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Whistle Blower Policy

Scope

The whistleblowing policy applies to the following situations:

  1. actions that lead to criminal offenses by our organization or our employees.
  2. all actual or suspected other violations of external laws and regulations by our organization or our employees.
  3. all actual or suspected violations of internal regulations by our organization or our employees.
  4. (threatening) intimidation of employees by colleagues or managers.
  5. (threatened) unlawful destruction or manipulation of data or information.
  6. and furthermore, all situations that, in the opinion of the reporter, qualify for reporting to the confidential counselor.

Procedure

  1. If there is a situation that falls within the scope of this whistleblower scheme, the reporter has the option to report this to the confidential counselor Mr. R. Verbruggen.
  2. Notification to the confidential counselor takes place exclusively electronically via info@daasluis.nl 
  3. External third parties can also submit a report via this address.
  4. The confidential counselor will confirm the report to the reporter within 1 week. The confidential counselor also informs the reporter how and within what period his report will be processed. This period is no later than four weeks after receipt of the notification.
  5. If there is a situation mentioned under points a and e above, the confidential counselor will immediately inform the partner. The confidential counselor also informs the reporter about this.
  6. If there is a (threatened) violation of internal or external professional regulations, the confidential counselor will inform the compliance officer.
  7. When informing the partner and the compliance officer as referred to in points 5 and 6, the confidential counselor does not disclose the source.
  8. The confidential counselor will inform the reporter no later than four weeks later about the handling of his report and the measures that have been taken. If this period cannot be met due to unforeseen circumstances, the confidential counselor will inform the reporter about this and indicate the period within which the reporter will be informed about the completion of his report.
  9. Reports relating to a (threatening) violation of internal or external professional regulations are in all cases handled by the confidential counselor in consultation with the compliance officer, taking confidentiality into account.

Confidentiality

The report, the correspondence about it and the treatment will take place under complete secrecy and confidentiality, unless the reporter releases the confidential counselor from his obligation of confidentiality.

Our organization guarantees employees who pass on reports to the confidential counselor on the basis of this whistleblower scheme that the report will in no way have a negative impact on his/her performance within our organization or his/her career.