a reporter disagrees with how we handled his report, what then

Dissatisfaction with the handling is not a dead end

If a reporter disagrees with the outcome of an internal report, that does not mean the matter automatically ends there — but it also does not mean the reporter has nowhere else to turn. The internal reporting procedure is designed to investigate a report and inform the reporter about what has been done with it, as described in Article 2 of the Whistleblower Protection Act. That feedback is an information obligation regarding the assessment and follow-up, not a decision against which internal appeal is available. In other words: the employer explains what was investigated and what conclusion was drawn from it, but is not required to establish a separate objection procedure for reporters who disagree with it.

What a reporter can do is take a step outside. The directive (EU) 2019/1937 provides for external reporting in addition to the internal channel, for example to a competent authority, as follows from Article 10 and Article 11 of that directive. In the Netherlands, this is possible, among other ways, with the House for Whistleblowers. Dissatisfaction with internal handling is therefore often not the endpoint but a reason for the reporter to resubmit the matter elsewhere. For the employer, this changes nothing about what has already been documented internally: how I close a report and what I record remains a careful file, even if the reporter approaches an external body. It is also conceivable that the reporter comes back with questions about the assessment itself, which relates to when I must inform a reporter about the assessment.

Where this comes from: the directive and the Whistleblower Protection Act

The internal feedback obligation follows from Article 2 of the Whistleblower Protection Act and from the feedback period of Article 9 of directive (EU) 2019/1937, while the possibility of external reporting is laid down in Article 10 and Article 11 of that same directive and is practically implemented by the House for Whistleblowers.