The whistleblower policy ensures that people outside our accounting organization and persons working for us or associated with our organization can report any suspected irregularities in and/or outside the organization without jeopardizing their legal position.
The policy enables complaints to be recorded, considered promptly and confidentially and, if upheld, to be resolved swiftly through appropriate measures taken by our organization.
The policy has been drawn up in accordance with article 32 of the Accounting Firms Regulation and published on the intranet and website of Moore DRV.
Article 1 Definitions
- Informant: the party who, whether or not employed by Moore DRV, performs work for Moore DRV and reports an Abuse under this policy.
- Moore DRV: the Moore DRV partnership and the associated private limited companies of Moore DRV.
- Confidential Advisor: Compliance officer (M. Witt);
- Board: the Executive Board of Moore DRV.
- An Abuse: a suspicion based on reasonable grounds relating to Moore DRV and/or its employees, in connection with:an
- actual or impending criminal offence;
- an actual or impending breach of laws and regulations;
- an actual or impending instance of deliberate misinformation;
- an actual or impending breach of rules or codes of conduct in force within Moore DRV.
Article 2 Procedure
- The Informant reports an Abuse to the Confidential Advisor by emailing email@example.com. The Informant may simultaneously inform his manager.
- The Confidential Advisor records the report and confirms to the Informant within five working days that the report has been received. The Confidential Advisor immediately notifies the Board of the report, unless the Abuse involves a member of the Board (see paragraph 5).
- The Confidential Advisor guarantees the anonymity of the Informant at all times, unless the Informant dispenses the Confidential Advisor from this obligation in writing.
- Immediately after receipt the Board will initiate an investigation into the Abuse.
- If the Abuse involves a member of the Board, the Confidential Advisor himself will also initiate an investigation into the Abuse.
Article 3 Deadlines
- No later than eight weeks after the recording of the report in accordance with article 2, paragraph 2, the Confidential Advisor will be informed in writing by or on behalf of the Board of the Board’s opinion on the Abuse as well as the measures to be taken or already taken.
- If it is not possible to state the opinion before the deadline referred to in the first paragraph, the Board will inform the Confidential Advisor in good time and state the period within which an opinion will be issued.
- In the case of article 2 paragraph 5 the Confidential Advisor will formulate or request an opinion himself.
- The Confidential Advisor will immediately notify the Informant of the opinion.
Article 4 Legal protection
- The Board (or the Confidential Advisor) will ensure that the position of the Informant who has reported an Abuse in good faith and in accordance with this policy is in no way disadvantaged.
- If an Informant has filed the report by a means other than this policy or publicizes it directly or through third parties, he may be considered at fault.
Article 5 Effective date and publication
- This policy comes into force on 11 May 2007. It may be amended in consultation between the Board and the Central Consultative Body.
- This policy will be published on the intranet and website of Moore DRV.
Last revision: March 25, 2020.