Complaints and whistleblowing procedure

At CapsNobel the delivery of high-quality services to satisfied customers comes first. If you have a complaint regarding our services and/or the actions of an employee, or if you see any opportunities for us to improve our services, we expressly invite you to share these with us. Of course, we treat your feedback with care. We want to work with you to find a suitable solution.

This complaints procedure explains how you can submit a complaint or suggestion for improvement. It also explains how and within what timeframe it will be addressed.

1. Responsibility of the Executive Board

The executive board is responsible for the handling and registration of complaints and suggestions for improvement concerning CapsNobel employees and/or work performed by CapsNobel. Confidential advisor Mr. Eli Hendriks is the first point of contact.

2. Filing a complaint

To ensure proper handling, we ask that you submit official complaints or points for improvement preferably in writing to CapsNobel to the attention of Mr. E. Hendriks, Postbus 4, 4660 AA Halsteren, or digitally via e.hendriks@capsnobel.nl. Please include at least the following information:

• the name and address of the petitioner;
• the date of the filing of the complaint;
• A clear description of the reason for the complaint or suggestion for improvement;
• branch office and/or name of the employee against whom the complaint is directed;
• the date on which the complaint arose.

We kindly request that you also enclose copies of all documents that may be relevant to the assessment of the complaint. This helps us to adequately process your feedback.

If you would prefer to provide additional comments in person, you can of course also contact our confidential advisor E. Hendriks by telephone at (0164) 680 010. Following your telephone report, he will complete the complaint form on your behalf. To ensure your feedback is properly articulated, this form will be sent to you for review and approval.

3. Handling and registration of complaints/points of improvement

After receiving and registering your feedback, our confidential advisor will investigate the complaint or point for improvement and take note of all relevant documentation in order to subsequently inform the Executive Board about the received complaint or suggestion for improvement.

If necessary, we will call in a specialist to adequately address the complaint.

4. Handling

Within two weeks after receipt of the complaint/improvement, we will send you a confirmation of receipt and inform you about the complaint handling procedure.

If desired, we will keep you informed about the progress of the handling process and will send you a written and motivated statement about the outcome.

1. General

CapsNobel has a regulation that ensures that individuals from outside the organisation and individuals employed by or associated with the organisation can raise alleged irregularities within or (partly) outside the organisation without endangering their legal position. These regulations ensure that reports are recorded, dealt with confidentially and in a timely manner. If substantiated, reported irregularities are addressed in a timely manner with the organisation taking appropriate measures.

2. Scope

The whistleblowing policy covers the following situations:

1. Actions that could possibly lead to criminal acts by CapsNobel or its employees;
2. Any other actual or suspected violations of external laws and regulations by CapsNobel or its employees;
3. All actual or suspected violations of internal regulations by CapsNobel or its employees;
4. (Impending) intimidation of employees by colleagues or managers;
5. (Impending) unlawful destruction or manipulation of data or information;
6. and furthermore, all situations that, in the opinion of a reporter, qualify for reporting.

3. Trustee

CapsNobel has appointed Mr. E. Hendriks as a confidential advisor within the framework of this whistle-blowing regulation. In the absence of the confidant, or if the report relates to the confidant himself, we ask you to report to the chairman of the board.

4. Procedure

The confidential adviser is notified exclusively electronically via e.hendriks@capsnobel.nl.

The confidential adviser shall confirm the reporting to the whistleblower within one week. The confidential adviser will also inform the whistleblower how and within what timeframe his/her report will be addressed.

If a situation referred to under a and/or e occurs within the scope of these whistleblowing procedures, the confidential adviser will immediately inform the Executive Board, unless the report concerns the Executive Board, in which case the confidential adviser will inform another member of the Executive Board. The confidential adviser will then also inform the whistleblower of this.

In informing the Executive Board, the confidant shall not disclose the source.

The confidential adviser will inform the whistleblower within six weeks of the reporting 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 adviser shall inform the whistleblower of this and indicate the term within which the whistleblower will be informed about the completion of his/her report.

Reports which concern an (impending) violation of internal or external professional regulations will in all cases be dealt with by the confidential adviser in consultation with the executive board with due observance of confidentiality.

5. Confidentiality

The report, the correspondence concerning it and the handling will take place in complete secrecy and confidentiality unless the whistleblower releases the confidential advisor from his obligation of confidentiality.

6. Legal protection

The Executive Board of CapsNobel guarantees that the whistleblower will not be disadvantaged in any way in his/her position on the basis of this whistleblowing procedure.

If the whistleblower has a complaint about the way in which a chartered accountant, accountant-administer, or tax adviser has behaved towards the whistleblower in the course of his or her professional activities, the whistleblower can also choose to submit it to the Complaints Committee of the Netherlands Institute of Chartered Accountants (NBA), the Audit Chamber or the Disciplinary Board of the Netherlands Association of Tax Advisers.

CapsNobel
August 2018