The number of employees must be calculated based on head counts per legal entity and thus independent of the employees' degree of employment.
Part-time employees, young workers, flex job employees, etc. must therefore be included in the calculation of the number of employees on the same terms as full-time employees.
However, there are a few exceptions to this in connection with seasonal or project-oriented activities.
The obligation to establish a whistleblower scheme is generally triggered when the organization has had an average of 50+ employees in the 4 preceding quarters.