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Pilot project with external experts


Published: 17 July 2018

Latest update: 09 November 2022

We launched a pilot project for involving external experts in our fit and proper assessments, in tandem with the AFM, which ran until July 2019. What did the pilot project entail?

We launched the pilot project in response to the recommendations of the Ottow Committee, which evaluated our fit and proper assessment process. Its aim was to strengthen the independence and professionalism of the process, as well as its public support.

DNB and the AFM each engaged their own external experts, whose tasks and activities were identical. We selected the experts on the basis of their governance experience and expertise.

They were involved in initial assessments for both propriety and fitness. They had access to the assessment file, took part in the assessment interview and participated in subsequent deliberations. They were engaged at the supervisory authority's request, meaning the appointee could not request their involvement. However, if an appointee were to object to the involvement of an external expert, that objection would be granted.

External experts were also involved in reviewing desk-based initial assessments in terms of their substance and the process. These assessments did not involve an interview. The external experts functioned independently and made their own judgements.

The pilot project also involved the appointment of a confidential adviser. Complaints about an appointee's treatment or procedural conflicts could be submitted to the confidential adviser, who was not involved in forming a judgement on the substance of the assessment.

If an appointee should disagree with a provisional or definitive decision, they could present their views and file an objection. The confidential adviser was not involved in this.

Lastly, the pilot project also involved the appointment of an external chair of our appeals committee, who was responsible for orderly proceedings during an appeal hearing. This person monitored the process, overseeing the careful gathering of all relevant facts to get to the heart of the matter.

All external experts were appointed for the duration of the pilot project.


Given the positive experience gained during the pilot, DNB and AFM decided to give the appointment of confidential advisors a more structural character. The appointment of the external chairman of the appeals committee against decisions on assessments has also been given a structural character.

As of July 2021, Ms D.M.J.J. Monissen and Mr prof. dr. J.A. van Manen have been acting as confidential advisers; as per August 2023 no longer as part of a pilot. In 2022, Mr mr.dr. J.A.F. Peters was appointed as the external chairman of the appeals committee.

You can contact the confidential advisors at vertrouwenspersoon@smclaren.com. This email address is for the sole purpose of establishing the initial contact. You can ask to be called back or emailed by the confidential adviser. It is therefore not intended for the exchange of documents. The confidential adviser will provide you with a different email address if desired.