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ESGBERT 25

ESG Environment, social and governance factors are increasingly important to the Company's stakeholders.

We need to be aware of these risks and, where we cannot eliminate them, mitigate them using appropriate internal controls and procedures.

We are committed to a zero tolerance policy for unethical conduct.

Our suppliers' activities support our overall business strategy and are in compliance with our Corporate Responsibility policy.

The Group continues to pay particular attention to reducing its impact on the environment and is committed to the principles of sustainable development.

We have a number of initiatives in place to promote diversity and inclusion within the business, including an emphasis on gender balance within our programme.

The Group encourages its employees to engage in voluntary work for associations or for the benefit of the community.

In 2011, we were certified as an A-rated employer by the Ethical Trading Initiative in recognition of our commitment to ethical principles in our employment practices.

The Company has an interest in ensuring the protection of the environment in which it operates.

In addition, the Company has substantially reduced its carbon emissions and taken a number of steps to promote a sustainable future.

We are committed to supporting the communities in which we operate and in which our employees live and work.

While the content of the code is ultimately a matter for the board itself, the board will want to ensure that the code is being applied in a transparent and consistent way.

Each plan has a different set of eligibility criteria and benefits that varies significantly from the other plans.

The Company's environmental policy is to comply with all applicable laws and regulations, and to continuously improve our environmental performance by reducing the environmental impact of our activities and increasing the use of renewable and recycled products.

The Group has a policy to reward employees for outstanding performance.

The Group has a policy of zero tolerance towards bribery and corruption and of compliance with all applicable laws and regulations, including the UK Bribery Act 2010. We also have a comprehensive whistleblowing policy.

For this reason, the Company has adopted a policy for the preparation of management accounts which conforms to the IFRS.

The Board has considered the report of the Audit Committee on the financial reporting and internal control systems of the Company.

We have fulfilled our ethical responsibilities under, and we remain independent of the Company in accordance with, UK ethical requirements including the FRC Ethical Standard as applied to public interest entities.

We are committed to a responsible and sustainable palm oil policy, in line with the RSPO Principles and Criteria.

As part of our commitment to corporate governance we have a high level of internal audit coverage.

We have a diverse team of 11,000 employees around the world, of whom 66% are women, and we are committed to attracting, developing and retaining the best talent.

The Group's culture is based on a set of values that underlie our business strategy, as well as the way we do business.

The inclusion of an equivalent indicator of value at the portfolio level would benefit investors interested in long-term performance.

The Group is committed to investing in its people and we aim to provide an inclusive, engaging and rewarding work environment, where people are enabled to maximize their potential.

The Group strives to maintain good relations with its suppliers and to be aware of their environmental and social performance.

For the year ended 31 December 2010, we paid out €8.4m in the form of dividends to our shareholders.

A regular governance process provides for regular interaction to identify changes in the client's desired outcomes and solicits feedback on the actual outcomes experienced by the client.

The Company has a commitment to the protection of the environment and is involved in various environmental activities.

The success of our global sourcing strategy and the key role played by our suppliers in ensuring that our products meet our quality and sustainability standards and our values of respect, care and honesty.

We are committed to creating a successful, sustainable business that is economically, socially and environmentally conscious.

The Diversity and Inclusion (D&I) function has now become a key component of the company's culture and is embedded into the strategic framework of the company.

The Company has a Code of Conduct and a whistleblowing policy, the details of which are available on the Company's website.

We will concentrate our efforts on improving our processes around the assessment and approval of all projects, and to ensure that appropriate, timely and effective action is taken to address all high, medium and low risks we identify.

The responsibility for the Group's business activities rests with the management.

Emissions from the UK House are predominantly from electricity use, transport and food waste.

The Board's commitment to the sustainable development of the Group is underpinned by strategic and operational risk management.

For the year ended 31 December 2018, the Group's total operating profit before tax was $1,281 million, an increase of $138 million (12.1%) on the prior year.

The company has a comprehensive and effective whistleblowing policy which is prominently displayed throughout the Company's global offices.

A key component of our social and corporate responsibility strategy is to provide financial and non-financial support and to encourage community involvement in the areas of our properties in which we operate.

The Board has adopted a formal governance and risk management statement, which is reviewed annually.

The Board of Directors is composed of 10 Directors and 1 alternate Director.

The Board will continue to monitor the Company's overall compliance with the Code and, where necessary, recommend that the Company makes appropriate changes to its policies, procedures and practices.

The Board considers that the Group's corporate governance structure and processes are in line with good practice, designed to promote effective and efficient decision-making and aligned with the regulatory framework.

Our portfolio companies are also required to appoint a chief compliance officer and a board committee to oversee the reporting of conflicts of interest.

The Company is committed to achieving a diverse and inclusive workforce and is vigilant in implementing its policies and practices to prevent discrimination of any kind.

SASB The Sustainability Accounting Standards Board is an ESG guidance framework that sets standards for the disclosure of financially material sustainability information by companies to their investors.

The Board is committed to maintaining the highest standards of corporate governance and has adopted a Code of Business Conduct.

The Company considers that, as a general rule, it is important that the Directors and senior management should own, directly or indirectly, shares in the Company.

The social policy package included a reduction in the statutory minimum wage.

The Board of Directors is responsible for Risk Management at the Company.

The firm has a team of experienced lawyers who concentrate on the following core areas of the law: Corporate and Commercial, Dispute Resolution, Employment, Financial Services and Real Estate.

The Company is committed to operating in compliance with the requirements of all the Environmental and Health and Safety laws and regulations in the countries where it operates.

We have not identified any issues that require disclosure under the current Dutch Corporate Governance Code.

The Board is currently considering the merits of establishing a Gender Pay Gap reporting regime.

The Company takes all reasonable steps to ensure that the Company, its subsidiaries and its business operations do not cause damage to the environment.

The Company will maintain a flexible approach to share incentives, and to encourage significant employee ownership.

A number of Group-wide policies and procedures are in place to monitor and control conflicts of interest, including a conflicts of interest policy for the Board of Directors.

The level of remuneration payable to directors shall be sufficient to attract and retain individuals who are able to make a positive contribution to the performance of the Company.

In 2012, the Group achieved a strong environmental performance in terms of the management of its risks and its environmental impacts.

The Company is committed to respecting the environment and is working to reduce its impact on the environment.

Measures have been introduced to improve the transparency of the remuneration of directors and executives and to strengthen the governance, corporate social responsibility and risk management function.

The Board of Directors, acting through the Audit Committee, monitors compliance by the Company's Internal Audit function with the Group Code of Conduct and Ethics, which includes a zero tolerance policy on fraud and corruption.

The group offers a diverse range of products and services to its customers, including retirement, investment and protection products, general insurance, life assurance, mortgages and savings.

The Company is committed to sustainable development and to conducting its business in an ethical manner.

The risk management process is intended to provide an integrated and consistent approach to managing and controlling business, market, credit, liquidity, legal, operational and strategic risk.

We have set in place an effective process for establishing procedures and systems to ensure compliance with relevant laws and regulations.

The Company has also established a register of any shareholder who has notified the Company of an interest in owning or disposing of 5% or more of the Company's issued share capital.

But the company was recently honored for its corporate social responsibility efforts, winning the 2013 Corporate Responsibility Award for its “relentless commitment to excellence in delivering social and environmental value.”

We have a dedicated team who manage a portfolio of relationships with key suppliers in order to gain better understanding of their business models and sustainability practices.

The company's approach to Corporate Social Responsibility ("CSR") is integrated into the development of its strategy, the activities of its operating divisions and its corporate structure.

We have always sought to conduct our business in a socially responsible manner and we are committed to acting ethically and responsibly for our shareholders, colleagues, customers, suppliers, communities and the environment.

The Group's business activities are conducted in a manner consistent with the Group's Core Values, which are integral to the Group's culture.

The Board of Directors is responsible for the Company's activities and controls and is accountable to the shareholders.

Regulatory environment The Company is subject to various European Union and United States laws and regulations, including those relating to the protection of human subjects and the environment.

The members of the audit and risk committee shall have appropriate technical knowledge and experience, and should have knowledge of the company's business model, products and services. They should have a sound knowledge of the financial markets.

We are committed to increasing the percentage of profits invested in social purpose activities.

The Company's Board of Directors approves the annual budget, the annual work program and the financing plan, which are submitted to the General Shareholders' Meeting for approval.

In addition, the group will seek to be good corporate neighbours and will work with our neighbours and the local community to pursue our shared goals.

The Board is responsible for ensuring that the Group's systems and controls are designed and maintained to ensure that its policies and procedures are implemented effectively.

The Group has now been awarded the European Foundation for Quality Management (EFQM) Excellence Award for the fifth time since 2007.

The Company's social policy is fully aligned with the Group's overall strategy, goals and processes.

The Group's aim is to reach a carbon-neutral status by 2025.

The first step in this process is to develop a better understanding of the business and its various contexts, followed by a process to identify risks and opportunities.

Our Company and its subsidiaries are largely self-insured.

Environmental protection is a fundamental part of the Group's responsibility.

It is working with a range of stakeholders to improve the social and environmental impact of its supply chain.

In order to reduce the impact of climate change, we are continually improving the efficiency of our operations.

Our sustainability strategy is embedded in our business practices, policies and decision-making.

The Group identifies a large number of risks, including those that could have a significant impact on the Group¹s ability to achieve the objectives set for it.

Our firm's investment process is firmly rooted in fiduciary duty, and is informed by the fiduciary duty principles of prudence, loyalty and due care, as well as the duty of disclosure.

The company has been a member of the Roundtable on Sustainable Palm Oil (RSPO) since 2009.

The Board has adopted the proposed code of conduct and code of ethics for the members of the Board of Directors.

The Group has developed a corporate governance code which is distributed to all Group employees.

Moreover, the Board's responsibilities as a fiduciary to the Company, its Shareholders and beneficiaries and the wider community are paramount.

The Directors believe that the Company's success depends upon the efforts of all of its employees, and as such, has established a number of initiatives to support its people strategy.

The Company is a member of the National Association of Corporate Directors (NACD) and has participated in their Director Education Program for more than 5 years.

We are committed to improving the way we work, and to reducing our environmental impact.

The Company also has a Code of Conduct that states that employees shall not commit any act of bribery or corruption.

The Company is committed to complying with all applicable laws, regulations and codes of practice, including those relating to the environment, health and safety and social responsibility.