Whistleblower policy

1. Introduction

Moore DRV values a good complaints procedure with careful and confidential handling of reported complaints. In this context, Moore DRV believes that employees, former employees, and other persons outside the organization should also be able to report alleged irregularities, anonymously or otherwise, without jeopardizing their legal position. Anyone who makes use of this whistleblower policy can report anonymously to Moore DRV’s Compliance Officer. This policy ensures that reports are recorded, handled confidentially and in a timely manner, and that the alleged abuses complained about, if substantiated, are dealt with promptly by taking appropriate measures.

A well-functioning whistleblower scheme must allow for both anonymous and non-anonymous reporting and guarantee that reports are carefully investigated. This requires:

• clear procedures,
• secure reporting channels (e.g., via external confidential advisors or digital platforms),
• training of reporting officers,
• and a culture in which non-anonymous reports are also safe.

 

2. Definitions

The following definitions apply in these regulations:

• Board: the Board of Directors of Moore DRV or the Board of the affiliated private companies of Moore DRV.
• Compliance Officer: the natural person appointed by the Board of Directors of Moore DRV as an independent officer who, within the framework of this whistleblower policy, takes note of the report, acts as the contact person for the reporter, and coordinates the handling of the report.
• Public interest: the public interest is in any case at stake if the act or omission does not only affect the personal interests of the reporter and there is either a pattern or structural nature to it, or the act or omission is serious or extensive.
• Reporter: a person who works or has worked for Moore DRV in any capacity (including freelancers, volunteers, flex workers, working students, and interns) or who works for one of its clients or suppliers, who makes a report as referred to in this whistleblower policy.
• Report: a report of a suspected misconduct or violation.
• Misconduct: an act or omission that jeopardizes the public interest. This is the case in the following situations (non-exhaustive list):
  – there is an (imminent) threat to public health;
  – there is (imminent danger of) a violation of a legal provision or an internal policy adopted pursuant to a legal obligation;
  – there is an (imminent) threat to the safety of persons;
  – there is an (imminent) threat to the environment;
  – there is an (imminent) threat to the proper functioning of Moore DRV;
  – there is (imminent) waste of public funds; or
  – there is a threat of deliberate withholding, destruction, or manipulation of information about the above-mentioned facts.
  – there is (imminent) infringement of EU law in the following areas (hereinafter also referred to as: ‘Infringement’):
  • public procurement;
  • financial services, products, and markets, prevention of money laundering and
  • terrorist financing;
  • 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 privacy and personal data and security of network and information systems;
  • infringements affecting the financial interests of the Union;
  • infringements related to the internal market.
• Moore DRV: the partnership Moore DRV advisors & accountants and Moore DRV Audit B.V., as well as all other companies affiliated with it.
• EU law: the law of the European Union.
• Confidential advisor: the person appointed to act as such for the employer. The names of the confidential advisors can be found in the digital work environment.
• Employer: the Moore DRV partnership and the affiliated private companies of Moore DRV.
• Employee: the person who performs work on the basis of an employment contract or the person who otherwise performs work for the employer in return for remuneration (e.g., interns, self-employed persons without personnel, partners, directors, supervisors).

3. Reporting channels

3.1 Internal

Anyone who believes that there is a (suspected) misconduct or violation within Moore DRV can report this (anonymously, if desired) to the Compliance Officer. The report can be made either in writing or verbally.

In writing: The report can be sent by letter addressed to Compliance or by email to the following email address: klokkenluider@moore-drv.nl.

Verbally: If the report is made verbally to the Compliance Officer, the Compliance Officer will draw up a report, which the reporter can check, correct, and sign for approval. The report can be made as follows:

• by telephone or via Teams and/or;
• a meeting on site (within a reasonable period of time).

The reporter is also free to consult an external advisor in confidence.

3.2 External

The reporter has the right, without making an internal report, to immediately report to a competent authority, such as, but not limited to, the House for Whistleblowers, the Financial Markets Authority, and the Consumer and Market Authority. In case of doubt, the reporter can seek advice from the House for Whistleblowers.

4. Report

4.1 Content of the report

It is desirable that a report contains at least the following:

1. the name of the reporter, unless the report is anonymous;
   when making the report, the reporter should preferably provide a (private) home address and/or (private) email address and telephone number at which the reporter can be contacted by post, email and/or telephone in connection with the report. The reporter is not obliged to provide contact details.
2. the reporter can be reached by post and/or email and by telephone in connection with the report. The reporter is not obliged to provide contact details.
3. if applicable: the name of the employee whose conduct is the subject of the report or complaint;
4. a description of the alleged violation that is the subject of the report or complaint. When making the report, the reporter should provide as much information as possible that they have in that regard.

The suspicion of misconduct must be based on reasonable grounds, arising from knowledge acquired by the reporter at the employer or arising from knowledge acquired by the reporter through his work at another company or organization that performs work for or on behalf of the employer. A third party cannot submit a complaint within the meaning of this policy that relates exclusively to an expense claim.

4.2 Confidential advice

Anyone who suspects misconduct can seek confidential advice (consult and request information, consultation, and support, for example). Confidential advice can be sought from the confidential advisor on undesirable conduct.

4.3 Procedure

• Receipt of the report will be confirmed to the reporter (as far as possible) within seven days of receipt, by sending a written confirmation to the (private) home or email address provided by the reporter. The confirmation of receipt will preferably contain a factual description of the report and a copy of the report or a written record of the report if it was made verbally.
• If the report is not based on reasonable grounds or if it is clear in advance that the report does not relate to misconduct, the reporter will be informed of this in writing, with an explanation of that finding.
• Unless the report is not based on reasonable grounds or it is clear in advance that the report does not relate to misconduct, the report will be investigated by one or more persons appointed for this purpose by the Board who are not directly involved in the reported facts.
• If a member of the Board is involved in the suspected misconduct, the independent officer will personally investigate the report.
• The person or persons to whom the report relates will be informed of the report, unless the employer considers this to be contrary to the interests of the investigation.
• Within a maximum of three months after sending the acknowledgment of receipt, the reporter will be provided with information (as far as possible) about the assessment and, where applicable, the follow-up to the report.
• The person(s) to whom the report relates will be informed of the assessment and, where applicable, the follow-up to the report at least at the same time as the reporter.

Within seven days of receiving the report, the Compliance Officer will confirm receipt of the report to the reporter. In this confirmation, the Compliance Officer will provide information about the procedure and the deadlines that will be followed in handling the report. No later than four weeks after receiving the report, the Compliance Officer will inform the reporter of the measures that have been taken and how the report will be handled going forward. In the exceptional circumstance that this notification cannot be made within the four-week period, the Compliance Officer will inform the reporter and indicate the period within which the report will be handled. The aforementioned period will not exceed three months after the confirmation of receipt has been sent.

5. Handling

The Compliance Officer will immediately inform the Board of Moore DRV, unless a member of the Board is involved in the suspected misconduct. The Compliance Officer will inform the reporter of this. Immediately after receiving the report, the Compliance Officer of Moore DRV will start an investigation into the (alleged) misconduct and/or violation. Both the Compliance Officer and the reporter are authorized to seek external (legal) advice if they deem this necessary. The Compliance Officer reports his findings to the Board in writing. This report also contains advice on any measures to be taken by the Board. If the Board wishes to deviate from the advice, this will be discussed with the
Compliance Officer. If the report concerns the Compliance Officer, the Board will initiate an investigation into the (alleged) irregularity.

6. Confidentiality and protection

Anyone within the employer’s organization who is involved in a report or in the investigation of a suspected misconduct, and who thereby gains access to information that they know or reasonably suspect to be confidential, is obliged to maintain the confidentiality of that information, except insofar as any legal provision obliges them to disclose it or the necessity to disclose it arises from their duties in the implementation of the Dutch Whistleblower Protection Act.

Confidential information includes, in any case: information about the identity of the reporter (insofar as this is known) and the identity of the person to whom the misconduct is attributed or with whom that person is associated, and information about a trade secret. The reporter may release the Compliance Officer from his duty of confidentiality in writing.

Confidentiality also applies to correspondence about and the handling of the report. Moore DRV will register the report and apply the appropriate data protection laws and regulations.

The Board of directors of Moore DRV guarantees that a report made by a reporter to the Compliance Officer or another competent authority under this whistleblower policy will in no way result in prejudice to the reporter, under the conditions set out in the Dutch Whistleblower Protection Act. This also applies to Moore DRV employees who assist the reporter. In this context, disadvantage includes the employer taking disadvantageous measures against the reporter, such as dismissal or suspension (other than at the reporter’s own request) or the imposition of a fine (as referred to in Section 7:650 of the Dutch Civil Code).

7. Final provisions

This policy has been drawn up in accordance with the Dutch Whistleblower Protection Act (Wbk) and has been published on Moore DRV’s digital work environment and website.

This policy may be amended in consultation between the Board and the works council.

This policy will take effect on January 1, 2026, and will be published on that date on the employer’s digital work environment and website.

Latest version: January 2026