Guidelines

The governance model and the related policy framework established by the Executive Board are key building blocks of Delta Lloyd Group's corporate governance. The Group has defined and recorded the objectives and frameworks of authority and responsibility that the business units are required to pursue and adhere to for a wide variety of policy fields. All policy documents are electronically accessible and are updated periodically.

Code of Conducts

In recent years, the financial services sector has also taken the initiative to introduce codes of conduct in various fields. The Insurers' Code of Conduct (Gedragscode Verzekeraars) and the Code of Conduct for the Processing of Personal Data by Financial Institutions (Gedragscode Verwerking Persoonsgegevens Financiële Instellingen) set out rules with which the entire industry must comply. These rules form an important policy framework for Delta Lloyd Group. In addition, Delta Lloyd Group has formulated internal codes of conduct to safeguard the integrity of its business operations.

Corporate Governance Code

As a listed company, Delta Lloyd Group is committed to complying wherever possible with the recommendations of the Dutch Corporate Governance Code. The Group believes its stakeholders stand to benefit from the transparency required by the Code. Delta Lloyd Group will also follow the corporate governance recommendations in its capacity as an institutional investor. Click here to see the differences between the Dutch Corporate Governance Code and corporate governance at Delta Lloyd Group.

SOx-compliant

The Group is in the process of implementing processes and procedures aimed at enabling Aviva to certify its compliance with SOx in respect of the year 2009 onwards. In 2008, the most important controls relating to financial reporting were identified. An ICT application for the systematic recording of all controls and the outcomes of test programmes was installed. The test phase, during which the proper operation of all controls will be assessed, is expected to be completed by the end of 2009 and the Group is working with Aviva on completing the SOx
assessment as soon as possible thereafter. One important area of attention for the project is the impact of strategic changes on the Group with respect to the internal control of the financial reporting processes. SOx controls mitigate the risks of failures in financial reporting.

Whistleblower Policy

The Executive Board and the Central Works Council approved the Delta Lloyd Group Whistleblower Policy in october 2009. Delta Lloyd Group expects all its staff to comply at all times with internal and external regulations and legislation. Employees have the right and the responsibility to report any suspicions of malpractice of a general, operational and/or financial nature. The whistleblower policy documents the manner in which malpractice or suspicions thereof must be reported and handled, guaranteeing anonymity and confidentiality wherever possible. The whistleblower policy is applicable to all divisions and group members of Delta Lloyd Group.

Insider Trading Regulations

Delta Lloyd Group has rules for dealing with price-sensitive information and for private portfolio investment transactions by staff. Employees with regular access to confidential information are governed by stricter rules as laid down in the Insider Trading Regulations. These regulations are applicable to the members of the Supervisory Board and the Executive Board and to roughly four hundred employees in the Netherlands. Insiders outside the Netherlands are subject to local laws and regulations.

Communications with shareholders

Delta Lloyd Group values the dialogue with its shareholders through the annual general meeting, analist meetings, roadshows and press conferences.

- Non-public material information
Information in these meetings will be limited to previously disclosed material information. Material non-public information will not be provided during such meetings.

Should an inadvertent disclosure of non-public material information occur or a knowing disclosure of non-public material occur, Delta Lloyd Group will make such information public as soon as possible. In addition, the Delta Lloyd Group representatives will explicitly advise the recipients of the material, non-public nature of the information and get their expressed agreement in writing to keep the information confidential and to avoid trading on such information until Delta Lloyd Group has the opportunity to make prompt and broadly disseminated disclosure of the information.

- Presentations
Any information presented during roadshows will be published on this website, in the presentations section.

- Aviva
To enable Aviva to satisfy its ongoing financial reporting, audit and other legal and regulatory requirements (including Aviva's tax, risk management and control procedures), as these requirements will apply to Aviva from time to time (the “Aviva Obligations”), Delta Lloyd Group will provide to Aviva the financial and other information reasonably requested by Aviva as detailed in and in accordance with the terms of Schedule 8 in the Strategic Investment Agreement.

US Patriot Act and General Statement

Pursuant to the US Patriot Act and final rules issued by the US Department of the Treasury, a US bank or a US broker-dealer in securities (a 'Covered Financial Institution') is required to obtain certain information from any 'Foreign Bank' that maintains a correspondent account with it.

As permitted by the final rules, Delta Lloyd Bank N.V. (Delta Lloyd Bank) has prepared a Delta Lloyd Bank US Patriot Act Certification for use by any financial institution that believes it requires a Patriot Act Certification from a Delta Lloyd Bank entity. See the General Statement. If you have any questions with regard to this Certification, please advice us by e-mailing us at louwrens_abercrombie@dlbank.nl.