Our whistleblower procedure

1. General

Pursuant to the laws and regulations for accountancy organisations and accountancy firms, Vermetten | accountants and advisers has a whistleblower procedure.

2. Scope

This whistleblower procedure covers the following situations:
a.    actions that lead to criminal acts by Vermetten | accountants and advisers or its employees;
b.    any actual or suspected other violations of external laws and regulations by Vermetten | accountants and advisers or its employees;
c.    any actual or suspected violations of internal regulations by Vermetten | accountants and advisers or its employees;
d.    (imminent) intimidation by colleagues or managers towards employees;
e.    (imminent) unlawful destruction or manipulation of data or information; 
f.    and all situations that, in the opinion of a reporter, qualify for reporting to the confidential adviser.

In the event of differences of opinion or complaints about the actions of Vermetten | accountants and advisers or its employees, this whistleblower procedure may also be used. The difference with the aforementioned guidelines is that use of the whistleblower procedure is always on the basis of anonymity.

3. Procedure

1. If a situation falls within the scope of this whistleblower procedure, the reporter has the option of reporting it to the confidential adviser.
2. Reporting to the confidential adviser can only be done electronically via vertrouwenspersoon@vermetten.nl (internal reporting) or nathalie@rechtmethart.nl (external reporting).
3. External third parties may also make a report using this e-mail address.
4. The confidential adviser will confirm receipt of the report to the reporter within one week. The confidential adviser will also inform the reporter how and within what period their report will be dealt with. This period should be no later than four weeks after receipt of the report.
5. If a situation is reported that falls within the scope of this whistleblower procedure, the confidential adviser will immediately inform the management. The confidential adviser will also inform the reporter of this.
6. If there is a(n imminent) of internal or external professional regulations, the confidential adviser will inform the compliance officer.
7. When informing the management and compliance officer as described in items 5 and 6, the confidential adviser will not disclose the source.
8. The confidential adviser will inform the reporter within four weeks about the handling of their report and any measures that have been taken. If this term cannot be met due to unforeseen circumstances, the confidential adviser will inform the reporter of this and indicate the term within which the reporter will be informed about the handling of their report.
9. In all cases, reports that concern a(n imminent) violation of internal or external professional regulations are handled by the confidential adviser in consultation with the compliance officer with due regard for confidentiality. 

4. Confidentiality

The report, the correspondence on it and its handling will take place in complete secrecy and confidentiality, unless the reporter waives the confidential adviser's obligation to maintain confidentiality.
The Vermetten management guarantees to employees who report their concerns to the confidential adviser on the basis of this whistleblower procedure that the report will in no way have a negative impact on their functioning within Vermetten | accountants and advisers or their career.
 
Management Vermetten | accountants and advisers