If the internal affairs are in good order and reporting is open and transparent, the basics for success are in place.

Integrity is all about behaviour - behaviour that conforms to rules and values. Compliance with the law comes first, of course, but the sector's codes of conduct must also be adhered to. And on top of this, there are our own internal rules. Meeting all these rules is a labour-intensive process, which must be kept within manageable bounds. And yet, if the internal affairs are in good order and reporting is open and transparent, the basics for success are in place. The same applies to sustainable and responsible investment. All of Delta Lloyd Group's direct investments are deliberately targeted at long-term value creation in accordance with environmental, social and governance criteria. Delta Lloyd Group has therefore signed the United Nations Principles for Responsible Investments (UNPRI). All direct investments for own risk are responsibly invested.
Objectives and results for integrity
Objective 2010 Result 2010 Objective 2011 and beyond
Delta Lloyd Group, together with its partners, is committed to promoting behaviour, products and services where integrity and sustainability are key aspects Decrease in number of reported fraud incidents Further integration of fraud, crime and corruption policy in a code of conduct
. Introduction of integrity screening Further embedment of integrity among all employees
. Responsible investment policy available to the public Policy on relevant themes and compliance are disclosed and refined

Integrity is an essential condition for good corporate governance and one of Delta Lloyd Group's core values. It is supported by legislation and regulations, Delta Lloyd Group's own codes of conduct and industry-based codes of conduct.

Codes of conduct

Delta Lloyd Group actively applies codes of conduct aimed at upholding the integrity of financial markets and restoring consumer confidence. Legislation and regulations are transposed into policy documents, instructions and guidelines at Group level. At divisional level, compliance officers help to convert Group policy into operational procedures and work instructions.

Raising awareness

Delta Lloyd Group feels it is important that management actively promote codes of conduct and the policy on integrity. We call this the 'tone at the top'. Rules and regulations alone are not enough; they must also be communicated to ensure adherence. Conveying the importance of compliance with behavioural standards and imparting knowledge about the associated operational requirements are all part of this awareness-raising exercise.

Sterknet and Sterkmagazine

The codes of conduct, policy documents and relevant legislation and regulations are published internally so staff can view them at any time. Information is posted on the Group's Dutch intranet (Sterknet) and published in the staff magazine (Sterkmagazine).

Code of Conduct Booklet

Information meetings are also held and in 2010 a code of conduct booklet (in Dutch) was compiled, combining all codes of conduct and guidelines applicable to employees. In the second quarter of 2011, this booklet was handed out to all employees and its contents were incorporated into the conditions of employment.

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