Integrity and ethical conduct are prerequisites to be a trustworthy company. Ethical awareness is strengthened within a.s.r. by the promotion of core values and ethical leadership, providing ethical training, embedding sound integrity policies and implementing ethical frameworks for specific business processes.

Code of Conduct and the oath or solemn affirmation

a.s.r.'s Code of Conduct is a guideline for actions and decisions and helps the company to fulfil its duties properly, with care and integrity. It also provides clear guidelines for how employees interact with each other, how a.s.r. serves its customers and how a.s.r. takes its responsibility for the environment in which it operates. The a.s.r. Code of Conduct applies to anyone who works for a.s.r., whether on a regular basis or not. a.s.r. expects everyone to observe the Code of Conduct and to hold each other to account for compliance with its stipulations. The a.s.r. Code of Conduct can be found at www.asrnl.com.

When starting employment at a.s.r., every employee, including temporary and external employees, must take an oath or make a solemn affirmation. This demonstrates that they accept and comply with the rules of conduct, and observe ethical principles in their actions.

Unethical behaviour

In order to guarantee sound and controlled business operations, a.s.r. has taken a number of control measures to prevent, identify and address unethical behaviour, including addressing corruption. Examples of control measures include integrity screening carried out by the investigations department prior to hiring new employees and in-employment screening. This integrity screening also extends to contracting parties. With these measures, a.s.r. seeks to prevent the risk of physical, financial or reputational damage to the company, its customers and/or business partners and other stakeholders. To complement this, a.s.r. has taken measures such as monitoring and stimulating awareness throughout the business with respect to conflicts of interest.

a.s.r. believes it is important that incidents are reported and that this can be done safely and with due care. a.s.r. has an internal reporting route for integrity incidents (included in the Code of Conduct) and a whistleblower scheme. See section 6.3.1.

a.s.r. has a policy on controlling unethical behaviour at group and business levels. a.s.r. investigates signs of unethical behaviour, including corruption and fraud, among employees, intermediaries, mandated brokers and suppliers. a.s.r. has a zero tolerance policy. Should integrity be compromised, for example through corruption and/or fraud, a.s.r. will take appropriate measures, with due regard for the applicable legislation and regulations-, and sector-based protocols. The risk of corruption is addressed in various policies, such as a.s.r.’s incentive policy and its anti-corruption policy. The latter also prohibits political contributions and charitable donations that may serve as means of bribery and corruption. Both policies are approved by the Management Board. a.s.r. uses the definition formulated by the DNB: ‘The risk of corruption is the risk of financial companies in the Netherlands being involved in bribery and/or conflicts of interest which impair the integrity of, and trust in, that company or in the financial markets’. By performing systematic integrity risk analyses (SIRA’s), a.s.r. maps integrity risks and determines which additional control measures must be taken if any risks fall outside the risk appetite. The SIRA contributes to the detection and prevention of involvement with violations of legislation and regulations or other socially or ethically undesirable acts. The fraud and corruption risks are part of the SIRA.

In 2024, 65 cases of alleged lack of integrity, including violation of the privacy policy, were investigated by the investigations department (2023: 86). 27 disciplinary measures (2023: 23) were taken in cases of proven lack of integrity in the conduct of an employee, intermediary or supplier. With respect to employee conduct, 16 employees were found to have violated the a.s.r. Code of Conduct. Following investigation, a lack of integrity – for example inappropriate conduct or behaviour – was proven. These employees were disciplined for the infringement of the company’s principles. This resulted in addressing the undesirable behaviour, a written warning or dismissal. The investigations department reports quarterly on the number of incidents and the measures taken. Where necessary, a.s.r. will take appropriate measures as described in the Code of Conduct.