Code of Conduct

Administratiekantoor Zen, represented by Mr. E. van Gelderen RFC, is affiliated with the following code of conduct:

Article 1 OBJECTIVE
This code of conduct establishes rules for Administratiekantoor ZEN.

The Code of Conduct serves as a basis for expectations for both third parties and registrants regarding the conduct of registrants in general, and specifically regarding their professional practice when acting as a controller.

Article 2 GENERAL

• Administratiekantoor Zen is obliged to maintain ethical standards in relation to its field of expertise. It may not instruct others to perform actions that conflict with these standards.
• In the exercise of its profession, Administratiekantoor Zen must refrain from anything that could damage its profession.
• Administratiekantoor Zen must limit its statements, actions, and decisions to its own expertise.

Administratiekantoor Zen is required to inform its employer and other direct stakeholders that this code of conduct applies to it.

Article 3 RESPONSIBILITY
In the exercise of its profession, Administratiekantoor Zen is responsible for:

• maintaining its level of professional knowledge and skills through continuing education.
• practicing its profession in accordance with current legislation and professional regulations;
• providing complete, clear reports and objective advice based on an efficient analysis of relevant and reliable data.

Article 4 CONFIDENTIALITY

• Administratiekantoor Zen ensures that everything entrusted to it in the exercise of its duties, or which has come to its knowledge as a confidential matter, remains confidential. This rule is subject to exception if the law specifically requires it;
• Administratiekantoor Zen ensures that its employees are instructed on handling the confidentiality of information, and monitors the actions of its employees to ensure, to the best of its ability, that this confidentiality is maintained;
• Administratiekantoor Zen does not use confidential information obtained during its work and/or by virtue of its position for the purpose of obtaining benefits, either for itself personally or for third parties.
  These provisions continue to apply even after the employment relationship has ended.

Article 5 INTEGRITY
Administratiekantoor ZEN

• Maintains an objective stance in conflicts of interest between parties within the organization. In such cases, it may advise all relevant parties if desired;
• Does not engage in activities that in any way hinder the ethically responsible performance of its duties;
• Refuses gifts, benefits, or hospitality that could actually or apparently influence its own actions;
• Refrains from active or passive actions that could harm the interests of its employer;

Article 6 OBJECTIVITY

• Administratiekantoor Zen must maintain an independent position and provide complete and objective information;
• Its attitude in consultation situations and/or discussions must therefore also be characterized by objectivity.

Article 7 ETHICAL CONFLICT

• If Administratiekantoor Zen is of the opinion, on reasonable grounds, that through the performance of its duties:
• an unlawful act is being committed and/or
• a course of action is required which is contrary to the letter and/or the spirit of this Code of Conduct, thereby compromising its credibility and/or integrity as an accounting firm through participation in the performance of work,

it shall consider taking one or more of the following actions:

• Documenting the problem in writing;
• Engaging in a confidential discussion with its own independent advisor to gain insight into the legal rights and obligations regarding the ethical conflict.
• Discussing the problem, with the knowledge of those involved, with a hierarchical superior, if necessary up to the highest level;
• Consulting the confidential counselor within its own organization;
• Making use of the possibilities offered by the whistleblower regulations applicable to its organization.

If an ethical conflict, after all internal possibilities have been exhausted, is not resolved in a manner acceptable to Administratiekantoor Zen, it shall inform the director of the organization in which it is active, stating the reasons, that it can no longer function as an accounting firm within the meaning of this Code of Conduct.

Article 8 FINAL PROVISION
The code of conduct (honor of the profession) will be permanently tested against new developments.