1. General
Pursuant to Art. Regulation 32 of the Accounting Firms (VAO) should have an audit firm on whistleblowers.
2. Scope
The whistleblower scheme covers the following situations:
a. Actions by directors, officers and employees (one of the companies) Van Oers leading to criminal offenses;
b. actual or suspected violations of external laws and regulations by directors, officers and employees (one of the companies) Van Oers;
c. actual or suspected violations of internal regulations by directors, officers and employees (one of the companies) Van Oers;
d. (Imminent) harassment of employees by customers, colleagues or superiors;
e. (Threatening) unlawful destruction or manipulation of data or information;
f. and all other situations that qualify for the opinion of a detector to alert the counselor.
3. procedure
a. Reports within the framework of this scheme can be carried out by by directors, officers and employees (one of the companies) Van Oers, customers of Van Oers and any other external outside Van Oers.
b. If there is a situation which falls within the scope of the whistleblowing scheme, the detector has the ability to report it to the Compliance Officer.
c. The notification to the compliance officer may or may not be provided anonymously and will only be in writing or electronically.
d. The compliance officer confirmed the report within one week to the petitioner. The compliance officer informs the reporter also how and within what period will be his message into treatment. This period is a maximum of four weeks after receiving the notice.
e. The compliance officer shall inform the complainant within four weeks on the handling of his report and the action taken. If this deadline can not be met due to unforeseen circumstances, the compliance officer informs the reporter about this and he indicates the time the alarm will be informed about finishing his report.
f. If there is mentioned of a situation under 2.a. and / or 2.e., the compliance officer shall immediately inform the Bureau, unless the notification in which case relates to the executive committee, the compliance officer shall inform the other board members.
g. In informing the Board referred to in paragraph f, the compliance officer does not know the source.
4. Confidentiality
The report, the correspondence on this subject and the treatment carried out under complete secrecy and confidentiality, unless the detector relieve the compliance officer of confidentiality.
5. Legal
An employee who has made good faith and notified in accordance with this regulation will not be disadvantaged in any way in his legal position.
6. Confidential
The compliance officer acts as trustee. In the absence of the compliance officer, or if the message should relate to the compliance officer, acting deputy compliance officer, Angela Hofman as deputy counselor.
7. Entry into force
This regulation comes into force on January 1, 2007