Complaint Procedure

Complaint Procedure

1. Definitions

  • Audit firm: A company or institution providing statutory audits or associated with such entities.
  • Board: The partners’ meeting or governing body responsible for policy and decisions within the audit firm.
  • Bta: Decree on the Supervision of Audit Firms.
  • Partner: A person authorized to enter into engagements on behalf of the audit firm.
  • Employee: Any individual working under contract involved in the execution of the firm’s engagements.
  • Network: The collaborative structure associated with the audit firm as defined in the Bta.
  • Complaint: A written expression of dissatisfaction about the behavior of a partner or employee, or someone working at a firm within the network.
  • Complainant: The person submitting the complaint.
  • Committee: The complaints committee (see section 3).
  • Compliance Officer: The designated officer overseeing complaints (see section 4).
  • Secretary: The person appointed as secretary of the committee.
  • Complaint Supervisor: Assigned contact for internal complainants (see section 10).

2. Board Responsibilities

The board is responsible for handling, registering, and publishing complaints involving partners, employees, or network-related individuals.

3. Complaints Committee

  • The board may set up a (permanent or temporary) independent committee of at least two members.
  • At least one board member must be included, and one member will act as chair; another as secretary.
  • The committee advises the board on unresolved complaints.
  • It may also advise on broader or emerging issues.
  • The committee can establish internal rules for its operations.

4. Compliance Officer

The board appoints a compliance officer responsible for:

  • Coordinating complaint handling
  • Maintaining the complaints register
  • Ensuring procedural and content evaluation
  • Generating management reports

5. Submitting a Complaint

  • A complaint must be written, signed, and include:
    • Name and address of complainant
    • Date
    • Clear description of the issue
  • Oral complaints can be documented by an employee and submitted once signed by the complainant.

6. Acknowledgement of Receipt

  • The compliance officer sends an acknowledgment within one week of receipt.
  • If the complaint is incomplete, the complainant has two weeks to correct it.
  • Anonymous complaints are not accepted.
  • If the complainant fails to respond within the deadline, the board may dismiss the complaint and inform them.

7. Complaints Involving Other Network Entities

  • If the complaint involves individuals from another network firm:
    • It must be forwarded within one week.
    • Both boards will coordinate on handling.
    • All parties will be kept informed.

8. Handling Complaints

  • Within two weeks, the complainant is contacted to explore resolution via discussion or mediation.
  • If resolved to the complainant’s satisfaction, the case is closed and both parties are notified.
  • If not resolved, the complaint moves forward for formal review.

9. Committee Review and Advice

  • If needed, the board appoints a temporary committee and sets a deadline for advice.
  • New developments must be shared promptly with the committee.
  • All involved have a duty of confidentiality.

10. Internal Complaints

  • The identity of internal complainants is protected.
  • A complaint supervisor may be assigned.
  • No one involved should face adverse consequences.
  • After 3–6 months, the committee follows up to ensure no retaliation occurred.
  • Complaint-related information will not be added to the personnel file unless agreed.

11. Extension

  • If the board cannot conclude the process within 10 weeks (or 14 if a committee is involved), a delay notice must be sent before the deadline to all parties.

12. Board Decision

  • The board issues a written, reasoned decision to the complainant.
  • If other firms are involved, they also receive a copy.

13. Complaint Registration

Each complaint is recorded, including:

  • Name and address
  • Date
  • Description of the issue
  • Submission and resolution details
  • Duration and board conclusion
  • Committee advice, if applicable

14. Internal Publication

Annually, anonymized complaint data is published internally, along with explanations on:

  • Identified structural issues
  • Measures taken to address them

15. Implementation and Delegation

  • The board may issue additional rules to improve the procedure.
  • It may delegate tasks to the executive board.
  • The compliance officer oversees implementation.

16. Short Title

This procedure is titled the “Complaint Procedure.”

17. Effective Date

This policy replaces the previous version dated and takes effect on 27 May 2025.

18. Contact details

Complaints can be addressed to admin@justaudit.nl