For the implementation of its Integrity Policy the Pension Fund has introduced a Code of Conduct for the Board of Trustees and for all persons that work for, on behalf of or on the instructions of the Pension Fund as well as for all stakeholders designated by the Board of Trustees. This is to prevent conflicts between the interests of the Pension Fund and the personal interests of the stakeholders, and to prevent the use of the Pension Fund’s confidential information for personal objectives.

Compliance officer

The Pension Fund has appointed the Dutch Compliance Institute based in Capelle aan den IJssel as its Compliance Officer. The Compliance Officer is an organisation appointed by the Board of Trustees to ensure that the Pension Fund complies with the current compliance legislation that is applicable to the Fund. For example, the Compliance Officer is charged with overseeing compliance with the provisions of the Code of Conduct that is applicable to all Trustees. The tasks and authorities of the Fund’s Compliance Officer are set out in the Compliance Program. The Compliance Officer has confirmed in writing that it has familiarised itself with its tasks and responsibilities.

It has also been agreed that the Compliance Officer will provide written feedback annually to the Board of Trustees about its findings regarding compliance.