Whistleblower Policy – Just Audit

Effective Date: 27 May 2025

Version: 2.0

Applies to: All employees, contractors, interns, partners, clients, and other stakeholders of Just Audit B.V.

1. Purpose

Just Audit is committed to conducting business with integrity, transparency, and accountability. This Whistleblower Policy is designed to provide a secure, confidential, and accessible channel for reporting suspected wrongdoing, while protecting whistleblowers against any form of retaliation.

2. Scope

This policy applies to all individuals associated with Just Audit who, in a work-related context, report concerns about:

  • Breaches of EU or Dutch law;
  • Financial misconduct or fraud;
  • Accounting or auditing irregularities;
  • Bribery or corruption;
  • Environmental violations;
  • Violations of privacy or data protection law;
  • Discrimination, harassment, or threats to public health and safety;
  • Other serious ethical, legal, or regulatory violations.

3. Reporting Channels

You may report concerns through the following internal reporting channels:

  • By Email (confidential): admin@justaudit.nl
  • By Phone: +31 (0) 620290041 (Sven) or +31 (0) 624900163 (Tjerk)
  • In Writing: Send a sealed envelope marked “Strictly Confidential – Whistleblower Report” to: Just Audit, Attn:
    Whistleblower Officer Bruggestraat 49-1 3841 CM Harderwijk
  • In-Person: Upon request, a meeting will be scheduled within a reasonable timeframe.

You may also choose to report externally to a designated competent authority, including:

  • The Netherlands Whistleblower Authority (Huis voor Klokkenluiders)
  • The Dutch Data Protection Authority (Autoriteit Persoonsgegevens)
  • The Dutch Authority for the Financial Markets (AFM)
  • Other EU/national supervisory bodies relevant to the matter

4. Anonymity and Confidentiality

Just Audit respects and protects your identity. Reports may be made anonymously. All reports—anonymous or not—will be treated as strictly confidential. We will not disclose the identity of the whistleblower without their explicit consent, unless required by law.

5. Protection Against Retaliation

Whistleblowers acting in good faith are protected against any form of retaliation, including dismissal, demotion, harassment, or discrimination. Retaliatory actions will result in disciplinary measures, which may include termination of employment or contracts.

6. Investigation and Follow-Up

Once a report is received:

  • A confirmation of receipt will be sent within 7 days (unless the report is anonymous).
  • A neutral investigation will be initiated by the designated Whistleblower Officer.
  • A follow-up with the whistleblower will take place within 3 months from the date of acknowledgment.

All investigations will be thorough, impartial, and handled with care.

7. No Penalty for Mistaken Reports

If a report is made in good faith, and later found to be unsubstantiated, the whistleblower will not face any sanctions, even if the concern turns out to be incorrect. However, knowingly false reports may result in disciplinary consequences.

8. Recordkeeping

All whistleblower reports and investigations will be documented and securely archived for a minimum of 5 years in accordance with applicable laws.

9. Questions or Concerns

For any questions about this policy, please contact our Whistleblower Officer at admin@justaudit.nl.

This policy is reviewed annually and updated as required to comply with applicable legislation.