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1. General
Pursuant to the Account Organisation Regulation (Verordening Accountantsorganisaties; “VAO”), an accountancy firm must have a whistleblower procedure.

Article 32 VAO is as follows:

  1. The accountancy firm has a procedure through which it guarantees that persons from outside the accountancy firm, or the persons employed by or related to it, can bring possible irregularity inside and/or outside the accountancy firm up for discussion, without the risk of losing their legal status. This procedure results in complaints being documented and being treated confidentially and in a timely fashion and that the irregularities that are under discussion are dealt with by taking appropriate measures by the accountancy firm, if deemed justified.
  2. The procedure, referred to in the first subsection, is placed on the website of the accountancy firm. If the accountancy firm does not have a website, it will notify persons within the accountancy firm in another way and will send documentation concerning this procedure to persons outside the accountancy firm, if so requested.

Besides the whistleblower procedure, a complaints procedure also applies. The difference  with the complaints procedure is that the notification concerning the whistleblower procedure always takes place anonymously.

2. Definitions

  • reporter: the person performing activities for vhm | abc and who has notified a deemed irregularity. This person is or is not employed by vhm | abc , or one of its holding companies;
  • vhm | abc: vhm | accountants & belastingadviseur B.V.
  • confidant: member of the board (see appendix);
  • board: the board of vhm | accountants & belastingadviseurs B.V.;
  • irregularity: a reasonable doubt in respect of vhm | abc and/or its employees, with respect to:
  • a. a (possible) criminal act;
  • b. a (possible) offence;
  • c. a (possible) act of providing incorrect information;
  • d. a (possible) breach of vhm|abc’s rules, or
  • e. (a possible) destruction or manipulation of information concerning the abovementioned facts;
  • f. all other circumstances that are considered for notification by the reporter.

3. Procedure

  1. The reporter notifies the confidant of a (possible) irregularity in writing. This can be done by sending an e-mail to, or by registered mail to our correspondence address, for attention of the confidant. The reporter can notify his or her manager thereof simultaneously.
  2. The reporter clearly describes the irregularity.
  3. The reporter includes his name and address details.
  4. The confidant must try to inform the reporter within a period of three weeks after receipt of the notification on how his notification has been dealt with and which measures were taken. If the confidant is unable to inform the reporter within this period, he will inform the reporter of this and will indicate within which period the reporter will be informed on how his notification is dealt with.
  5. The confidant will, at all times, ensure the reporter’s anonymity, unless the confidant is relieved of this requirement by the reporter in writing.
  6. The board will ensure that an investigation is initiated into the irregularities directly after receipt of the notification and will take additional measures, if necessary.

4. Legal protection

  1. The board guarantees that the reporter, who is of good faith and reports a suspicion of irregularities in accordance with the present procedure, is in no way disadvantaged in his position.
  2. If a reporter made a public notification in a different way than that stated in the current procedure, either directly or through third parties, this could have consequences for the reporter.

5. Taking effect and publication

  1. This procedure takes effect on 19 January 2012.
  2. This procedure is published on vhm | abc’s website (

Staff member
Confidant: E. Veldhuis RA

Address for written correspondence

Correspondence address
vhm | abc
Attn: The confidant
Postbus 344
8160 AH Epe

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