Bouwinvest sees integrity, transparency and corporate social responsibility and important prerequisites to achieving its business objectives. In that context, Bouwinvest strives for ethical and controlled business operations, in which Bouwinvest and its employees comply with laws and regulations and the company’s own code of conduct.
Bouwinvest has an independent compliance function. This function focuses on monitoring compliance with laws and regulations, the development of policy, the monitoring of the management of compliance risks, conducting investigations in response to integrity reports and providing (solicited and unsolicited) advice.
In addition to this, the compliance function focuses on increasing integrity awareness and promoting the desired behaviour in the Bouwinvest organisation, among other things through training courses.
The compliance function reports to the Chief Executive Officer and also reports on a quarterly basis to the Audit, Risk and Compliance Committee of the Supervisory Board.
In 2019, the compliance function intensified its cooperation with other Bouwinvest departments, including Risk management, HR, Internal Audit and Corporate Communications. The reason behind this drive to intensify cooperation is Bouwinvest’s wish to take a more integrated approach to the likes of risk management and activities on the culture & conduct front.
Laws and regulations
Laws and regulations are constantly changing. Once again in 2019, the compliance function worked on the regular updates of a number of internal rules and regulations.
Bouwinvest closely monitors legal and regulatory developments and will continue to adapt its own internal policies to changes in new or amended legislation.
In 2019, Bouwinvest started a project aimed at revising the company’s internal policies related to the implementation of the Dutch Act on the Prevention of money-laundering and the financing of terrorism.
Management of compliance risks
Bouwinvest applies the three lines of defence model to manage its risks. In the context of this model, the compliance function is part of the second line of defence and its primary task is to manage any compliance risks. Compliance risks include the main risk categories regulatory risk and integrity risk.
As part of its second line of defence role, the compliance function supports, advises, coordinates and monitors the first line of defence’s management of Bouwinvest’s identified compliance risks. The compliance function supports the first line of defence by increasing the awareness of these risks and by making it clear how employees can mitigate or manage these risks, and what Bouwinvest expects of them on this front. One important activity on this front is the execution of the annual Systematic Integrity Risk Analysis (SIRA), which involves a large number of people across the organisation. The aim of the SIRA is to take stock of the compliance risks and assess the effectiveness of the management of those risks. The SIRA is applied to both the management company and the funds and includes specific scenarios for the various activities. The results of the SIRA are used as input for the compliance year plan for the year ahead.
In the spring of 2019, the compliance function ran a number of integrity workshops. The workshops were mandatory for all Bouwinvest employees were aimed at increasing integrity awareness among employees by prompting the discussion of integrity themes.
Training & awareness
In addition to the main compliance themes, such conflicts of interest, corruption, fraud and courtesy and respect (conduct), one of the central themes of the workshops was moral courage. The workshops were also used to address dilemmas that people can face in their day-to-day work.
Reports and advice
In 2019, there were no incidents that resulted in a report to the regulator, the Dutch Financial Markets Authority (AFM).
The compliance function is largely asked for advice on the subjects; assessment of business partners, ancillary positions, gifts & events and privacy.