DNB screens directors, (co-)policymakers of corporate pension funds and industry-wide pension funds in the Caribbean Netherlands (‘BES’) to ensure they are fit and proper persons. In addition, the expertise of day-to-day policymakers is assessed.
Why an assessment?
If directors, (co-)policymakers are fit and proper persons, this contributes towards the stability and integrity of the financial sector. This guarantees that members of the pension fund and other stakeholders can rely on pension funds. The assessment also stems from section 5a of the BES Pensions Act.
DNB has an independent task to ensure the integrity of the financial sector in the Caribbean Netherlands and must therefore form its own opinion regarding the reliability of the (co-)policymakers of the pensions funds established in the Caribbean Netherlands.
The integrity assessment is applicable to (co-)policymakers such as directors. The objective is to establish whether the integrity of the (co-)policymakers, as based on his intentions, actions and antecedents, is beyond any doubt. Attention is devoted in this connection to various aspects, such as the possible presence of criminal, tax and supervisory antecedents. The assessment starts with the completion of the ‘Questionnaire (BES Islands)’ by the person being assessed. Other information that must always be supplied in addition to the ‘Questionnaire (BES Islands)’ for this assessment are a curriculum vitae (see question 8 of the questionnaire) and a legible copy of a valid passport.
Under Article 4 of the BES Pensions Act Regulation the integrity of a (co-)policymaker of an institutions in the Caribbean Netherlands is beyond doubt for a term of 3 years. However, if any change in the relevant facts or circumstances gives reasonable cause for a new assessment, a reassessment can be carried out within this term.
After the 3-year term, the integrity of the (co-)policymaker is reassessed by DNB. This takes place on the initiative of DNB, where the institution is required to re-nominate the persons to be assessed by means of the BES Questionnaire.
The expertise of day-to-day policymakers in institutions in the Caribbean Netherlands is assessed. This concerns not only those persons designated as (co-)policymakers according to the legal structure but also persons who exercise actual influence over the institution’s policymaking in practice. This assessment is intended to establish whether the person concerned has the required expertise. For instance, a person who is unable to make sufficient time available may be competent, but still unsuitable for the position.
The expertise assessment takes account of:
- the policymaker’s position;
- the nature, scale, complexity and risk profile of the undertaking;
- the composition and performance of the policymakers collectively.
The situation of the pension fund and the policymaker’s position are taken into consideration in the expertise assessment. If the pension fund intends to alter these circumstances (e.g. a change in position), it must notify DNB of this intention.
Submission of forms
To accelerate the assessment process, you can already send the form plus enclosures by email to email@example.com or by fax to +31 (0) 20 524 9106. We will send you confirmation of receipt as soon as possible. However, you must also still send the physical documents, provided with a signature. If you have any questions about the assessment procedure, please call the Expert Centre Fit and Proper Testing and Information Services (Expertisecentrum Toetsing en Informatievoorziening) on +31 (0) 20 524 6211.