Whistleblower policy

Van Hoesel de Blaey accountants and tax advisors find it very important that employees can report any suspicion of irregularities within its offices in an adequate and safe manner. Under Article 32 of the Verordening accountantsorganisaties (audit firm regulation) (VAO), Accountancy firm Van Hoesel de Blaey should have a complaints policy (whistleblower policy) in place.

Art. 32 VAO

  1. The audit firm has an arrangement that ensures that persons from outside the audit firm and persons associated with it can raise concerns of alleged irregularities within or (partly) outside the audit firm putting their own legal position in jeopardy. This arrangement means that complaints are recorded, treated confidentially and in a timely manner and that the complaints made in relation to the irregularities, if found to be justified, are dealt with in a timely manner by taking appropriate measures taken by the audit firm.
  2. The arrangement referred to in the first paragraph will in any case be placed on the website of the audit firm. If an audit firm does not have a website, it will distribute this arrangement in a different way within the audit firm and, if requested, it will send this arrangement to persons outside the audit firm.

Scope

This whistleblower policy applies to the following situations:

  1. actions that lead to criminal offenses by the audit firm or its employees;
  2. any actual or suspected other violations of external laws and regulations by the audit firm or its employees;
  3. any actual or suspected other violations of internal laws and regulations by the audit firm or its employees;
  4. (threatened) intimidation of employees by colleagues or managers;
  5. (threatened) unlawful destruction or manipulation of data or information;
  6. all situations that, according to the person making the report, qualify for reporting to the confidential advisor.

This whistleblower policy can also be used in the event of a conflict, or in dealing with complaints about the actions of the audit firm or its employees.
 The difference with the complaints and incidents regulation is that when the whistleblower procedure is used, the anonymity of the individual making the report is guaranteed.

Procedure

  1. If there is a situation that falls within the scope of this whistleblower policy, the person making the report has the option to report this to the confidential advisor.
  2. The report to the confidential advisor can only be sent electronically via ‘complaints@hoesel.nl’
  3. External third parties can also send a report via this email address.
  4. The confidential advisor confirms the report to the individual who sent the report within a week. The confidential advisor also informs the individual sending the report how and the timeframe in which their report will be processed. This period is no later than four weeks after receipt of the report.
  5. If a situation mentioned in a and e under section 2 occurs, the confidential advisor immediately informs the management. The confidential advisor also informs the individual sending the report about this.
  6. In the event of a (imminent) violation of internal or external professional regulations, the confidential advisor does not inform the source of this information.
  7. The confidential advisor does not reveal the source when informing the management and the head of quality & technical office as referred to in points 5 and 6.
  8. The confidential advisor informs the individual sending the report no later than four weeks about the progress surrounding their report and the measures that have been taken. If this timeframe cannot be met due to unforeseen circumstances, the confidential advisor informs the individual sending the report about this and indicates the timeframe in which the relevant individual will be informed about the completion of the report.
  9. Reports that relate to a (threatened) violation of internal or external professional regulations are, in all cases, handled by the confidential advisor in consultation with the head of quality & technical office, with due observance of confidentiality.

Confidentiality 

  1. The notification, correspondence and handling thereof will take place under complete confidentiality and good faith, unless the individual sending the report releases the confidential advisor from their duty to uphold confidentiality.
  2. The management of the audit firm guarantees employees who report to the confidential advisor under this whistleblower policy that the report will in no way adversely affect his/her performance within the audit firm or his/her career.