The Compliance program of NN Investment Partners (NN IP) has been established to address the potential conflicts of interest for its clients and make sure clients’ interests are served. NN IP is committed to the preservation of its reputation and integrity through compliance with applicable laws, regulations and ethical standards in each market in which it operates. NN IP’s management is responsible for ensuring such compliance and the Compliance department assists in creating and maintaining an efficient and effective compliance program.
Devotion to the highest integrity standards and respect for our business values are expected from each NN IP employee. We believe that the trust and confidence we earn from employees and clients determine the success of our business. The compliance policies contain rules, principles, processes and procedures to illustrate expected ethical behavior.
Our Compliance Handbook summarizes the most of the compliance policies and procedures.
Policies available to download:
For our SEC-registered entities:
NNIP Advisors B.V.
NN Investment Partners North America LLC
In case of inquiries about our policies and procedures, please contact our Compliance department at email@example.com
It is NN IP’s believe that exercising our rights as shareholder in the companies we are invested in, contributes to the goal of providing an optimal return to our clients. NN IP’ corporate governance policies and activities are focused on protecting and enhancing the economic value of the companies we are invested in on behalf of our clients. Proxy voting is one of the primary methods for exercising our shareholder rights and playing a role in the checks and balances of investee companies. Good corporate governance underpins the development of profitable businesses while securing shareholder rights and the equitable distribution of benefits.
Among NN IP’s clients are large and small institutional investors from all regions of the world. Together they represent a very diverse selection of values and preferences. Therefore NN IP has decided to base its proxy voting policy on generally accepted corporate governance best practices. These best practices are among others reflected in the OECD Principles of Corporate Governance and the Global Corporate Governance Principles (Revised 2009) of the International Corporate Governance Network (ICGN). The proxy voting policy of NN IP International serves as a framework for exercising voting rights at shareholder meetings worldwide. While we believe that there are some overarching principles of corporate governance that apply globally, we recognize that corporate governance practices vary internationally.
We publish our voting activity for Clients Assets held in Dutch mutual funds, Belgian funds and Luxemburg SICAVs as well as the Proprietary Assets managed NN IP. All votes cast can be accessed through the link below, NN IP’ voting activity for NN Group’s Proprietary Assets and Client Assets. We provide regularly updated detailed information on our voting conduct.
NN IP makes use of swing pricing to protect funds’ shareholders from the negative effects of transaction costs related to subscriptions and redemptions made by incoming and outgoing investors. These transaction costs are shared by all of the fund’s shareholders, not only those subscribing or redeeming on a given day.
The single price at which investors buy or sell a fund’s shares reflect only the value of the fund’s net assets. Dealing costs are not taken into account, and can therefore reduce the fund’s performance, affecting all of its shareholders. Swing pricing seeks to mitigate this impact by adjusting the fund’s net asset value, based on estimates of average trading costs.
UK Modern Slavery Act
Under the UK Modern Slavery Act (the “Act”) certain large organisations doing business in the United Kingdom are required to produce a yearly “slavery and human trafficking statement”. The concept of “modern slavery” under the Act encompasses behaviors such as forced, compulsory or coerced labour, deprivation of personal freedom or facilitating the movement of people for exploitation. Pursuant to Section 54 of the Act the present statement describes NN IP’s approach to, and contribution to prevention of modern forms of slavery in its business and value chain. The statement is updated yearly.
Promoting Corporate Governance
The introduction in 2004 of the Dutch Corporate Governance Code (the “Code”) has led to companies in the Netherlands paying more attention to the subject of good corporate governance. NN IP is convinced that companies that pay sufficient attention to good corporate governance perform better in the long term. We feel it is our responsibility to encourage good corporate governance among the companies that we invest in on behalf of our clients. One of the ways to achieve this is by making effective use of the voting rights that are linked to the shares held. When casting our votes during a shareholders’ meeting, we act strictly in the interest of our clients. Apart from exercising our voting right, we also actively enter into dialogue with the companies in which we invest on behalf of our clients.
The Dutch Corporate Governance Code
The includes principles and best practices that are specifically aimed at institutional investors (IV.4.1 - IV.4.3) as well as all shareholders in Dutch listed companies (IV.4.4 – IV.4.6). Institutional investors are expected, among other things, to publish a voting policy (find below download) on their respective websites that serves as the basis for the way their voting rights are exercised at shareholders’ meetings.
NN IP applies best practices IV.4.1 to IV.4.6, but it does make a reservation with regard to best practice IV.4.4. This article relates to what is referred to as the response time. If a shareholder intends to request that a subject be put on the agenda that may lead to a change in company strategy, then the directors must be given a reasonable period of time to respond to this. In the Code, this reasonable period is fixed at 180 days. NN IP endorses the best practice principle that the right to ask for a subject to be placed on the agenda must only be exercised after the shareholder has entered into discussion on this with the directors. In exceptional circumstances, however, there may be no opportunity to consult with the directors because of the limited time available. As and when necessary, NN IP will therefore assess whether there is sufficient opportunity to notify the directors in time regarding the matter of placing a shareholder resolution on the agenda. Shareholders have a legal right to submit a subject for inclusion on the agenda of the shareholders’ meeting no later than 60 days before the meeting.
Eumedion best practices for engaged share-ownership
NN IP is a member of the Dutch corporate governance forum . This organisation has published best practices for engaged share-ownership, which came into effect at the start of 2012. These best practices apply to all institutional investors participating in Eumedion. Our objective as NN IP is to give substance to our role as shareholder, on behalf our clients, in a responsible manner. The Eumedion best practices are in line with this objective. The document below presents for each best practice in what way NN IP intends to work this out in concrete situations. NN IP's implementation of Eumedion's best practices for engaged share-ownership
NN IP' remuneration policy is aimed at being an attractive employer and correctly remunerating its staff. We link correct remuneration to our corporate objectives, i.e. running a solid business, controlling risks and correct customer service. For that reason, the variable remuneration of our staff depends on the financial results, personal performances and how our customers rate us. Customer satisfaction is measured by an independent external agency every two years. The ranking of NN IP within the group of Asset Managers represents the customers' interests. In addition, the investment performances over one year and three years are compared to the target performance and the performance of our immediate competitors. As a result, the remuneration policy does not serve as an incentive to take undesirable risks or offer inadequate customer service. NN IP endorses the need for a controlled remuneration policy and complies with the legislation in this area.
Tax Strategy and Principles
NN IP adheres to the NN Group Tax Strategy and Principles. Please click here to read the NN Group Tax Strategy and Principles.