Control Framework
Fund management - Fund management is ultimately responsible for fund-related activities, including managing the control environment and risks.
Assurance on risk relating to failure of systems and processes
The Fund Manager is structured with an affiliated Fund Services Provider (Amvest Management B.V.). The Fund Services Provider employs all employees of Amvest Group and provides relevant management services to the Fund Manager.
ARC Fund Risk Management Framework
The Fund Manager applies a Risk Management Framework to identify, measure, manage, monitor and report risks, and sets the corresponding risk indicators, limits and risk appetite.
Compliance programme
The corporate Compliance Programme 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 compliance-related policies and procedures.
Integrity and customer due diligence
Integrity and customer due diligence are key elements of Amvest’s Compliance Programme. In 2025, various policies were reviewed and updated following adjustments in internal procedures and relevant laws and regulations.
Code of Conduct
In 2025, 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 a 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 (last significant revision in 2014 with