Whistle-blowing procedure

The following topics are described in the Whistle-blowing procedure:
1. General;
2. Scope;
3. Procedure;
4. Confidentiality.

1. General

In accordance with art. 32 of the Statute of accountancy organizations, an accountancy firm is required to have a whistle-blowing policy: Art.32 VAO
1. The accountancy firm has a regulation which ensures that persons from outside the accountancy firm and persons connected with him/her may raise issues about alleged irregularities within or outside the accountancy firm without jeopardizing their legal position. This regulation means that complaints are recorded, treated as confidential and are dealt with in a timely fashion and that if the irregularities reported, are valid, appropriate and timely measures are taken by the accountancy firm.
2. The regulations referred to in the first paragraph shall in any case be posted on the website of the accountancy firm. In the event that an accountancy firm does not have a website at its disposal, it must communicate this regulation within the accountancy firm and, if requested, send this to persons outside the accountancy firm.

2. Scope

This whistle-blowing policy applies to the following situations:
a) acts that lead to criminal offenses by Stolp+KAB advisors and accountants (hierinafter: Stolp+KAB) or its employees;
b) any actual or suspected violations of external laws and regulations by Stolp + KAB or its employees;
c) any actual or suspected violations of internal regulations by Stolp + KAB or its employees;
d) (impending) harassment of employees by colleagues or management;
e) (impending) unlawful destruction or manipulation of data or information;
f) and any and all situations that the informant believes he/she should notify the person of trust about.
If there are any differences of opinion, or complaints about the actions of Stolp + KAB or its employees, you can also make use of this whistle-blowing procedure. The difference with the aforementioned guidelines is related to the fact that the use of the whistle-blowing procedure is always based on anonymity.

3. Procedure

1. If there is a situation which falls within the scope of the whistle-blowing policy, the informant has the possibility to notify the person of trust.
2. Any and all notifications are communicated electronically only. To notify the person of trust send an email to vertrouwenspersoon@stolpkab.nl
3. External third parties may also carry out a notification via this e-mail address.
4. The person of trust sends a confirmation to the informant within 1 week of receiving the report. The person of trust informs the informant about how the report will be dealt with and within what time frame. This time frame is no longer than four weeks after the report has been made.
a) In the event of a situation referred to under (a) and (e) of paragraph 2, the person of trust immediately informs the partner. At the same time the person of trust informs the informant.
b) In the event of an (impending) breach of internal or external professional rules, the person of trust immediately informs the compliance officer.
c) When informing the partner and compliance office about matters mentioned in 4a and 4b the person of trust does not reveal the source.
5. The person of trust informs the informant of the measures taken in regard to his report, within four weeks. If unforeseen circumstances stand in the way of this deadline, the person of trust contacts the informant and indicates how long it will take to finalize the procedure.
6. Reports that are related to (impending) violations of internal and external professional regulations are dealt with in consultation with the compliance officer in strict confidentiality.

4. Confidentiality

The report, all correspondence and actions regarding this statement are carried out in strictest secrecy and confidentiality, unless the informant relieves the person of trust from his pledge of confidentiality. The board of directors of Stolp+KAB guarantees that employees who report to the person of trust according to the whistle-blowing policy, shall not suffer any negative consequences with regard to his/her position and/or career at Stolp+KAB.