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Awareness

Awareness of integrity-related topics is an important theme within Amvest. The Code of Conduct is reviewed and updated annually. Employees receive an explanation of the updates from the RCO and sign the new Code of Conduct annually. 

In line with the issuance and public listing of green bonds, a market abuse policy in accordance with laws and regulations was drafted.
Part of this is a list of insiders and closely associated persons who need to be aware of inside information and market-sensitive information that could affect the listed prices. 

As of 17 January 2025, new EU legislation in the field of digital resilience came into effect: the Digital Operational Resilience Act (DORA). Business Continuity and Disaster Recovery are important topics of DORA. Given the ever-increasing digitisation of our world, cybersecurity is also a relevant theme.

In 2025, a mandatory ongoing cybersecurity e-learning was introduced. Every two weeks, employees receive a short training course with questions combined with random phishing mails. The goal is to make employees alert and aware of the risks related to digital security.

In addition, we have implemented the web version of Microsoft Copilot within Amvest. In line with the European AI Act, employees have also received training on this topic. The goal is to inform employees about what AI is, how it works and to ensure that AI is used safely, transparently and responsibly. The next step in 2026 is to introduce the M365 version of Copilot.

Every two years (most recently in February 2024), identified staff and all other employees involved with transactions, investors and other relevant business relations, attend a training session on the provisions of the Anti-Money Laundering and Counter-Terrorist Financing Act (‘Wwft’) and the Dutch Sanctions Act (‘Sw’). It is important for client-facing employees to be aware of related risks and the latest adjustments. 

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