[EN Version] # Allegations and legal basis (ALLEGATIONS_AND_LAW) This file is a map: **“what we allege (based on documents)”** + **“which rules we rely on as legal anchors”**, consistent with what is described in the public report. > Important: the public version describes facts and evidence (documents/communications/audio/video). Legal qualification should be confirmed by an independent lawyer where needed. --- ## A) Intrixo B.V. – alleged labour-law and standards violations ### 1. Pay during no-work periods / guaranteed hours - **Dutch Civil Code (BW), Book 7, art. 7:628** – entitlement to wages in certain “no work, still wages” situations where the cause lies with the employer (general rule). - **BW, Book 7, art. 7:610b** – statutory presumption of working hours (after at least 3 months: the agreed working time in a given month is presumed to match the average of the previous 3 months). - **EU Charter of Fundamental Rights, art. 31** – fair and just working conditions. ### 2. Late wage payments - **BW, Book 7, art. 7:625** – statutory increase (“penalty”) for late wage payment (maximum **50%**, and the court may reduce it). ### 3. Holidays (leave) and holiday pay - **BW, Book 7, art. 7:639–641** – paid leave and calculation rules for holiday pay. - **EU Charter, art. 31(2)** – right to an annual period of paid leave. ### 4. Holiday allowance (8%) - **Minimum Wage and Minimum Holiday Allowance Act (WML), art. 15** – minimum holiday allowance (generally **at least 8%**). ### 5. Housing deductions - **WML/WAS rules + implementing regulations**: housing deductions from (the part of) the minimum wage are only permitted under strict conditions, with a **maximum of 25% of the gross minimum wage** (e.g., written authorisation/power of attorney from the worker, and quality/certification requirements for the accommodation). ### 6. Data accuracy / payroll records integrity - **GDPR, art. 5(1)(d)** – the **accuracy** principle: personal data must be accurate and kept up to date where necessary. ### 7. Privacy in agency accommodation / entering a locked, occupied room - Reference to **privacy and safety standards** and the general principle that entering occupied living space without consent/prior notice requires strong justification and proper procedures (in the report supported by video evidence). --- ## B) Legal representatives – diligence, information duties, and file handover ### 1. Missing documents / lack of information - Professional standards for legal services: **timely and clear information**, acting in the **client’s best interests**, and **handing over the file/case documents** so the client (or a new representative) can verify what happened and continue the matter. - European rule-of-law standard: the right to an **effective remedy** and **real access to legal protection**. > Note: in the public version we describe facts and evidence. Legal qualification (disciplinary liability/breach of contract) should be confirmed by an independent lawyer. --- ## C) SNCU – role of the monitoring body and our points regarding the handling ### SNCU role and mandate (what it is and what it is expected to do) - **SNCU** (Foundation for Compliance with the Collective Labour Agreement for Agency Workers) monitors compliance with CAO rules in the agency work sector (including **ABU CAO / NBBU CAO**) and can investigate based on reports/signals. - According to SNCU’s described process, a key step is obtaining **payroll administration data** and verifying CAO compliance against verifiable records. - Input material for a control process should be **concrete, verifiable, and traceable**; otherwise the control loses its meaning. ## C) SNCU — serious procedural shortcomings, no genuine audit, and de facto erosion of workers’ rights protection (EU standards) **STATUS (02.02.2026):** This section is based on documents and correspondence. We do not speculate about SNCU’s intentions. We describe facts and standards. Lack of response/transparency is itself an evidentiary event. ### 1) The role of SNCU — what “control” must be (and what it must not become) SNCU only makes sense if it operates as a data-based control body, i.e., it verifies compliance with the sector CAO by reviewing source data (e.g., payroll administration, roster/planning, time registration, leave records). SNCU must not operate as: - an “employer mailbox”, - an administrative filter that closes a case after one employer reply, - a mechanism where the complainant receives no response and cannot know what was checked. If the “check” ends at “the employer says everything is fine”, then it is **not control** — it is **the appearance of control**. ### 2) No reply to the complainant = no transparency and no minimum procedural standard In case **SNCU----**, the complainant sent at least two formal letters: - **13-01-2026** — request for status + identification of key contradictions and a demand for verification using source data, - **22-01-2026** — reminder/request to reopen + demand for a list of verified documents and the complaint procedure. No response was received — not even an acknowledgment of receipt. As a result, the process becomes a “black box”: the complainant does not know the scope of review, the basis of the decision, or whether any evidence was genuinely verified. This conflicts with the minimum standard of effective legal protection and fair procedure under the **EU Charter of Fundamental Rights (Article 47)**. ### 3) Operational model: contact the employer and “preliminary” closure without demonstrating source-data verification From the materials relayed to the complainant via Juridisch Loket, it appears that SNCU: - contacted the employer (Intrixo B.V.), - closed the case at the “preliminary stage”, - relied on the employer’s narrative (including the claim that work ended in week 31 / “did not return”). In a dispute where the employer is an interested party, accepting a narrative without demonstrating verification of source data means that audit has been replaced by correspondence. That is a defective standard and results in **administrative shutdown** instead of genuine verification. ### 4) Evidence: payroll documents contradict the employer narrative and show retroactive “minus” corrections This case contains contradictions that cannot be credibly closed without source verification: **(a)** Employer narrative: “last day of work 28-07-2025 (week 31) / worker did not return”. **(b)** A payroll document contradicts this: **loonspecificatie for Week 32 (2025)** shows pay period **04-08-2025 to 10-08-2025** and **Contracturen: 32:00 per week**. This is inconsistent with “employment ended in week 31”. **(c)** Retroactive correction and “minus”: **loonspecificatie for Week 8 (2025)** appears again much later (dated in August 2025), showing **Contracturen: 1:00 per week** and a negative **Netto te betalen** (e.g., -191.62). This strongly suggests a retroactive correction creating a negative balance/offset — particularly in the context of a dispute and formal settlement requests. If payroll documents themselves show contradictions (Week 32 = 32:00) and retroactive minus corrections (Week 8 = 1:00 + negative net), then a “preliminary” closure based on the employer’s narrative is **not reliable and not credible**. ### 5) Evidence: 61.11 hours of leave — written approval → reversal → pressure In the leave track, the evidentiary chain is: - written information/approval for using **61.11 hours** of leave, - later reversal/denial and pressure (“report to work or consequences”), - formal notice and a demand for written confirmation. This requires source verification: leave balance history, approvals/reversals, system logs, roster/planning, and work communication. Closing without such verification effectively accepts a mechanism where paid leave can be “undone” after the fact. ### 6) EU standards: rights must be effective in practice (not “on paper”) Relevant EU standards include: - **Article 31(2) CFR**: right to rest and paid annual leave, - **Directive 2003/88/EC (Article 7)**: minimum paid leave standard, - **Directive 2008/104/EC**: protection and equal treatment of temporary agency workers in basic working conditions, - **Directive (EU) 2019/1152**: transparent and predictable working conditions, - **Article 47 CFR**: effective remedy and fair procedure. If a control body does not reply, does not disclose what was checked, and closes a case relying on the employer’s position despite documentary contradictions, then workers’ rights become unenforceable in practice. ### 7) Minimum data package for an honest verification (without this, conclusions are not credible) For a proper assessment, SNCU (or a state authority) must obtain and verify at minimum: - full payroll administration with correction history (who/when/why/what changed), - roster/planning at least for weeks 31–32, - time registration (actual hours), - leave records + logs (balance, approvals/reversals, change history), - explanation/audit: why Week 32 shows 32:00 against the “end in week 31” narrative, - explanation/audit: why Week 8 shows 1:00, negative net, and was processed later, - rules and calculations behind deductions/negative balances (including housing/insurance), including calculation logic. ### Final conclusion (maximally firm, fact-based) In this case, SNCU did not perform a genuine, verifiable audit: the complainant received no response, and the case was closed “preliminarily” based on the employer narrative despite contradictions in payroll documents (**Week 32 = 32:00**) and despite retroactive minus corrections (**Week 8 = 1:00 + negative net**) and despite leave evidence (**61.11h: approval → reversal → pressure**). This operational model shuts down complaints before any meaningful source-data verification — contrary to EU standards. ### Evidence to attach (repo) - Letters to SNCU: **13-01-2026** and **22-01-2026** — `[FILE_LINK_1]`, `[FILE_LINK_2]` - “Case closed” information + SNCU–employer correspondence — `[LINK]` - Loonspecificatie **Week 32 (2025)** — `[LINK]` - Loonspecificatie **Week 8 (2025)** — `[LINK]` - Materials on **61.11h leave (P4F)** + formal notice — `[LINK]` - (Optional) internal employer note “stop working 28-7-2025 / another job” — `[LINK]` --- # Criminal law consequences (EN) — potential offences for individuals in the recording (manager / staff / interpreter) **Important disclaimer:** This document describes **possible** criminal-law risks under Dutch law **if** the facts and intent are established by the police/prosecutor/court. Publicly, this must be presented as a **legal assessment / suspicion**, not as a final verdict. ## 1) Who can be prosecuted — the company and individuals In the Netherlands, a **legal entity (company)** can be prosecuted, and in addition **individuals** can be prosecuted if they: - gave an **order**, or - **directed** the unlawful conduct in practice (“feitelijk leidinggeven”), or - knowingly participated. **Article 51 Dutch Penal Code (Sr)** — legal entity + “ordering / factual leadership”: https://maxius.nl/wetboek-van-strafrecht/artikel51 --- ## 2) Key criminal-law risk areas (pressure, “negative hours”, “debt”, forced signature) ### A) Coercion (“dwang”) — **Article 284 Sr** If someone unlawfully **forces** another person to do/not do/tolerate something (e.g., signing, waiving rights, accepting a “debt/negative hours”) through (threat of) force or another coercive act, this may fall under **coercion**. **Maximum penalty:** imprisonment **up to 2 years** or a **4th category** fine. Text of Art. 284 Sr: https://www.inview.nl/openCitation/id0f20e2e056d18a65776eb4a56464f567/wetboek-van-strafrecht-artikel-284 **Why it may be relevant in this case (indicators):** - strong time pressure to sign (“little time”, “no discussion”, “solve it now”), - refusing to provide documents on the spot for calm review, - using “negative hours / minus balance” as leverage to close the matter quickly. > Note: the legal qualification depends on details (context, wording, objective, real freedom to refuse). --- ### B) Extortion (“afpersing”) — **Article 317 Sr** (requires violence or threat of violence) Extortion concerns forcing someone **by violence or threat of violence** to hand over property, accept a debt/obligation, or provide data, with the intent to obtain unlawful benefit. **Maximum penalty:** imprisonment **up to 9 years** or a **5th category** fine. Text of Art. 317 Sr: https://www.inview.nl/openCitation/idad3ee965cc4dab89e767700491a003d3/wetboek-van-strafrecht-artikel-317 **Practical note:** without violence or threat of violence, Art. 317 is typically harder to apply; labour-related cases more often focus on **Art. 284 (coercion)**. --- ### C) Forgery / false documents — **Article 225 Sr** If documents are deliberately falsified or fabricated (e.g., “negative hours”, “debts”, hour statements, wage calculations, settlement papers) or knowingly used as genuine, this may fall under **forgery / false documents**. **Maximum penalty:** imprisonment **up to 6 years** or a **5th category** fine. Text of Art. 225 Sr: https://www.inview.nl/openCitation/idbe7a24edb101c273013194ea8c25887b/wetboek-van-strafrecht-artikel-225 --- ### D) Fraud (“oplichting”) — **Article 326 Sr** If a person is induced by deception (false narrative, trick, “web of lies”) to sign, accept a debt/obligation, or waive rights, this may fall under **fraud (oplichting)**. **Maximum penalty:** imprisonment **up to 4 years** or a **5th category** fine. Text of Art. 326 Sr: https://www.inview.nl/openCitation/id8fa9a143265d922b148752df4c785a8b/wetboek-van-strafrecht-artikel-326 --- ## 3) What may happen to the involved individuals (if criminal proceedings start) Depending on the evidence and seriousness: - questioning as **witness** or **suspect**, - collection of records / investigation into payroll administration in broader cases, - sanctions: fine / community service / (in severe cases) imprisonment, - real-life impact: reputational damage, dismissal, difficulty in roles requiring high trust / VOG. --- ## 4) How to phrase this publicly (strong, but legally safe) Recommended wording: - “This conduct **may potentially** fall under Art. 284 Sr (coercion) **if** unlawful pressure is established.” - “If document manipulation is proven, Art. 225 Sr (forgery) and/or Art. 326 Sr (fraud) **may** be relevant.” - “Final criminal qualification is for the police/prosecutor/court.” Not recommended (defamation risk): - “They definitely committed offence X.” - “This is certainly extortion.” - publishing full personal identities without necessity. --- ## [EN] Unannounced entry into hotel room (Mixx Inn, room 267) — potential criminal consequences (NL) **Evidence statement (based on video recordings):** on multiple dates and times, third parties opened the door and entered a room that was in the residents’ factual use (D. N., B. S.), **without prior notice and without the residents’ consent**. The incidents show a recurring pattern (multiple entries, different individuals, actions at/near the door and in the entrance area). ### 1) Unlawful entry / house trespass — “huisvredebreuk” (Art. 138 Dutch Criminal Code) Unlawfully entering a dwelling / enclosed space that is in another person’s use, or unlawfully remaining there and refusing to leave when ordered, may constitute **huisvredebreuk**. A hotel/agency room used as a person’s actual place of stay is generally treated as protected “home/private space” (house-right protection). **Maximum penalty:** up to 1 year imprisonment or a fine. ### 2) Coercion — “dwang” (Art. 284 DCC) if used as pressure If the entry is used to force someone to do, not do, or tolerate something (e.g., to sign documents, accept a disputed “minus/debt”, comply with demands), it may qualify as **criminal coercion**. **Maximum penalty:** up to 2 years imprisonment or a fine. ### 3) Stalking/harassment — “belaging” (Art. 285b DCC) if systematic A **systematic** invasion of privacy aimed at forcing compliance or instilling fear may constitute **belaging**. **Maximum penalty:** up to 3 years imprisonment or a fine. (Procedural note: often requires a formal complaint by the victim.) ### 4) Corporate liability + “de facto directing” (Art. 51 DCC) Not only the individuals who entered, but also the **company** (legal entity) and persons who **directed or systematically tolerated** the conduct (de facto leadership) can be held criminally accountable. ### 5) Practical consequences - police report/investigation → interviews, suspect status, possible prosecution, - potential protective measures if the situation escalates, - fines/community service/(suspended) imprisonment depending on severity and repetition, - in parallel: civil damages for breach of privacy and peaceful enjoyment of the residence. ### 6) Publishing evidence When publishing: anonymise faces/names, preserve originals and hashes, describe as “according to the recordings/evidence” (avoid stating guilt as a fact). --- ## Sezer Duygulu Sezer Duygulu is publicly presented as the Founder of the Home of People group. The same group publicly displays a network of affiliated brands, including Uitzendbureau Solutions, T&S Flexwerk, TENS Holanda, NWH Jobs, Efficient at Work, Intrixo, and Masterteam. This does not look like a small local business, but rather a broad structure operating in a sector that has been under scrutiny for years because of risks related to migrant labor, housing, and workers’ dependence on intermediaries. The strongest red flag concerns labor rights. Uitzendbureau Solutions B.V. was a party to a case that reached the Dutch Supreme Court. The core issue was very serious: whether an agency worker can, in practice, lose employment simply because they become ill. The mere fact that the case reached that level shows that this was not a minor misunderstanding, but an important issue concerning the protection of workers during illness or incapacity for work. A second strong red flag concerns housing for migrant workers. In a publicly available case before the Raad van State, the use of a property as lodging for migrant workers was described, along with administrative enforcement measures related to fire safety violations and unlawful use of the building. The case description also refers to a connection with Solutions B.V. as the tenant financing the accommodation. This is not a minor administrative detail, but a signal of risk in one of the most sensitive areas of the entire business model. The third red flag is the operating model itself. When one group controls work, housing, and often transport as well, the worker becomes dependent on a single structure for almost everything. This is precisely the type of arrangement that the Dutch government identifies as especially vulnerable to abuse: underpayment, poor working and living conditions, and circumvention of regulations. That is why the government introduced the Wtta, aimed at agencies and labor suppliers that circumvent the law or operate at the expense of workers. What is additionally striking is that these activities are also firmly embedded in official industry and certification structures. Uitzendbureau Solutions B.V. appears on the NBBU website as a member, and the listing also points to SNA certification. In the SNA register, the company is listed as certified, and the registration document confirms its entry in the Register Normering Arbeid. In the SNF register, Solutions B.V., Uitzendbureau is also listed, which means it is present within the standards system relating to housing for migrant workers. In other words: the company is not operating on the margins of the market, but within the official industry and certification framework. That does not, however, clean up the picture. Membership in the NBBU and presence in SNA/SNF do not automatically mean there are no problems. They only show that the company operates within the industry system and has passed certain formal checks. Even so, serious questions remain in the public sphere regarding the treatment of workers and the safety of the housing arrangements. The fairest way to summarize it is this: around the activities associated with Sezer Duygulu, real red flags are visible — a labor dispute at the level of the Supreme Court, issues involving migrant worker housing, and operations in a sector that the state itself considers especially vulnerable to abuse. However, these sources do not provide a basis to state as fact that Sezer Duygulu personally was convicted of fraud or formally found to be responsible for exploitation. That distinction matters: one may speak of serious risk and a troubling pattern, but not of proven personal guilt without hard evidence. Sezer Duygulu is publicly presented as the founder of Home of People — a group operating in the temporary labor and migrant worker sector. Serious red flags appear around companies linked to that group: a labor dispute involving Uitzendbureau Solutions reached the Dutch Supreme Court, and public administrative materials also contain a housing-related case involving migrant workers and fire safety violations. At the same time, the company operates within official industry structures — it is listed as an NBBU member and appears in the SNA and SNF registers. That does not remove the risks. Rather, it shows that despite its formal place within the industry system, significant questions remain about labor rights, housing compliance, and the model of worker dependence on the intermediary. Source links https://www.homeofpeople.nl/over-ons/ https://www.homeofpeople.nl/team/sezer-duygulu/ https://www.nbbu.nl/nl/onze-leden/uitzendbureau-solutions-bv https://uitspraken.rechtspraak.nl/details?id=ECLI:NL:HR:2023:426 https://www.raadvanstate.nl/@138720/202103252-1-r3/ https://www.normeringarbeid.nl/snakeurmerk/gecertificeerde-ondernemingen https://www.normeringarbeid.nl/snakeurmerk/gecertificeerde-ondernemingen/4c2e95bf-f454-4b15-b279-eaf2a1860f48/verklaring/nl https://www.normeringflexwonen.nl/register https://www.normeringflexwonen.nl/snfkeurmerk/gecertificeerde-ondernemingen/export https://www.rijksoverheid.nl/onderwerpen/hervormingen-arbeidsmarkt/aanpak-miss --- ## Sources (primary/authoritative links) - Dutch Civil Code (BW) Book 7 – wetten.overheid.nl: https://wetten.overheid.nl/BWBR0005290/ - BW art. 7:610b (presumption of working hours) – (text overview): https://lokaleregelgeving.overheid.nl/CVDR682512 (search for “Article 610b”) - Statutory increase max. 50% (Dutch judiciary explanation): https://www.rechtspraak.nl/Onderwerpen/Loonvordering - WML (Minimum Wage and Minimum Holiday Allowance Act): https://wetten.overheid.nl/BWBR0002638/ - Housing deduction max. 25% + conditions (Dutch government): https://www.rijksoverheid.nl/onderwerpen/minimumloon/vraag-en-antwoord/kosten-voor-huur-en-zorgverzekering-inhouden-op-minimumloon-werknemer - EU Charter art. 31: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12012P/TXT - GDPR (EU 2016/679): https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng - SNCU info: https://www.sncu.nl/ and ABU on SNCU’s role: https://www.abu.nl/faq/wat-is-de-rol-van-de-sncu-bij-het-lid-worden/