As a listed company Delta Lloyd is subject to the Dutch corporate governance code. We comply with this code as far as possible.
Our stakeholders benefit from the transparency that the code requires. In our capacity as an institutional investor we also follow its recommendations. Delta Lloyd NV complies with the best practice provisions of the Dutch Corporate Governance Code.
All information that is relevant for our shareholders and that we are statutorily obliged to disclose or publish is available on our website, in accordance with the corporate governance code. Information Delta Lloyd files at the Chamber of Commerce is available here.
Codes of conduct
The financial sector has introduced various codes of conduct in recent years, like the Banking Code of the Dutch Banking Association, the Corporate Governance Code en de Governance Principles. The Code of Conduct for Insurers and the Code of Conduct for Processing Personal Data by Financial Institutions set out rules that the whole industry has to comply with. These play an important part in Delta Lloyd’s policy. We have also drawn up an internal Code of Conduct to safeguard the integrity of our business operations.
Solvency II is an updated set of regulatory requirements for insurance companies operating in the European Union. It is a risk-based system that measures risk according to consistent principles and capital requirements relate directly to the outcome. Solvency II is based on economic principles for measuring assets and liabilities. While the preparations required for Solvency II are far-reaching and wide-ranging, we endorse the principles underlying the new framework. Early in 2015 Delta Lloyd opted to use an ‘internal model’ for reporting the required solvency to DNB (Dutch Central Bank) effective from 2016. Based on a thorough analysis of our solvency position, the Executive Board of Delta Lloyd announced at the end of November that the standard formula under Solvency II would serve as the basis for reporting our capital position. DNB was kept informed throughout this decision-making process and approves our decision. The internal model will be reviewed again in the coming year, after which the management will decide whether its implementation is appropriate for Delta Lloyd.
Delta Lloyd has had a whistleblower policy in place since 2009. Everyone in our organisation is expected to comply with internal and external rules and regulations. When employees suspect any impropriety or irregularities they have the right and the responsibility to report these. Our whistleblower policy sets out how to report general, operational or financial irregularities and how we deal with them. As far as possible it guarantees anonymity and confidentiality. The whistleblower policy is applicable to everyone at Delta Lloyd.
Delta Lloyd has rules for how to deal with market-sensitive information and for personal investment transactions of employees. There are stricter rules for those employees who have regular access to confidential information. The Insider Trading Regulations apply to all members of the Executive Board and Supervisory Board, as well to more than 650 employees in the Netherlands. Employees outside the Netherlands are subject to their local legislation and regulations.
Under Dutch law, members of the Executive Board and Supervisory Board are required to report all transactions of Delta Lloyd financial instruments that are made by or for them to the financial markets authority AFM. Transactions are published on the AFM website.
Communication with shareholders
Delta Lloyd values the dialogue with shareholders at the Annual General Meeting, analyst meetings, roadshows and press conferences. During these meetings, we only distribute information that has been previously disclosed. We do not disclose material, non-public information. Should such disclosure happen inadvertently, then Delta Lloyd must make that information public as soon as possible. In addition, we will explicitly advise the recipients of that information of its material non-public nature and ask them to promise, in writing, to keep it confidential and not trade on it until we have had the opportunity to promptly and widely disclose the information.
All the information presented at our roadshows is published on this website.
US Patriot Act and General Statement
The US Patriot Act and US Treasury anti-money laundering rules require any ‘foreign bank’ that maintains a correspondent account with a US bank or US broker-dealer in securities (a 'Covered Financial Institution') to provide the US institution with certain information.
As permitted by the final rules, Delta Lloyd Bank has prepared a US Patriot Act Certificate for any financial institution that requires such from a Delta Lloyd Bank entity. Delta Lloyd Bank has also prepared a General Statement regarding anti-money laundering.