In our Frequently Asked Questions (FAQ), you can read all about the Integrity Coordinator, the Whistleblower Protection Act, and whistleblowing in general!
We act as an independent coordinator of whistleblowing procedures, also referred to as whistleblowing arrangements, reporting procedures or speak-up procedures, with many years of experience in handling anonymous reports. We support organizations in establishing and managing a whistleblowing reporting channel and whistleblowing system, including anonymous reporting channels.
We help organizations comply with the Dutch Whistleblower Protection Act and the EU Whistleblowing Directive. This legislation requires organizations to establish reporting procedures and secure reporting channels that contribute to the protection of whistleblowers. We also ensure proper follow-up of reports.
In addition, we provide in-house training to educate employees and internal officers on the correct implementation of whistleblowing arrangements and the management of reporting procedures and anonymous reporting channels.
With our support, your organization will have an independent reporting channel and independent follow-up of anonymous reports, fully compliant with the Dutch Whistleblower Protection Act and the requirements relating to reporting channels and anonymous reporting channels.
The Integrity Coordinator was founded by Geert Vermeulen. His mission is to help organizations conduct business in an honest and ethical manner and to implement effective whistleblowing arrangements and reporting procedures.
Since 2007, Geert has been involved in rolling out and coordinating reporting channels and whistleblowing systems. He has handled several hundred cases involving multinational companies, SMEs, NGOs, and organizations in the public and semi-public sectors. He regularly writes and speaks about whistleblower protection, reporting procedures, and compliance under the Dutch Whistleblower Protection Act.
Geert is an experienced and renowned Ethics & Compliance Officer. In 2020, he received the National Compliance Award in recognition of his contributions to the profession. The jury described him as a leading figure and role model for the compliance community.
In 2023, he was also named a “Top Thought Leader in Trust” by Trust Across America / Trust Across The World.
Since 17 December 2023, every legal entity with 50 or more employees must establish a whistleblowing arrangement and reporting procedure that complies with the Dutch Whistleblower Protection Act. This means organizations must provide a reporting channel and whistleblowing system through which reports can be submitted safely and confidentially and properly followed up.
Legal entities subject to financial legislation or to the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) must always implement a whistleblowing arrangement and reporting channel, regardless of the number of employees. The Wwft also requires organizations to provide an anonymous reporting channel.
These obligations follow from the EU Whistleblowing Directive and are intended to strengthen the protection of whistleblowers within organizations.
The Dutch Whistleblower Protection Act entered into force in phases in 2023 and requires organizations to establish a reporting procedure, reporting channel and whistleblowing system that complies with the EU Whistleblowing Directive.
The obligation to provide anonymous reporting channels as part of a whistleblowing arrangement is expected to enter into force in 2027/2028. Anonymous reporting channels are an important component of whistleblower protection and ensure that reporting persons can submit reports safely and without risk of retaliation.
Offering anonymous reporting channels is considered a best practice and has already been mandatory for organizations subject to anti-money laundering legislation for many years. Reports provide organizations with an opportunity to address potential issues at an early stage. Without anonymous reporting channels, organizations are likely to receive significantly fewer reports.
Whistleblower protection applies to reports submitted in a work-related context through a reporting channel, reporting procedure, or whistleblowing system.
The Act protects not only employees but also:
- Self-employed contractors
- Volunteers
- Interns
- Job applicants
- Former employees
- Employees of suppliers
- Shareholders and supervisory board members
- Family members and companies connected to the reporting person
Additionally, individuals who support the reporting person, such as confidential advisers or consultants, and individuals responsible for receiving or following up reports within a whistleblowing system are protected against retaliation.
This broad protection is established in the Dutch Whistleblower Protection Act and derives from the EU Whistleblowing Directive.
Organizations must appoint an independent person or department to receive reports through a reporting channel or whistleblowing system and an independent person or department to follow up on these reports. This may be the same person or department, provided independence is ensured. According to the EU Whistleblowing Directive, this person must act impartially.
Preferably, this role should not be assigned to a confidential adviser, as such advisers support and assist the reporting person and may act on their behalf. Due to the requirement of independence and impartiality, the possibilities for internal appointment are limited. An Ethics & Compliance Officer or Integrity Manager with a Compliance Charter and a dual reporting line could fulfil this role. It is important that employees also perceive this person as independent.
Organizations may also appoint an external party as an independent coordinator of a whistleblowing arrangement, reporting procedure, or (anonymous) whistleblowing procedure, such as The Integrity Coordinator. Outsourcing a reporting channel to an external party prevents conflicts of interest and contributes to the protection of whistleblowers.
Organizations may also appoint an external party as an independent coordinator of a whistleblowing arrangement, reporting procedure, or (anonymous) whistleblowing procedure, such as The Integrity Coordinator. Outsourcing a reporting channel to an external party prevents conflicts of interest and contributes to the protection of whistleblowers.
The Integrity Coordinator advises against this. A confidential adviser provides support, information and sometimes advice to the reporting person and is in principle aligned with the reporting person’s interests.
Under the Dutch Whistleblower Protection Act, the individual responsible for receiving and following up reports within a reporting channel, reporting procedure or whistleblowing system must be independent. The EU Whistleblowing Directive states that this role must be carried out impartially.
The Integrity Coordinator supports organizations in establishing and implementing a whistleblowing arrangement, reporting procedure, reporting channel and anonymous reporting channels.
If you appoint us as your external independent coordinator of the internal procedure, you will receive our standard reporting procedure and investigation protocol free of charge. This enables your organization to establish a whistleblowing system and reporting channel that complies with the Dutch Whistleblower Protection Act and the EU Whistleblowing Directive.
In addition, we advise on the design and implementation of (anonymous) reporting procedures and provide in-house training for employees who act as coordinators of a reporting procedure or whistleblowing arrangement.
A reporting person may submit a report through several reporting channels within the reporting channel and whistleblowing system:
- Verbally
- In writing
- Anonymously through an anonymous reporting channel
- Through a personal meeting upon request
Providing multiple reporting channels is mandatory under the Dutch Whistleblower Protection Act. The obligation to provide anonymous reporting channels is expected to enter into force in 2027/2028. For organizations subject to anti-money laundering legislation, providing an anonymous reporting channel is already mandatory.
These reporting channels contribute to a secure reporting procedure and optimal whistleblower protection.
For more information about the Dutch Whistleblower Protection Act, whistleblowing arrangements, reporting procedures and reporting channels, you can request The Integrity Coordinator’s whitepaper.
This whitepaper provides practical guidance on whistleblower protection, legal obligations and establishing a compliant whistleblowing system and reporting channel.
