Earning Trust
The Essence of our Business
Our Code of Conduct helps us stay true to our principles in every situation
About AEGON*
AEGON is an international life insurance, pension and asset management company.
We commit ourselves to this Code of Conduct which consists of our Purpose, Core
Values, Business Principles and Rules of Conduct. These Rules of Conduct apply to all
employees of AEGON companies worldwide.
* For the convenient internal use of our employees, in this Code of Conduct, AEGON N.V. and the AEGON companies are
jointly referred to as “AEGON”, “Group” , “we” , or the “company”. Please consult your local legal, compliance or
communications manager for the proper use of the AEGON name in other contex ts.
2
Code of Conduct
Letter from the CEO
Dear Colleague,
The success of AEGON’s business comes down to one essential component: Trust. As a
financial services company that has as its mission to help individuals and families take
responsibility for their financial security, earning each and every day the trust of our
many customers, business partners and other stakeholders around the world is the
responsibility of us all.
Conducting our business with integrity, openness and clarity is critically important in
today’s demanding environment. The extreme turmoil within world financial markets in
recent years has served to undermine the fundamental trust in financial services
companies that previously was taken for granted. We have defined a clear ambition for
the coming years: to be a leader in all our chosen markets. This means simply being the
most preferred provider of financial security, the most preferred partner among our
distributors and the employer of choice for our employees. As such, no single factor is
more critical to our success than working diligently at every level and in every role
within our organization to distinguish AEGON among our many stakeholders for what
we do and how we do it.
AEGON’s Code of Conduct is not so much a rule book as it is a framework which defines
day-to-day attitudes and behaviors that we expect all employees to adopt as part of the
ONE AEGON family. Supported by our Core Values of Working Together, Bringing Clarity
and Exceeding Expectations, the Code outlines in specific terms what we stand for as a
company and the conduct required in the workplace, in how we deal with business
partners, serve our customers and also, the broader responsibilities we have to the
communities in which we work and live. In this updated version of our Code we have
integrated these new Core Values and also taken the opportunity to make some further
adjustments to reflect current realities.
3
Although living AEGON’s Code of Conduct is the responsibility of all employees, those in
leadership positions have a special requirement to lead by example. If you are
responsible for supervising others, it is expected that you will not only actively promote
observance of the principals defined by the Code, but also identify those areas in which
we need to improve. Furthermore, when members of your teams are faced with
situations that challenge both the spirit and letter of the Code of Conduct, there can be
no business priority more important than providing the necessary guidance and
support, ensuring that no person fears pointing out inappropriate business or personal
conduct.
Thank you for your continued commitment to conducting our business with utmost
integrity, clarity of purpose and personal accountability. I welcome your insights into
how we can further improve as together we work to safeguard the trust and confidence
of our many stakeholders in the years to come.
Alex Wynaendts
CEO AEGON N.V.
4
Code of Conduct
The AEGON Strategic Framework
AEGON’s strategic framework brings together the company’s purpose, values, strategic
objectives and ambition.
This Code of Conduct guides us in our daily business. It helps us stay true to our
principles and to fulfill our purpose.
The AEGON Strategic Framework
Purpose
Values
Help people take responsibility for their financial future
Working
Together
Bringing
Clarity
Exceeding
Expectations
Strategic
Objectives
Ambition
Why
How
What
Leader in all of our chosen markets by 2015
1
5
The Code of Conduct
6
Our Purpose
8
Our Core Values
9
Our Business Principles
10
Company
10
Governance
10
The Marketplace
11
The Workplace
11
The Wider Community
12
Our Rules of Conduct
13
Company & Governance
13
Complying with laws and regulations
13
Recording financial transactions
13
Insider dealing
14
Communications for AEGON
14
Marketplace
15
Treating our stakeholders fairly
15
Providing clear products and services
15
Dealing with business partners
16
Briber y and corruption
16
Avoiding conflicts of interest
17
Avoiding unfair business practices
18
Preventing money laundering
19
Discouraging anti-competitive behavior
19
Confidentiality and third-party property rights
20
Code of Conduct
Workplace
20
Non-discrimination
20
Protecting personal information
21
Proper use of AEGON assets and equipment
21
Co-operating with external and internal investigations
22
Reporting illegal or unethical behavior
22
Wider Community
24
Community activity
24
Investing responsibly
24
Supporting and protecting human rights
25
Who must comply with these Rules of Conduct?
26
These Rules of Conduct are endorsed by every AEGON company
27
Employee pledge and accountability
28
AEGON closing words
29
Contact details AEGON Global Ethics Line
30
Contact details AEGON N.V. Group Compliance Officer
31
7
Our Purpose
AEGON’s core purpose is to help people take responsibility for their financial future.
This is not just a statement, but a firm belief that people deserve to understand and feel
confident about their financial futures. As AEGON employees, we are personally
committed to fulfilling this purpose. Ever ything we do and say should contribute to
helping our customers make better financial decisions and help them feel confident that
they are building a brighter financial future for themselves and their families.
8
Code of Conduct
Our Core Values
Working Together, Bringing Clarity and Exceeding Expectations constitute AEGON’s core
values. AEGON continually strives to meet the evolving needs of its customers, business
partners, shareholders, employees and the wider communities in which we operate. We
aim to be an employer of choice. We are driven to deliver new thinking and our ambition
is for AEGON to be a leader in all its chosen markets.
Our core values
•
Working Together: Operating as a team makes us stronger, smarter and better. We
build relationships as we work together with respect across disciplines, across
borders and with partners across the value chain. We welcome new perspectives
and fully leverage the considerable knowledge and professional expertise that
exists across the AEGON organization.
•
Bringing Clarity: By ensuring that we are relevant to our customers and that they
understand what we do and provide through our products and services, we
demonstrate integrity and have the possibility to earn trust. We utilize our expertise
to develop need-specific solutions and are also committed to providing clear
communications. We are transparent, challenge complexity and work to maintain an
open and ongoing dialogue with our stakeholders.
•
Exceeding Expectations: Our care for customers and the commitment we
demonstrate to providing exceptional service will result in loyalty and true customer
recommendation. We constantly ensure we understand our customers’ expectations
and pursue innovative ways to exceed them. We constantly challenge ourselves and
each other to excel and are accountable for what we do and how we do it.
9
What you can expect of AEGON:
Our Business Principles
Company
AEGON’s corporate strategy emphasizes the importance of local knowledge and
empowerment, within an expanding global group. AEGON’s goal is to help people take
responsibility for their financial future.
•
We empower our local business units to identify and provide solutions designed to
help meet the long-term needs of our customers, using distribution channels suited
to their local markets.
•
We take pride in balancing a local approach with the power of an expanding global
operation.
Governance
We operate as a responsible company in an ever-changing business environment.
•
•
•
We provide a strong capital base to meet our long-term financial obligations.
We make decisions that are in the interests of our stakeholders.
We are accountable to our stakeholders for clear and transparent disclosure of our
management practices, policies and results.
•
•
We identify and manage risk prudently.
We provide timely and accurate information to our customers, shareholders,
employees, regulators and business partners.
•
We comply with applicable laws and regulations, and we proactively promote such
compliance.
10
Code of Conduct
•
We set clear internal guidelines and policies relating to the way we behave as a
responsible company with a global reach.
The Marketplace
We seek to build long-term relationships with our customers, business partners and
regulators based on open, honest and clear business principles.
•
•
We treat our customers fairly.
We provide solutions that are fair, clear and meet our customers’ evolving long-term
needs.
•
We offer solutions that provide the best long-term risk-adjusted returns possible
consistent with individual customer requirements.
•
•
We seek to build long-term relationships with our customers.
We strive to provide customers with the information they need to make the right
financial decisions for themselves and their families. We also support financial
education initiatives and strive to promote a better understanding of the financial
services industry.
•
•
•
We strive to deal with business partners who share our core values.
We are committed to fair competition.
We recognize the importance of confidentiality and take measures to keep
confidential the personal information relating to our customers, employees,
business partners and shareholders.
The Workplace
Our goal is to be an employer of choice, to create a work environment where people are
able to realize their potential and where both individuality and diversity are respected.
11
•
We promote ethical behavior and encourage the reporting of any illegal or unethical
behavior.
•
•
We promote respect for people and their work environment.
We actively enforce policies that promote non-discrimination in the workplace and
encourage diversity.
•
We hire, promote and pay our employees fairly and do so based on their
qualifications, their experience and their ability to do a job.
•
•
We provide training to encourage our employees to reach their potential.
We require our employees, within the scope of their professional activities for the
company, to act in the best interests of all our stakeholders and abide by these
business principles that promote our core values:
Working Together, Bringing Clarity and Exceeding Expectations.
•
•
•
We provide employees with a safe place to work.
We encourage personal and career advancement.
We allow our employees the free right of association.
The Wider Community
We have a long-term commitment to the communities in which we operate, creating job
opportunities and contributing to sustainable economic growth. We support good
causes. We help protect and promote human rights in the countries in which we operate.
•
•
We are active corporate citizens in the communities in which we operate.
We actively support and respect the protection of internationally proclaimed
human rights and ensure we are not complicit in human rights abuses.
•
We take a responsible approach to investment, which allies the need for returns
with broader consideration for social well-being and development.
•
We strive to respect the environment and undertake initiatives to promote greater
environmental responsibility.
12
Code of Conduct
What AEGON expects of you:
Our Rules of Conduct
Our Rules of Conduct apply to the employees of all AEGON companies. They set out rules for
how AEGON expects us to behave as responsible employees and how AEGON expects its
business principles and objectives to be applied in practice.
Company & Governance
1
Complying with laws and regulations
Employees must comply with applicable laws and regulations as well as with internal
company rules and regulations, including these Rules of Conduct.
What does this mean?
AEGON companies serve more than some 40 million customers in over twenty countries
around the world. Complying with applicable laws and regulations is not only a legal
requirement, but also vital if we are to maintain our reputation as a reliable and
responsible company.
2
Recording financial transactions
Employees shall properly and fairly record all financial transactions in appropriate books
of accounts available for inspection by corporate directors, officers and the company’s
appointed auditors.
What does this mean?
The trust of all our stakeholders – customers, shareholders, employees, and the wider
community – is based on our reputation for integrity and transparency. Employees must
not use secret accounts or issue documents that do not properly or fairly reflect the
transactions they relate to.
13
3
Insider dealing
Employees who have access to inside information may not enter into securities
transactions based on i) inside information or ii) misuse of confidential information. In
addition, employees must not disclose any inside information to any other person
(other than to individuals who have a need to know for company business reasons) by
“tipping them off” or passing on that information.
What does this mean?
Insider dealing, also referred to as ‘insider trading’, involves using information that has
not been made public, in order to profit – either directly or indirectly – from the
purchase or sale of a company’s stock or other securities. It also includes “tipping off”, or
passing the information on to, unauthorized individuals. Both are strictly forbidden by
law. Employees must, of course, comply with all laws and regulations on insider dealing
as well as internal company rules and regulations that strictly prohibit such activities.
4
Communications for AEGON
•
Employees must endeavor at all times to comply with relevant disclosure
obligations by producing reports, submissions and communications that are full,
fair, timely, accurate and understandable. At the same time, such communications
should protect AEGON’s confidentiality and interests.
•
Only specifically authorized employees are allowed to communicate with the media
on behalf of AEGON. Press enquiries regarding AEGON companies should be
directed to the designated AEGON company spokesperson. This includes any verbal
and written communications with the media, and unsolicited telephone calls from
journalists.
•
Employees are prohibited from engaging in any communication on behalf of
AEGON companies which is false, harmful to the company’s reputation and/or
contrary to these Rules of Conduct.
14
Code of Conduct
What does this mean?
How the media represents us may have an important impact on our reputation and our
share price. It can affect how we are regarded not only by the public in general, but also
by our customers, shareholders, employees, and the wider community. It is essential
therefore that all employees abide by the terms of these Rules of Conduct. To be
successful and effective, communication on behalf of AEGON must be consistent with
AEGON’s overall strategies and objectives.
Marketplace
5
Treating our stakeholders fairly
Each employee, within the scope of his or her professional activities on behalf of the
company, shall endeavor to deal fairly with customers, shareholders, employees,
business partners and competitors. None should take unfair advantage through
manipulation, concealment, abuse of privileged information, misrepresentation of
material facts, or any other unfair-dealing practice.
What does this mean?
As one of the world’s leading providers of long-term financial products and services,
AEGON companies make long-term promises to a wide range of customers,
shareholders, employees and the wider community. Treating these interest groups fairly
will help ensure AEGON companies keep those promises through sound and
responsible business practices and through the integrity of the products and services
delivered.
6
Providing clear products and services
Employees shall, within the scope of their professional activities on behalf of the
company, endeavor to provide products and services that are fair, clear and meet our
customers’ evolving long-term needs.
15
What does this mean?
AEGON companies strive always to act in the interests of their stakeholders, providing
products and services that are designed to help meet the evolving needs of their
customers. This means providing products and services that are fair, clear and meet our
customers’ evolving long-term needs. Sound and responsible business practices and
transparent and customer friendly services help AEGON companies honor these
commitments and build long-term relationships with these customers.
7
Dealing with business partners
AEGON is committed to dealing with business partners who share its core values and its
business principles. We require all employees, within the scope of their professional
activities on behalf of the company, to support this objective. In addition, employees
are required to apply our Rules of Conduct in their dealings with business partners.
What does this mean?
AEGON companies seek to build long-term relationships with business partners who
share similar core values and business principles. These partners include agents,
brokers, suppliers and joint venture partners. We strive to adhere to this objective,
wherever and whenever we can. We believe this is essential to maintain the quality of
the products and services we deliver. AEGON companies rely on their employees to
promote and sustain these core values, principles and the Rules of Conduct wherever
possible in their dealings with our business partners.
8
Bribery and corruption
•
Employees are strictly forbidden from offering any bribe (consisting of money or
anything of value) to public officials, irrespective of the worth, its results, local
custom, the tolerance of such payments by local authorities, or the alleged necessity
of the payment in order to obtain or retain business or any other advantage.
16
Code of Conduct
•
All commissions and other fees paid or accrued to insurance sales agents, business
agents or other representatives of AEGON companies must be in accordance with
sound business practice, for legitimate commercial reasons, and represent an
appropriate remuneration for services rendered.
•
Employees are forbidden from seeking to obtain new business or any other
improper commercial advantage by allowing undue payments to be made to clients
via either agents or any other AEGON company representatives.
•
Employees must not accept or solicit any undue payment or any other improper
advantage. Employees are allowed to accept corporate hospitality and gifts,
provided these advantages are reasonable in value and in accordance with the
relevant AEGON company policy. Such advantages should be properly disclosed in
accordance with the established procedures. Hospitality or gifts that might appear
to place employees under any obligation, or which have any appearance of
impropriety, are to be avoided.
What does this mean?
A bribe refers to any undue payment, gift or improper advantage offered directly or
indirectly to a person, company, political party or public official. Usually in offering a
bribe some personal gain or illicit advantage is being sought often related to current or
future business. Bribes may include personal or company payments aimed at retaining
the business of a particular customer or supplier. Bribery is strictly forbidden. It is in
direct contradiction to our core values. Moreover, bribery can cause severe damage to
our reputation. Similarly, accepting undue payments or other improper advantages may
have the same consequences. AEGON will not tolerate such behavior from any of its
employees.
9
Avoiding conflicts of interest
Employees have an obligation to promote AEGON’s best interests at all times and
should avoid any actual or apparent personal conflict of interest. Employees are
required to communicate potential conflicts of interest to their local company
management, human resources or legal departments.
17
What does this mean?
A conflict of interest may arise if competing professional or personal obligations or
financial interests prevent an employee from carrying out his or her duties in an open
and even-handed manner. A conflict of interest could impair the integrity and fairness
of the products and services AEGON companies deliver. Everything possible should be
done to ensure such situations do not arise.
Such conflicts of interest may include:
(a) An outside interest that prevents an employee from devoting his/her full attention
or ability to his/her duties as an employee;
(b) Employees or their close family members having a material interest in one of
AEGON’s major suppliers, agents, customers or competitors which might impair
their ability to make impartial decisions on behalf of AEGON companies;
(c) Representing AEGON companies in a transaction in which an employee has a
material personal interest;
(d) Disclosing or using confidential AEGON company information for personal profit or
advantage.
10 Avoiding unfair business practices
Employees are not permitted to:
•
Profit personally from opportunities that are discovered through the use of corporate property, information or position;
•
•
Use corporate property, information, or position for personal gain;
Compete with AEGON.
Employees have a duty to advance the legitimate interests of AEGON whenever there is
the opportunity to do so.
What does this mean?
It is unfair business practice to use company information or assets for personal gain.
Employees shall do their utmost to maintain the trust and confidence of customers.
18
Code of Conduct
Advancing the legitimate interests of AEGON whenever possible and not pursuing
personal business opportunities are vital if we are to maintain such trust and
confidence.
11 Preventing money laundering
Employees must not participate in any activity aimed at laundering money. In addition,
they must not provide assistance to any person or organization trying to benefit from the
proceeds of a criminal act or illegal activity or controlling funds invested for the benefit of
a terrorist organization.
What does this mean?
Sound and responsible business practices form the building blocks of our company.
Money laundering involves processing the proceeds from crime in an attempt to
disguise their illegal origin. Money laundering is considered a crime in itself and runs
contrary to our business principles and our fundamental interests. Employees are
strictly forbidden to engage in any kind of money laundering activities. Employees must
follow the relevant internal company rules and regulations governing money
laundering in their own country.
12 Discouraging anti-competitive behavior
Employees shall refrain from directly or indirectly engaging in any discussion or activity
that constitutes anti-competitive behavior or in any way violates anti-trust provisions.
What does this mean?
Anti-competitive behavior refers to any business practice that prevents and/or restricts
competition. Examples of anti-competitive behavior include:
(a) Arranging to split a particular market with competitors either by sales or by number
of customers;
(b) Engaging in joint price fixing agreements; or
(c) Entering into joint selling and purchasing agreements (assuming such agreements
are not specifically allowed by local laws and regulations).
19
Anti-competitive behavior cannot be squared with our commitment to sound and
responsible business practices. It runs contrary to the interests not only of our
customers, business partners and shareholders, but also of both employees and the
company itself. Employees are strictly forbidden from engaging in anti-competitive
behavior.
13 Confidentiality and third-party property rights
Employees shall maintain the confidentiality of information entrusted to them by
AEGON or its customers and business partners, except when disclosure is permitted or
required by law. Confidential information includes all non-public information that might
be of use to competitors or harmful to the company, its customers, or business partners,
if disclosed. It also includes the personal data of customers and employees. Employees
shall respect all trade secrets, copyrights, trademarks and rights of patent.
What does this mean?
In this context, information includes company information, customer information,
business partner and personal employee data. Proprietary or other confidential
information may only be disclosed as permitted or required by law. Access to this
information within the company is restricted to those who have a legitimate business
need to know. Confidentiality is an essential requirement to maintain the trust and
confidence of our customers, business partners and employees.
Workplace
14 Non-discrimination
Employees must refrain from any discriminatory practices either with regard to
recruitment, promotion, pay or bonuses, or in their general conduct in the workplace.
AEGON does not tolerate discrimination in the workplace.
20
Code of Conduct
What does this mean?
AEGON companies are committed to promoting non-discrimination in employment and
to providing employees with a safe working environment. Non-discrimination means
simply that employees are selected on the basis of their ability to do the job and that
there is no distinction, exclusion or preference made on other grounds, either during the
recruitment process or after.
To uphold this important principle, AEGON must be able to rely on the trust and integrity
of all employees.
15 Protecting personal information
Employees must handle all information with care. In particular, personal data should be
safeguarded in accordance with applicable laws, regulations and internal company
rules. Disclosure of personal information to third parties is prohibited, except as
permitted or required by law.
What does this mean?
AEGON is committed to maintaining the trust and confidence not only of its customers,
but its employees as well. This means safeguarding employees’ personal data. All
employees are required to comply with internal company rules and regulations aimed
at ensuring information, knowledge and data are properly stored and protected.
16 Proper use of AEGON assets and equipment
Employees shall use AEGON’s assets only for legitimate business or other approved
purposes. Company’s internal communication tools (such as mail, e-mail, telephones,
computer networks, as well as access to intranet and internet sites, etc.) may be used
only for legitimate company purposes. Incidental personal use by employees may be
allowed at the discretion of the employee’s manager, providing it does not interfere
with AEGON’s business.
21
What does this mean?
AEGON companies are committed to providing their customers with high quality
products and services. To do so, the companies must be able to rely on the respect and
trust of all employees when using company assets and communication tools.
17 Co-operating with external and internal investigations
Employees are required to co-operate with any appropriately authorized internal or
external investigations. Making false statements or otherwise misleading internal or
external auditors, legal counsel, compliance officers, company representatives or
regulators can result in severe penalties. AEGON companies will not retaliate against any
employees for co-operating with any such investigations.
What does this mean?
AEGON companies are committed to maintaining the trust and respect of all
stakeholders. For this reason, we should strive always to be open, honest and
straightforward. This is particularly important in investigations, either internal or
external. All employees are therefore required to co-operate with all such investigations
and to avoid misrepresentations.
18 Reporting illegal or unethical behavior
All employees are expected to identify both actual and potential violations of these
Rules of Conduct and to seek advice if or when questions arise. Any suspicious or
unlawful activity, unethical conduct, threat to public interest or infringement of these
Rules of Conduct should be reported immediately to:
(a) Management, and
(b) The compliance officer, or
(c) The general counsel or
(d) The internal audit department.
22
Code of Conduct
•
If a senior officer of the company is involved or if senior management has failed to
take action, the matter should be brought at once to the attention of more senior
management.
•
If the matter involves member(s) of your most senior management, it should then
be reported directly to the Group Compliance Officer of AEGON N.V. (please refer to
page 31 of these Rules of Conduct for contact details).
•
Alleged irregularities regarding the members of AEGON N.V.’s Executive Board
should be reported to the chairman of AEGON N.V.’s Supervisory Board.
•
If you are unsure about where to go, wish to remain anonymous or are reluctant to
use one of the sources mentioned above, you can make use of:
(a) A help line established by your local AEGON company, or
(b) The AEGON Global Ethics Line.
Please refer to page 30 of these Rules of Conduct for all contact details. •
Any behavior that damages the reputation of AEGON companies or prejudices the
safety and rights of company employees will be fully investigated. Employees must
co-operate fully with any such investigation.
•
Confidentiality will be maintained to the extent consistent with the interests of all
parties involved and AEGON’s obligations under relevant laws and regulations.
•
AEGON will not retaliate, and will not condone retaliation, against any employee
who, in good faith, reports illegal or unethical conduct.
What does this mean?
AEGON’s core values of Working Together, Bringing Clarity and Exceeding Expectations
are central to many considerations, and guide our business decisions. To a large degree,
our reputation among customers, shareholders, employees, and business partners
depends on our ability to behave in a manner consistent with these values. AEGON
actively promotes ethical behavior. This also means that we encourage all employees to
report any incidents of illegal and unethical behavior.
Complainants may call the AEGON Global Ethics Line anonymously if they wish. The line
is open 24 hours a day /seven days a week and is available in your own language.
23
Wider Community
19 Community activity
AEGON companies are committed to sound and responsible business practices and to
contributing to the long-term well-being of the communities in which their employees
live and work. We encourage employees to take part in activities that enrich their local
communities. However, employees should ensure that their personal activities do not
create a conflict of interest under company policies.
What does this mean?
AEGON companies are committed to behaving responsibly and, wherever they operate,
to contributing to the long-term well being of the community. We encourage
employees to take part in activities that enrich their local communities. This includes
political activity, assuming it does not interfere with their responsibilities as an AEGON
company employee.
20 Investing responsibly
AEGON is a significant investor in a large number of industries and companies, and
we take our responsibility as a capital provider seriously. AEGON aims to contribute
broadly to wellbeing and sustainable development through active ownership. We
believe that integrating environmental, social, and governance (ESG) criteria into
ownership and investment decision-making may have a positive impact on long-term
returns. We require all employees, particularly those involved in investment-related
activities to support this approach.
What does this mean?
Employees involved in managing assets should follow the mandates and investment
instructions, and satisfy customers’ investment requirements. This includes managing
each portfolio against the agreed risk profile. AEGON further seeks to incorporate
environmental, social and governance aspects into its investment activities and
employees are expected to comply with AEGON’s responsible investment policy.
24
Code of Conduct
21. Supporting and protecting human rights
AEGON is committed to upholding internationally-recognized human rights. Employees
are expected to be guided by AEGON’s human rights policy.
What does this mean?
Under AEGON’s human rights policy, all the company’s activities are guided by the
articles of the United Nations’ Universal Declaration of Human Rights, the core
standards of the International Labor Organization and the principles on human rights
and labor standards contained in the UN Global Compact. AEGON expects its
employees to abide by these standards and principles during their business dealings
and work for the company.
25
Who must comply with these Rules
of Conduct?
These Rules of Conduct apply to all directors, officers (regardless of the contractual basis
of their employment) and employees of all AEGON companies. This includes members of
the Executive Board, the Management Board and the Supervisory Board of AEGON N.V. as
well as other executive and non-executive or supervisory directors of AEGON companies.
For the purpose of these Rules of Conduct all of the above may be jointly referred to as
“employee(s)”.
These Rules of Conduct also apply to employees who represent AEGON at associate
companies, joint ventures and other co-operations.
26
Code of Conduct
These Rules of Conduct are
endorsed by every AEGON
company
Every AEGON company has agreed to comply with these Rules of Conduct. Individual
company management, however, reserves the right to maintain or introduce additional
rules and regulations as appropriate.
27
Employee pledge and
accountability
All employees are expected to act in a manner that is consistent with the highest ethical
standards and in compliance with AEGON’s core values and business principles.
In addition, all employees are held responsible and accountable to AEGON for conducting
business in accordance with these Rules of Conduct as well as for complying with internal
and external laws, rules and regulations.
Failure to comply with these Rules of Conduct may result in disciplinary action up to and
including termination of employment. Violations of these Rules of Conduct may also be
violations of the law and result in civil or criminal penalties.
28
Code of Conduct
AEGON closing words
Acting as a responsible company is vital for the future both of AEGON and its employees
around the world. As an international life insurance, pension and asset management
company, we rely on employees to respect our core values, to abide by our Rules of
Conduct and to endeavor to act always in accordance with our business principles.
We thank all employees for their commitment to AEGON and to the future success of
the Group.
29
Contact details AEGON Global
Ethics Line
AEGON encourages openness and therefore expects its employees to report actual and
potential violations of AEGON’s Code of Conduct and to seek advice if they are uncertain
as to how to handle those violations. All reports received will be investigated and
reporters will be informed of any developments. Reporters will be contacted within 6
business days of filing a report.
Please visit the website: www.aegonethicsline.com.
Or dial toll-free for your location*:
30
Australia
1-800-339276
Bermuda
1-866 -737-6850
Brazil
0800-8911667
Canada
1-888-396-9029 or 1-855-350-9393
Chile
1230-020 -5771
China (Northern)
10-800-712-1239
China (Southern)
10-800-120-1239
Czech Republic
800 -142-550
France
0800-902500
Germany
0800-1016582
Hong Kong
800-964214
Hungar y
06 -800 -17199
India
000-800 -100 -1071 or 000-800-001-6112
Indonesia
001-803-011-3570 or 007-803-011-0160
Ireland
1-800615403
Italy
800 -786907
Japan
0066-33-112505 or 00531-121520
Code of Conduct
Korea (South)
00798-14-800-6599 or 00308-110-480
Mexico
001-800 -840-7907 or 001-866-737-6850
Netherlands
0800-0226174
Poland
0-0-800-1211571
Puerto Rico
1-888-396-9029
Romania
0808-03-4288
Singapore
800-1204201
Slovakia
0800 -001-544
Spain
900-991498
Sweden
020 -79 -8729
Taiwan
00801-13-7956
Thailand
001-800-12-0665204
Turkey
0811-288-0001 at the prompt dial 888-396-9029
Ukraine
0 ^ 00-11 at the prompt dial 888-396-9029
United Kingdom
0800 -032-8483
United States (S.H.A.R.E.)
866-263-7787
* The toll-free numbers may change from time to time for certain countries. Please check the website at www.aegonethicsline.com. ^ Indicates second dial tone.
Contact details AEGON N.V. Group Compliance Officer:
Group Compliance Officer
AEGON N.V. P.O. Box 85
2501 CB The Hague
The Netherlands
E-mail: GroupComplianceOfficer@aegon.com
31
Code of Conduct