In principle, we only assess propriety once. Candidates who have passed the assessment will not require reassessment. Our decision will stand unless a change in the relevant facts or circumstances provides grounds for reassessing propriety.
A propriety assessment relates only to the candidate. This means that – unlike a fitness assessment – our decision does not depend on circumstances such as the composition of the management board, the type of institution that the proposed appointment pertains to or the specific position that the candidate will hold.
We assess propriety based on information provided by the institution and the results of our own preliminary assessment.
Assessment criteria are defined in the Decree on Prudential Rules for Financial Undertakings and in the 2012 Policy Rule on Suitability for trust offices (Dutch only). The Decree Implementing the Pensions Act and the Mandatory Occupational Pension Scheme Act applies to the assessment of governing board members, internal supervisors and members of stakeholder bodies of occupational and other pension funds.
Propriety assessments cover qualities such as veracity, sense of responsibility, respect for the law, openness, sincerity, prudence, punctuality, incorruptibility, discretion and probity.
Propriety is an ongoing requirement. The relevant management or supervisory board member as well as the institution are themselves responsible for reporting any changes in circumstances to DNB that have not been reported earlier. We will then establish whether or not such notification constitutes reasonable grounds to reconsider our earlier decision (reassessment). We will treat failure to report any material facts, professional history and other relevant background information, and will take this very seriously when assessing propriety.