Bouwinvest has a dedicated compliance function that identifies, assesses, advises on, monitors and reports on the company’s compliance risks. For the planning, execution and reporting of all compliance activities, Compliance employs the Bouwinvest Compliance Cycle. This cycle contains groups of activities that are vital for the compliance function. The first group of activities focuses on the identification and interpretation of existing and new legislation relevant to Bouwinvest and its stakeholders and to determine its impact. Bouwinvest subsequently identifies and assigns scores to the relevant compliance risks and, on the basis of same, determines priorities. Next, the (amended) legislation and identified risks are translated into policies, which are then implemented. For this, Compliance facilitates the design of the processes, procedures and/or controls needed to execute the updated and new policies. During implementation and on an ongoing basis, Compliance devotes a great deal of effort to creating awareness and providing advice on relevant compliance risks and how to deal with them, ensuring a reduction in the number of incidents.
Bouwinvest’s compliance function supervises and monitors the effectiveness of the controls and initiates specific investigations when incidents or findings from regular monitoring activities necessitate this. Compliance reports on findings and on any areas of improvement in regular compliance reports, as well as reports on any investigations initiated.
The Bouwinvest Compliance Cycle
Key priorities
One of the key priorities of Bouwinvest’s integrity and compliance function is creating and increasing company-wide awareness of compliance risks, how employees can mitigate or control these risks and what is expected from them on this front. Increasing awareness was a major focus in 2016, and Compliance ran a number training courses and sessions on legislative changes and updated procedures. Bouwinvest also has a mandatory annual integrity workshop for all employees. The compliance risk environment is very dynamic and the legislation governing asset managers and investment managers changes constantly. In 2016, the Compliance officer worked on the risk-based updating of a number of internal rules and regulations. These included the rules governing the screening of business partners, as well as rules related the Sanctions Act, privacy legislation and ancillary positions. In 2017, Compliance will update the remaining internal compliance policies. Bouwinvest monitors relevant legislation and regulations closely and will continue to adapt and update its own internal compliance regulations to new or amended legislation.
Code of Conduct
Bouwinvest has a Code of Conduct that applies to all its employees and which includes rules that apply to the Board of Directors and Supervisory Board with respect to conflicts of interest and investments. The Code of Conduct deals with issues such as ethical behaviour, conflicts of interest, compliance with laws and (internal and external) regulations, CSR (corporate social responsibility), health and safety and requirements for our business partners. Bouwinvest also has a whistleblower policy with guidelines for the reporting and investigation of unethical behaviour. All employees receive code of conduct training.
Conflicts of Interests policy
Bouwinvest has a Conflicts of Interests policy. The purpose of this policy is to ensure that no material conflicts of interests occur which are damaging for our clients, our funds, or our management organisation. The policy also describes how Bouwinvest should act with respect to the allocation of different investment opportunities over the respective funds and clients. The policy is intended to supplement but not replace any applicable Dutch laws governing conflicts of interests.