Whistleblower Policy

1. General
   Pursuant to Article 27 of the Regulation on Accountancy Organisations (VAO), an accountancy organisation must have a whistleblower policy.

Art. 27 VAO

1. The accountancy organisation has a scheme that ensures that persons from outside the accountancy organisation and persons working for or connected to it can raise alleged irregularities within or (partly) outside the accountancy organisation without endangering their legal position. This scheme ensures that complaints are recorded, treated confidentially and in a timely manner, and that the irregularities complained of, if well-founded, are dealt with in a timely manner by the accountancy organisation by taking appropriate measures.
2. The scheme referred to in the first paragraph shall in any event be placed on the website of the accountancy organisation. If an accountancy organisation does not have a website, it shall disseminate this scheme within the accountancy organisation in another manner and send it to persons outside the accountancy organisation on request.

2. Scope
   This whistleblower policy relates to the following situations:

1. acts leading to criminal offences by the accountancy organisation or its employees;
2. all actual or suspected other violations of external laws and regulations by the accountancy organisation or its employees;
3. all actual or suspected violations of internal regulations by the accountancy organisation or its employees;
4. (threatened) intimidation of employees by colleagues or managers;
5. (threatened) unlawful destruction or manipulation of data or information;
6. and furthermore all situations that, in the opinion of a reporter, qualify for reporting to the confidential advisor.

If there are differences of opinion or complaints about the conduct of the accountancy organisation or its employees, this whistleblower policy may also be used. The difference with the aforementioned guidelines is related to the fact that the use of the whistleblower policy always takes place on the basis of anonymity.

3. Procedure

1. If there is a situation that falls within the scope of this whistleblower policy, the reporter has the option of reporting it to the confidential advisor.
2. The report to the confidential advisor takes place exclusively electronically via dirk@theauditcompany.nl
3. External third parties can also submit a report via this e-mail address.
4. The confidential advisor confirms the report to the reporter within one week. The confidential advisor also informs the reporter how and within what period his report will be processed. This period is no more than four weeks after receipt of the report.
5. If there is a situation mentioned under the scope of this whistleblower policy ad a and/or e, the confidential advisor shall immediately inform the director. The confidential advisor also informs the reporter about this.
6. If there is a (threatened) violation of internal or external professional regulations, the confidential advisor shall inform the compliance officer.
7. When informing the director and compliance officer as referred to in points 5 and 6, the confidential advisor shall not disclose the source.
8. The confidential advisor shall inform the reporter no later than four weeks after the handling of his report and the measures taken. If this period cannot be met due to unforeseen circumstances, the confidential advisor shall inform the reporter of this and indicate the period within which the reporter will be informed about the completion of his report.
9. Reports relating to a (threatened) violation of internal or external professional regulations shall in all cases be handled by the confidential advisor in consultation with the compliance officer, taking into account confidentiality.

4. Confidentiality
   The report, the correspondence about it and the handling take place under full confidentiality, unless the reporter releases the confidential advisor from his obligation of confidentiality.

The board of the accountancy organisation guarantees employees who pass on reports to the confidential advisor on the basis of this whistleblower policy that the report will in no way have a negative influence on his/her functioning within the accountancy organisation, or his/her career.