Out of respect for Horten’s cooperation with public authorities and publicly owned companies etc. throughout Denmark, we wish with this briefing to answer some of the serious questions raised by TV2's programme series, "The Black Swan".


Thursday, 2 May, Horten’s management received an e-mail from TV2 regarding statements made by then partner and attorney at Horten, Nicolai Dyhr, in the now published programme series, “The Black Swan”. The e-mail contained written extracts from the recorded conversations and general information about the programme series.

Immediately, it was clear to Horten’s management that these were statements that in no way reflect how an attorney and partner at Horten should behave. The displayed behaviour is completely incompatible with our values, and Horten’s management therefore immediately decided to suspend Nicolai Dyhr - less than a day after TV2’s e-mail.

Nicolai Dyhr subsequently presented two reports on the course of events. This information did not change the management's view on the matter, and Horten therefore decided to discontinue the cooperation with Nicolai Dyhr.

Horten has clearly and unequivocally condemned Nicolai Dyhr’s statements and completely agree with the statements made by the Danish Bar and Law Society, among others.


We take an open and honest approach to our clients’ and the media’s perfectly understandable and legitimate interest in both Nicolai Dyhr’s statements and Horten’s reactions to them. We actively distanced ourselves from Nicolai Dyhr’s statements, even before the series became publicly accessible. We are available to media inquiries and we continuously speak out on the questions we are presented with. We are aware of our responsibility to the public, our clients, and our employees.

Horten has now initiated an external investigation into the matter. The investigation is conducted by an expert appointed by a professional organisation. In addition, Horten has clearly stated that we are available to the Danish Debt Collection Agency in expected investigations of present and previous bankruptcy estates with Nicolai Dyhr as trustee. And Horten will continuously analyse and decide what other measures we can take to safeguard our values and ensure compliance with Horten’s internal guidelines.

It should be noted that where Nicolai Dyhr was affiliated with Horten’s department of Reconstruction and Insolvency (i.e. bankruptcy proceedings), Horten’s advice to the country’s municipalities is essentially handled by the department of Public Regulation. Nicolai Dyhr was not responsible for any of Horten’s municipal or other public clients.


Horten has a number of existing compliance programmes that cover the company’s operations. Moreover, because of TV2’s programme and the questions we receive about the programme from clients, business partners and society, we have chosen to meticulously examine how our compliance programmes can be strengthened.

We wish to emphasise that Horten fully complies with the existing rules to prevent money laundering, including the so-called KYC procedures which should be completed before we take on cases covered by the Anti-Money Laundering Act. We also have procedures for ongoing monitoring and random checks of our cases and our employees’ compliance with Horten’s guidelines and procedures for notification of the police and the Danish Financial Intelligence Unit.


When the results from the ongoing investigations are available, we will of course share them with our clients, including municipalities and other public organisations.

Even though our investigations have not yet been completed, we can say already now that we are going to introduce new measures and strengthened guidelines as we cannot live with any doubt being cast on our integrity and accountability.

We hope for understanding of the process and we stress that we will do our utmost to earn society's trust and ensure that the country's municipalities etc. can continue to trust Horten as a business partner in the future.

Horten is a law firm consisting of more than 330 talented and professional employees; our history dates back more than 70 years, and our underlying values are based on integrity, professional standards, and transparency. Our values form a solid and fundamental foundation for the culture at Horten and will always continue to do so. An individual’s deeply reprehensible choices and actions cannot change that.


Anders Bager Jensen