„      Abiding by laws, rules and regulations (including insider trading laws) as well as the internal policies of Bouwfonds Real Estate Investment Managment and Rabo Real Estate Group.

„      Being familiar with guidelines, manuals and emerging best business practices relevant to their duties and implementing them conscientiously to the best of their abilities.

„      Acting at all times in good faith, responsibly, with due care, competence and diligence, and without any misrepresentation of material facts.

„      Acting at all times in an honest and ethical way, including the ethical handling of actual or apparent conflicts of interests.

„      Acting objectively, without allowing his or her judgment to be subordinated.


Investment Research
Investment research is material that generally contains either:

„      Analysis of factors likely to influence the future performance of an investment or issuers; or

„      Advice or recommendations based on those results or that analysis.It is substantive analysis that incorporates the critical and careful consideration and assessment of new and existing facts. Any material containing substantive analysis into investments or issuers is likely to be viewed by Bouwfonds Real Estate Investment Management B.V. as investment research.

Bouwfonds Real Estate Investment Management’s policy is only to publish investment research that is impartial, independent, clear, fair and not misleading. Such research may be produced and published only by employees of the Research & Investment Strategy department (“Bouwfonds REIM Research”).

„      The views expressed in the report accurately reflect their personal views about any and all of the investments or issuers to which the report relates; and

„      No part of the Analyst’s remuneration was, is or will be directly or indirectly related to the specific recommendations or views expressed in the report.

„      The provision of internal guidance and training on the identification of possible issues of conflict as and when they arise;

„      Escalation procedures for ensuring that issues identified are referred to and considered at the appropriate level within the Firm, and on use of and reducing the risk of inappropriate exercise of influence;

„      Bouwfonds Real Estate Investment Management’s Risk Management department monitors potential conflicts arising out of the publication of research in the period before, during and after Investment Banking transactions;

„      Internal guidance and arrangements for regulating the flow of information between and within business areas. These include locating Analysts separately from Investment Banking transactions, Capital Markets and Sales and Trading employees; requiring that any research report is produced in an area away from the Investment Banking transactions, Capital Markets or Sales and Trading businesses and having arrangements, including “Chinese Walls” and other information barriers, to stop and control the flow of information between the Bouwfonds REIM Research and other parts of the business;

„      Editorial guidelines and procedures for supervisory review of research prior to publication; and

„      Limiting the production and publication of investment research to employees of the Research & Investment Strategy Department and only allowing the publication of investment research that is impartial.

„      The Analyst’s individual performance and productivity;

„      The overall quality and accuracy of the Analyst’s research;

„      Evaluations by investor clients and employees in other parts of Bouwfonds Real Estate Investment Management with whom the Analyst interacts, excluding employees from Investment Banking or Capital Markets transactions;

„      The size and trading value of, the profitability of, and the potential interest of Bouwfonds Real Estate Investment Management’s investor clients in Research; and

„      Bouwfonds Real Estate Investment Management’s overall performance, which may include, in part, the profitability of Investment Banking and Capital Markets transactions as well as the profitability of Rabo Real Estate Group.

„     
Economics & Forex Research
Economics & Forex research is classified as secondary research

Methodology
Based on a quantitative and qualitative assessment of real economy and monetary indicators, economics & forex research derives macroeconomic forecasts such as GDP, population and inflation trends. This fundamental macroeconomic view also serves as a basis for its interest rate and yield forecasts, which are backed both by long-term and short-term quantitative models from our main suppliers. Our main suppliers for economics & forex research are Experian Business Strategies, Bloomberg, Michael Bauer Research, Consensus Economics, and Rabobank.

Markets covered
Economics & Forex research follows the most important financial markets. In this regard, the analysis covers the global markets in general and European and USA markets in particular.

The investment recommendations given by economics & forex research are based upon a structured forecasting process, which encompasses regular - and if necessary, ad hoc - meetings to review the forecasts. The recommendations are regularly communicated.

„      Real Estate Research
Real Estate research is classified as secondary research

Methodology
The research is based on the regular assessment of fundamental data and market expectations. The analysis is quantitative, partially underpinned by models, and takes into account additional qualitative factors such as assumptions for future monetary policy decisions by central banks.

The sector and country weightings are derived by means of a top-down approach. The relative attractiveness is ascertained from macroeconomic forecasts (e.g., expectations for growth, interest rates and exchange rates), various valuation methodologies, and from technical indicators (e.g., fund inflows, cash positions). At the stock level, the selection takes into account the relative attractiveness of individual shares versus the sector, market position, growth prospects, balance-sheet structure and valuation.

The applied valuation methodology comprises dividenddiscount models, tactical sector-rotation models based on earnings and price momentum, and discounted cash flow models (DCF), as well as traditional valuation multiples such as price/earnings, EV/EBITDA, price/book value, etc.

Markets covered
Real Estate research covers most European and USA residential markets in general and the Dutch, German, French and Belgian residential markets in particular. For commercial real estate real estate research covers the Dutch, German, French and Belgian commercial real estate markets.

The investment recommendations given by real estate research are based upon a structured forecasting process, which encompasses regular - and if necessary, ad hoc - meetings to review the forecasts. The recommendations are regularly communicated.

„      Real Assets
Real Assets research is classified as secondary research

Methodology
The research is based on the regular assessment of fundamental data and market expectations. The analysis is as quantitative as possible but is heavily depended on qualitative factors since lack of reliable data series.

The sector and country weightings are derived by means of a combination of top-down and bottom-up approach. The relative attractiveness is ascertained from macroeconomic forecasts (e.g., expectations for growth, interest rates and exchange rates), various valuation methodologies, and from technical indicators (e.g., fund inflows, cash positions).

Markets covered
Real Assets research is active globally, especially on Land markets. For other categories the focus is mainly on the Netherlands.

The investment recommendations given by real assets research are based upon a structured forecasting process, which encompasses regular - and if necessary, ad hoc - meetings to review the forecasts. The recommendations are regularly communicated.

„      An explanation of the meaning of the Firm's ratings; information relating to the valuation methods used by the Firm; the percentage of securities on which the Firm has a rating of outperform, neutral or underperform; and a chart depicting the share price of the companies referred in research reports over time and the points at which the Firm assigned or changed a rating or price target;

„      Whether Bouwfonds Real Estate Investment Management B.V. holds 1% or more of the securities of companies referred to in research reports;

„      Whether Bouwfonds Real Estate Investment Management B.V. has significant holdings in the securities of companies referred in research reports;

„      Whether companies referred in research reports hold more than 5% in Rabo Vastgoed Group Holding N.V.;

„      Whether research has been sent to any of the companies referred in research reports for fact checking and whether it has been changed as a result;

„      Whether Bouwfonds Real Estate Investment Management B.V. acts as a market maker in the securities of companies referred to in research reports;

„      Information regarding any directorships or other material relationships of individual officers of Bouwfonds Real Estate Investment Management B.V. with companies referred to in research reports;

„      Any personal interest of the Analyst or close relations of the Analyst in securities of companies referred to in research reports;

„      Past significant relationships of Bouwfonds Real Estate Investment Management B.V. with companies referred to in research reports, including Investment Banking or other advisory assignments or relationships;

„      Subject to legal and confidentiality constraints on disclosure, current or prospective relationships between Bouwfonds Real Estate Investment Management B.V. and companies referred to in research reports, or the fact that such relationships may exist; and

„      The organisational and administrative arrangements for the prevention of conflicts of interest.
The following policies apply to all Analysts with regard to personal account dealing and outside business activities:

„      Analysts are generally prohibited from trading in any securities, loans, derivatives or other instruments of companies (and their affiliates) in their coverage industry globally, whether or not they currently provide research coverage of the company;

„      Analysts are required to comply with Bouwfonds Real Estate Investment Management’s rules on personal account dealing, which include the requirement to pre-clear any proposed dealings with Compliance and/or Research senior management;

„      Analysts are prohibited from serving as an officer, director or member of a supervisory board of any publicly quoted company;

„      Analysts are required to comply with Bouwfonds Real Estate Investment Management’s rules on outside business activities, which will require approval from Research senior management and Compliance.