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1. General
On the basis of art. 27 of the Accountancy Firms Regulation (VAO), an audit firm must have a whistleblower scheme.

Art. 27 VAO

  1. The audit firm has an arrangement that guarantees that persons from outside the audit firm and persons employed by or associated with it can raise alleged irregularities within or (partly) outside the audit firm without endangering their legal position. This arrangement means that complaints are recorded, treated confidentially and in a timely manner and that the irregularities complained of, if justified, are dealt with in a timely manner by taking appropriate measures by the audit firm.

  2. The regulation referred to in the first paragraph will in any case be placed on the website of the audit firm. In the event that an audit firm does not have a website, it will distribute these regulations in a different manner within the audit firm and, upon request, will send these regulations to persons outside the audit firm.



2. Definitions and Scope

In this scheme, the following definitions apply:

  1. Berkenrode Audit: Berkenrode Audit BV;

  2. Reporter: the person who, whether or not employed by Berkrode Audit, performs work for Berkenrode Audit and reports an abuse under these regulations;

  3. Employee: a reporter who is employed by Berkenrode Audit;

  4. Manager: the person who supervises the other employee;

  5. Compliance officer: the external party appointed by the board to act as such for Berkenrode Audit;

  6. Board: the board of Berkenrode Audit, charged with the implementation or compliance with these regulations;

  7. Misconduct: a suspicion based on reasonable grounds with regard to Berkenrode Audit and/or its employees, in connection with:

    • acts that lead to criminal offenses by the audit firm or its employees;

    • all actual or suspected other violations of external laws and regulations by the audit firm or its employees;

    • any actual or suspected violations of internal regulations by the audit firm or its employees;

    • (threatened) intimidation of employees by colleagues or managers;

    • (imminent) unlawful destruction or manipulation of data or information; and

    • furthermore, all situations that, in the opinion of a reporter, qualify for reporting to the confidential adviser.


If there are differences of opinion, or complaints about the conduct of Berkenrode Audit or its employees, use can also be made of this whistleblower policy. The difference with the aforementioned guidelines is related to the fact that use of the whistleblower policy always takes place on the basis of anonymity.




3. Procedure

  1. If there is a situation that falls within the scope of this whistleblower scheme, the whistleblower has the option of reporting this to the confidential adviser.

  2. The report to the confidential counselor will only take place electronically via

  3. External third parties can also make a report via this e-mail address.

  4. The confidential counselor confirms the report to the reporter within one week. The confidential counselor also informs the reporter how and within what period his report will be processed. This term is no later than eight weeks after receipt of the notification.

  5. If there is a situation referred to under the definitions and scope of this whistleblower regulation on 7a and/or 7e, the confidential counselor immediately informs the board. The confidential counselor also informs the reporter about this.

  6. If there is an (imminent) violation of internal or external professional regulations, the confidential counselor will inform the compliance officer.

  7. When informing the board and compliance officer as referred to in points 5 and 6, the confidential counselor does not disclose the source.

  8. The confidential counselor informs the reporter after four weeks at the latest about the handling of his report and the measures that have been taken. If this term cannot be met due to unforeseen circumstances, the confidential counselor will inform the reporter about this and will indicate the period within which the reporter will be informed about the completion of his report.

  9. Reports relating to an (imminent) violation of internal or external professional regulations are in all cases handled by the confidential adviser in consultation with the compliance officer, with due observance of confidentiality.



4. Confidentiality

The report, the correspondence about this and the handling will take place under complete secrecy and confidentiality, unless the reporter releases the confidential advisor from his duty of confidentiality.

The board of Berkenrode Audit guarantees employees who report reports to the confidential counselor on the basis of this whistleblower policy that the report will in no way negatively affect his/her performance within Berkenrode Audit, or his/her career.

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