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Complaints Procedure

Cohesie is committed to providing its services to the highest possible standard. If you, as an employer or employee, are dissatisfied with our services, you may submit a complaint using the designated complaints form. Cohesie considers it important that complaints can be raised promptly and accessibly.

Cohesie handles complaints in accordance with the requirements of the Dutch Working Conditions Act (Arbowet), the General Data Protection Regulation (“GDPR”) and, where applicable, the Dutch Healthcare Quality, Complaints and Disputes Act (Wet kwaliteit, klachten en geschillen zorg, “Wkkgz”).

The purpose of this procedure is to ensure that complaints are handled carefully, objectively and within a reasonable timeframe, and to contribute to the continuous improvement of the quality of Cohesie’s services.

For the purposes of this procedure, a complaint means any expression of dissatisfaction, submitted by or on behalf of an interested party, concerning Cohesie’s services in general or the acts or omissions of individual employees of Cohesie, which is not resolved by a simple explanation or immediate correction.

Complaints relating to the medical conduct or medical opinion of an occupational physician fall outside the scope of this complaints procedure. Such complaints may be submitted to the competent Regional Disciplinary Board for Healthcare, in accordance with the Dutch Individual Healthcare Professions Act (Wet BIG).

For the purposes of this procedure, the following definitions apply:

  1. A working day means any day other than a Saturday, Sunday or a national public holiday recognised under the Dutch General Extension of Time Limits Act (Algemene termijnenwet). A week means a period of seven days, commencing on a working day and ending seven days later at 24:00 hours. A month means a period commencing on a working day and ending on the corresponding day of the following calendar month.
  2. The person submitting the complaint may be assisted, when submitting the complaint and throughout the complaints procedure, by one or more experts or advisers appointed by them.

    For the purpose of handling a complaint, Cohesie processes personal data, including names and contact details, and, where applicable, information relating to health or working conditions. This processing is based on Cohesie’s legitimate interest within the meaning of Article 6(1)(f) GDPR. Where special categories of personal data, including health data, are processed, such processing is based on Article 9(2)(f) GDPR, insofar as processing is necessary for the establishment, exercise or defence of legal claims.  The personal data will be used solely for the purpose of handling the complaint, will be stored securely, and will be destroyed no later than two years after the complaint has been closed, unless a longer statutory retention period applies.
  3. Every oral or written complaint will be registered by the recipient in a complaints form, stating the source of the complaint, a brief description of its substance, the date of receipt and the manner in which it was received.

    Cohesie has appointed an independent complaints officer who assesses complaints objectively and, where appropriate, mediates between the parties involved. The complaints officer is not part of the hierarchical reporting line of the employee to whom the complaint relates.
  4. The registered complaint will be forwarded to a representative of Cohesie’s management on the day of receipt. Receipt of the complaint will be acknowledged to the complainant as soon as possible, and in any event no later than the fifth working day after the date of receipt. The acknowledgement will also inform the complainant of the further course of the procedure.
  5. The complainant will receive a written response from Cohesie’s management no later than three weeks after receipt of the complaint. This response will set out the complaint, the proposed resolution and/or the measures to be taken. The complainant will also be informed of the further procedure to be followed if they do not agree with the proposed handling of the complaint.

    If a complaint cannot be resolved within three weeks, the complainant will receive an interim written notice within that period, stating the reason for the delay and the expected date of completion. The total handling period will not exceed six weeks, unless a longer period is justified by the circumstances and the complainant is informed accordingly.
  6. If the complainant does not agree with the proposed written handling of the complaint, they must notify Cohesie’s management in writing within one month.
  7. Within one week after receipt of such notification, Cohesie will give the complainant the opportunity to provide an oral explanation of the complaint, either by telephone or during a meeting at Cohesie. If both parties consider this useful, and where applicable, the oral explanation may take place in a meeting at which all relevant parties are represented. A written record will be made confirming that the oral procedure took place and in what form. If the complainant does not make use of the opportunity to provide an oral explanation, they will receive a final decision from Cohesie’s management within two weeks.
  8. During the oral explanation, the complainant may be presented with a proposal for resolving the complaint. The complainant may respond to this proposal immediately. If a satisfactory resolution is reached during the meeting, this will be recorded in writing at the end of the meeting.
  9. If the meeting does not result in a mutually satisfactory resolution, the complainant will receive a final written proposal for the handling of the complaint within two weeks. If, after this internal review procedure, the complainant is of the opinion that the complaint has not been handled satisfactorily, the complainant may refer the matter to the Occupational Health Services Disputes Committee (Geschillencommissie Arbodiensten). Further information is available at www.klachtregeling.nl/klacht-indienen. In addition, complaints concerning the conduct of an occupational physician may be submitted to the competent Healthcare Disciplinary Board. For privacy-related complaints, Cohesie refers to its privacy statement and to the possibility of lodging a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
  10. Cohesie’s clients may expect Cohesie to provide proactive and customer-focused services.
  11. All complaints are recorded in a complaints register. On an annual basis, the nature, origin and outcomes of complaints are analysed for the purpose of quality improvement. Data used for internal reporting purposes will be anonymised before being included in such reports.
Version 1.2, dated 8 juli 2026