Whistleblower Scheme

1. General

Based on Article 27 of the Regulation for Audit Firms (Verordening Accountantsorganisaties, VAO), an audit firm must have a whistleblower scheme in place.

Article 27 VAO

 

1. The audit firm has a scheme that ensures that individuals outside the audit firm, as well as its employees or affiliated persons, can report alleged irregularities within or (partly) outside the audit firm without endangering their legal position. This scheme ensures that complaints are recorded, treated confidentially and in a timely manner, and that the alleged irregularities, if substantiated, are promptly addressed through appropriate measures taken by the audit firm.
2. The scheme referred to in the first paragraph shall be posted on the audit firm’s website in any case. If an audit firm does not have a website, it shall distribute this scheme in another manner within the audit firm and provide it to individuals outside the audit firm upon request.

2. Scope

This whistleblower scheme applies to the following situations:

1. acts leading to criminal offenses committed by the audit firm or its employees;
2. actual or suspected violations of external laws and regulations by the audit firm or its employees;
3. actual or suspected violations of internal regulations by the audit firm or its employees;
4. threats of intimidation of employees by colleagues or superiors;
5. threats of unlawful destruction or manipulation of data or information;
6. and all other situations that, in the opinion of a reporter, are eligible for reporting to the confidential advisor.

If there are differences of opinion or complaints about the actions of the audit firm or its employees, this whistleblower scheme can also be used. The difference with the guidelines mentioned above is that the use of the whistleblower scheme always occurs on the basis of anonymity.

 

3. Procedure

4. If a situation falls within the scope of this whistleblower scheme, the reporter has the possibility to report it to the confidential advisor.
5. The report to the confidential advisor is exclusively done electronically via dirk@theauditcompany.nl.
6. External parties can also make a report through this email address.
7. The confidential advisor confirms the report to the reporter within one week. The confidential advisor also informs the reporter how and within what timeframe their report will be handled. This period shall not exceed four weeks from the receipt of the report.
8. If a situation mentioned in the scope of this whistleblower scheme under points a and/or e occurs, the confidential advisor immediately informs the director. The confidential advisor also informs the reporter about this.
9. If there is an actual or threatened violation of internal or external professional regulations, the confidential advisor informs the compliance officer.
10. When informing the director and compliance officer as mentioned in points 5 and 6, the confidential advisor does not disclose the source.
11. The confidential advisor informs the reporter about the handling of their report and the measures taken within four weeks. If, due to unforeseen circumstances, this timeframe cannot be met, the confidential advisor informs the reporter about this and indicates the timeframe within which the reporter will be informed about the completion of their report.
12. Reports relating to an actual or threatened violation of internal or external professional regulations are always handled by the confidential advisor in consultation with the compliance officer while ensuring confidentiality.

 

4. Confidentiality

The report, the corresponding correspondence, and the handling of the report are carried out with complete confidentiality, unless the reporter releases the confidential advisor from their duty of confidentiality.

The board of the audit firm guarantees employees who report to the confidential advisor under this whistleblower scheme that the report will not have any negative impact on their functioning within the audit firm or their career.