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1.1 Definitions

In this procedure, the following terms are understood to mean:

 

  1. accounting organization:

a company or institution that conducts statutory audits as a business activity, or an organization in which such companies or institutions are connected;

  1. board:

the partners’ meeting or other governing body of our accounting organization that determines the policies and makes decisions regarding all matters of our accounting organization;

  1. Bta:

Supervision of Accountants Organizations Decree;

  1. Partner:

a person authorized to enter into commitments on behalf of the accounting organization for the execution of assignments in the field of professional services;

  1. employee:

all individuals working under an employment contract or other types of contracts and involved in the execution of assignments of our firm;

  1. network:

the cooperative structure of our firm, including the accounting organization, in accordance with the definition in the Bta;

  1. complaint:

a written expression of dissatisfaction regarding the conduct of a partner or employee of our accounting organization or a person working in a firm belonging to the network to which our accounting organization is affiliated;

  1. complainant:

the submitter of a complaint;

  1. committee:

the complaints committee as referred to in point 3;

  1. compliance officer:

the officer referred to in point 4;

  1. secretary:

the officer referred to in point 3;

  1. complaint handler:

the officer referred to in point 10.

 

1.2 Board’s responsibility

The board is responsible for the handling, registration, and publication of complaints about partners and employees of our accounting organization or individuals working in a firm belonging to the network to which our accounting organization is affiliated.

 

1.3 Complaints Committee

  1. The board may establish a complaints committee for a specific complaint or permanently.
  2. The complaints committee consists of at least two independent (not involved in any way with the complaint) members working in or associated with our accounting organization. The committee must include at least one board member.
  3. The board appoints a board member as chair and a secretary.
  4. The committee is responsible for the handling and advice to the board on complaints that are not resolved through consultation with the complainant or through mediation.
  5. In case an advice is given not to handle a complaint, the committee delegates the advice to its chair.
  6. The committee may provide the board with requested or unsolicited advice on the handling of the complaint, matters not explicitly included in a complaint but relevant, or matters that the committee becomes aware of that merit a complaint.
  7. The committee may establish further rules on its working procedures in a code of conduct.

 

1.4 Compliance Officer

The board appoints a compliance officer to coordinate complaint handling, register all received complaints, perform procedural and substantive assessments, and generate management information.

 

1.5 Submission of a Complaint

  1. A complaint must be submitted in writing, signed, and must include at least:
  • the name and address of the complainant;
  • the date;
  • a clear description of the conduct against which the complaint is directed.
    1. Complaints submitted orally will be put in writing by the partner or employee of our accounting organization who speaks to the complainant upon their request and, after being signed by the complainant, forwarded to the board.

1.6 Acknowledgment of Receipt of Complaint

  1. The compliance officer ensures that the complainant or the person who submitted an oral complaint in writing receives an acknowledgment of receipt and information about the complaint handling procedure from the board within one week after its receipt. If a complaint is referred to the committee for advice, the board informs the complainant as soon as possible.
  2. If a complaint does not meet the requirements formulated in point 5, the complainant will be given two weeks to remedy the deficiencies.
  3. Anonymous complaints are not possible.
  4. If the complainant does not rectify the omission within the mentioned two-week period, the board may decide to dismiss the complaint. The complainant will be informed of this within two weeks after the expiration of the aforementioned two-week period.

1.7 Complaints relating to another part of the network

  1. If the complaint relates not only to the performance of a partner or employee belonging to our auditing organization but also to a partner or employee of another part of the network, the board shall submit the complaint to the board of that organization within one week of receipt.
  2. In consultation with the board of the respective organization, a decision will be made on how to further handle the complaint. The board of our auditing organization will inform the complainant and the network board accordingly.
  3. If the network board decides to take over the further handling of the complaint, all parties involved shall be notified.

 

1.8 Complaint handling

  1. Within two weeks of receiving a complaint, a discussion will be held with the complainant. This discussion aims, among other things, to determine whether the complaint can be resolved through mediation and to assess to what extent the complaint should be further addressed.
  2. The board may waive the requirement to hold a discussion, as mentioned in the previous clause, if it deems it not meaningful in the particular case.
  3. If the discussion or mediation leads to a solution satisfactory to the complainant, the complaint will not be further pursued. The complainant and the person whose behavior is the subject of the complaint shall be informed in writing about the conclusion of the complaint handling.
  4. In cases where the discussion with the complainant or mediation does not result in satisfaction for the complainant, the complaint handling process will continue.

 

1.9 Handling and advice by committee

  1. If the complaint handling needs to be continued, the board may consider appointing a temporary committee for this purpose. The board shall provide the committee with all relevant information pertaining to the complaint and set a deadline for providing advice on the complaint handling.
  2. The committee shall submit a report to the board within the specified deadline.
  3. If any additional matters come to light during the committee’s handling of the complaint, the board shall promptly inform the committee.
  4. All partners and employees involved in the complaint handling process are bound by confidentiality.

 

1.10 Handling of internal complaints

  1. When a complaint is submitted by an internal official, all individuals involved in the complaint handling process have a duty to ensure that suspicions about the identity of internal complainants do not arise.
  2. If desired, the internal complainant may approach a complaint counselor, who will be designated by the board or compliance officer for this purpose.
  3. The board and the complaint counselor ensure that the complainant, members of the committee, and any other individuals involved in the complaint handling process are not disadvantaged in their (employment) position within the auditing organization.
  4. After the complaint has been resolved, the committee is responsible for informing whether the complainant, the complaint counselor, and/or other individuals involved have suffered any adverse consequences as a result of the submitted complaint within three to six months.
  5. Unless otherwise agreed with the complainant, data relating to the complaint shall not be included in his or her personnel file.

 

1.11 Extension

If the board fails to resolve a complaint within ten weeks or, if the complaint has been submitted for handling and advice by the committee, within fourteen weeks from the date of receipt of the complaint letter, the board shall ensure that a notification of extension is sent to the complainant and the person whose behavior is the subject of the complaint before the applicable deadline expires.

 

1.12 Board’s judgment

  1. The board shall inform the complainant in writing and with justification of the findings of the investigation into the complaint, as well as any conclusions drawn from it.
  2. If other network organizations are involved in the complaint, the board shall also send them a copy of its closure letter.

 

1.13 Registration of complaints

The board ensures that every written complaint is registered. The registration includes:

  • Name and address of the complainant.
  • Date of submission.
  • Description of the behavior that the complaint is directed against.

Furthermore, data is recorded regarding the method of submission, handling and resolution of the complaint, the processing time, and – if applicable – the board’s judgment on any measures taken as a result of the complaint.

If the committee has provided advice on the complaint, this advice is also included in the registration.

1.14 Internal publication

The board ensures that the registered data mentioned in the previous point is published annually in a clear and anonymized manner. This publication is accompanied by an explanation indicating the extent to which certain complaints indicate structural deficiencies in the functioning of our organization and addressing any measures to resolve identified issues.

 

  • mplementation regulation and delegation

 

  1. The board may establish additional rules for the implementation of the complaints procedure in order to ensure careful, effective, and efficient complaint handling.
  2. The board may delegate, by means of a delegation decision, all powers necessary for effective and efficient complaint handling, except those handled by the committee, to the executive board.
  3. The compliance officer is appointed by the board to supervise the implementation of the complaints procedure.

1.16 Citation title

This procedure may be referred to as the “complaints procedure.”