Compliance program

The corporate Compliance Program forms the basis for all relevant compliance-related themes. It consists of a Compliance Charter, an annual Compliance Plan, and a Compliance Manual containing all policies and procedures.

Integrity, customer due diligence

Integrity and customer due diligence are key elements of Amvest’s Compliance Program. In 2023, various policies were reviewed and updated following adjustments in internal procedures and relevant laws and regulations.

Code of Conduct

In 2023, as in previous years, all employees of Amvest were asked to sign the internal Amvest Code of Conduct. The Code of Conduct is an inseparable part of the employment contract.

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.

AIFMD and Depositary

The ARC Fund (the AIF) and its Fund Manager (Amvest REIM B.V., the AIFM) are fully within the scope of the AIFM Directive.

Dutch law

The AIFMD requires investment funds to prepare an annual report including fund manager’s report according to Dutch law. Certain requirements included in the law should be disclosed in the fund manager’s report.

INREV

Since 2002, the European Association for Investors in Non-listed Real Estate Vehicles (INREV) has published various guidelines and recommendations that were incorporated into a set of standard INREV Guidelines.

Sustainable Finance Disclosure Regulation

The European Union has set in motion a legislative program regarding environmental, social and governance (ESG) for the financial services industry. Part of this package is the Sustainable Finance Disclosure Regulation (or “SFDR”).

SFDR at the fund level

On the basis of the SFDR, financial market participants are required to indicate how they handle sustainability risks and to detail the consequences of this approach. In addition, the regulation contains transparency requirements at fund level.