There is a companywide policy on conflicts of interest and Chinese Walls. The goal of this policy is to limit the possibility of any potential conflicts of interest and respond properly if a conflict of interest does occur. Compliance to the policy is monitored by the responsible management of a business unit and an independent compliance officer. Besides that an internal audit committee provides an independent assessment on the overall effectiveness of the control measures of all business units. An example of a control measure is the development of so called 'Chinese Walls'.
With respect to conflicts of interests regarding exclusions, engagement or voting decisions, ACTIAM has a committee including an external expert that reviews RI policies and exclusion decisions. ACTIAM does not accept mandates of clients that want to invest in entities which are excluded based on the responsible investment policy.