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Whistle-blower scheme


Based in part on Article 32 of the Dutch Audit Firms Regulation, we have implemented a whistle-blower scheme so that people from outside our audit firm who work for us as well as our own people can sound the alarm if they encounter any irregularities during their work within or in relation to our audit firm without jeopardising their legal position.

1 - Definitions
•Practice: Lentink Accountants / Tax Advisers;
•Whistle-blower: the person, whether or not an employee of Lentink Accountants / Tax Advisers, who performs activities for Lentink Accountants / Tax Advisers and reports an abuse under this scheme
•Employee: a whistle-blower who is employed by Lentink Accountants / Tax Advisers;
Superior: the employee's superior;
Compliance officer: the compliance officer appointed by the board of Lentink Accountants / Tax Advisers. •Board: the management board of Lentink Accountants / Tax Advisers, responsible for compliance with and execution of the rules and regulations;
•Abuse: a reasonably founded suspicion relating to Lentink Accountants / Tax Advisers and/or its employees, in conjunction with: an actual or imminent offence
•an actual or imminent violation of the law or regulations
•the actual or imminent deliberate provision of false information
•an actual or imminent violation of the rules or code of conduct within Lentink Accountants / Tax Advisers or
• the actual or imminent destruction or manipulation of information about the aforesaid acts

2 Procedure
•The whistle-blower reports an abuse to the Compliance Officer by email to compliance@lentink.org. This email address is protected by spambots; Javascript is required to see this part. The whistle-blower can also report the abuse to his or her superior at the same time. If the abuse relates to the Compliance Officer, the abuse can be reported to another officer. This officer will then proceed as set out below.
•The Compliance Officer registers the report and confirms receipt to the whistle-blower within five business days. De Compliance Officer informs the Board immediately, unless the abuse relates to a member of the Board (see 5).
•Compliance Officer protects the identity of the whistle-blower at all time, unless the whistle-blower releases the Compliance Officer from this duty in writing.
•Immediately upon receipt, the Board launches or commissions an investigation into the abuse.
•If the abuse relates to a member of the Board, the Compliance Officer himself launches or commissions an investigation into the abuse.

3 Terms
•Within a period of eight weeks of the time the report is registered in accordance with 2.2, the Compliance Officer is informed in writing by or on behalf of the Board of the latter's standpoint on the abuse and the measures which have been or will be taken.
•If it is not possible to provide a standpoint within the aforesaid period of time, the Board will inform the Compliance Officer in a timely manner and state by what date they will provide their standpoint.
•In the case of 2.5, the Compliance Officer himself will provide or commission a standpoint.
•The Compliance Officer will immediately inform the whistle-blower of the standpoint.

4 Legal protection
•The Board (or the Compliance Officer) ensures that a whistle-blower who has reported an abuse in good faith and in accordance with these rules will not be disadvantaged in his job in any way.
•If a whistle-blower reports an abuse without adhering to these rules or publicises an abuse directly or via third parties, that can be held against him.

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Transparency
General terms
Whistle-blower scheme
Code of conduct


Huizen

Huizermaatweg 460
1276 LM Huizen
Postbus 1165
1270 BD Huizen
Tel: +31 (0)35-5232575

Almere

G T. Rietveldstraat 180
1333 LJ Almere
Postbus 1165
1270 BD Huizen
Tel: +31 (0)36-5486777
Hilversum
Stationsstraat 2b
1211 EM  Hilversum
Tel: 035 5232575
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