Our whistleblower scheme guarantees that anyone connected with Your Trust, be they an employee, a business associate or a third party, can draw our attention to suspected misconduct or irregularities within or affecting our organization without jeopardizing their legal position.
The scheme ensures that whistleblower reports are recorded properly, are examined promptly and in confidence and, if found to be justified, are acted upon effectively by the organization taking timely and appropriate measures to deal with the irregularities identified.
ARTICLE 1. DEFINITIONS
- Your Trust: Your Trust (Netherlands) BV.
- Informant: a person, whether or not an employee of Your Trust, who undertakes activities on behalf of Your Trust and in that capacity reports an irregularity as defined in these regulations.
- Confidante: Your Trust’s Compliance Officer (C. Vermij);
- Board: the directors of Your Trust
- Irregularity: a suspicion concerning Your Trust and/or its employees, based on reasonable grounds, related to:
- an actual or impending criminal offence;
- an actual or impending violation of legal statutes or regulations;
- the actual or impending deliberate provision of incorrect information;
- an actual or impending violation of rules applicable within Your Trust, including those pertaining to personal conduct; or,
- any other actual or impending breach of integrity.
ARTICLE 2. PROCEDURE
- The Informant reports an irregularity to the Confidante by e-mailing firstname.lastname@example.org. They may at the same time also report the irregularity to their own supervisor.
- The Confidante records the report and confirms its receipt to the Informant within five working days. Unless the irregularity concerns a member of the Board (see 2.5), the Confidante immediately notifies the Board that the report has been received.
- Unless relieved of this obligation in writing by the Informant, the Confidante guarantees their anonymity throughout the procedure and thereafter.
- Immediately upon receipt of the report, the Board initiates an investigation into the irregularity.
- If the irregularity concerns a member of the Board, the Confidante himself initiates an investigation into the irregularity or assigns someone to initiate an investigation.
ARTICLE 3. DURATION
- Within eight weeks following the moment the report is recorded in accordance with Article 2.2, the Confidante is informed in writing by or on behalf of the Board of its opinion regarding the irregularity and of any measures already taken to deal with it.
- If it is not possible to issue the opinion by the deadline mentioned in Article 3.1, the Board informs the Confidante thereof in good time and states when its opinion will be provided.
- If Article 2.5 applies, the Confidante either formulates an opinion himself or has one formulated on his behalf.
- Immediately after the opinion becomes available, the Confidante notifies the Informant of it.
ARTICLE 4. LEGAL PROTECTION
- The Board (or the Confidante) ensures that an Informant who has reported an irregularity in good faith and in accordance with the present regulations is in no way whatsoever disadvantaged by Your Trust.
- An Informant who reports an irregularity in a manner not in accordance with the present regulations, and in particular who discloses it publicly, either directly or through third parties, is not protected by these regulations and may be held accountable for their actions.
ARTICLE 5. EFFECTIVE DATE, AMENDMENTS AND PUBLICATION
- These regulations enter into force on 25 January 2019. They may subsequently be amended by agreement between the Board and the Confidante.
- These regulations will be published on the Your Trust website.