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Procedure for the handling of Complaints by the Board of Directors of AT&C audit BV and AT&C accountants BV

Introduction

It is important to us that you have the opportunity to let us know if you are dissatisfied with our services. To this end, we have adopted a Complaints Procedure under which complaints concerning the professional conduct of AT&C professionals and any alleged irregularities in relation to the services provided by AT&C may be submitted. Complaints will only be considered if they are submitted pursuant to Articles 1 and 3 of the following Complaints Procedure. This Procedure concerns Complaints regarding the professional conduct of AT&C employees. The Procedure will take effect on 1 August 2020.

Definitions

For the purposes of this Procedure, the term ‘AT&C’ shall be taken to mean: the group of affiliated legal entities providing business services under the name ‘AT&C’. For the purposes of this Procedure, the term ‘Complaint’ shall be taken to mean: any written notification of conduct that potentially conflicts with laws and regulations, rules of professional conduct or agreements between AT&C and the Complainant and satisfies the provisions of Articles 1 and 3. The term ‘Board of Directors’ shall be taken to mean the Board of AT&C audit BV and AT&C accountants BV. The term ‘Complainant’ shall be taken to mean any natural or legal person who submits a Complaint on the basis of this Procedure.

The term ‘Employee’ shall be taken to mean any AT&C employee who rightfully presents himself as being employed by or associated with the aforementioned legal entities. Any use of the masculine form (he or him) in this Procedure shall also be presumed to refer to the feminine form (she or her).

Article 1

  1. Anyone who wishes to complain about the behaviour of an AT&C employee during the performance of their professional duties must notify the individual concerned of this behaviour in writing.
  2. If the Complainant considers the involved individual’s response unsatisfactory, he may then submit a Complaint in writing to the Board of AT&C audit BV or AT&C accountants BV. The Complainant must specify when and how the notification referred to in paragraph 1 was submitted, describe the subsequent response and indicate why they consider this response to be unsatisfactory. If this condition is not met, the Complainant must explain why this was not the case.
  3. A Complaint within the meaning of this Complaints Procedure cannot relate solely to the amount of an invoice.

Article 2

The Board shall ensure that all written Complaints are handled carefully and adequately.

Article 3

  1. The Complaint must be signed and contain at least the following information:
  2. the name and address of the complainant;
  3. the name of the employee to whose conduct the Complaint relates;
  4. the date;
  5. a description of the conduct to which the Complaint relates;
  1. the extent to which the relevant conduct justifies a complaint;
  2. the complainant’s relationship with AT&C.
  1. A copy of any documents invoked by the Complainant must be attached to the Complaint. The Complaint must contain a clear reference to these documents or any relevant passages therein.
  2. If the Complaint is submitted in a foreign language and a translation will be needed in order to ensure proper handling, the Complainant will provide a translation.
  3. The Complaint may also contain a settlement proposal.

Article 4

Employees who receive a written Complaint shall immediately forward this Complaint to the Board.

Article 5

  1. The Board will confirm receipt of the written Complaint within ten working days.
  2. The Board will forward any Complaint that falls under the discretion of another authority to the relevant authority without delay, while simultaneously notifying the Complainant.
  3. Any Complaint that is not intended for the Board nor designated to be forwarded to another party shall be returned to the Complainant as soon as possible. The accompanying letter shall state the reason for return.

Article 6

The Complaint will be handled by an employee (or employees) who was not involved in the conduct to which the Complaint relates.

Article 7

  1. The Board is not obliged to address the Complaint if:
  2. it relates to conduct that is or has been subject to the discretion of the Complaints Committee for the professional bodies or the Complaints Committee of another audit organisation or accounting firm;
  3. it relates to professional conduct that took place more than one year after it was initially discovered or took place more than three years before the Complaint was filed;
  4. it relates to conduct that is or has been subject to the opinion of the Board of Appeal following the filing of a Complaint;
  5. if and for as long as the conduct to which the Complaint relates is the subject of a criminal investigation ordered by the Public Prosecutor or criminal proceedings or if the conduct forms part of the investigation or prosecution of an offence and is the subject of a criminal investigation ordered by the Public Prosecutor or criminal proceedings.
  6. if the Complaint has not been presented to the employee involved in accordance with the provisions of Article 1, paragraph 1.
  7. if the Board deems that the Complaint does not meet the requirements set forth in article 2, paragraph 1.
  8. In the event that the Complaint is deemed inadmissible, the Board will notify the complainant in writing as soon as possible, but no later than four weeks after receipt of the complaint.

Article 8

  1. If the Board decides to accept the Complaint, it shall ensure that it is handled carefully and satisfactorily. The Complaint will be handled by an employee (or employees) who was not involved in the conduct to which the Complaint relates.
  2. The complainant and employee concerned may be heard as part of the investigation. This hearing will be recorded in a report.
  3. The Complainant, the Board and any third parties engaged by the Board will handle the Complaint confidentially. No information will be provided on the substance of the Complaint, nor will information be provided on the identity of the Complainant or Employee involved, unless the Board deems this necessary in ensuring that the Complaint is handled with due care, e.g. while investigating the relevant facts.

Article 9

  1. The Board will handle the Complaint as quickly as possible.
  2. The Board will inform the complainant and the employee to whose conduct the Complaint relates of its findings in writing, stating the grounds for its decision.

Article 10

The Board may suspend the complaint handling procedure at any time if there are grounds to do so, e.g. if this is or could be conducive to the resolution of the relevant dispute.

Article 11

The Complaint will be voided if the Complainant informs the Board that the employee to whose conduct the Complaint relates has satisfactorily addressed their Complaint.

Article 12

The Board shall ensure that all submitted Complaints are registered.

Article 13

The submission and handling of a Complaint shall not infringe on any statutory limitations or expiry dates.

 

Complaints may be submitted to:

AT&C audit BV/AT&C accountants BV
attn. of Bestuurssecretariaat
Laan van Westroijen 2
4003 AZ Tiel