Code of Conduct

The Heineken Pension Fund has drawn up a Code of Conduct on the basis of the model code of conduct of the Federation of Dutch Pension Funds.

Rules and guidelines are included in the Code of Conduct for Board members, staff and other allied persons and insiders of the pension fund. These rules and guidelines relate inter alia to preventing conflicts of interests between the Heineken Pension Fund and private interests and preventing misuse and improper use of confidential information present within the Heineken Pension Fund or obtained from the Heineken Pension Fund.

Integrity risks can be prevented by means of the Code of Conduct. Additionally, the Code of Conduct promotes transparency of the rules of conduct and makes it clear for all persons concerned what is and what is not permitted.

The Heineken Pension Fund also uses this Code of Conduct to coordinate the guarantee of a controlled and sound management within the meaning of the Pensions Act and pension regulations.