On 4 September 2019, GRECO published its fifth round evaluation report on Denmark. The country traditionally achieves high scores in corruption perception indices, and the risk of actual bribery taking place is considered to be very low. Trust is a central feature of the integrity system, yet regulations on preventive and control measures are lacking in certain areas. GRECO therefore recommends the adoption of more binding rules.

First, there is a need to develop an overall strategy based on an analysis of integrity-related risks involving members of the government and their special advisors. Next, a code of conduct for persons with top executive functions focusing on integrity-related matters (together with briefing and confidential counselling) needs to be adopted, coupled with supervision and enforcement mechanisms. In addition, the current system also needs to be complemented with rules governing the contacts of officials in top executive functions with lobbyists and governing their employment after termination of their service in the public sector. The current guidelines on financial declarations by members of the government should additionally be laid down in legislation that is subject to review; exceptions to the rule of public disclosure are to be interpreted more narrowly in practice.

As for law enforcement, the police in Danish society enjoys a high degree of trust. Various reforms implemented in the last ten years deserve mention:

• The establishment of the Independent Police Complaints Authority in 2012;
• The introduction in 2015 of standard vetting of new police recruits by the Danish Security and Intelligence Service;
• The adoption of new guidelines “Good behaviour in the police and prosecution service” in 2018;
• The strengthening of police procurement procedures in 2018.

That said, GRECO recommends improvements in the training available to police officers on integrity requirements, which should also be made mandatory for managers. In addition, there is a need to develop a streamlined system for authorisation of secondary activities of police officers, coupled with effective follow-up. Finally, GRECO lauded the new whistleblowing system introduced into the Danish police, hoping that it will also lead to whistleblower regulations in other sectors of society.