NN Group Code of Conduct
Our purpose is to help people care for what matters most to them. To fulfil our purpose, we are guided in our work by our values: care, clear, commit. Our values, which are published under the title NN statement of Living our Values, set the standard for conduct and provide a compass for decision-making. These values are further expanded in the General Code of Conduct NN Netherlands (‘Code of Conduct’). Furthermore, the Code of Conduct provides additional standards and rules, to ensure that the requirements NN has for the employees are clear to them.
NN Group Whistleblower Policy
The NN Group Whistleblower Policy applies to all NN Group entities. NN Group's reputation and organisational integrity are key requirements to operate successfully in financial services. Failing to meet these requirements would violate the NN Group Values and may expose NN Group and its employees to possible regulatory and/or criminal liability.
Internal reporting of (suspected) criminal or unethical conduct by or within NN is vital for maintaining sound business conduct. Employees are encouraged to report any of these behaviours through the normal reporting channels (i.e. through their immediate or next higher level manager) in order to keep an open dialogue.
However, an employee may feel unable or uncomfortable raising a concern through the normal reporting channels. The NN Group Whistleblower Policy enables every employee to report, including anonymously, a concern outside the normal reporting channels. NN Group guarantees several rights, including protection from retaliation, for an employee who reports a concern in good faith, who provides information, who causes information to be provided or who otherwise assists in an investigation and who respects the confidentiality of the matter.
As of 1 July 2016 an Annex is added for the NN Group entities established in the Netherlands to implement the requirements of the Dutch House for Whistleblowers Act.
NN Group Compliance Function Charter
Effective compliance risk management helps NN to live up to and deliver on its strategic focus and values. It contributes to building trust in the company, both internally and externally, and protects NN’s brand. It enables NN to meet its compliance obligations and protect it from financial loss or reputational damage. It improves the way NN interacts with its stakeholders, enables NN to maintain a sustainable business and provides the license to operate.
This Charter, which was renewed in July 2019 and reviewed in February 2021, describes the way NN Group’s Compliance Function enables, advises, challenges, supports and oversees NN Group’s Compliance Risk Management.
Personal Trading Standard
The Personal Trading Standard is an NN Group policy, based on the Market Abuse Regulation (Verordening Marktmisbruik). An essential element of this policy is to prevent (the appearance of) dealing while having inside information regarding NN Group and/or other listed companies. Employees within the organisation who (could) possess inside information regarding NN Group and/or 3rd Party issuers are assigned as ‘Full Regime NN and/or Full Regime Third Party issuers’ and are as such governed by the (additional) rules of the Personal Trading Standard. These rules refer, among other things, to their personal account dealing in NN financial instruments and/or other listed companies, the monitoring thereof and the treatment of confidential information.
Gifts, Events and Business meals Policy
The Gifts, Events and Business meals Policy lists mandatory minimum requirements that need to be met to support NN Group and its underlying entities in mitigating the risk of bribery, corruption and unsound conflicts of interest related to gifts, events and business meals.
NN strictly prohibits the offering or accepting of bribes. We expect employees not to engage in any activity that may give the appearance of offering or accepting a bribe. As offering and receiving gifts and events and/or offering sponsorship and donations can be part of doing business, we have established rules to help prevent employees from unwittingly crossing boundaries and/or compromising their independent position towards third parties. As a general guideline, we expect all gifts, events and business meals to be reasonable in cost, quantity and frequency. And they should be provided and received in an open and transparent way. In case of doubt, employees are expected to seek guidance from management. Each NN entity has its own standard for gifts, events and business meals in place, approved by the Group, which defines thresholds and limits to frequencies, as well as registration requirements for gifts, events and business meals. These thresholds, limits and registration requirements may differ per NN entity. As a minimum requirement, however, all standards should reflect that employees may not offer or accept travel, accommodation, facilitation payments and cash or cash equivalents. NN entities are not permitted to make gifts or political donations or to offer events to political parties or candidates for political office.