Candidates are not allowed to carry out any policy-making activities until we have issued a positive decision.
If an institution publicly announces a proposed appointment before initiating or completing the assessment procedure, it does so at its own responsibility and the candidate's responsibility. The announcement will need to mention clearly that the proposed appointment is subject to assessment and a positive decision issued by DNB. The candidate too must consider the possible implications when referring to their new position on social media.
Consideration periods depend on the laws under which candidates are assessed. In practice, we try to complete the procedure within six weeks. However, depending on the nature and complexity of the assessment this period may increase to 13 weeks, and even longer in exceptional cases. Should this situation arise, we will inform institutions of the reasons for the extension.
Based on our preliminary assessment and any assessment interviews, we draw up a provisional decision. This invariably involves a responsible senior manager, with any doubts or special cases always discussed and reviewed at higher levels. Significant banks must also take into account the procedures prescribed by the ECB.
A candidate can be appointed and work in a policy-making capacity once we have issued a positive decision. We first contact the candidate and the institution by telephone to inform them of our positive decision, and we subsequently send them a written confirmation.
If we intend to issue a negative decision, we will inform the candidate in writing of our intention to issue a provisional negative decision and contact them by telephone to explain our findings and conclusions. The candidate and the institution may present a statement of views in response to the provisional decision. If we decide to uphold our negative decision, they will have the option to object and appeal successively.
In those cases in which we intend to issue a provisional negative decision, the reason for doing so is often based on the candidate's lack of knowledge and experience for the specific position combined with the composition of the board as a whole. Negative decisions also occur relatively often for specialist positions requiring specific knowledge. For a proposed appointment to a pension fund’s investment committee, for instance, we apply stricter requirements regarding the level of knowledge about investment policies and asset management.