Questionnaires concerning the reporting of substantial holdings and insider transactions

In December 2008 the AFM has sent out questionnaires to selected market participants regarding the reporting of substantial holdings and the reporting of transactions of directors and members of the Supervisory Board.

The purpose of these surveys was to gain insight into the systems and compliance rules concerning the substantial holdings and insider transactions notification process.

In June 2010 the AFM invited other market participants to participate in a new survey regarding the reporting of substantial holdings and insider transactions, seeking to update the previous results. This will help the AFM to understand how market practice has developed. It will also allow the AFM to identify best practices, which may serve to offer guidance to the market.

The AFM expresses its gratitude to the participants and hopes that the report that follows provides information which may prove useful in the assessment of the effectiveness of the internal rules, policies and controls concerning the notification process.