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The Client Due Diligence (CDD) policy of Bouwfonds REIM in a nutshell

 

To prevent Bouwfonds REIM from entering into a relationship with a party that is involved in activities that may harm its reputation or that can cause other damage, Bouwfonds REIM first conducts a screening of every new potential relationship (investors, suppliers, partners, staff, etc.).

 

CDD at Bouwfonds REIM should minimize the risks that a (potential) relation, this might be a person as well as a legal entity, brings with it.

 

Bouwfonds REIM operates in the field of property-related investments. Geared towards the nature of this business Bouwfonds REIM has made a tailored version of the CDD policy of Rabo Real Estate Group. This policy is applicable for all Bouwfonds REIM entities from 50% ownership onwards. 

 

Consequently Bouwfonds REIM meets, amongst others, the obligations of the Dutch Financial Supervision Act.

 

 

Principles of the CDD policy of Bouwfonds REIM

  • Bouwfonds REIM does not do business with relations that may harm its reputation whether directly or indirectly.
  • Bouwfonds REIM Management is primarily responsible for an effective CDD at Bouwfonds REIM. In cooperation with the Compliance department the Management ensures that the employees reach and maintain the level of knowledge and skills required for CDD.
  • Before entering into a relationship with an external party a relation investigation is conducted. Every new counterparty is put in a temporary risk category based on a risk matrix. Depending on the risk profile of the counterparty in combination with the type of product or service that will be delivered the relation acceptance investigation can be more profound.
  • The execution and coordination of the operational CDD activities is the responsibility of Risk Management department of Bouwfonds REIM. 
  • All information that must be recorded due to statutory or internal rules, are recorded for a period of 5 years after the relation has been ended or the incidental transaction has been performed. 
  • During the time of the relationship a permanent or periodical review of the relation and transactions will take place. 

 


The CDD-proces at Bouwfonds REIM

The CDD proces at Bouwfonds REIM exists of four steps. Hereafter you find a description of this proces.

 

Step 1

Initial risk categorisation of each potential relationship

Based on the initial information of a potential relation, a first temporary risk categorisation of the potential relation is determined. 

 

Step 2

Obligatory relation acceptance measures at Bouwfonds REIM

On the basis of the temporary risk categorisation at Step 1 a number of obligatory relation acceptance measures must be accomplished.

  1. A standardised Business Relation Acceptance Form must be used to record the purpose and nature of the potential relationship.
  2. If the potential relation is a person identification and verification of the identity must take place.For legal entities the Ultimate Beneficial Owner (UBO), the ownership structure and governance must be identified in case an UBO has a stake of 25% or more of equity.
  3. Bouwfonds REIM checks the potential relation and uses internal resources to check whether new counterparties have developed illegal activities in the past; also the authenticity of the identification document is checked.
  4. For relations with their registry abroad, establishing whether the relation is a Politically Exposed Person (PEP) or whether the relation comes from or has its registered offices in a sanctioned or NCCT country.
  5. Bouwfonds REIM checks the reputation of a potential relation via internal and public resources.
  6. If Bouwfonds REIM intends to cooperate with another company then a preceding CDD investigation must be conducted by a department of Rabobank specialized in CDD investigations. This department is also involved if the initial risk categorisation of a potential relation is scaled up to a higher risk category.
  7. Additional for property sellers: property must be checked at land registry that no unusual or unexplained transactions took place in the past two years.
          

Step 3

Definitive classification of the relation in a risk category and the acceptance proces

A definitive classification is made based on the outcome of the relation acceptance investigation and a decision is taken if this relation can be accepted by Bouwfonds REIM.

NB. Relations that are categorised as unacceptable in their risk assessment will not be      accepted by Bouwfonds REIM (and neither by other companies of Rabo Real Estate Group) while existing agreements are to be terminated after due consideration.

 

Step 4

Monitoring the relationship

Business relations are, depending on their definitive risk category, reviewed periodically in order to determine whether their risk profile has been changed and supplementary screening activities are required.