Governance

Bouwfonds IM is committed to operating its fund management activities in a responsible and professional manner. This implies that a great deal of attention must be devoted to good governance, including the aligning of interests, transparency and dealing with conflicts of interest. In all these matters Bouwfonds IM must comply with its legal obligation to act in the reasonable interest of the investors and its assumed fiduciary responsibility towards investors.

Bouwfonds IM has defined this set of principles for specific situations related to fund governance. When dealing with potential conflict-of-interest situations, Bouwfonds IM will act in accordance with the Bouwfonds IM Conflict of Interest Policy and will endeavour to apply the specific principles defined herein reasonably and fairly. In situations that may not be covered by these principles, Bouwfonds IM will in general seek to use international best practices to the extent available. Bouwfonds IM pledges to resolve any situation after reasonable and fair consideration of all the relevant facts and circumstances and with due consideration for the interests of the investors (and other stakeholders),

Fund governance at Bouwfonds IM is incorporated and maintained by way of the following three elements: a) periodic review of application of the principles, b) reporting of the review to relevant parties, and c) supervision.

a) Periodic review
The Management Board of Bouwfonds IM is ultimately responsible for compliance with the principles at Bouwfonds IM and has implemented a permanent and competent compliance function at Bouwfonds IM. Bouwfonds IM has assigned the compliance duties to the compliance officer, who reviews periodically (at least once a year) whether Bouwfonds IM operates in compliance with the principles.

b) Reporting
The compliance officer reports the results of the reviews to the management of Bouwfonds IM and to the Head of Compliance of the Rabo Real Estate Group. These parties ensure that reporting takes place to the Executive Board and the Supervisory Board of the Rabo Real Estate Group.

c) Supervision
The Supervisory Board is responsible for supervising the (compliance function of the) Executive Board of the Rabo Real Estate Group and fulfils the role of supervising entity with regard to fund governance. As supervising entity, the Supervisory Board has the task of verifying at least once a year that fund management takes place in accordance with these principles and, more generally, that fund management follows through on its responsibility to act in the interest of the investors in the fund. The Executive Board of the Rabo Real Estate Group is ultimately responsible for effectively managing compliance and integrity risk within the Rabo Real Estate Group.