With the International Responsible Business Act (WIVO), the European "Corporate Sustainability Due Diligence Directive" will be implemented in Dutch legislation. For the asset management sector, DUFAS did identify a number of important concerns in the proposal. These are included in the response to the bill submitted on December 24, 2024.
In particular, DUFAS calls attention to further clarification that the investments its members manage for clients fall outside the scope of the WIVO. The same should also apply to activities related to these investments, such as engagement, voting at shareholder meetings and formulating exclusion policies. A second concern is whether the ACM should also be the regulator for regulated financial companies. DUFAS believes that the AFM is the appropriate supervisor for its members because the WIVO requirements are closely related to other financial sector legislation that the AFM already supervises. This prevents differences in interpretation and in implementation of supervision.
Finally, DUFAS notes that the WIVO once again demonstrates that the implementation of the supervision of financial enterprises cannot be separated from the public interest that the supervision serves with it. It is therefore obvious that the government should also make a financial contribution for this supervision, as DUFAS has previously advocated.
