We are an independent coordinator of whistleblower procedures with many years of experience in this field. We help you comply with the Whistleblowers Protection Act and the EU Whistleblower Protection Directive. We also offer (in-house) training sessions to educate your staff on these matters.

As of December 17, 2023, every legal entity with 50 or more employees is required to establish its own whistleblower procedure that complies with the new legislation. Legal entities that fall under financial legislation or anti-money laundering regulations must also do so, regardless of the number of employees.

The law came into effect largely in 2023.

The protection applies to reports made in a work-related context and applies not only to the reporter’s own employees, self-employed workers, volunteers and trainees but also, for example, to job applicants, former employees, (employees of) suppliers, shareholders, supervisory directors, relatives and companies of the reporter and his or her family. In addition, the persons who assist the reporter (such as confidential counsellors or other advisers) and those who receive and follow up reports are also protected against detriment by the employer.

Organisations must appoint an independent person or department to receive the reports and an independent person or department to follow up the reports. This may also be the same person or department. This should preferably not be the confidential advisor, as they support and advise the reporter and sometimes act on the reporter’s behalf. Nor is it an employee of management, legal affairs or HR, as these are not independent.

The role can be perfectly well fulfilled by the Ethics & Compliance Officer or Integrity Manager, as long as their independence is well established, for instance in a Compliance Statute, combined with a double reporting line.

If there is no such person, it can also be outsourced to an independent external party, such as The Integrity Coordinator. Or possibly your industry or umbrella association offers a facility. Indeed, outsourcing to a reliable and suitable external party is always allowed.

The Integrity Coordinator advises against this: a confidential advisor is there for support and advice and is basically on the side of the reporter. The person who receives and follows up the report should be independent according to Dutch law; the European directive states that it should be impartial.

The Integrity Coordinator can help with this. If you appoint us as external independent coordinator, you will receive our standard reporting procedure and investigation protocol free of charge. We can also advise on this. We also provide (in-house) training to those who will act as coordinators themselves.

This can be done orally, in writing and anonymously. And on request through a personal interview. Offering all these channels is mandatory under the new law. The obligation to offer anonymous reporting channels is unlikely to take effect until 2026.

For more information about the Whistleblowers Protection Act, you can request the whitepaper from the Integrity Coordinator.

The Integrity Coordinator was founded by Geert Vermeulen. His mission is to help organizations conduct business in an honest and ethical manner.

Since 2007, Geert has been involved in implementing and coordinating reporting schemes. Since then, he has handled several hundred cases, both with multinational corporations, SMEs, NGOs, and in the (semi-)public sector. He also regularly writes and speaks on this topic.

Geert is an experienced and renowned Ethics & Compliance Officer. In 2020, he received the National Compliance Award for his contributions to the field. The jury described him as a figurehead and role model for the compliance community. When he was nominated, he was referred to as “The Compliance Guru.”

He was also named a top thought leader in trust by Trust Across America/Trust Across The World in 2023.

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