Pursuant to Article 32 of the Dutch Accounting Firms Decree (VAO), EJP must have a whistle-blower scheme. EJP has a scheme which ensures that persons from outside the accounting firm and any affiliated persons can, without any risks to their legal position, report alleged irregularities within or (partly) outside the accounting firm.
This scheme ensures that complaints are recorded, handled in a confidential and timely manner, and that the irregularities that are the subject of the complaint, if founded, are addressed timely by the implementation of suitable measures by the accounting firm. The scheme has been published on the website of the accounting firm.
The counsellor will inform the whistle-blower on the handling of his report and any implemented measures within four weeks. If this period cannot be met due to unforeseen circumstances, the counsellor will inform the whistle-blower and indicate within which period he will be informed about the handling of his report.
This whistle-blower scheme governs the following situations:
- A. Acts that lead to offences by the accounting firm or its employees;
- B. All actual or suspected violations of external laws and regulations by the accounting firm or its employees;
- C. All actual or suspected violations of internal regulations by the accounting firm or its employees;
- D. (Impending) intimidation of employees by colleagues or managers;
- E. (Impending) unlawful destruction or manipulation of data or information;
- F. And all situations which the whistle-blower believes must be reported to the counsellor.
The whistle-blower scheme can also be relied on in case of differences of interpretation, or complaints about the conduct of the accounting firm or its staff. The whistle-blower scheme is different from the guidelines set out above because it will be applied on the basis of anonymity.
Reports that concern a(n) (impending) violation of internal or external professional regulations will always be handled by the counsellor in consultation with the compliance officer, with due observance of the confidentiality of the whistle-blower.
A whistle-blower can report any situation covered by the scope of this whistle-blower scheme to the counsellor, Mr J.T.A. de Koning. Reports to the counsellor can be made by electronic means by contacting firstname.lastname@example.org or by letter. External third parties can also submit reports to this e-mail address.
The counsellor will inform the whistle-blower of the receipt of the report within 1 week. The counsellor will also inform the whistle-blower how and within which period his report will be handled. This will be within four weeks of receipt of the report.
The counsellor will immediately inform the accounting firm in case of a situation listed in item A or E. The counsellor will also inform the whistle-blower.
The counsellor will inform the compliance officer in case of a(n) (impending) violation of internal or external professional regulations.
The counsellor will not disclose the source of the report when informing the board and compliance officer as referred to in items 2a and 2b.
The report, any related correspondence, and the handling thereof will take place in full confidentiality and secrecy, unless the whistle-blower relieves the counsellor of his duty of confidentiality.
The board of the accounting firm guarantees that the performance or career within the accounting firm of any employee who submit reports to the counsellor based on the whistle-blower scheme will in no way be adversely affected.