Code of Conduct
Vesteda’s strategy is focused on the growth of our portfolio and improving its performance, resulting in increased returns and liquidity for its participants, together with satisfied tenants. To achieve our ambitions, we focus in our daily operations on cooperation, professionalism and an entrepreneurial spirit. We strive for continuous improvement, as we wish to distinguish ourselves from our competitors and demonstrate our added value to our participants and tenants. Achieving results is important, but the manner in which those results are achieved is just as important.
While we trust our employees will adhere to our values and principles, Vesteda has laid down principles and guidelines as a framework for acting in a careful, diligent and ethical manner. These principles and guidelines are set out in Vesteda’s Code of Conduct (the Code). The Code lays down rules on how we expect employees to interact with each other, how they should act in the event of conflicts of interest, how they should interact with third parties and how they should handle Vesteda’s property and confidential information. As a member of the Dutch Association of Institutional Investors in Real Estate (IVBN), Vesteda has used the IVBN’s sample code of conduct as a basis for its own Code.
Vesteda is aware that merely having a Code will not prevent unethical behaviour. Therefore, it encourages its employees to adhere to the Code on the basis of their own conviction that this is the right thing to do. Furthermore, Vesteda expects employees to set the right example and to confront each other with respect to undesired behaviour, if conditions permit. Managers are expected to register, intervene and take action. The overriding principle is: you can make mistakes, as long as you have adhered to the rules of conduct that we have laid down.
Each year, Vesteda employees are sent a request to reaffirm that they comply with the Code and to confirm their awareness of the whistle blower procedure as described below.
Reporting by employees
Employees are obliged to report any intentional or unintentional unethical behaviour to Vesteda’s Compliance Officer. If the employee in question does not do so him/herself, other employees who have knowledge of the incident are expected to report to the Compliance Officer. Other matters that need to be reported include: potential conflicts of interest, acceptance of corporate gifts, and invitations to events abroad. Any report to the Compliance Officer will be included in a confidential register. No material incidents were reported in 2017.
Counsellors are available to employees who are the victim of undesirable behaviour, such as (sexual) intimidation, aggression or violence, bullying, etc. The counsellors offer a safe place to discuss an incident and, when necessary, can refer an employee to external professional agencies. Counsellors are subject to a duty of confidentiality and will not share information without the employee’s consent.
To avoid incidents not being reported, employees should be able to rely on the fact that a report is treated in a confidential manner and with the utmost care. In view of this, Vesteda has a whistle blower policy in place, which sets out who to report to, what happens with a report (management escalation) and how persons involved are expected to act. To facilitate reporting, Vesteda introduced Speakup, which facilitates anonymous reporting, by phone or email, via a third party. Any Speakup report will be sent to the Compliance Officer, who is in charge of handling the incident, together with the Internal Auditor.
In view of the AIFMD license, Vesteda has an extensive integrity policy in place to address issues such as Corporate Due Diligence (CDD) and pre-screening of employees. Whenever it is deemed necessary under the policy, a CDD report is requested from an external professional party, which provides insight into potential integrity issues on the part of a potential business partner. During the course of 2017, Vesteda received various CDD reports. None of these provided any reason for Vesteda to not enter into a business relationship with a third party.
Reporting by the Compliance Officer
The Compliance Officer keeps a register of reports under the Code. The Compliance Officer reports to the Managing Board and periodically to the Audit Committee. No material incidents were reported in the year under review and as a result, no material sanctions were received.