1. Complaints procedure

1.1 Definitions

The following definitions apply in this procedure:

a. audit firm:

an enterprise or institution that performs statutory audits on a commercial basis, or an organisation in which such enterprises or institutions are associated with each other;

b. board:

the partners’ meeting or other administrative body of our audit firm that determines the policy and makes decisions regarding all matters of our audit firm;

c. Bta:

Decree on the supervision of audit firms;

d. Partner:

a person with the authority to enter into obligations on behalf of the audit firm for the performance of assignments in the field of professional services;

e. employee:

all persons who perform work on the basis of an employment contract or other contracts and are involved in the execution of our firm’s assignments;

f. network:

the collaboration structure of our firm, including the audit firm, in accordance with the definition in the Bta;

g. complaint:

a written expression of dissatisfaction with an act or omission by a partner or employee of our audit firm or by a person working at an office belonging to the network to which our audit firm is affiliated;

h. complainant:

the submitter of a complaint;

i. committee:

the complaints committee as referred to in point 3;

j. compliance officer:

the officer as referred to in point 4;

k. secretary:

the officer as referred to in point 3;

l. complaint advisor:

the officer as referred to in point 10.

1.2 Responsibility of the board

The board is responsible for the handling, registration and publication of complaints about partners and employees of our audit firm or about persons working at an office belonging to the network to which our audit firm is affiliated.

1.3 Complaints committee

a. The board may establish a complaints committee for a specific complaint or on a permanent basis.

b. The complaints committee consists of at least two independent (not involved in the complaint in any way) members who work in or are affiliated with our audit firm. At least one member of the board is represented on this committee.

c. The board appoints a board member as chairman and a secretary.

d. The committee is responsible for handling and advising the board on complaints that are not resolved through consultation with the complainant or through mediation.

e. In the event that advice relates to not considering a complaint, the committee assigns the advice to its chairman.

f. The committee may, at the request of the board or on its own initiative, advise the board on the handling of the complaint or on issues that are not explicitly included in a complaint but are relevant, or on matters worthy of complaint of which the committee is aware.

g. The committee may lay down further rules on its working methods in internal regulations.

1.4 Compliance officer

The board appoints a compliance officer to coordinate the handling of complaints, register all complaints received, conduct procedural and substantive reviews, and generate management information.

1.5 Submitting a complaint

a. A complaint must be submitted in writing and signed and must contain at least:

• the name and address of the submitter;
• the date;
• a clear description of the conduct against which the complaint is directed.

b. Complaints that are submitted orally will, at the request of the complainant, be put in writing by the partner or employee of our audit firm who speaks to the complainant and, after signature by the complainant, forwarded to the board.

1.6 Acknowledgement of receipt of complaint

a. The compliance officer ensures that the submitter of a written complaint or the person whose orally submitted complaint has been put in writing is sent an acknowledgement of receipt and information about the complaint handling procedure within one week of receipt thereof by the board. If a complaint is submitted to the committee for advice, the board will inform the complainant of this as soon as possible.

b. If a written complaint does not meet the requirements formulated in point 5, the complainant will be given the opportunity within two weeks of receipt thereof to remedy the omission within two weeks.

c. Anonymous complaints are not possible.

d. If the complainant does not remedy the omission within the aforementioned period of two weeks, the board may decide not to consider the complaint. The complainant will be informed of this within two weeks after the expiry of the aforementioned period of two weeks.

1.7 Complaints relating to another part of the network

a. If the complaint relates not only to the functioning of a partner or employee belonging to our audit firm but also to a partner or employee of another part of the network, the board must submit the complaint to the board of that organisation within one week of receipt.

b. In consultation with the board of the organisation in question, a decision will be made as to how the further handling of the complaint will take place. The board of our audit firm will inform the complainant and the board of the network of this.

c. If the board of the network decides to take over the further handling of the complaint, it will inform all parties involved.

1.8 Complaint handling

a. Consultation will be held with the complainant within two weeks of receipt of a complaint. This consultation serves, among other things, to determine whether the complaint can be handled through mediation and to determine the extent to which the complaint is eligible for further handling.

b. The board may decide not to hold consultations, as referred to in the previous paragraph, if it is of the opinion that this is not useful in the case in question.

c. If consultation or mediation leads to a solution with which the complainant is satisfied, the complaint will not be processed further. The complainant and the person to whose conduct the complaint relates will be informed in writing about the termination of the complaint handling.

d. In cases where consultation with the complainant or mediation does not lead to satisfaction of the complainant, the handling of the complaint will be continued.

1.9 Handling and advice by committee

a. In the event that the complaint handling must be continued, the board will consider appointing a temporary committee for this purpose. The board will inform the committee about all matters related to the complaint and set a deadline for the committee to provide advice on the complaint handling.

b. The committee reports to the board within the set deadline.

c. If further matters become known during the committee’s handling, the board will inform the committee of this immediately.

d. All partners and employees involved in the complaint handling are subject to a duty of confidentiality.

1.10 Handling of internal complaints

a. When the complaint has been submitted by an internal officer, all officers involved in the complaint handling have a duty to ensure that suspicions about the identity of internal complainants cannot arise.

b. If desired, the internal complainant may turn to a complaint advisor, who will be appointed for this purpose by the board or the compliance officer.

c. The board and the complaint advisor will ensure that the complainant, the members of the committee and any other parties involved in the handling of a complaint will not be disadvantaged in their (legal) position in the audit firm as a result.

d. The committee has the task of informing, after handling the complaint, within three to six months whether the complainant, the complaint advisor and/or other parties involved are experiencing any adverse consequences as a result of the complaint submitted.

e. Unless otherwise agreed with the complainant, data relating to the complaint will not be included in his or her personnel file.

1.11 Postponement

If the board fails to settle a complaint within ten weeks or, if the complaint has been

submitted to the committee for handling and advice, within fourteen weeks after

receipt of the written complaint, it shall ensure that the complainant and the person to

whose conduct the complaint relates are sent a notification of postponement before the expiry of the applicable

term.

1.12 Opinion of the board

a. The board informs the complainant in writing and with reasons of the findings of the investigation into the complaint as well as of any conclusions it draws from it.

b. When other network organisations are involved in the complaint, the board also sends them a copy of its settlement letter.

1.13 Registration of complaints

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

• name and address of the submitter of the complaint;
• the date;
• a description of the conduct against which the complaint is directed.

Data are also included on the method of submission and handling and

settlement of the complaint, on the processing time, and – if applicable – on the opinion

of the board on any measures taken in response to the complaint.

Insofar as the committee has advised on the complaint, this advice is also included in the

registration.

1.14 Internal publication

The board ensures that the registered

data referred to in the previous point are published annually in a clear and anonymised manner. This

publication is accompanied by an explanation, which indicates the extent to which certain

complaints indicate structural shortcomings in the functioning of our organisation, and which

addresses any measures to resolve identified bottlenecks.

1.15 Implementing regulations and mandate

1. In the interest of careful, effective and efficient implementation of the complaint handling, the board may lay down further rules for the implementation of the complaints procedure.
2. In a mandate decision, the board may delegate all powers that are necessary for effective and efficient complaint handling, insofar as this does not take place by the committee, to the executive board.
3. The compliance officer is charged by the board with supervising the implementation of the complaints procedure.

1.16 Citation title

This procedure can be cited as: complaints procedure.