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 operating successfully in financial services. Failure 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.
The NN Group Whistleblower Policy is updated with the new EU Whistleblower Directive as of 17 December 2021.
Internal reporting of (suspected) criminal or unethical conduct or breaches of (EU) law by or within NN is vital for maintaining sound business conduct.
Employees are encouraged to report any misconduct or any breaches of our rules and regulations, the NN statement of Living our Values, or our Code of Conduct:
Through the normal reporting channels (i.e. through their immediate or next higher level manager) in order to keep an open dialogue.
If they feel uncomfortable reporting to their management, employees can reach out to the Whistleblower (WB) Reporting Officers. In principle this is a compliance officer who has been appointed to manage reports confidentially and to communicate with reporters about their duties and rights, and to follow up on their case.
If employees do not feel comfortable with one of the above mentioned possibilities, they can report (anonymously) via the Speak Up system in their own language. The Speak Up system is designed, established and operated in a secure manner that ensures the confidentiality of the identity of the reporter if desired and prevents access thereto by unauthorised NN employees. A WB Reporting Officer will handle the report and communicate with the reporter.
NN Group guarantees several rights, including protection from retaliation, for a Whistleblower who reports a concern or breach in good faith and in a work-related context.
The Policy also applies to external reporting persons as defined in paragraph 7.2 (2III) of the Policy who acquired information on breaches in a work-related context with NN. If you are such a reporting person you can report via the Speak Up System.
Speak Up system
Report via web: www.speakupfeedback.eu/web/nngroupexternal/nl (access code 90749)
Report via phone: 0800 0222931 (access code 90749)
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.