whistleblowing scheme




The Whistleblower Scheme covers the following situations:


    a. acts leading to criminal acts by our organization or our staff.

    b. any actual or suspected violations of external laws and regulations by our organization or our


    c. any actual or suspected violations of internal regulations by our organization or our staff.

    d. (Imminent) harassment of staff by colleagues or managers.

    e. (Threatening) unlawful destruction or manipulation of data or information.

    f. and all other situations that qualify in the opinion of the detector to alert the trustee.




    1. if there is a situation that falls within the scope of the whistleblowing scheme, the detector has

        the ability to report it to the trustee.

    2. any alert or information being sent to a trusted person (trustee), should be sent electronically

        by completing the appropriate Whistleblower Scheme form.

    3. external parties may also send a message using this Whistleblower form.

    4. The trustee confirms the report within one week to the petitioner. The trustee also informs the

        reporter how and within what period will be his message is handled. This period shall be not

        be longer than four weeks after receipt of the report.

    5. If a situation is mentioned in point a. and e. above, the trustee should immediately inform a

        partner. The trustee should also inform the detector.

    6. if there is a (potential) violation of internal or external appeal regulations, the trustee informs

        the compliance officer.

    7. in informing a partner and the compliance officer referred to in paragraphs 5 and 6, the trustee

        does not reveal the source.

    8. The trustee informs the complainant within four weeks on receiving his report and the action

        taken. If this deadline cannot be met due to unforeseen circumstances, the trustee informs

        the reporter about this and he indicates the amount of time needed for the complainant to be

        informed about finishing his report.

    9. Reports related to a (potential) violation of internal or external appeal regulations are in all

        cases handled by the trustee in consultation with the compliance officer respecting





The reporting of an incident including the correspondence on this subject and handeling will be carried out under complete secrecy and confidentiality, unless the detector relieve the trustee of his duty of confidentiality.


Our organization ensures employees who pass on information to a trustee protection under the whistleblower policy. Any information given will not reflect on his / her performance in any way or have a negative impact in our organization, or on his / her career.