The Spoorwegpensioenfonds only has a board. The content of the conflict of interest policy of the board of SPF is:
- Every (potential) conflict of interest has to be reported to the compliance officer.
- Transactions with an/or gifts received from (potential) clients and/or relations of SPF have to be reported.
- Personal investment transactions can in no means be executed based on insider information. The compliance officer has the right to research all personal investment transactions of board members.
- The compliance officer has the right to research any transaction, gift and (potential) conflict of interest. The results of this research will be reported to the CEO and, if necessary, the Supervisory Board. Sanctions (from warnings to immediate dismissal) are involved for not complying with the conflict of interest policy.
- The conflict of interest policy, jointly with the code of conduct, have to be reviewed and signed every year by all board members.
SPF Beheer, where all of our transactions and the manager selection is done, also has a conflict of interest policy. For more information, see the transparency report of SPF Beheer.