Founded in 1845, NN Group is a financial services company active in several European countries and Japan, dedicated to meeting and exceeding customers’ expectations. NN’s values – including, most importantly, integrity – are the foundation of its culture Tweet This!, and provide the basis for its company-wide policy framework.
This case study is based on the 2019 Annual Review by NN published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Acting with honesty, integrity and transparency and doing business with the future in mind, is a top priority for NN. In order to promote ethical business conduct NN took action to:
- implement the NN Code of Conduct
- launch an online learning platform
- apply a Whistleblower Policy
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With this case study you will see:
- Which are the most important impacts (material issues) NN has identified;
- How NN proceeded with stakeholder engagement, and
- What actions were taken by NN to promote ethical business conduct
What are the material issues the company has identified?
In its 2019 Annual Review NN identified a range of material issues, such as customer experience, cost reduction and efficiency, development of new products and services, data protection, privacy and cybersecurity. Among these, promoting ethical business conduct stands out as a key material issue for NN.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups NN engages with:
|Stakeholder Group||Method of engagement|
|· Client panels
· NPS survey
· Global Brand Health Monitor
|Customers (institutional)||· Client survey
· Client events
· Client roundtables
|Financial advisors, brokers, agents||· Training|
|Shareholders, analysts, investors
|· Annual shareholders meeting
· Analyst calls
· Investor meetings
|· Townhall meetings
· Works councils
· International leadership and other conferences
|· Voting at shareholder meetings
· Dialogue with company management
|Regulators, government bodies
· Information exchange
How stakeholder engagement was made to identify material issues
To identify and prioritise material topics NN engaged with its stakeholders – including customers, employees, investors, regulators, business partners and societal organisations – through an online survey.
In its 2019 Annual Review NN reports that it took the following actions for promoting ethical business conduct:
- Implementing the NN Code of Conduct
- Founded on the NN statement of Living our Values, the NN Code of Conduct offers clear guidance in a single, comprehensible document on how NN employees should behave: how to interact with colleagues and customers; how to deal with information and data; how to deal with conflicts of interest, fraud, corruption and financial economic crime; how to use equipment and the internet; and how to report and deal with breaches. Employees must formally acknowledge annually that they understand the content of the NN Code of Conduct and that they can and will apply the policies and standards. Formal acknowledgement of the NN Code of Conduct has been mandatory for all business units, for several years. In October 2019, NN achieved an acknowledgement score of 100% for internal NN staff (excluding employees on long-term leave and sick leave). When misconduct occurs, NN carefully reviews and assesses whether an investigation or other action is needed. Breaches of the NN Code of Conduct are not taken lightly and have consequences.
- Launching an online learning platform
- Prior to sending out the NN Code of Conduct acknowledgement email in 2019, NN launched the online learning platform Conduct Matters. The aim of this learning platform is to raise awareness of the NN Code of Conduct and is accessible for all employees in all local languages. The platform includes exercises, dilemmas, examples of important conduct-related topics, films, articles and hands-on guidance on how to act according to the NN Code of Conduct.
- Applying a Whistleblower Policy
- The NN Group Whistleblower Policy enables every employee to report, if desired anonymously, a concern outside normal reporting channels. NN Group guarantees various rights, including protection from retaliation, for any employee who reports a concern in good faith, provides information, causes information to be provided, or otherwise assists in an investigation. The main outline of the Whistleblower Policy is explained in the NN Code of Conduct. Relevant training materials are developed and rolled out to the business units. In 2019, NN recorded four concerns filed through the Whistleblower Policy (2018: seven concerns). In three reported concerns, Corporate Security & Investigations was involved for further investigation. The concerns reported in 2019 were related to, amongst others, power harassment, misconduct by manager, and other unethical employee behaviour. The concerns are recorded and reported periodically (in numbers) through the Chief Compliance Officer up to the level of the Management Board.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standard addressed in this case is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
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1) This case study is based on published information by NN, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
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