Whistleblower scheme


Ruitenburg adviseurs & accountants attaches great importance to a proper complaints system which will ensure that any complaints that are made are handled carefully and confidentially.

In this context, Ruitenburg adviseurs & accountants takes the view that employees and persons from outside the organisation should also be able to report suspected irregularities without endangering their legal position. Anyone who uses this whistleblower scheme may report a suspected irregularity anonymously to the Ruitenburg adviseurs & accountants confidant.


The following terms are used in these scheme rules:

Ruitenburg adviseurs & accountants

The accountancy firm Ruitenburg adviseurs & accountants (hereinafter Ruitenburg).


Any Ruitenburg personnel member, including partners and/or board members.

External third party

Any natural or legal person other than Ruitenburg or one of its employees.


Any natural or legal person who reports a suspected irregularity as provided for in this whistleblower scheme.


The natural persons appointed by the board of Ruitenburg under this whistleblower scheme. One confidant per branch is appointed by the board. Ruitenburg board members are not eligible for this position.

(Suspected) irregularity

A suspicion based on reasonable grounds with regard to Ruitenburg and/or its employees concerning:

a. an imminent or actual criminal offence;

b. the imminent or actual destruction or manipulation of information about such offences;

c. the imminent or actual deliberate provision of false information;

d. an imminent or actual violation of a law or regulation;

e. an imminent or actual violation of rules of conduct or other rules at Ruitenburg or

f. any other situation that the informant believes should be reported to the confidant.


An employee or external third party who believes or suspects that there is an irregularity may make a report to one of the confidants. The report may be sent by email to one of the following email addresses:

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Within five working days of receipt of the report, the confidant shall confirm receipt of the report to the informant. In this confirmation, the confidant shall also indicate the procedure and time limit that will be applied in handling the report. Within no more than four weeks, the confidant shall report to the informant what measures have been taken and what further action will be taken. In the event that such a report cannot be made within the four-week period, the confidant shall notify the informant of this, indicating the time-frame within which the report will be handled.


The confidant shall immediately inform Ruitenburg’s board and compliance officer. The confidant shall inform the informant of this. Immediately after receiving the report, Ruitenburg’s compliance officer shall initiate an investigation into the (suspected) irregularity. The compliance officer is authorised to seek external legal or other advice if he/she deems it necessary; all other aspects of his/her duties and powers are defined in Ruitenburg’s compliance manual. The compliance officer shall report his/her findings to the board in writing. This report shall also contain advice on any measures that should be taken by the management.

If the board wishes to deviate from this advice, this shall be discussed with the compliance officer. If the informant’s report concerns the compliance officer, the board shall initiate or arrange an investigation into the (suspected) irregularity.

Confidentiality and protection

The informant’s report shall be subject to complete secrecy and confidentiality. This also applies to correspondence about and the handling of the report. The informant may only relieve the confidant of his/her confidentiality obligation in writing.

The board of Ruitenburg guarantees that reports to the confidant under this whistleblower scheme will not have any negative effect on the employee’s work within Ruitenburg or on his/her career opportunities. If the informant publicises the report either directly or through third parties, he/she may be subject to reprimand by Ruitenburg.

Ruitenburg adviseurs & accountants