Dutch Banking Code

Dutch Banking Code

The Banking Code was introduced on 1 January 2010 and applies to all banks in the Netherlands. The Code consists of principles that stipulate how Dutch banks should ensure ethical business operations and treat the interests of all stakeholders. The Banking Code contains principles relating to corporate governance, risk management, audits and remuneration that banks need to comply with.

On 1 January 2015, the Banking Code was updated as part of the 'Future-oriented banking' package. The revised Banking Code, the Social Charter and the implementation of the bank-wide bankers' oath (and consequently the rules relating to conduct and ethics), which apply to all employees of Dutch financial institutions, emphasise the role that banks play in society and encourage them to fulfil the expectations of society.

Read how the Banking Code* is applied at InsingerGilissen here (in Dutch).

Remuneration policy

InsingerGilissen drew up a new remuneration policy in 2018. This policy fits within the parameters of the Quintet Group Remuneration Policy. The Performance Management process over Performance Year 2018 was conducted based on this policy. In addition, the bank made sure that this process is in line with applicable laws and legislation.

This approach enables InsingerGilissen to apply a transparent remuneration policy that also ensures that the interests of both clients and the bank are served. The policy reflects the strategy, objectives, values and long-term interests of the bank and eliminates any conflicts of interest. It contributes to effective risk management and prevents risks being taken that would be unacceptable to the bank. The policy is also directed at preserving the integrity and solidity of InsingerGilissen as a bank and as part of the Quintet Group, with a view to their interests in the long term.

The main elements of the implemented remuneration policy are:

• Any variable remuneration is a consequence of the results achieved over the year in question at Group level, at InsingerGilissen level, but also at team and individual level. At individual level, we examine both the achieved results (what) and the way they were achieved (how), based on competences and conduct defined in advance. This creates a clear and transparent line between the strategy, the results and any variable remuneration;
• Employees' goals are defined annually based on financial, non-financial, quantitative and qualitative criteria;
• Any variable remuneration may not exceed 20% of the employee's fixed annual salary; 
• With a view to InsingerGilissen meeting the criteria of good governance, the board of directors and the supervisory board have discretionary powers to award no variable remuneration, to reduce it or recover variable remuneration that has already been paid in the event of undesirable incidents, e.g. relating to risk management and compliance;
• On the basis of the importance that InsingerGilissen attaches to good governance and the code of conduct that derives from this, the board of directors and the supervisory board have discretionary powers to award no variable remuneration or to reduce it in the event that an employee has acted contrary to the code of conduct that is aligned with the principles of good governance;
• No variable remuneration is awarded over the year in question to employees who fail to perform satisfactorily;
• InsingerGilissen has the option of adjusting the variable remuneration (in retrospect) or of recovering it (claw-back) in the circumstances laid down in the applicable laws and legislation;
• Guaranteed variable remuneration is prohibited.

The total amount paid out in variable remuneration in 2018 was €3.8 million (2017: €4.1m). No employees received total annual remuneration in excess of €1 million.