Whistleblower Policy

Introduction

Kreston Lentink considers it important to conduct a sound integrity policy. A good whistleblower policy is part of this, according to Kreston Lentink.

The Works Council

The Works Council has approved this regulation.

Article 1 Definitions

• Advisory Department of the House for Whistleblowers: The advisory department of the House for Whistleblowers, as referred to in Article 3a, paragraph 2 of the House for Whistleblowers Act.
• Investigation Department of the House for Whistleblowers: The investigation department of the House for Whistleblowers, as referred to in Article 3a, paragraph 3 of the House for Whistleblowers.
• Involved Third Party: A third party who is connected to a reporter in a work-related context or a legal entity owned by the reporter, for which the reporter works or with which the reporter is otherwise work-related.
• Competent Authority: An authority designated by law to receive and handle reports of suspected misconduct.
• Compliance Officer: The internal officer or their deputy appointed by Kreston Lentink to receive and handle reports.
• Person Assisting the Reporter: A natural person who advises a reporter in the reporting process in a work-related context and whose advice is confidential.
• Reporter: A natural person who reports or discloses a suspicion of misconduct in the context of their work-related activities.
• Report: The oral or written report of a suspicion of misconduct.
• External Report: A report to a person or entity outside Kreston Lentink, such as a competent authority.
• Reporting Point: The organization and procedure at a competent authority for receiving and handling reports of information about a breach.
• Misconduct: An act or omission that affects the public interest, involving a violation of a legal provision, a danger to public health, a danger to the safety of persons, a danger to the environment, a danger to the proper functioning of the organization due to improper conduct or omission.
• Suspicion of Misconduct: The suspicion of a reporter that there is misconduct within the organization where the reporter works or has worked (or at another organization if the reporter has come into contact with that organization through their work), provided the suspicion is based on reasonable grounds. The reasonable grounds arise from the knowledge the reporter has gained from their employer or from their work at another company or organization.
• Work-Related Context: Current or former work-related activities in the public or private sector through which, regardless of the nature of those activities, individuals can obtain information about misconduct and may face retaliation if they report such information.

Article 2 Information and Advice

A reporter can contact the compliance officer in case of (a suspicion of) misconduct. Additionally, the advisory department of the House for Whistleblowers can be consulted confidentially. The person assisting the reporter or another involved third party can also consult the advisory department of the House for Whistleblowers confidentially in case of a suspicion of misconduct.

Article 3 External Reporting

A report can be made by a person who is or was employed by Kreston Lentink. Additionally, a report can be made by an applicant and a person who is not or was not employed by Kreston Lentink but has come into contact with the organization through their work. The reporter can make an internal report to the compliance officer or an external report to another party, such as a competent authority (e.g., supervisors, such as the police in case of a criminal offense) or the investigation department of the House for Whistleblowers. A reporter with a suspicion of misconduct has the option to report it orally, by letter, or as an electronic message (e.g., by email). An oral report to the compliance officer can be made by phone or, at the reporter’s request, through a physical meeting within a reasonable time. An oral report can be recorded by making an audio recording in a durable and retrievable form, with the reporter’s prior consent, or by providing a written summary of the conversation, which the reporter can review, correct, and sign for approval. If there is a criminal offense, the reporter is strongly advised to consider filing a report, even if a report has already been made under this regulation.

Article 4 Reporting Procedure

A report of a suspicion of misconduct is registered upon receipt in a register managed by the compliance officer. Only the compliance officer has access to this register. The compliance officer confirms the report to the reporter within one week of receipt. The confirmation includes a brief description of the report, the date it was received, and a copy of the report. The compliance officer also informs the reporter how and within what timeframe the report will be handled. This period starts no later than four weeks after the receipt of the report. The compliance officer informs the reporter in writing that an investigation has been initiated and by whom. This is done immediately after the investigation is initiated. If no investigation is initiated, the compliance officer also informs the reporter in writing, stating the reason for not initiating an investigation. This may be because it is evident that the suspicion is not based on reasonable grounds or that the reported matter does not concern a suspicion of misconduct and this regulation does not apply. The compliance officer informs the reporter in writing within three months of the confirmation of receipt of the report about the position regarding the reported suspicion of misconduct and the follow-up to the report and any internal investigation. If it becomes clear that the compliance officer cannot provide the position within three months of the confirmation of receipt of the report due to unforeseen circumstances, the compliance officer informs the reporter in writing. The compliance officer also provides feedback on the steps already taken and the expected duration of the procedure.

Article 5 External Reporting

The reporter is not obliged to report a suspicion of misconduct internally or to the compliance officer first. They can also make an external report directly to another authority. The reporter can also choose to make an external report if they disagree with the compliance officer’s position, believe the report has been unjustly dismissed or insufficiently investigated, or have not received a position on the report within three months of the confirmation of receipt. External reports can be made to a competent authority. Competent authorities include the investigation department of the House for Whistleblowers ([www.huisvoorklokkenluiders.nl](http://www.huisvoorklokkenluiders.nl)), the Authority for Consumers and Markets (ACM) ([www.acm.nl](http://www.acm.nl)), the Financial Markets Authority (AFM) ([www.afm.nl](http://www.afm.nl)), and the Data Protection Authority (AP) ([www.autoriteitpersoonsgegevens.nl](http://www.autoriteitpersoonsgegevens.nl)). The websites of the competent authorities provide the procedure for making an external report and how the competent authority handles and investigates the report. If necessary, the reporter can obtain information from the advisory department of the House for Whistleblowers about making an external report and choosing the competent authority.

Article 6 Confidentiality and Protection Against Retaliation

Kreston Lentink guarantees that everyone involved in the reporting or investigation of a suspicion of misconduct is bound by confidentiality. The compliance officer ensures that the information about the report and the investigation is stored in such a way that it is only accessible to those involved in handling the report and the investigation. The identity of the reporter and the information from which the reporter’s identity can be directly or indirectly inferred will not be disclosed by Kreston Lentink or the compliance officer without the reporter’s explicit written consent, except for legal obligations. However, the compliance officer may decide to inform the management of Kreston Lentink about the misconduct if it involves a criminal offense, due to its seriousness and/or the compliance officer’s conscience, after discussing it with the reporter, even if it is unavoidable or necessary for the management to know the reporter’s identity. According to legal requirements, a reporter must not be disadvantaged during and after the handling of a report or disclosure of a suspicion of misconduct, provided the reporter had reasonable grounds to believe that the reported information about the suspicion of misconduct was correct at the time of the report. Kreston Lentink will ensure, as far as reasonably possible, that a report made on reasonable grounds in accordance with this whistleblower policy will not have adverse effects on the reporter’s functioning within the accounting organization or their career.

Article 7 Publication, Reporting, and Evaluation

Kreston Lentink ensures that this regulation is published on the intranet and made public on the Kreston Lentink website. Kreston Lentink prepares an annual report on the policy regarding the handling of reports of suspicions of misconduct and irregularities and the implementation of this regulation. This report includes information about the policy in the past year and the handling of reports of suspicions of misconduct and irregularities and the policy to be pursued in the coming year in this area; information about the number of reports and an indication of the nature of the reports, the outcomes of the investigations, and the employer’s positions; general information about the experiences with or the extent to which reports have indeed had no negative impact on the functioning of reporters within the accounting practice or their careers; information about the number of requests for investigation into retaliation in connection with making a report of a suspicion of misconduct and an indication of the outcomes of the investigations and the employer’s positions. Kreston Lentink sends the draft report to the Works Council for discussion, after which the report is discussed in a consultation meeting with the Works Council. Kreston Lentink gives the Works Council the opportunity to express its position on the policy regarding the handling of reports of suspicions of misconduct and irregularities, the implementation of this regulation, and the report. The highest executive ensures that the Works Council’s position is incorporated into the report and submits this incorporation to the Works Council for approval.

Article 8 Entry into Force and Repeal of the Current Regulation

This regulation enters into force on February 12, 2025. This regulation replaces the current whistleblower policy. The old regulation will be repealed on February 12, 2025.