Whistleblower policy

1. General

In accordance with art. 32 of the VAO (Dutch ordinance for accounting firms), our firm must have a whistleblower policy.

Art. 32 VAO 1. The accounting firm has a plan that ensures that people inside and outside the accounting firm can report any irregularities without any fear of losing their legal status. This policy will ensure that the accounting firm will record and handle complaints in a confidential and timely manner, and that the firm will implement the appropriate measures to settle any valid complaints in a timely manner.

2. The policy specified in paragraph one will be placed on the accounting firm’s website. If the accounting firm does not have a website, it will distribute this policy through a different channel within the accounting firm and will send this policy to people outside the accounting firm upon request.

2. Scope

This whistleblower policy applies to the following situations:

A. Actions that lead to criminal offences by our firm or its staff

B. All real or presumed offences of external laws and regulations by our firm or its staff

C. All real or presumed offences of internal rules by our firm or its staff

D. (Threatening) intimidation of staff by colleagues and/or supervisors

E. (Threatening) wrongful destruction or manipulation of data or information

F. All other situations that are deemed eligible by the informant to the confidential advisor

This whistleblower policy can be invoked for any differences of opinion and/or complaints regarding the actions of our firm and/or its staff. The difference between this and the guidelines specified above has to do with the fact that the whistleblower policy is always based on anonymity.

3. Procedure

1. If a situation occurs within the scope of this whistleblower policy, the informant has the opportunity to report it to the confidential advisor.

2. Incidents may only be reported to the confidential advisor via e-mail to info@joore.nl.

3. External third parties can also report incidents to the same e-mail address.

4. The confidential advisor sends a confirmation of the report back to the informant within 1 week. The confidential advisor also notifies the informant how the reported incident will be handled and within what time frame. This time frame equals four weeks maximum after the receipt of the report.

5. a) The confidential advisor shall notify the board immediately of any actions that result in a criminal offence or the unlawful destruction or manipulation of data or information. The confidential advisor will also notify the informant of the same.

b) The confidential advisor will also notify the board of any (threatening) criminal offence against internal or external rules that apply to the profession.

c) The confidential advisor shall not disclose the source when notifying the board of any actions as specified under items 5a and 5b.

6. The confidential advisor shall notify the informant within four weeks maximum how the reported incident has been settled and what measures have been taken. If this time frame cannot be met due to unforeseen circumstances, the confidential advisor will notify the informant of the delay and will advise the informant when (s)he can expect a report regarding the settlement of the reported incident.

7. Reports related to a (threatening) offence against internal or external rules of the profession are always handled by the confidential advisor in consultation with the board, while maintaining confidentiality.

4. Confidentiality

The report, all related correspondence and subsequent actions take place under full confidentiality and secrecy, unless the informant releases the confidential advisor from his commitment to maintain confidentiality.

Our firm’s board guarantees that staff who report incidents to the confidential advisor in accordance with this whistleblowers policy will not be subjected to any negative influence on his/her position at the accounting firm and/or his/her career.

5. Effective date

This policy goes into effect on 1 January 2007.

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