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KAS BANK (Delisted)

Service Providers Framework 2020

You are in Strategy and Governance » Policy on ESG beliefs

Policy on ESG beliefs

SG 01. Responsible investment policy

01.1. Describe how your organisation’s philosophy incorporates environmental, social and governance factors, and the link to your business offerings.

We have defined strategic priorities that convey our ambition and core values. The propagation of our strategic priorities helps us with our commitment to enabling prosperity for future generations, we actively monitor these priorities.

This makes them the link to our CSR focus areas. In line with our ambition to make prosperity possible for future generations, our CSR policy is focused on our social contribution.

This means that we see our added value in the relationship we have with our stakeholders and society. Our strategic priorities form our pillars within which we have an effect and in which we have defined the focus areas of our CSR policy.

01.2. Indicate whether you have policies that formalise the incorporation of your ESG beliefs in your business offerings.

01.3. Indicate the components/types of your internal policy and provide the URL and/or an attachment of the document/s if they are publicly available.

Policy components/types

Public availability

Public availability

Public availability

01.4. Indicate how these are put into practice internally across the organisation.

01.5. Additional information [OPTIONAL]


SG 02. Norms used to develop policies

02.1. Indicate what frameworks and guidelines you have used to develop your organisation’s policies. Tick all that apply.

          The Dutch Corporate Governance Code
        

02.2. Additional information. [OPTIONAL]


SG 03. Policy offerings to clients

03.1. Indicate whether you offer standard, off the shelf, policies to clients as part of your product offerings, and/or whether you create tailored versions for individual clients.

Off the shelf
Tailored
Asset class-specific RI guidelines
Sector-specific RI guidelines
Screening/exclusions policy
Engagement policy
(Proxy) voting policy
RI guidelines set out within the Investment Policy Statement (IPS)
RI guidelines set out in a freestanding RI policy
Multi-year RI implementation project plan
Conflict of interest management policy
Stockbroker allocation policy
Securities lending policy
Other, please specify (1)
Other, please specify (2)
Other, please specify (3)
None of the above

03.2. Provide a brief description of the key elements, any variations, or exceptions applying to these policies.

We do not advise clients on their policies. we only provide extensive compliance reporting with tailored investment guidelines.

03.3. Additional information. [OPTIONAL]


SG 04. ESG/RI in business offerings

04.1. Briefly describe how you include ESG/RI factors as part of your business offerings.

Business area

Reporting

How you include ESG/RI factors


KAS BANK offers ESG Screening and compliance monitoring services. This service means that KAS BANK monitors pension funds and investment funds or mandates are adhered to by the fund manager and reports in case of violation of the mandate.

In adittion KAS BANK provides Class Action and Proxy Voting services. KAS BANK offers support in participating in class actions or submitting claims.

04.2. Indicate the roles in your organisation, and indicate for each whether they have oversight and/or implementation responsibilities for ESG/RI within the organisation.

Roles present in your organisation
Oversight/accountability for ESG/RI
Implementation of ESG/RI
Board
Directors
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Chief Operating Officer (COO), Chief Information Officer (CIO)
Other chief-level staff

Please specify

          COO
        
Other heads of department

Please specify

          Managing Directors
        
Dedicated ESG/RI staff
Other role, specify (1)
Other role, specify (2)
Other role, specify (3)
None of the above

04.3. Indicate how you ensure ESG/RI expertise for the roles where there are RI oversight/accountability or implementation responsibilities.

04.4. Indicate whether your organisation has any ESG/RI linked incentives for its employees.

04.7. Additional information [OPTIONAL]


SG 05. Outsourcing of services (Private)


SG 06. Providing training/education

06.1. Indicate whether you provide training/educational services on ESG/RI. Tick all that apply.

06.4. Additional information. [OPTIONAL]


SG 07. Applying, advancing and promoting the PRI principles

07.1. Describe how your organisation applies, advances and promotes the PRI Principles.

Compliance monitoring offers our clients a second opinion on the investment activities of the fund manager. Compliance monitoring is based on the data from Fund Accounting. KAS BANK checks and reports to the client if the fund manager does not act in accordance with the agreed investment guidelines. The Investment Management Services (IMS) department is responsible for compliance monitoring. The client's investment policy and the investment guidelines derived from it for the fund manager are the starting point for the controlling function. In consultation with the client, it is decided what should be checked and reported and at what time. Based on this report, the client can, if desired, set out corrective actions.
In addition, it is agreed whether the fund manager will also be reported.
 

07.2. Highlight whether there are any ways that your organisation would like to engage further with the PRI. [OPTIONAL]


SG 08. Actions taken to promote responsible investment

08.1. Indicate which of the following actions your organisation has taken to promote responsible investments during the reporting year, independently of collaborative initiatives.

08.2. Additional information. [OPTIONAL]


SG 09. Long term trends

09.1. Indicate which of the following long-term trends are addressed in your product outputs.

09.2. Explain how this long-term trend affects your product outputs.

In a rapidly changing world, with increasing uncertainties, building capital resources is an important part of the social foundation. Increasingly, people are taking this responsibility into their own hands and preparing themselves for the increasing individualisation and digitisation of our society. We are the bank that helps them realise their goals with our knowledge and by developing unique and sustainable administrative and banking services and solutions.

09.2. Explain how this long-term trend affects your product outputs.

New technology enables fundamental change. In a society where technology and a growing economy offer us more prosperity, we strive for greater financial security. To achieve this, we build up pension funds, we save money for our children and take out insurance.
We aim for security for both now and in the future. For ourselves and for future generations.


SG 10. Interaction with asset owners (Not Applicable)


SG 11. Aligning approach with investor goals

11.1. Describe how you typically align your organisation’s philosophy and approach to ESG/RI with your investor clients’ goals.

KAS BANK has a responsibility within the financial supply chain. Next to compliance with laws and regulations related to responsible investment, we constantly review our attitude towards companies in which we invest and the low risk profile which KAS BANK pursues to ensure both are balanced.

KAS BANK signed the climate statement. KAS Bank has developed a product for its clients, such as pension funds, that shows daily whether their investments comply with the UN Global Compact Principles, the list of guidelines drawn up by the United Nations in the areas of human rights, labour, the environment and the fight against corruption. This allows customers to better implement their sustainability policy.

11.2. Additional information. [OPTIONAL]


SG 12. ESG recommendations not aligned with investor goals

12.1. Describe what steps you take, if any, when your ESG recommendations are not in line with your investor clients’ goals.

12.2. Additional information. [OPTIONAL]


SG 13. Seeking feedback from clients

13.1. Indicate whether you seek feedback from clients on your RI/ESG services and product offerings

13.2. Describe how you use this feedback in your RI/ESG services and product offerings.

We ask our clients for feedback on all our product offerings in client service reviews.


SG 14. Managing conflicts of interest

14.1. Indicate whether your organisation has a policy for managing potential conflicts of interest.

14.2. Describe how you manage potential conflicts of interest.

Firstly, conflicts of interest should be avoided where possible. Conflicts of interest which may not be avoided, should be managed appropriately. KAS BANK has adopted several measures designed to prevent conflicts of interest from adversely affecting the interests of the client:

• the administrative organisation and organisational arrangements ensure a sufficient degree of independence between the different services and activities exercised by the Bank;
• policies and procedures are in place to manage potential conflicts of interest; these policies and procedures are maintained on a regular basis and compliance is monitored;
• fees or commissions from third parties in relation to (investment) services to the client are only allowed if these have been clearly disclosed to the client beforehand and if the fee or commission enhances the quality of the relevant service and does not impair compliance with the Bank’s duty to act in the best interest of the client;
• all employees of KAS BANK are subject to internal rules for treatment of price sensitive and other confidential information;
• all employees of KAS BANK are subject to rules of conduct with respect to personal account dealing; in addition, a restricted list is applicable and all personal account transactions should be reported;
• all employees are subject to rules of conduct with respect to accepting and offering gifts and invitations for entertainment. The receipt of gifts and invitations should be reported. The receipt of gifts should be limited to gifts where the commercial value is small;
• additional activities and functions of employees (not part of their employment with KAS BANK) are subject to restrictions; specific functions are subject to prior written approval of the managing board.

14.3. Describe how you ensure that company employees do not derive any personal gain from the use of information collected during your work process.

Firstly, conflicts of interest should be avoided where possible. Conflicts of interest which may not be avoided, should be managed appropriately. KAS BANK has adopted several measures designed to prevent conflicts of interest from adversely affecting the interests of the client:

• the administrative organisation and organisational arrangements ensure a sufficient degree of independence between the different services and activities exercised by the Bank;
• policies and procedures are in place to manage potential conflicts of interest; these policies and procedures are maintained on a regular basis and compliance is monitored;
• fees or commissions from third parties in relation to (investment) services to the client are only allowed if these have been clearly disclosed to the client beforehand and if the fee or commission enhances the quality of the relevant service and does not impair compliance with the Bank’s duty to act in the best interest of the client;
• all employees of KAS BANK are subject to internal rules for treatment of price sensitive and other confidential information;
• all employees of KAS BANK are subject to rules of conduct with respect to personal account dealing; in addition, a restricted list is applicable and all personal account transactions should be reported;
• all employees are subject to rules of conduct with respect to accepting and offering gifts and invitations for entertainment. The receipt of gifts and invitations should be reported. The receipt of gifts should be limited to gifts where the commercial value is small;
• additional activities and functions of employees (not part of their employment with KAS BANK) are subject to restrictions; specific functions are subject to prior written approval of the managing board.

14.4. Additional information. [OPTIONAL]


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