The case for CSR/ Sustainability Reporting Done Responsibly


Insights on how you can protect the environment, maintain and increase the value of your company, through a structured process.

Insights on how you can protect the environment, maintain and increase the value of your company, through a structured process.

Home / case studies / Case study: How NN promotes ethical business conduct

Case study: How NN promotes ethical business conduct

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.

Layout 1Abstract

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

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:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

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
Customers (retail)



·      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

·      Unions

·      International leadership and other conferences

·      Surveys

Investee companies



·      Voting at shareholder meetings

·      Dialogue with company management

·      Engagement

Regulators, government bodies


·      Meetings

·      Reporting

·      Information exchange

Non-governmental organisations


·      Correspondence

·      Meetings

·      Reports

·      Benchmarks

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.

What actions were taken by NN to promote ethical business conduct?

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:


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

FBRH GRI Standards Certified, IEMA & CIM recognised Sustainability Course | Venue: London LSE

By registering for the next 2-day FBRH GRI Standards Certified, IEMA & CIM recognised course you will be taking the first step in gaining the many benefits of sustainability reporting.

Most importantly, you will gain the knowledge to use the GRI Standards, project manage your own first-class sustainability report and:

  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP



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:


Note to NN: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.