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Response to consultation on Guidelines on internal governance (revised)
Go backQuestion 1: Are the guidelines regarding the subject matter, scope, definitions and implementation appropriate and sufficiently clear?
yesQuestion 2: Are there any conflicts between the responsibilities assigned by national company law to a specific function of the management body and the responsibilities assigned by the Guidelines, in particular within paragraph 23, to either the management or supervisory function?
n.a.Question 3: Are the guidelines in Title I regarding the role of the management body appropriate and sufficiently clear?
yesQuestion 4: Are the guidelines in Title II regarding the internal governance policy, risk culture and business conduct appropriate and sufficiently clear?
yesQuestion 5: Are the guidelines in Title III regarding the principle of proportionality appropriate and sufficiently clear?
yesQuestion 6: Are the guidelines in Title IV regarding the internal control framework appropriate and sufficiently clear?
While the draft guidelines are generally excellent, I propose a couple small but important changes. See the attachment.Question 7: Are the guidelines in Title V regarding transparency of the organization of the institution appropriate and sufficiently clear?
yesQuestion 8: Are the findings and conclusions of the impact assessments appropriate; please provide to the extent possible an estimate of the cost to implement the Guidelines differentiating of one-off and ongoing costs?
n.a.
