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Whistleblowers procedure

In accordance with art. 27 of the Accountancy Firms Regulation (VAO) our office is required to have a whistleblower policy in place.

Art. 27 VAO 1. The accountancy organisation has a policy that guarantees that people from outside the accountancy organisation and persons associated with it can raise suspected irregularities within or (also) outside the accountancy organisation without endangering their legal position. This policy ensures that complaints are recorded, treated confidentially and in a timely manner and that the irregularities that are the subject of a complaint are, if justified, dealt with in a timely manner through appropriate measures taken by the accountancy organisation.
2. The regulation referred to in the first paragraph will in any case be posted on the website of the accountancy organisation. In the event that an accountancy organisation does not have a website, it shall distribute this plan in different manner within the accountancy organisation and, upon request, also to people outside the accountancy organisation.

General

This whistleblower policy covers the following situations:

  • Acts that lead to criminal offences by our company or its employees;
  • Any actual or suspected other violations of external laws and regulations by our company or its employees;
  • Any actual or suspected violations of internal regulations by our company or its employees;
  • (Impending) harassment of employees by colleagues or supervisors;
  • (Impending) unlawful destruction or manipulation of data or information;
  • And, furthermore, all situations that, in the opinion of a whistleblower, qualify for reporting to the confidential adviser.

In the case of any differences of opinion or complaints about the performance of our company or its employees, this whistleblower policy can also be used. The difference with the aforementioned guidelines is related to the fact that the whistleblower policy is always used on the basis of anonymity.

Procedure

  1. In the event of a situation that falls within the scope of this whistleblower policy, the whistleblower has the option to report this to the confidential adviser.
  2. The report to the confidential adviser shall only be made electronically, via info@trivent.nl.
  3. External third parties may also make a report using this email address.
  4. The confidential adviser confirms reception of the report to the whistleblower within 1 week. The confidential adviser also informs the whistleblower about how and within what period of time his report will be processed. This period shall be no longer than four weeks after receipt of the report.
  5. a) In the case of an act leading to a criminal offence or unlawful destruction or manipulation of data or information, the confidential adviser shall immediately inform the Board. The confidential adviser shall also inform the whistleblower of this.
    b) In the event of an (impending) violation of internal or external professional regulations, the confidential adviser will also inform the Board.
    c) When informing the Board as referred to in points 5a and 5b, the confidential adviser shall not disclose the source.
  6. The confidential adviser shall inform the whistleblower about the handling of their report and the measures that have been taken, at the latest after four weeks. If, due to unforeseen circumstances, this deadline cannot be met, the confidential adviser shall inform the whistleblower about this and indicate the deadline by which the whistleblower will be informed about the completion of their report.
  7. Reports relating to an (impending) violation of internal or external professional regulations are in all cases handled by the confidential adviser in consultation with the management with due observance of confidentiality.

Confidentiality

The report, the correspondence about it and the handling shall take place under complete secrecy and confidentiality, unless the whistleblower relieves the confidential adviser of their duty of confidentiality.

The Board of our company guarantees to employees who pass on reports to the confidential adviser on the basis of this whistleblowers' scheme, that the report will in no way have a negative impact on their performance within the accountancy organisation or their career.