Whistleblower policy

Schuiteman M&A – Corporate Finance

General

In accordance with article 27 of the Regulation on Audit Firms (VAO), Schuiteman Registeraccountants B.V., Schuiteman M&A – Corporate Finance B.V., Schuiteman Accountants & Adviseurs B.V. (hereinafter referred to as ‘Schuiteman’) is required to have a whistleblowing policy. This article reads as follows:

Art. 27 VAO

  1. The audit firm shall have a policy ensuring that individuals external to the audit firm, as well as those employed by or connected to it, can report suspected irregularities within or (partially) outside the audit firm without fear of reprisal against their legal position. This policy ensures that complaints are documented, handled confidentially and promptly, and that any substantiated irregularities are promptly addressed through appropriate measures by the audit firm.
  2. The policy referred to in the first paragraph shall in any case be published on the audit firm’s website. In the event that an audit firm does not have a website, it shall distribute this policy through other means within the audit firm and provide this policy upon request to individuals external to the audit firm.

Article 1: Definitions

  1. Schuiteman Registeraccountants B.V., Schuiteman M&A – Corporate Finance B.V., Schuiteman Accountants en Belastingadviseurs B.V.;
  2. Reporting party: The person who, whether or not employed by Schuiteman, performs activities for Schuiteman and reports a misconduct under this arrangement;
  3. Compliance officer: The person appointed by the management of Schuiteman for this purpose. This is Mr. W. van Reenen RA;
  4. Management: The management of Schuiteman, responsible for compliance with and implementation of regulations;
  5. Misconduct: a reasonable suspicion concerning Schuiteman and/or its employees, relating to:
    • An (imminent) criminal offense;
    • An (imminent) violation of laws or regulations;
    • An (imminent) act of knowingly providing incorrect information;
    • An (imminent) violation of internal Schuiteman (behavioral) rules or (imminent) destruction or manipulation of information concerning the aforementioned matters.

Article 2: Procedure

  1. The reporter submits a report of misconduct in writing to the compliance officer via email at complianceofficer@schuiteman.com. Simultaneously, the reporter may also report to their supervisor.
  2. The compliance officer records the report and confirms receipt to the reporter within five working days. The compliance officer promptly informs the management team of the report, except when the
    misconduct involves a member of the management team (refer to clause 5).
  3. The compliance officer ensures the anonymity of the reporter at all times, unless the reporter releases the compliance officer from this obligation in writing.
  4. Immediately upon receipt, the management team initiates an investigation into the misconduct.
  5. If the misconduct involves a member of the management team, the compliance officer initiates an investigation into the misconduct.

Article 3: Timelines

  1. Within a period of four weeks from the registration of the report as per Article 2, clause 2, the compliance officer is informed in writing by or on behalf of the management team about the management team’s position regarding the misconduct, as well as the measures to be taken.
  2. If it is not possible to provide a position within the timeline mentioned in the first clause, the management team will inform the compliance officer in a timely manner and specify the deadlines by which a position will be provided.
  3. In case of Article 2, clause 5, the compliance officer will formulate a position.
  4. The compliance officer informs the reporter promptly of the management team’s position.

Article 4: Legal Protection

  1. Notifications, related correspondence, and the handling thereof shall be conducted under complete confidentiality, unless the whistleblower releases the confidential advisor from their duty of confidentiality.
  2. The management (or compliance officer) of Schuiteman guarantees that employees who report incidents to the confidential advisor under this whistleblowing policy will not be negatively affected in their functioning within the accounting organization or their career in any way.
  3. If a whistleblower makes the report in a manner other than in accordance with this policy, or if they publicize it directly or through third parties, it may be held against them.

Article 5: Operation and Publication

  • The regulation may be amended by mutual agreement.
  • This regulation is published on the Schuiteman website.

Notification, correspondence, and handling thereof shall be conducted under complete confidentiality and secrecy, unless the reporting person releases the confidentiality obligation from the confidential advisor. The management of Schuiteman guarantees employees reporting incidents to the confidential advisor under this whistleblowing policy that the report will in no way negatively affect their functioning within the accounting organization or their career.