Swedish Whistleblowing Act: Preparing for New Compliance Requirements and the Impact on Data Privacy

Swedish Whistleblowing Act: Preparing for New Compliance Requirements and the Impact on Data Privacy

Thursday, 25 August 2022 | 10:00 AM ET (3:00 PM GMT)

On 29 September 2021, Swedish Parliament signed into law the Whistleblowing Act, with an effective date of 17 December 2021. Outlining specific requirements for both private and public employers (depending on company size), the Act also established a gradual phase-in of internal functions related to whistleblowers. Implementation dates for companies range from 17 July 2022 – 17 December 2023.

During this session, hear from Natali Engstam Phalén, Specialist Counsel at Lindahl and former Secretary-General of the Swedish Anti-Corruption Institute and Ottilia Boström, Partner at Lindahl as they provide an overview of how companies can prepare for the new requirements under the Act including an overview of:


  • Some anticipated similarities/differences in the implementation of the Swedish Act compared to other EU countries
  • How internal whistleblower functions must be structured in order to be compliant
  • Changes under the new law regarding the type of misconduct and by whom such misconduct can be considered a whistleblowing matter
  • Pertinent updates to whistleblower protections and the anticipated impact on data privacy
  • Best practice compliance recommendations to reduce whistleblower risk exposure



Natali Engstam Phalén

Specialist Counsel

Natali is responsible for Lindahl’s Compliance & Investigations as well as EU and competition law practice in Stockholm. Natali has extensive experience from the compliance field and has most recently held the position as Secretary-General of the Swedish Anti-Corruption Institute (Sw: Institutet Mot Mutor, IMM). Prior to that, she worked for several years as an attorney.


Natali is a frequent speaker and lecturer as well as a published author within the field of anti-corruption. She has extensive experience in assisting organizations with identifying and mitigating legal risk from a compliance perspective. Among other things, Natali advices clients in relation to investigations related to suspicions of corruption, implementation of compliance programs and whistleblowing systems and due diligence processes in an anti-corruption/compliance context. In the years 2018-2021, Natali was recognized as one of the future female leaders and in 2019 one of the most powerful women in business.


Ottilia Boström


Ottilia is a member of the Employment team and a member of the Dispute Resolution team, with her main focus being employment law and employment law related disputes. Ottilia advises clients on the full range of both contentious and non-contentious employment, pension and incentive matters, from hiring to firing (including issues related to work environment, discrimination, integrity and co-determination and including internal investigations, trade union consultations and disputes). Ottilia has particular experience from advising on employment, pension and incentive matters arising in connection with large-scale cross-border transactions, restructurings and re-organizations. Ottilia is ranked within employment law by Chambers & Partners and Legal 500.

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