Whistleblower reporting policy

In these regulations, the following terms shall have the following meanings:

a. advisor: a person who, by virtue of their position, has a duty of confidentiality and who is consulted in confidence by an employee about a suspected wrongdoing;

b. advisory department of the Whistleblowers Authority: the advisory department of the Authority, as referred to in Article 3a, paragraph 2, of the Whistleblowers Protection Act;

c. investigation department of the Whistleblowers Authority: the investigation department of the Authority, as referred to in Article 3a, paragraph 3, of the Whistleblowers Protection Act;

d. contact person: the person designated by the management after receipt of the report, in consultation with the reporter, as a contact person with a view to preventing prejudice;

e. management: the employer's board of directors;

f. external third party: any organization or representative of an organization that, in the reasonable opinion of the reporter, may be considered capable of directly or indirectly resolving or having resolved the suspected misconduct;

g. external body: the body that, in the reasonable opinion of the reporter, is most suitable for handling the external report of the suspected misconduct;

h. internal supervisory body: the compliance officer;

i. whistleblower: employee and partner who has reported a suspected misconduct or irregularity under this policy;

j. report: the report of a suspected misconduct or irregularity under this policy;

k.investigators: those to whom the management assigns the investigation of the misconduct;

l. partner: co-owner of the employer;

m. suspicion of a breach of EU law: an act or omission relating to the following areas of Union law:

• public procurement;
• financial services, products, and markets, prevention of money laundering and combating terrorism;
• product safety and product conformity;
• transport safety;
• environmental protection;
• radiation protection and nuclear safety;
• food and feed safety, animal health and animal welfare.
• public health;
• consumer protection;
• protection of personal data.

n. suspicion of misconduct: the suspicion of an employee that there is misconduct within the organization in which he works or has worked, or at another organization if he has come into contact with that organization through his work, insofar as:

• the suspicion is based on reasonable grounds arising from the knowledge the employee has gained at the employer or arising from the knowledge the employee has gained through his work at another organization, and
• the public interest is at stake in the event of:
  • the (imminent) violation of a legal provision, including an (imminent) criminal offense;
  • an (imminent) danger to public health;
  • an (imminent) danger to the safety of persons;
  • an (imminent) danger to the environment;
  • an (imminent) danger to the proper functioning of the organization as a result of improper conduct or omission;
  • an (imminent) violation of rules other than a legal provision;
  • an (imminent) waste of public funds;
  • (a threat of) the deliberate withholding, destruction, or manipulation of information about the facts mentioned in i through vii above.

o. suspicion of irregularity: a suspicion based on reasonable grounds of an imperfection or injustice of a general, operational, or financial nature that occurs under the responsibility of the organization and is so serious that it falls outside the scope of regular work processes and exceeds the responsibility of the immediate supervisor;

p. confidential advisor: the person designated to act as such for the employer's organization: Leonie Pongers;

q. employee: the person who performs or has performed work under a civil law employment contract or the person who performs or has performed work other than in the context of an employment relationship;

r. employer: De Jong & Laan Beheer B.V. and its subsidiaries, which performs or has performed work under a civil law employment contract or performs or has performed work other than in the context of an employment relationship;

2. Where the masculine form is used in these regulations, the feminine form should also be read.

1. Employees may consult a confidential advisor about a suspected wrongdoing or violation of EU law.
2. In accordance with paragraph 1, employees may request information, advice, and support from the confidential advisor regarding suspected misconduct or violations of EU law.
3. In accordance with paragraph 1, employees may also request information, advice, and support from the advisory department of the Dutch Whistleblowers Authority regarding suspected misconduct or violations of EU law.

1. Employees who suspect misconduct, a violation, or irregularity within the employer's organization can report this to the confidential advisor (vertrouwenspersoon@jonglaan.nl). The confidential advisor will forward the report, in consultation and with the employee's consent, to a branch manager, partner, or the management. If the employee has reasonable grounds to suspect that the management is involved in the suspected misconduct, violation, or irregularity, the report may also be forwarded to the compliance officer (compliance@jonglaan.nl). In that case, ‘the management’ in this regulation should be read as ‘the compliance officer’.
2. Employees may also report suspected misconduct, violations, or irregularities within the employer's organization to any branch manager, partner, or the management, or the compliance officer.

1. An employee of another organization who, through his or her work, has come into contact with the employer's organization and suspects misconduct or a violation within the employer's organization may report this to any branch manager, partner, or member of the management. If an employee of another organization has reasonable grounds to suspect that the management is involved in the suspected misconduct, they may also report this to the compliance officer (compliance@jonglaan.nl). In that case, ‘the management’ in this regulation should be read as ‘the compliance officer’.
2. Employees of other organizations as referred to in the previous paragraph may also report suspected misconduct or violations within the employer's organization via the confidential advisor (vertrouwenspersoon@jonglaan.nl). The confidential advisor will forward the report, in consultation with the employee, to a branch manager, partner, or the management, or the compliance officer, respectively.

1. The employer shall ensure that the information about the report is stored in such a way that it is physically and digitally accessible only to those involved in handling the report.
2. All those involved in handling a report shall not disclose the identity of the reporter without the reporter's express written consent and shall treat the information about the report as confidential.
3. If the suspicion of misconduct, infringement, or irregularity has been reported via the confidential advisor and the reporter has not given permission for their identity to be disclosed, all correspondence about the report will be sent to the confidential advisor, who will forward it to the reporter without delay.
4. All those involved in handling a report shall not disclose the identity of the advisor without the express written consent of the reporter and the advisor.

1. The employer shall not disadvantage the reporter in connection with the reporting in good faith and in an appropriate manner of a suspected wrongdoing or irregularity at the employer, another organization, an external body as referred to in Article 14(3), or an external third party under the circumstances referred to in Article 14(4).
2. Discrimination as referred to in paragraph 1 shall in any case be understood to mean the taking of a discriminatory measure, such as:
   1. dismissal, other than at the employee's own request;
   2. the premature termination or non-renewal of a temporary employment contract;
   3. the non-conversion of a temporary employment contract into a permanent employment contract;
   4. taking disciplinary action;
   5. imposing a ban on investigation, speaking, workplace and/or contact on the reporter or the reporter's colleagues;
   6. imposing appointment to another position;
   7. expanding or limiting the reporter's duties, other than at their own request;
   8. relocating or transferring the reporter, other than at their own request;
   9. refusing a request to relocate or transfer the reporter;
   10. changing the workplace or refusing a request to do so;
   11. withholding salary increases, incidental remuneration, bonuses, or allowances;
   12. withholding promotion opportunities;
   13. not accepting a sick note or keeping an employee registered as sick.
   14. rejecting a request for leave;
   15. granting leave other than at the employee's own request;
3. Discrimination as referred to in paragraph 1 also occurs if there are reasonable grounds to address the reporter about his performance or to take a discriminatory measure as referred to in paragraph 2 against him, but the measure taken by the employer is not reasonably proportionate to those grounds.
4. If, within a reasonable period of time after a report has been made, the employer takes a disadvantageous measure as referred to in paragraph 2 against the reporter, it shall explain why it considers this measure necessary and that this measure is not related to the reporting in good faith and in an appropriate manner of a suspicion of misconduct or irregularity.
5. The employer shall ensure that managers and colleagues of the whistleblower refrain from any form of discrimination in connection with the reporting in good faith and in accordance with the rules of a suspected abuse, violation, or irregularity that impedes the professional or personal functioning of the whistleblower. This includes, in any case:
   1. bullying, ignoring, and excluding the reporter;
   2. making unfounded or disproportionate accusations regarding the reporter's performance;
   3. effectively imposing a ban on investigation, discussion, workplace, and/or contact on the reporter or the reporter's colleagues, however formulated;
   4. intimidating the reporter by threatening certain measures or behaviors if they proceed with their report.
6. The employer will address employees who are guilty of harming the reporter and may issue them a warning or impose disciplinary measures.

1. The contact person designated pursuant to Article 9(6) shall immediately discuss with the reporter what risks of detriment are present, how those risks can be reduced, and what the employee can do if he or she believes that detriment has occurred. The contact person shall ensure that this is recorded in writing and shall submit this record to the reporter for approval and signature. The reporter shall receive a copy of this record.
2. If the reporter believes that harm has been done, they can discuss this with the contact person without delay. The contact person and the reporter will also discuss what measures can be taken to prevent harm. The contact person will ensure that this is recorded in writing and will submit this record to the reporter for approval and signature. The contact person will immediately forward the report to the management or the compliance officer. The reporter will receive a copy of this.
3. The management or the compliance officer will ensure that the necessary measures are taken to prevent disadvantage.

1. The employer shall not disadvantage the advisor employed by the employer for acting as an advisor to the reporter.
2. The employer shall not disadvantage the confidential advisor for performing the tasks described in this regulation.
3. The employer shall not disadvantage the contact person for performing the tasks described in these regulations.
4. The employer shall not disadvantage the investigators employed by the employer for performing the tasks described in these regulations.
5. The employer shall not disadvantage employees who are interviewed by the investigators for making a statement in good faith.
6. The employer shall not disadvantage employees in connection with their provision of documents to the investigators that, in their reasonable opinion, are relevant to the investigation.
7. Article 5, paragraphs 2 to 6, shall apply mutatis mutandis to the disadvantage of the persons referred to in paragraphs 1 to 6.

1. If an employee reports a suspected abuse, violation, or irregularity verbally to a branch manager, partner, or the management, or provides a written report of a verbal explanation, the branch manager, partner, or management, in consultation with the reporter, ensure that this is recorded in writing and submit this record to the reporter for approval and signature. The reporter will receive a copy of this record.
2. If an employee reports a suspected misconduct, violation, or irregularity verbally via the confidential advisor or provides a written report of a verbal explanation, this confidential advisor, in consultation with the reporter, will ensure that this is recorded in writing and submit this record to the reporter for approval and signature. The reporter will receive a copy of this.
3. The person to whom the report is made shall immediately forward the report to the management or the compliance officer.
4. If the reporter or the branch manager/partner to whom the report was made has reasonable grounds to suspect that the management is involved in the suspected misconduct, violation, or irregularity, the branch manager/partner shall immediately forward the report to the compliance officer. In that case, references to “the management” in these regulations shall be read as “the compliance officer.”
5. The management will send the reporter confirmation that the report has been received without delay, but no later than within seven days. The confirmation of receipt will in any case contain a factual description of the report, the date on which it was received, and a copy of the report. The management will send the reporter information about the next steps no later than three months after the confirmation of receipt.
6. After receiving the report, the management, in consultation with the reporter, will immediately appoint a contact person with a view to preventing any disadvantage.

1. The management will investigate the reported suspicion of misconduct, violation, or irregularity, unless:
2. the suspicion is not based on reasonable grounds, or
3. it is clear in advance that the report does not relate to a suspicion of misconduct, violation, or irregularity.
4. If the management decides not to investigate, it will inform the reporter in writing within two weeks of the internal report. It will also indicate the grounds on which the management considers that the suspicion is not based on reasonable grounds, or that it is clear in advance that the report does not relate to a suspicion of misconduct, violation, or irregularity.
5. The management will assess whether an external body as referred to in Article 14(3) of the internal report of a suspected wrongdoing should be notified. If the management notifies an external body, it will send a copy of this notification to the reporter, unless there are serious objections to doing so.
6. The management assigns the investigation to researchers who are independent and impartial and does not allow the investigation to be carried out by persons who may be or have been involved in the suspected misconduct, infringement, or irregularity.
7. The management shall immediately inform the reporter in writing that an investigation has been initiated and by whom the investigation is being conducted. It shall send the reporter a copy of the investigation assignment, unless there are serious objections to this.
8. The management shall inform the persons to whom a report relates about the report and about the notification of an external body as referred to in paragraph 3, unless this could harm the interests of the investigation or enforcement.

1. The investigators shall give the reporter the opportunity to be heard. The investigators shall ensure that this is recorded in writing and shall submit this record to the reporter for approval and signature. The reporter shall receive a copy of this record.
2. The investigators may also hear other persons. The investigators shall ensure that this is recorded in writing and shall submit this record to the person heard for approval and signature. The person heard shall receive a copy of this record.
3. The investigators may inspect and request all documents within the employer's organization that they reasonably deem necessary for the investigation.
4. Employees may provide the investigators with all documents that they reasonably deem necessary for the investigators to examine in the context of the investigation.
5. The investigators draw up a draft investigation report and give the reporter the opportunity to comment on it, unless there are serious objections to this.
6. The investigators then finalize the investigation report. They send a copy of this to the reporter, unless there are serious objections to this.

1. Within eight weeks of the report being made, the management will inform the reporter in writing of its position regarding the reported suspicion of misconduct, violation, or irregularity. It will also indicate what steps the report has led to.
2. If it becomes clear that the position cannot be communicated within the set period, the management will inform the reporter of this in writing. It will also indicate the period within which the reporter can expect to receive the position. If this means that the total period exceeds twelve weeks, the management will also indicate why a longer period is necessary.
3. After completing the investigation, the management will assess whether an external body as referred to in Article 14(3) of the internal reporting of a suspected misconduct, violation, or irregularity and of the investigation report and the employer's position should be informed. If the management informs an external body, it will send a copy of this to the reporter, unless there are serious objections to this.
4. The persons to whom the report relates will be informed in the same way as the reporter on the basis of paragraphs 1 to 3, unless this could harm the interests of the investigation or enforcement.

1. The employer shall give the reporter the opportunity to respond to the investigation report and the employer's position.
2. If, in response to the investigation report or the employer's position, the reporter substantiates that the suspicion of misconduct, infringement, or irregularity has not been properly investigated or that the investigation report or the employer's position contains material inaccuracies, the employer will respond to the substance of the response and, if necessary, initiate a new or additional investigation. Articles 10 to 13 apply mutatis mutandis to this new or additional investigation.
3. If the employer informs or has informed an external body as referred to in Article 14(3), it shall also send the aforementioned response from the reporter to the investigation report and the employer's position to that external body. The reporter shall receive a copy of this.

1. After making an internal report of a suspected wrongdoing, violation, or irregularity, the reporter may make an external report if:
   1. the reporter disagrees with the position referred to in Article 12 and believes that the suspicion has been unjustly dismissed;
   2. the reporter has not received a position within the period referred to in Article 12(1) or (2).
2. The reporter may immediately make an external report of a suspected wrongdoing, violation, or irregularity if it cannot reasonably be expected of them to first make an internal report. This is certainly the case if it arises from any legal provision or if there is:
   1. acute danger, whereby a serious and urgent social interest necessitates immediate external reporting;
   2. a reasonable suspicion that the management is involved in the suspected misconduct;
   3. a situation in which the reporter can reasonably fear reprisals in connection with making an internal report;
   4. a clearly identifiable threat of concealment or destruction of evidence;
   5. a previous report in accordance with the procedure of the same misconduct, which did not remedy the misconduct;
   6. an obligation to report directly externally.

3. The reporter may submit the external report to an external body that, in the reporter's reasonable opinion, is most appropriate for this purpose. An external body is understood to mean, in any case:

   1. a body responsible for investigating criminal offenses;

   2. a body responsible for supervising compliance with the provisions of or pursuant to any legal regulation;

   3. any other competent body to which a suspected wrongdoing can be reported, including the investigation department of the Dutch Whistleblowers Authority.

   4. If, in the reasonable opinion of the reporter, the public interest outweighs the employer's interest in confidentiality, the reporter may also make the external report to a member of the supervisory board or an external third party who, in his reasonable opinion, may be deemed capable of directly or indirectly remedying or having remedied the suspected misconduct.

1. The reporter who believes that he or she has been disadvantaged in connection with reporting a suspected abuse, violation, or irregularity may request the management to investigate the manner in which he or she is being treated within the organization.
2. Articles 10 through 13 apply mutatis mutandis.
3. Paragraphs 1 and 2 apply mutatis mutandis to the persons referred to in Article 7, paragraphs 1 to 6.
4. The reporter may also request the investigation department of the Dutch Whistleblowers Authority to investigate the manner in which the employer has treated him or her in response to the report of a suspected wrongdoing, violation, or irregularity.

1. The management shall ensure that this policy is published on the intranet and made public on the website.
2. The management shall draw up an annual report on the policy regarding the handling of reports of suspected misconduct, violations, and irregularities and the implementation of this policy. This report shall in any case contain:
   1. information about the policy pursued in the past year regarding the handling of reports of suspected misconduct, violations, and irregularities, and the policy to be pursued in this area in the coming year;
   2. information about the number of reports and an indication of the nature of the reports, the results of the investigations, and the positions taken;
   3. general information about experiences with preventing retaliation against the reporter;
   4. information about the number of requests for investigations into victimization in connection with reporting a suspected abuse, violation, or irregularity and an indication of the outcomes of the investigations and the positions taken.
3. De directie stuurt het concept voor de in het vorige lid bedoelde rapportage ter bespreking aan de ondernemingsraad, waarna dit in een overlegvergadering met de ondernemingsraad wordt besproken.
4. De directie stelt de ondernemingsraad in de gelegenheid zijn standpunt over het beleid aangaande het omgaan met het melden van vermoedens van misstanden, inbreuken en onregelmatigheden, de uitvoering van deze regeling en de rapportage kenbaar te maken. De directie draagt zorg voor verwerking van het standpunt van de ondernemingsraad in de rapportage en legt deze verwerking ter goedkeuring aan de ondernemingsraad voor.

1. This regulation will take effect on October 1, 2023.
2. This regulation is referred to as the regulation for dealing with reports of suspected misconduct, violations, or irregularities at Jong & Laan B.V. and its subsidiaries.
3. The Internal Reporting Regulation dated February 7, 2017, is hereby repealed.