NN Group Whistleblower Policy
The NN Group Whistleblower Policy was
renewed in July 2014 and applies to all NN Group entities. NN Group's
reputation and organizational integrity are key requirements to operate
successfully in financial services. Failing to meet these requirements would
violate the NN Group Business Principles 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.
download the NN Group Whistleblower Policy
NN Group Compliance Charter & Framework
NN Group is committed to the preservation of its reputation and integrity through compliance with applicable laws, regulations and ethical standards in each of the markets in which it operates. All employees are expected to adhere to these laws, regulations and ethical standards, and management is responsible for ensuring such compliance. Compliance is therefore an essential ingredient of good corporate governance.
The purpose of this policy, which was renewed in April 2014, is to help businesses to effectively manage their Compliance Risks. The first part of the document - the Charter - describes the organization, operation and governance of compliance for NN Group. The Framework consists of structures, tools and processes that guide compliance activities. It enables senior management, business managers, and employees to understand and effectively manage compliance risks.
download the NN Group Compliance Charter & Framework
Insider Regulation NN
The Insider Regulation NN is an NN Group policy, based on the Dutch Financial Supervision Act (Wet op het financieel toezicht). An essential element of this policy is to prevent (the appearance of) dealing while having inside information regarding NN Group. Employees within the organisation who (could) possess inside information regarding NN are assigned as ‘Insider NN’ and are as such governed by the (additional) rules of the Insider Regulation NN. These rules refer, among other things, to their personal account dealing in NN financial instruments, the monitoring thereof and the treatment of confidential information relating to NN Group.
download the Insider Regulation NN
Personal Account Dealing Policy
The Personal Account Dealing Policy is an NN Group policy, based on the Dutch Financial Supervision Act (Wet op het financieel toezicht).
An essential element of this policy is to prevent (the appearance of)
insider dealing. Employees within the Netherlands who (could) possess
inside information are assigned as ‘Insider’ and are as such governed by
the (additional) rules of the Personal Account Dealing Policy. These
rules refer, among other things to their personal account dealing, the
monitoring thereof and the treatment of confidential information.
download the Personal Account Dealing Policy