Whistleblower

Pursuant to article 32 of the regulation audit firms (VAO) Jolles & Ko Accountants BV is obliged to have a whistleblower regulation. VAO article 32 reads as follows:

The audit firm is obliged to establish a regulation which ensures that people from outside the audit firm and its affiliated persons to blow the whistle on alleged irregularities within or (also) outside the audit firm without jeopardizing their legal status. This regulation means that complaints are recorded, be treated confidentially and in good time and that the irregularities complained about, if valid, are handled timely by taking action by the audit firm.

The regulation referred to in the first paragraph is placed on the audit firm's website. Where an audit firm does not have a website, they spread these rules otherwise within the audit firm and on request send that scheme to persons outside the audit firm.

Article 1: Definitions
In this whistleblowing regulation the following definitions are being used:
Jolles & Ko Accountants: Jolles & Ko Accountants BV
Reporter: the person who, whether or not employed with Jolles & Ko Accountants performs duties for Jolles & Ko Accountants and reports an irregularity under this scheme
Counsellor: The director of Jolles & Ko Accountants
Suspected irregularity: a suspicion based on reasonable grounds regarding Jolles & Ko Accountants and / or its employees referring to:
- A (imminent) criminal offense;
- A (imminent) violation of laws or regulations;
- A (threat) of deliberately false information;
- A (imminent) violation of following rules (of conduct) within Jolles & Ko Accountants;
- A (threatening) unlawful destruction or manipulation of data or information
- All other situations, which in the opinion of the reporter, require reporting to the confidential eligibility.

Section 2: Procedure
If there is a Suspicion of wrongdoing, the reporter has the option to report this to the counsellor.
The notification to the Confidential has to take place exclusively via e-mail / letter to the Counsellor (Jolles & Ko Accountants Attn vertrouwenspersoon@jolles.nl). External parties may also carry a message through this email address.
The message contains at least the date and a clear description of the wrongdoing. In addition, the report includes the name and address of the Reporter.
The counsellor confirms within a week, in writing, to the Reporter that the report is received in good order.

The counsellor guarantees at all times the anonymity of the reporter, unless the reporter in writing exempt the Counsellor of this obligation.
The counselor notes the contents of the report and will launch an inquiry and possibly take other necessary measures.
The counsellor informs the Reporter within six weeks of receipt of the notification about the handling of his report and the action taken. If this deadline cannot be met due to circumstances, the Counsellor informs the Reporter and indicates how soon the reporter is informed about the handling of its report of irregularity.

Item 3: Legal
The counsellor ensures that the reporter, who in good faith made a report of an irregularity, will not be disadvantaged in any way in his position.
If the reporter makes a report of an irregularity in any other way than stated in this regulation or bring directly or through third parties in publicity, he can possible be charged.

Article 4: Operation and publication
This regulation is used as from January 1, 2008
This scheme will be published on the website Jolles & Ko Accountants
We assume that reports are in good faith and expressing genuine, legitimate concerns. All reports are carefully evaluated by us. We will handle your complaint or report confidential.

The management of Jolles & Ko Accountants