Whistleblowing policy

Pursuant to art. 27 of the Accountancy Firms Regulation (VAO), VHM Audit must have a whistleblower scheme.

Article 27 VAO reads as follows:

1. The audit firm has an arrangement that guarantees that persons from outside the organization and persons associated with it can raise alleged irregularities within or (partly) outside the organization without endangering their legal position. This arrangement means that complaints are recorded, treated confidentially and in a timely manner and that the irregularities about which the complaint is based, if justified, are dealt with in a timely manner by taking appropriate measures by the audit firm.

2. The regulation referred to in the first paragraph will in any case be placed on the website of the audit firm. In the event that an audit firm does not have a website, it will distribute these regulations in a different manner within the audit firm and, upon request, will send these regulations to persons outside the audit firm.

This whistleblower procedure applies in addition to:

• The complaints procedure as stated in chapter 8.3.1 of the quality manual.

• The consultation procedure in the event of differences of opinion within (control) teams as included in chapter 6.4 of the quality manual.

Article 1. Definitions

The following definitions are used in this whistleblower policy:

VHM Audit

Reporter: The person who makes a report as referred to in this whistleblower policy, either someone employed by VHM Audit or an external party involved.

Confidential adviser: The person appointed by the board of vhm in the context of this whistleblower policy.

Suspicion of wrongdoing: A suspicion based on reasonable grounds in connection with:

• a criminal offense or acts that lead to a criminal offense by vhm or its employees;

• all actual or suspected other violations of external laws and regulations by vhm or its employees;

• any actual or suspected violations of internal regulations by vhm or its employees;

• (threatened) intimidation of vhm employees by colleagues or supervisors;

• (imminent) unlawful destruction or manipulation of data or information;

• and furthermore all situations that, in the opinion of a Reporter, qualify for reporting to the Confidential Advisor.

Article 2. Procedure

If there is a Suspicion of wrongdoing, the Reporter has the option of reporting this to the Confidential Advisor.

The report to the Confidential Adviser will only be made by email to info@vhmaudit.nl (attn. confidential adviser).

The Confidential Advisor will confirm to the Reporter within 1 week that the report has been received in good order.

The Confidential Advisor informs the board of the report. This person will carry out an investigation (or have it carried out) and possibly take other necessary measures.

The Confidential Advisor informs the Reporter after six weeks at the latest about the handling of his report and the measures that have been taken.

If this term cannot be met due to unforeseen circumstances, the Confidential Advisor will inform the Reporter about this. At that time, he will indicate the period within which the Reporter will be informed about the completion of his report.

Reports relating to an (imminent) violation of internal or external professional regulations are in all cases handled by the Confidential Advisor in consultation with the compliance officer, with due observance of confidentiality.

Article 3. Confidentiality

The report, the correspondence about it and the handling are done under complete secrecy and confidentiality, unless the Reporter releases the Confidential Advisor from his duty of confidentiality.

The board of vhm guarantees that the Reporter who reports a Suspicion of Abuse in good faith within the framework of this whistleblower policy will not be disadvantaged in any way in his/her position. Article 4. Operation and publication.