This Whistle-Blowing Scheme guarantees that people from outside our accountants’ organisation and the people working for us or affiliated with our organisation are able to address any alleged irregularities within or (partly) outside of the accountants’ organisation without jeopardising their legal position. This scheme means that reports are drawn up, handled confidentially and in a timely manner and that the irregularities that have been reported, if justified, are handled in a timely manner by our accountants’ organisation taking appropriate measures. For the people working for us or affiliated with our organisation, please also refer to section 7.7. of the Quality Accountants Handbook.
Article 1
In this regulation, the following definitions apply:
Reporter: the person who, whether or not employed by Horlings Accountants & Belastingadviseurs, reports and Abusive Situation under this regulation;
Horlings Accountants & Belastingadviseurs: the public limited liability company Horlings Accountants & Belastingadviseurs;
Trusted representative: Compliance officer (W.H. Plaisier RA);
Board: the Board of Horlings Accountants & Belastingadviseurs;
An Abusive Situation: a reasonable suspicion in relation to Horlings Accountants & Belastingadviseurs and/or its employees, in relation to:
- a punishable offence/threat of a punishable offence;
- a violation/threat of violation of legislation or regulations;
- consciously providing/a threat of consciously providing incorrect information;
- a violation/threat of a violation of rules/code of conduct that applies within Horlings Accountants & Belastingadviseurs;
- consciously holding back, destroying or manipulating information (or the threat thereof) in relation to these or other facts that could cause harm to Horlings Accountants & Belastingadviseurs;
- any other situations that the reporter believes qualify for reporting to the Trusted Representative.
Article 2
1. The Reporter reports an Abusive Situation to the Trusted Representative by e-mail. The Reporter may also make a report to his line manager at the same time if required.
2. The Trusted Representative records the report and confirms to the Reporter within five working days that the report has been received. The Trusted Representative informs the Board of the report straight away, unless the Abusive Situation concerns a member of the Board (see paragraph 5).
3. The Trusted Representative shall guarantee the anonymity of the Reporter at all times, unless the Reporter relieves the Trusted Representative of this obligation in writing.
4. As soon as the report has been received, that Board shall (undertake to) start an investigation into the Abusive Situation.
5. In the event that that Abusive Situation concerns a member of the board, the Trusted Representative shall (undertake to) start his own investigation into the Abusive Situation.
Article 3
1. Within a period of eight weeks from the moment of recording the report, in accordance with article 2 paragraph 2, the Trusted Representative shall be notified in writing by or on behalf of the Board of the Board’s verdict in relation to the Abusive Situation as well as the measures to take or already taken.
2. In the event that it is not possible to provide the verdict within the period set forth in the first paragraph, the Board shall notify the Trusted Representative in good time and name the period in which an opinion shall be given.1414
3. In the event of article 2 paragraph 5, the Trusted Representative shall (undertake to) formulate his own verdict.
4. The Trusted Representative shall notify the Reporter of the verdict straight away.
Article 4
1. The Board (or the Trusted Representative) shall ensure that the Reporter who reported an Abusive Situation in good faith and in accordance with this regulation, shall not be prejudiced in his position in any way.
2. In the event that a Reporter has made the report in a way other than in accordance with this regulation, or publicises it directly or through third parties, that may be held against him.
