<Focus on sustainability <Employees <Products and services <Society <Ecological impact Ethics and integrity
In the areas of ethics and integrity, Argenta continues on an unchanged path. Honest sales methods and a no-nonsense culture remain extremely important for Argenta. Argenta is aware of the importance of promoting and safeguarding integrity in all areas The Integrity Charter also forms the official basis for Argenta's banking and insurance policy and serves as a guideline for actions and decision-making in Argenta. Integrity implies loyalty to the generally accepted standards in the banking and insurance sector, but also to the company purpose and specific company values: close to customers, enterprising, pragmatic and simple.
Focus values and purpose
In an unpredictable world, Argenta’s raison d’être consists in doing something that is exceptional in the financial sector: taking care of its customers and employees in a responsible manner. This raison d'être was made explicit in 2021 in Argenta’s purpose and works through into the field of ethics and integrity. To stimulate the desired behaviour among employees, the 'DOPE' programme was introduced in 2018. The word 'DOPE' comes from the initial letters, in Dutch, of the focus values that all employees actively bear in mind in their daily work. These are:
CLOSE TO EACH OTHER
All employees respect each other's opinions, share knowledge and experiences, are honest with each other and enter into long-term relationships in which there is no room for self-interest. On top of this comes constant attention to the customer, to ensure excellent service provision.
ENTERPRISING
Employees undertake the initiative themselves to achieve the set goals and, when they detect opportunities somewhere, go for them.
PRAGMATIC
Argenta staff members go straight to the target, without detours. A good solution does not have to be unnecessarily difficult.
SIMPLE
Communication with each other is clear and focused on essentials. Simple solutions should be sought that do not complicate matters unnecessarily.
Integrity Charter
Having a good corporate governance framework significantly strengthens the commitment and dedication of all Argenta employees. For this reason, in addition to the strategic objectives, the Board of Directors also defines Argenta's integrity policy and the internal codes of conduct or formal rules. These define how the company acts in a spirit of integrity and of commitment towards all Argenta stakeholders. These values and codes of conduct are communicated and promoted within Argenta.
This framework is laid down in the 'Integrity Charter'. This sets out Argenta's own focus values and purpose, but also ethical standards for ensuring the integrity of the banking and insurance sector. In addition to value-conscious and ethical responsible conduct by Argenta, it is also important that employees safeguard their personal integrity. Given its model role, it is essential that management imposes strict rules of conduct on itself and sets a good example ('tone at the top').
The ethical standards for the integrity of the banking and insurance sector outlined in the Integrity Charter are elaborated in greater detail in thematic policies. In 2021, the Integrity charter, the Inducements11 policy and the AML/CFT2, Customer Acceptance and Sanctions & Embargoes policy were updated. In addition, a Duties of Care policy has been drawn up, which contains the most important integrity and conduct rules in the field of consumer protection for the various products.
1 Specific rules regarding the receipt and payment of commissions, fees and other monetary or non-monetary benefits 2 Anti-money laundering / Combating the financing of terrorism
To ensure that everyone is attentive to the ethical standards at all times, Argenta organises integrity training sessions. In addition, every employee receives periodic, digital updates of the most important standards and of new rules and risks. In addition to the usual checks at the time of recruitment, Argenta permanently verifies its employees' compliance with the internal, legal and regulatory provisions relating to integrity and conduct.
Transparency is essential to promoting integrity. Argenta therefore has an open organisational culture in which employees feel free and safe to point to practices that violate integrity or to express appreciation of good examples with a compliment. Everyone is expected to give feedback and be open to receiving it. Anyone encountering a breach of business ethics is expected to report it, regardless of whether the breach was committed by the employee himself, a customer, another employee or an external party.
A whistle-blowing rule ensures that (attempts at) illegal, immoral or non-legitimate practices that are under Argenta's control come to light. Employees are provided with a channel to report perceptions or observations of (what appear to be) irregularities within the company without having to must follow the hierarchical path. The anonymity of the whistle-blower is always guaranteed. No incident was reported in this way in 2021.
Compliance
The Compliance department plays an important role in the enforcement of Argenta policy. It plays a coordinating and initiating role in implementing the integrity policy, reporting on this to the Argenta Bank- en Verzekeringsgroep Executive Committee and Board of Directors. It fulfils this role both by assisting other departments with information and advice (frame), and by checking compliance with the integrity policy.
In order to increase risk awareness within the organisation and to offer assurance to all relevant stakeholders that risks are demonstrably under control, Argenta has developed an integrated, i.e. institution-wide, risk management framework. This is also applied for the compliance risks.
In order to apply this as effectively as possible, the department consists of (i) a separate team set up to combat money laundering and terrorist financing, under the anti-money laundering compliance officer (AMLCO), (ii) a team that provides advice to the operational departments, (iii) a team that audits the operating departments, and (iv) a data protection officer (DPO) who ensures that the privacy of customers and employees is respected. The mandate and organisation of the Compliance Department is laid down at the highest level in a Compliance Charter.
Notification of complaints
Argenta offers its customers the opportunity to report complaints. In 2021 the handling time for complaints averaged 5.5 working days. The number of complaints in 2021 increased by 6.3% compared to 2020. This increase was strongest in the first half of 2021 following the introduction of packages. In the third quarter, the number of files was comparable to the complaints figure in 2020. During the fourth quarter, we recorded 25% fewer complaints than in the same period of 2020 owing to an increased number of complaints in the fourth quarter of 2020 related to phishing and packages.
Anyone who is not satisfied with the efforts of the Argenta Complaints Management service is free to contact the Ombudsman (the Banking - Credits - Investments mediation service) or the Insurance Ombudsman. Argenta Spaarbank is a member of Ombundsfin, the financial ombudsman system, while Argenta Assuranties is a member of the Insurance Ombudsman service.
Risk management
The risk management framework is constantly updated and adjusted based on new regulations, evolving market standards, daily experience and changes in Argenta's activities, including changes resulting from sustainable choices made by Argenta (and which always tie in with Argenta's activities as a bank, insurer and asset manager). Demonstrating that adequate risk management procedures are in place is a key condition for acquiring and retaining the trust of all stakeholders: customers, investors, branch managers, supervisory authorities and rating agencies, as well as directors, management and employees.
The dynamics of the financial world, in particular with respect to climate risk and sustainability policy, demand a permanent, proactive development of the risk management process. Risk management consists of exercising control of risks, comprising the cycle of identifying, evaluating, managing and monitoring risks to which Argenta or one of the Argenta entities can be exposed.
To increase risk awareness within the organisation, Argenta has developed its integrated, i.e. institution-wide, risk management policy.
The Integrated Risk Management policy defines the entire spectrum of of building blocks, practices and processes according to which Argenta applies its company-wide risk management model.
Professional risk management with an eye for all possible risks is an essential condition for achieving sustainable, profitable growth. The Argenta group recognises this and sees risk management as one of its core activities.
In 2021, Argenta started implementing the ECB guide on climate related and environmental risks by defining an ambitious roadmap based on a self-assessment that aims to implement the 13 principles proposed by the regulator. The roadmap includes projects that will be rolled out in 2021-2022 involving climate strategy, governance, risk management and disclosure reporting.
In terms of risk management, Argenta strives to appropriately and proactively manage the climate and sustainability risks associated with its risks and activities with a view to responsibly achieving the business objectives of the various business lines, in accordance with Argenta's sustainability policy and purpose. In this way, climate and sustainability risks are monitored within the home loan, investment and insurance portfolios, and within the wholesale funding and the asset management activities. In addition, the calculation of climate risk stress tests (within Pillar 2) provides insight into the impact of transition and physical climate risks on the realisation of the business strategy of the banking and insurance activities. Argenta has also started preparing for the ECB climate risk stress tests, planned for the first half of 2022.
Climate and sustainability risks are thus an integral part of the company-wide risk management framework with, in 2021, a clarification of the operation of the three Lines of Defence, the appointment of the Chief Sustainability Officer, the formalisation of the Sustainability Committee, the Investment Exclusion Committee and the embedding of climate and sustainability risks in the governance of the regular committees. Climate risk will continue to be identified as a 'hot spot' risk in 2022. This means that the existing framework will be further expanded in 2022 with a focus on the realisation of the ECB's implementation plan on climate risk and this within Argenta’s own sustainability action plan, in close consultation with the Board of Directors and the supervisor(s).
