
https://www.domstol.dk/aktuelt/2020/3/noedberedskab-ved-danmarks-domstole-

information. 
yderligere-information/.     

Parliamentary Ombudsman (2020), 2019 Annual Report.  

Parliamentary Ombudsman (2017), 2016 Annual Report.  

Reporters without Borders, 2020 World Press Freedom Index.  

Transparency  International  (2018),  Exporting  corruption  –  progress  report  2018:  assessing 
enforcement 
convention. 
https://images.transparencycdn.org/images/2018_Report_ExportingCorruption_English_200402_0
75046.pdf.  

anti-bribery 

OECD 

the 

of 

UNCAC  (2017),  UNCAC 

implementation  review  –  country  review  report  of  Denmark. 
https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/2017_10_21_Denm
ark_Final_Country_Report.pdf.   

Virtual country visit to Denmark in the context of the 2020 Rule of Law Report.  

14 

 
 
 
Annex II: Country visit to Denmark 

The Commission services held virtual meetings in June and July 2020 with: 

  Danish Journalists’ Association  
  Danish Judges’ Association 
  Danske Medier 
  Danish Press Council 
  Ministry of Justice 
  National Courts Administration 
  Parliamentary Ombudsman 
  Prosecution Service 
  Special Prosecutor’s Office 
  Supreme Court 
  Transparency International Denmark 

In addition, the Agency for Culture and Palaces provided a written contribution in place of a virtual 
meeting.  

* The Commission also met the following organisations in a number of horizontal meetings:  

  Amnesty International 
  Civil Liberties Union for Europe 
  Civil Society Europe 
  Conference of European Churches  
  EuroCommerce 
  European Center for Not-for-Profit Law  
  European Centre for Press and Media Freedom 
  European Civic Forum  
  Free Press Unlimited 
  Front Line Defenders 
 
ILGA-Europe 
 
International Commission of Jurists 
 
International Federation for Human Rights  
 
International Press Institute  
  Lifelong learning Platform  
  Open Society Justice Initiative/Open Society European Policy Institute 
  Reporters without Borders  
  Transparency International EU  

15