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OUR CORPORATE GOVERNANCE
CHARTER
We adopted the 2009 Belgian Corporate
Governance Code as reference code
for our corporate governance charter.
It describes a series of rules, procedures
and practices which define how the
company is managed and controlled.
It recommends transparency in decisions
taken at all levels and defines the ethical
principles which our employees must
apply to their professional practices and
conduct with all interlocutors.
The Compliance Officer ensures
compliance with the ethical rules and
duties in our company. He provides
assistance and advice to all employees
who request help with ethical matters
and contributes to the adoption and
deployment of the Charter.
The fundamental principles to comply
with are:
Compliance with the laws and
regulations of the countries in which
we operate
Respect for persons
Respect for the environment
Prevention of conflicts of interest
Protection of assets
Information transparency and integrity.
All of the documents included in our
company's governance charter can
be viewed on our website
(
about-us/governance/charters).
OUR COMPANY ETHICS
We emphasise the principles of honesty,
integrity and fairness. Our employees
comply in their daily work, with a Code of
Conduct and the corporate values
( see also pages 20-21 of the 2017
Sustainability Report). A whistleblowing
policy has been implemented to enable
employees to report any ethical fault they
know about.
We expect the same attitude from third
parties with which we have a business
relationship. Attempted corruption
is covered in a specific article of the
general purchasing terms and conditions,
appended to all orders. Any occurrence
would be severely punished. All forms of
fraud and misappropriation are naturally
prohibited and very strict rules govern
calls for tenders:
Segregation of Duties principle
(a double signature by different persons
for all commitments and payments);
consultation of an appropriate number
of suppliers or service providers;
rotation of tenders.
The internal auditor verifies the
establisment of internal controls to ensure
reliability, consistency and integrity of
information and operational procedures.
Financial results are certified by an
external auditor.
Likewise, a systematic control of the
workers present on construction sites is
organised to detect and prevent cases of
social fraud.
Since 2000, we also have a vade mecum
for real estate agents. It specifies in detail
the collaboration and remuneration rules
applied for the marketing of our buildings.
OUR 2017
ACHIEVEMENTS
DEALING CODE
We have a duty to ensure confidentiality
at all times. Members of the company's
bodies and employees who plan to carry
out transactions on Cofinimmo shares
must report their intent to the Secretary
General beforehand. They are strictly
forbidden from buying or selling shares
during key periods around the publication
of corporate reports or if they are in
possession of confidential information
which may potentially impact the share
price. They are also forbidden from
providing the information to third parties,
including their family members.
The ‘Dealing Code’, which sets the rules
governing the purchase and sale of
Cofinimmo shares, has been revised and
distributed throughout the company. The
Dealing Code and whistleblowing policy
have been incorporated into the Code of
Conduct. (see .
com/about us/governance/charters/ ).
INTERNAL AUDITOR
At the request of the Audit Committee,
the internal auditor conducted two new
missions in 2017 to verify the soundness of
the internal control system implemented
by management and to provide
recommendations to improve controls in
the audited areas.
Recommendations are issued from:
conclusions from internal audit
missions;
conclusions from external audit
missions (IT and others);
annual analysis of 'incidents' identified
(for example: fraud to the president). An
incident is an event whose proven or
potential impact may have an effect on
the company's objectives.
Once a year, the auditor prepares and
submits a report on the internal control
systems within the company to the
supervisory authority (FSMA). This report is
also validated by the external auditor.