PwC Norway HR Director threatened disciplinary action to stop communication with safety rep

Kristin Hesla Halvorsen (), National HR Director in PricewaterhouseCoopers Norway, in a meeting used the threat of disciplinary action to discourage an employee from speaking with the legally protected health and safety officer (‘Verneombud’)

Halvorsen’s words were captured in a speech recording. The employee raised the threat as illegal in law, and whistleblew through the official whistleblowing channel.

PwC’s Norway’s whistleblowing function falsely claimed the incident never took place. An attorney and Board member of the law firm constructed deliberately misleading “documentation” to cover up the incident and pretend that it never took place.

The words, however, are clearly audible in a recording.

National HR Director Kristin Hesla Halvorsen and Board Member Cecilie Pande Dramstad Aas () were both asked for comment, but declined to respond.

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Documentation after “flippant” “jargon”

Attorney-in-training Linn Katrin Hansen ( ) stated in a fact-finding investigation that she and attorney-in-training Ole Jakob Raa ( ) together and jointly had subjected a new hire to what she called a “flippant” “jargon”. Raa repeatedly and without consent positioned himself directly in front of the colleague with his camera phone outstretched, took pictures and laughed, and said he would make a collage out of the pictures taken.

After some time, the new hire started to take notes, then speech recordings.

The role of safety representatives

The role of safety representative (‘verneombud’) is a heavily protected position under Norwegian law with a number of responsibilities. The appointment is mandatory, cf. the Working Environment Act chapter 6. Whistleblowing to the safety representative is protected in law, cf. Section 2 A-2 (1) d.

Ordered to complete silence

PwC Norway’s HR function had ordered the employee to complete silence about specific events connected to the workplace. The employee was ordered to be “done with the matter”, and not being “done with the matter” meant that a formal disciplinary warning would be considered:

This matter shall not be discussed with anyone, neither involved parties nor non-involved parties. Any and all attempt to refer to this matter from this point shall be interpreted as him not being done with the matter, and this is then a breach of the third mitigating circumstance that he has put it behind him, and we must then consider a verbal or written warning.

Written instructions from PwC Norway’s HR function to the employee, translated

PwC Norway issued threat during meeting

Some days later the employee was called into a meeting with National HR Director Kristin Hesla Halvorsen ( ). Halvorsen is asked about the consequences of speaking with the safety rep, and states that if this is done a formal disciplinary warning would be considered.

The statements were recorded:

NN: The premise here was that if I talked about this, it would trigger a formal warning?

KH?: Mm.

NN: Does that also apply to talking about it with the safety rep?

KH: Then you’re not done with the matter, I think.

NN: So then, it would…

KH: Then I think you’re not done with the matter. If anyone at the workplace outside of those in this room must be involved…

NN: Yes?

KH: … then I think you’re not done with the matter.

NN: So that would basically trigger a formal warning?

KH: Nooo, that is, in that case we would have to consider it, and speak with an employment attorney.

Meeting between Kristin Hesla Halvorsen, Cecilie Aas, HR-assistant and the employee translated

Immediate whistleblowing to board member – who “documented” that such a thing never happened

The employee immediately alerted about the events, and that this would be a breach of the law, to a Board member in the firm, lawyer and director Cecilie Pande Dramstad Aas ( ) who was present in the meeting.

Board member Aas immediately and secretly to the employee produced “documentation” that such an exchange never took place, covering up the events.

Additional alert through the whistleblowing channel

The employee whistleblew shortly after through the formal whistleblowing channel, to the appointed attorney Gunnar Holm Ringen ( ), quoting the conversation line by line.

Attorney Ringen would later, contrary to fact, claim that no attempt had ever been made to discourage from speaking with the safety rep using the threat of disciplinary action.