Whistleblower Policy

1. General

In accordance with the obligation under Article 27 of the Regulation on Accounting Organizations, Qwestor B.V. has a whistleblower policy. This policy ensures that employees of Qwestor B.V. and individuals outside the organization can raise suspected irregularities related to Qwestor B.V. without jeopardizing their legal position.

2. Scope

This whistleblower policy applies to the following situations:
a) Actions leading to criminal offenses by Qwestor B.V. or its employees;
b) Any (suspected) violations of external laws and regulations by Qwestor B.V. or its employees;
c) Any (suspected) violations of internal regulations by Qwestor B.V. or its employees;
d) (Threatened) harassment of employees of Qwestor B.V. by colleagues or supervisors;
e) (Threatened) unlawful destruction or manipulation of data or information;
f) Other situations that, in the opinion of the whistleblower, warrant reporting to the Compliance Officer.

In case of a difference of opinion or complaint regarding the actions of Qwestor B.V. or its employees, this whistleblower policy may also be used. The difference with the above guidelines is that the whistleblower policy always operates anonymously.

3. Procedure

If a situation falls under the scope of this whistleblower policy, the whistleblower has the option to report it to the Compliance Officer, Johan van Leeuwen.

The report to the Compliance Officer can be made electronically via johan@qwestor.nl, or by mail addressed to Qwestor B.V., for the attention of the Compliance Officer, Fred Roeskestraat 115, 1076 EE Amsterdam, with “Strictly Confidential” written on the envelope. If the report concerns the Compliance Officer, it should be made to a board member.

The Compliance Officer will acknowledge receipt of the report within one week and inform the whistleblower of the procedure and the timeline for handling the report.

If the report concerns a situation mentioned under points a and/or e of the scope, the Compliance Officer will immediately inform the board. The Compliance Officer will also inform the whistleblower about this.

The Compliance Officer will inform the whistleblower about the handling of the report and the actions taken within four weeks of receipt. If this period is exceeded due to unforeseen circumstances, the Compliance Officer will inform the whistleblower about this and provide a new timeline for when the whistleblower will be informed.

An employee making a report has the option to consult an advisor in confidence. Those involved in handling the report will not disclose the advisor’s identity without explicit written consent from both the whistleblower and the advisor.

For a report to be valid, it must be based on reasonable grounds for suspicion of misconduct, made in good faith, and the whistleblower must act with due care in all respects.

4. Confidentiality

Those involved in handling a report will not disclose the identity of the whistleblower without the whistleblower’s explicit written consent and will treat the information about the report as confidential. Qwestor B.V. ensures 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.

5. Legal Position

The board of Qwestor B.V. guarantees that the employee making a report under this whistleblower policy will not be disadvantaged in their legal position during or after the handling of the report. Discriminatory actions include, but are not limited to, dismissal, reassignment, refusal of a transfer request, withholding of salary increases, or denial of leave.

6. Effective Date

This policy comes into effect on March 17, 2022.