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Whistleblower scheme

Scope

The whistleblower scheme covers the following situations:

       a. actions that result in criminal offences being committed by the accountancy organisation or its staff;
       b. all other actual or suspected breaches of external legislation and regulations by the accountancy organisation or its staff;
       c. all actual or suspected breaches of internal rules and regulations by the accountancy organisation or its staff;
       d. (imminent) harassment of staff by colleagues or managers;
       e. (imminent) unlawful destruction or manipulation of data or information;
       f. and all other situations that the whistleblower believes merit being reported to the trusted person.

This whistleblower scheme can also be used in the event of disputes or complaints about the actions of the accountancy organisation or its staff. The difference between this scheme and the guidelines above is the fact that the whistleblower scheme is always based on anonymity.

Procedure

  1. If a situation arises that falls within the scope of this whistleblower scheme, the whistleblower has the option of reporting it to the trusted person.
  2. The report to the trusted person can only be made electronically by sending an e-mail to the secretarial office of one of our branches.
  3. External third parties can also send a report to this e-mail address.
  4. The trusted person will acknowledge receipt of the report to the whistleblower within one week. The trusted person will also inform the whistleblower how his/her report will be dealt with and within what timescale. This timescale will not exceed four weeks after receipt of the report.
  5. If a situation as referred to at A and E arises, the trusted person will inform the managing director immediately. The trusted person will also inform the whistleblower about this.
  6. In the event of an ongoing or imminent breach of internal or external professional rules of conduct, the trusted person will inform the compliance officer.
  7. The trusted person will not reveal the source when informing the managing director and compliance officer as described in 5 and 6 above.
  8. The trusted person will inform the whistleblower within four weeks at the latest how his/her report was handled and what measures were taken. If it is not possible to achieve this timescale due to unforeseen circumstances, the trusted person will inform the whistleblower accordingly and specify when the latter will be informed how his/her report was dealt with.
  9. Reports that relate to an ongoing or imminent breach of internal or external professional rules of conduct will in all cases be handled – in confidence – by the trusted person in consultation with the compliance officer.

Confidentiality

The report, any related correspondence and the process will be treated as completely private and confidential, unless the whistleblower relieves the trusted person of his/her duty of confidentiality.

The management committee of the accountancy organisation guarantees to staff who make reports to the trusted person under this whistleblower scheme that any such report will not have an adverse effect of any kind on his/her role in the accountancy organisation or on his/her career.