Based in part on Article 32 of the Dutch Audit Firms Regulation, we have implemented a whistle-blower scheme so that people from outside our accountancy firm as well as those who work for or are associated with us can sound the alarm if they encounter any irregularities during their work within or in relation to our accountancy firm, without jeopardising their legal position. Article 1 Definitions
- Practice: Lentink Accountants and Tax Advisers;
- Whistle-blower: the person, whether or not an employee of Lentink Accountants and Tax Advisers, who performs activities for Lentink Accountants and Tax Advisers and reports an abuse under this scheme
- Employee: a whistle-blower who is employed by Lentink Accountants and Tax Advisers; Superior: the employee’s superior; Compliance officer: the compliance officer appointed by the board of Lentink Accountants and Tax Advisers;
- Board: the management board of Lentink Accountants and Tax Advisers, responsible for compliance with and execution of the rules and regulations;
- Abuse: a reasonably founded suspicion relating to Lentink Accountants and Tax Advisers and/or its employees, in conjunction with an actual or imminent offence:
- an actual or imminent violation of the law or regulations;
- the actual or imminent deliberate provision of false information;
- an actual or imminent violation of the rules or code of conduct within Lentink Accountants and Tax Advisers; or
- the actual or imminent destruction or manipulation of information about the aforesaid acts.
Article 2 Procedure
- The Compliance Officer registers the report and confirms receipt to the whistle-blower within five business days. The Compliance Officer informs the Board immediately, unless the abuse relates to a member of the Board (see 5).
- The Compliance Officer protects the identity of the whistle-blower at all times, unless the whistle-blower releases the Compliance Officer from this duty in writing.
- Immediately upon receipt, the Board launches or commissions an investigation into the abuse.
- If the abuse relates to a member of the Board, the Compliance Officer takes responsibility for launching or commissioning an investigation into the abuse.
Article 3 Terms
- Within a period of eight weeks from the time the report is registered in accordance with 2.2, the Compliance Officer is informed in writing by or on behalf of the Board of the latter’s standpoint on the abuse and the measures which have been or will be taken.
- If it is not possible to provide a standpoint within the aforesaid period of time, the Board will inform the Compliance Officer in a timely manner and state by what date they will provide their standpoint.
- In the case of 2.5, the Compliance Officer takes responsibility for providing or commissioning a standpoint.
- The Compliance Officer will immediately inform the whistle-blower of the standpoint.
Article 4 Legal protection
- The Board (or the Compliance Officer) ensures that a whistle-blower who has reported an abuse in good faith and in accordance with these rules will not be disadvantaged in their job in any way.
- If a whistle-blower reports an abuse without adhering to these rules or publicises an abuse directly or via third parties, that can be held against them.
Article 5 Effective date and publication
- This scheme is effective from 1 January 2008. The scheme is subject to change.
- This scheme will be published on the website of Lentink Accountants and Tax Advisers.