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a report concerns the actions of the director himself, who handles that

When a report concerns the director, someone else handles the case

A report about the director's own conduct does not go to the director, even if that person is normally the designated handler. The internal reporting procedure must provide for an impartial person or department to follow up on reports, and that impartiality is precisely why a report about one's own management goes through a different channel. In practice, this means that the handler role then lies with someone else in the organization, or with an external party designated for such situations — for example, a commissioner, a member of the supervisory board, a compliance officer who does not report to the director, or an external confidential advisor. Exactly who that is depends on how the organization has arranged it beforehand; the point is that there must be someone outside the director's own line to receive and handle the report.

The fact that another handler takes over the case does not change the statutory deadlines: the receipt confirmation and the feedback on the assessment proceed as normal, regardless of who ultimately handles the report. The protection of the whistleblower also remains fully in force, which in a report about the director often weighs even more heavily because the power relationship within the organization is more unequal. For more information about what must happen immediately after a report is received, see what to do upon receipt of a whistleblower report, and the question of what counts as retaliation — something that applies with particular force in a report about one's own director — is described on the page on retaliation against a whistleblower.

Where this comes from: impartiality and confidentiality

Article 9 of Directive (EU) 2019/1937 requires that the internal reporting procedure has follow-up carried out by an impartial person or department, which is the basis for directing a report about the director to a different handler. Article 2 of the Whistleblower Protection Act translates the requirement for an internal reporting procedure into Dutch law, and Article 16 of the Directive regulates the obligation of confidentiality regarding the whistleblower's identity, which also applies in full in a report about one's own management.

What you must do concretely

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This is not legal advice. This page provides general information on the legislation this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections are prioritized.