During the course of 2004, Ahold has set up and implemented a single and uniform whistleblower procedure that applies to both its U.S. and European operations.
In doing this, Ahold has put in place a strong, effective and uniform procedure that meets the requirements of both U.S. and European rules and regulations, in particular for the U.S. Sarbanes-Oxley Act of 2002 (the “Sarbanes-Oxley Act”) and for The Netherlands, the recommendations of the Tabaksblat Code. The procedure helps us to further establish and sustain an ethical workplace environment by describing the types of behaviors that are encouraged as well as those that should be reported.
The Whistleblower Procedure consists of a hotline program that provides for a centralized database for documenting the steps taken by us, or, depending on the nature of the complaint, the Audit Committee to investigate allegations reported via the hotline. This means 24-hour, around the year access to a skilled interviewer. Any caller can remain anonymous. All workplace issues that have been reported, including but not limited to any issues regarding accounting or audit irregularities, are brought to the attention of our Audit Committee or an appropriate department. Reporting employees also are protected from retaliation. The hotline provides us with fast, efficient and effective means to launch the Whistleblower Procedure. Additional value will be gained through the standardized collection, measurement and reporting of other regulatory or business process concerns.