Ethical business conduct

Bouwfonds IM places integrity at the heart of its policy and activities. The company operates honestly, sincerely, with due care and reliably, both inside and outside its own working environment.

Bouwfonds IM places integrity at the heart of its day-to-day operations. Our socially responsible corporate behaviour is the basis for all our decisions. We are transparent towards all stakeholders in our business operations. We aim to be compliant with industry guidelines (e.g. INREV) on transparency, reporting, etc. Our communication about products, cost structure, risks and opportunities is clear. The decision-making process, revenues and underlying assumptions are communicated openly and clearly. Bouwfonds IM implements its ethical business practices in its day-to-day operations via internal policy documents and procedures. The most important documents in that respect are:

• the Code of Conduct;
• the Customer Due Diligence (CDD) Policy;
• the Fund Governance Principles;
• the Conflict of Interest Policy.

The Code of Conduct 
The Code of Conduct contains all rules that apply for everyone who works for Bouwfonds IM. These rules ensure that employees conduct themselves in such a manner that no damage, including reputational damage, is caused to society in general and to the group and/or parts of it in particular. The goal is to give employees clear guidelines as to what is ac¬ceptable and unacceptable conduct at our company.

The Customer Due Diligence (CDD) Policy 
The CDD policy of Rabobank, the Rabo Real Estate Group and Bouwfonds IM is structured in such a way as to prevent these companies and/or their employees from collaborating with and/or doing business with parties that could damage society in general or the reputation of Rabobank, the Rabo Real Estate Group and/or Bouwfonds IM in particular.

The Fund Governance Principles
Bouwfonds IM is a real estate and infrastructure investment manager. In this capacity Bouwfonds IM also assumes a fiduciary responsibility towards its investors. The Bouwfonds IM Fund Governance Principles contain guidelines and best practices for the management of the funds initiated or managed by Bouwfonds IM.

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 fiduciary responsibility towards them.

Bouwfonds IM has defined principles for specific situations related to fund governance. 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),

The Conflict of Interest Policy
The conflict of interest policy provides insight into how conflicts of interest or potential conflicts of interest between funds managed by Bouwfonds IM or between a fund and Bouwfonds IM itself (in its role as shareholder, sponsor, financier or manager of that fund) are handled. 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.


Bouwfonds IM Conflicts of Interest Policy
Bouwfonds IM Fund Governance Principles
Bouwfonds IM Customer Due Diligence (CDD) Policy