Answers_OPFVBUvB_GreenPaper_final_121110

8/8/2019 Answers_OPFVBUvB_GreenPaper_final_121110

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Green Paper towards adequate, sustainable and

safe European pension systems

Answer of the Dutch Pension Fund Organizations, VB, UvB and OPF

November 12th

, 2010

Preliminary Remarks

The Dutch Pension system is based on a multi-pillar approach with a strong role for

occupational pensions in the second pillar covering 90% of the working population in The

Netherlands. The Dutch Pension Fund Organizations OPF (representing the company pension

funds), UvB (representing the pension funds for liberal professions) and VB (representing the

sector wide pension funds) emphasize the need for such a multi-pillar approach to pensions in

Europe. In the occupational pensions area the Dutch Pension Fund Organizations favor

collectivity and risk sharing as powerful principles in their system.

At the European level, occupational pensions should continue to be considered as part of

labor agreements. Pension funds use the financial markets to increase the return on

investment and to hedge risks for the sole profit of the beneficiaries. Any EU rule on

occupational pensions should take account of these specific characteristics.

Apart from adequacy, sustainability and security, the governance of the pension schemes and

communication to beneficiaries are also important issues in retirement provision.

The second pillar pension system in the Netherlands is fully funded. High inflation is one of

the most important threats. The Dutch Pension Fund Organizations would like to stress the

importance of the Growth and Stability pact to ensure an acceptable level of inflation in the

European Union.


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The Dutch Pension Fund Organizations call for an impact assessment of any planned EU

regulation on pensions whilst respecting the social and labour law of the Member States.

Any EU regulation on pensions should

take into account the specific role of social partners, whilst governments at Member

State and EU level offer a facilitating regulatory framework;

respect the subsidiarity principle in retirement benefit provision and associated

regulatory framework in the Member States;enhance long-term sustainability of the rich variation in retirement provision in EU;

ensure efficiency and flexibility for all provisions in the Member States.

This is certainly important for a review of the IORP Directive. We think that more time for

the IORP Directive is needed to demonstrate its use in practice, since it is after all a very

young directive.We also draw the attention to the discussions around the international

accounting standards in this respect.

The Dutch Pension Fund Organizations are ready to provide their expertise in the ongoing

discussions.

Contact:

Sibylle Reichert

Representative of the Dutch Pension Fund Organizations

[email protected]

Tel.: 0032 2 647 02 00
mailto:[email protected]:[email protected]:[email protected]


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The following contains the Dutch Pension Fund Organizations answers to the Green Paper

towards adequate, sustainable and safe European Pensions, and their reflections on the future

of the European Pension Systems.

QUESTION 1

How can the EU support Member Statesefforts to strengthen the adequacy of pensionsystems? Should the EU seek to define better what an adequate retirement income might

entail?

We do not subscribe to the need for the EU to define what an adequate retirement income

means, since this differs largely from one Member State to another and in addition within

each Member State. Here we refer to the principle of subsidiarity and to the capacity of the

Member States to organize their pension system and their adequacy according to their national

needs.Dutch pension funds are not in the position to define an adequate retirement income.However, we do underline the important elements of our national pension systems in order to

achieve such an adequate income. These elements, a basic old age State pension, collective

spreading of risks, responsibility of the individual and flexibility in occupational pension

provision are present in a multi pillar system such as ours.

Many countries rely strongly on their statutory pension pillar. In the opinion of the Dutch

Pension funds achieving adequacy of pension systems is best served with a solid multi-pillar

approach to pensions, where all pillars provide their share to an adequate retirement income.

As representatives of occupational pension systems, we do subscribe to a strong second pillar

to supplement the first pillar and give people the opportunities to look for supplementary

private provision in order to be able to rely on several pillars for their retirement income.

Member States and the European Commission should facilitate the setting up of occupational

pension systems that are managed by Social Partners. Social Dialogue on social protection

issues should therefore be enhanced at European and national level.


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QUESTION 2

Is the existing pension framework at the EU level sufficient to ensure sustainable public

finances?

Pensions are foremost a matter that fall under the subsidiarity principle. In the framework of

the Open Method of Coordination Member States are encouraged to reform their pension

systems. This is on the one hand a soft law instrument, where Member States agree on joint

objectives for their social protection reforms, report on the ongoing and outcomes of reforms

and share their experiences. In this context, the EU could certainly enhance sharing of best

practices of Member States on their reforms.

On the other hand the Stability and Growth Pact agreed upon by the Member States at the

launching of the EURO could represent an even stronger instrument to encourage Member

States to make their pension system shock proof to the ageing of the societies and to future

economic crises. The Dutch Pension Fund Organizations think that the European Union

Pension framework on ensuring sustainable public finances should therefore be re-inforced

whilst respecting the subsidiarity principle. The recent measures taken with regard to the

Stability and Growth Pact and the so-called European semester should be strong enough to

ensure that sound economic governance and reforms of the social protection systems will be

promoted and realized in all the Member States.

QUESTION 3

How can higher effective retirement ages best be achieved and how could increases in

pensionable ages contribute? Should automatic adjustment mechanisms related to

demographic changes be introduced in pension systems in order to balance the time spent in

work and in retirement? What role could the EU play in this regard?

Setting the retirement age is falling under the Member States sovereignty and under the

principle of subsidiarity. In this respect it is also important to underline the role of social

partners within the sectoral and companywide social dialogue.


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In the Netherlands, the Social Partners came up with a new Pension Deal1

in order to face the

challenges of Ageing and the Financial and Economic Crisis. They propose more flexibility in

the pension contracts and a number of fundamental adjustments:

Equal pension age for the state and occupational pension;

increase retirement age to 66 in 2020 and possibly to 67 in 2025;

pension age shall affect pension accruals and rights thus conditioning accrued pension;

rights to the increasing life expectancy;

apply this automatic adjustment mechanism once every five years on authorized data

regarding life expectancy;

adjust to life expectancy on a fund by fund basis;

allow for individual flexibility.

The EU should play a role in assisting to changing the attitudes towards elderly workers,

which is of utmost importance to convince companies to hire elderly and profit from their

experience. At the same time, the EU should support national programs for lifelong learningand foster the social dialogue at European level.

Automatic adjustment mechanisms related to demographic changes need to be introduced in

pension systems in order to balance the time spent in work and in retirement. The

implementation of these automatic adjustment mechanisms is up to the Member States. The

European Union can provide for corresponding recommendations. The Dutch Pension Fund

Organizations think that it is not sufficient to adjust the pension systems only, but that there is

also a need to provide for an elderly friendly employment policy.

With regard to adjustment mechanisms, the Dutch National Bank requires Pension Funds to

take into account the national mortality tables and adjust their technical provisions

accordingly. In case of a shortfall, the Dutch pension funds have the possibility to increase

contributions, limit indexation or as a measure of last resort to reduce pension rights.

1 See: http://www.stvda.nl/nl/publicaties/convenanten/2010-2019/2010/20100604.aspx


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QUESTION 4

How can the implementation of the Europe 2020 strategy be used to promote longer

employment, its benefits to business and to address age discrimination in the labour market?

The EU 2020 strategy foresees that until 2020, 75% of the population aged 20-64 should be

employed. In the flagship initiative An Agenda for new skills and jobs the aim is to

modernize labour markets with a view to raising employment levels and ensuring thesustainability of our social model.

2

The instruments proposed such as the flexicurity agenda, cooperation in education and

training involving all stakeholders, the European Skills, Competences and Occupations

framework (ESCO) etc. seem to be good starting points to help change the attitudes of

companies in hiring elderly on the one hand and ensure that people continue learning and

educating themselves in the course of their professional life. Also in this area, the Dutch

Pension Fund Organizations call for enhancing the social dialogue at European level and

support Member States and national social partners in implementing the proposed measures.

QUESTION 5

In which way should the IORP Directive be amended to improve the conditions for cross-

border activity?

The IORP directive (2003/41/EG, June 3.2003) was intended to allow pension funds to

benefit from the free provision of services and free movement of capital, but also to set up

prudential standards for occupational pension institutions. Although it was aimed at the

removal of barriers for the cross border movement of retirement provision and hence

promoting the free market objectives in this particular area, the uptake of the Directives

opportunities is not significant. One would assume that the internationalization of businesses

and international mobility will demand efficient facilities for cross border pension provision.

2 See Europe 2020, page 16 ff.


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It is obvious that evidence has not materialized since the introduction in 2003, nor is it clear

as yet how strong this demand will be in the near future. Many traditional international

companies seem to have found adequate solutions for retirement provision for their

international workforce and are (currently) predominantly interested in cross border asset

management and or pooling for which they found (near) adequate solutions within the

framework of national legislation. Nevertheless a trend can be seen that multinational

companies are increasingly investigating the possibilities of establishing cross border (group)

pension vehicles, as some of those companies are on their way of establishing cross-borderIORPs.

A number of definition shortcomings have already been identified by the Commission and

will be addressed, e.g. what constitutes cross border activity, ring-fencing of assets and what

constitutes social and labor law as well as tax issues. The real challenge, however, will be in

creating frameworks/rules for facilitating cross-border activity and enhance security and

sustainability of pension provision without creating a tightening European regulatory

framework for second pillar pensions that, in practice, may apply to only very few member

States because of the very nature of their legal framework for pensions in the (historical)

context of social and labor law development. Against this background, a top down approach

aiming at minimum retirement income levels and equalized or harmonized pension security

levels across Europe is considered inappropriate and will probably not be effective in its end

result given the rich variety of retirement provision and the funding/financing thereof in

Europe. Furthermore, according to us, the establishment of cross-border DB schemes is

virtually impossible by the IORP Directive, because of the fully funding requirement of

technical provisions in respect of cross border DB-schemes (article 16.3 IORP). That means

that cross-border pension funds will most likely to accelerate even more the shift from DB to

DC schemes. Therefore, we think that it is necessary to relaxing the fully funding provision

by allowing for appropriate recovery periods.


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QUESTION 6What should be the scope of schemes covered by EU level action on removing obstacles for

mobility?

Increased job mobility and more people alternating periods of paid employment with self-

employment or resort to self-employment for most of their working life are becoming more

common features. Discontinuity in accrual of retirement income provision occurs more often

and could lead to insufficient provision in old age. This demands a strengthening and

increased flexibility of 2nd pillar pension provision and the recognition of the need to start

building up pension rights from very early stages. The Dutch Pension Fund Organizations

underline nevertheless that pensions are not the only issue that may hinder mobility. Member

States should cooperate bi-laterally to remove all obstacles to mobility. Only a small

proportion of the population is mobile, therefore we question the need for setting up a

European framework for the portability of pensions. Wed advocate bi-lateral agreements or

EU-wide agreements of social partners. Therefore, redrafting the pension contract between

social partners will be needed, also against the background of the effect of the financial crisis

and longevity on all sorts of pension provision. This will probably prove to be a difficult and

cumbersome process in all Member States.

Occupational retirement schemes in are looked at in many different ways in the Member

States, e.g. some rank these under the 1st pillar, most under the 2nd pillar and some, even

although they are regulatory, under the 3rd pillar. In addition there is the DB and DC issue.

Any action on removing obstacles for mobility should therefore concern all work related

pension schemes in every member state, independent of how these schemes are submitted to

national pillar structures. Mobile citizens moving cross border between the Member States

should, in principle not be disadvantaged against citizens moving within a Member State as

far as the accumulation of pension rights and the protection of accrued pension benefits is

concerned. But also in this respect the European Commission should not go any further than

defining general principles with sufficient flexibility for the Member States to accommodate

them within their own (legal) structures.


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QUESTION 7Should the EU look again at the issue of transfers or would minimum standards on

acquisition and preservation plus a tracking service for all types of pension rights be a

better solution?

The original portability proposal afforded employees the right to transfer accrued pension

rights. But transfer was too complex with regard to the valuation and taxation of pension

rights. Pension contributions are often exempt from taxation and pension benefits are taxed.

So, Member States with high retirement wealthand a high future tax claimcould face asubstantial loss in tax revenue with cross-border transfers of pension capital. On the valuation

part there appeared a large variety in technical and actuarial parameters used for transfers

within the various Member States, even those where a longstanding practice had been

established. This situation has not changed since then and we consider it very doubtful

whether a common base can be found for achieving this in the foreseeable future. It would

only work if pension institutions were allowed to use their own standards for the valuation

and transfer, regardless the level of pension benefit a beneficiary would receive for this value

in the new country of work/residence and Member States would be able to maintain effective

safeguarding mechanisms for preventing tax evasion on pension benefits.

Minimum standards on the acquisition of pension rights suitable for incorporating in the

framework of social and labor law in the Member states and on the preservation of accrued

pension rights are, in our opinion, the better solution for this issue. Due attention should be

paid to the effect of any such regulation on the cost level of the retirement provision. The

more so since the social partners and governments in many Member States are now going

through a difficult and sometimes painful process of reforming retirement provision in order

to contain the cost and revamp the sharing of risk of retirement provision.

A tracking service for pension benefits is a vital tool for member and client communication.

Initiating a tracking system at a European level seems a bridge too far. Some Member States

have existing good working systems;3

others are making progress in setting this up. An up

scaling activity demands a great deal of coordinated effort and does not go without

(considerable) cost. Before embarking on such a complex project it would seem advisable to

3 See also: http://www.pensioenregister.nl/


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learn first from the experienced Member States. An important point to assess will be, whether

the mobile citizen will be served according to his/her needs and whether the number of

international mobile workers stands in a reasonable proportion to the total working population

in Europe. Here the EU could play a stimulating role.

QUESTION 8

Does current EU legislation need reviewing to ensure a consistent regulation and supervision of

funded (i.e. backed by a fund of assets) pension schemes and products?

If so, which elements?

A review of current EU legislation could be desirable if one wants to achieve a more

consistent regulation and supervision of pensions.

The Dutch Pension Fund Organizations propose to broaden the scope of this regulation and

supervision (in the IORP-directive) to all types of occupational/work related pension schemes

(DB, DC, book reserves, PAYG) which exist in the EU Member States, independent of how

these schemes are submitted to national pillar structures. The exemption of book reserve and

pay-as-you-go schemes nowadays gives rise to the situation in which similar pension schemes

may be covered by the IORP Directive in one country and not in another country.

To ensure a clear separation of prudential regimes for insurers and pension funds, the scope of

the IORP Directive could be restricted to not-for-profit institutions where the risks are borne

by employers and (future) plan members. As a result, Art. 4 of the IORP Directive should be

deleted from the text.

QUESTION 9

How could European regulation or a code of good practice help Member States achieve a better

balance for pension savers and pension providers between risks, security and affordability?

The Dutch Pension Fund Organizations propose to give more attention to the pension benefits

and the risks involved.


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This does not imply that pension providers and pension savers may not benefit from the

availability of information about practices applied in EU Member States.

Such information should become available, preferably in the form of a survey of good

practices. A code of good practice would not be recommended, because this would imply a

rule setting character which would not be suitable for the diverse pension landscape in Europe

as explained above.

In a survey of good practices, attention might be paid to the Dutch pension system. This

system comprises a strong second pillar occupational pension provision (DB-type) with thefollowing characteristics: (i) risk sharing between generations, (ii) limited (or lower?) costs

as a result of collectivity, (iii) professional investment policies, and (iv) the delivery of an

annuity (thus not a lump sum payment) on the pension date. In practice these characteristics

vary substantially between pension schemes within EU Member States as well as between

Member States. As a result, European regulation (adequately covering all these situations)

would not seem feasible.

In case of DC-arrangements good practice could contain the following characteristics: (i) the

possibility of a default option, in combination with life cycle investment strategies,

(ii) restricted number of alternatives for participants, (iii) collectivity, and limited costs as a

result, and (iv) the delivery of an annuity on the pension date.

QUESTION 10

What should an equivalent solvency regime for pension funds look like?

First of all, we would propose to talk about a pension security regime rather than a solvency

regime. This would allow to clearly differentiating from solvency rules for insurers. Secondly,

the Dutch Pension Organizations recommend a proper qualitative and quantitative impact

assessment before deciding about rules for pension security. Thirdly all reflections on pension

security should go hand in hand with the review of the IORP Directive and be part of that

directive.


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The Dutch Pension Fund Organizations think that the current IORP directive already contains

elements for improving the security of pensions. As also mentioned in the Green Paper, a

pension security regime should be tailor made for pension schemes (as also expressed by

renowned organisations such as the Groupe Actuariel Consultatif and the OECD) and should

take fully into account the specific features of pension funds and the nature and duration of

the pension promise (as also mentioned in the Green Paper).

Furthermore the level of focus on quantitative rules, qualitative conditions, and disclosure

requirements should be related to the character and security of the pension promise involvedand should be a societal choice.

In respect of the desirable scope of a security regime for pension funds we refer to our answer

on Question 8.

A security regime for pension funds can be developed by extending it with the principles put

forward by CEIOPS, Group Consultatif and the OECD.

The Groupe Consultatif4

offers the following list:

Balanced: Achieve a balance between a high degree of security and affordable cost to the

sponsor in the context of sustainable pension systems as decided by member states.

Forward-looking and risk-based: Take account of the inherent risks, not just at particular

points in time but also on aforward-looking basis.

Market-based: Use available market inputs to determine the appropriate measurement

basis for assets and liabilities, within the context of the risks that are considered

acceptable.

Transparent: Provide full transparency to all stakeholders about how the financial position

has been determined, including how the various risks are managed and their potential

rewards and consequences.

Proportionate: Beproportionate to the nature, complexity and scale of the inherent risks

without imposing disproportionate compliance costs.

Flexible: Haveflexibility to adapt to changing conditions.

4See Security in occupational pensions (May 2010). The principles of the Groupe Consultatif include these of

CEIOPS and OECD.


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Counter-cyclical: Be counter-cyclical, with incentives for pension schemes to improve

security buffers during favorable economic and business conditions so that they may

provide protection in less favorable conditions.

Practical: Bepractical to implement and administer.

The detailed implementation of those principles should be left to the member states to

facilitate the diversity in funding and valuation rules. In particular the security mechanisms ofpension schemes, which make pensions very distinctive from bank and insurance products,

should be taken into account (CEIOPS 2008). A good and fair assessment of these security

mechanisms and how they will be applied if and when needed is relevant. However, in the

event of common regulatory approaches, the principles should be further elaborated in the

IORP Directive. An overarching principle of a future IORP Directive should be that

communication is consistent with the pension promise and the security position. This is a very

strict requirement that ensures that pension funds possess sufficient (internal or external)

capital to back-up pension promises. Pension funds that place risks with the plan members

as with DC schemesshould be transparent on that.

We see scope for reinforcing the IORP Directive with regard to provisions in the area of

governance (risk management, conflict of interests, remuneration, involvement of employers

and employees), outsourcing to external service providers and responsible investment policy.

In that respect, a pension security regime should also include guidance on risk management,

governance and the role of various stakeholders. A survey of best practices about risk

management and governance would be very useful to assist shaping the guidance.

Possibly, there can be some tensions between the targeted adequacy and supervision in the

form of a pension security regime. Stricter supervision in the form of a (very) prudent pension

security regime can lead to higher costs for servicing a pension scheme and could put pressure

on the sustainability and adequacy. Another possible tension is that between prudential

supervision of (individual) pension schemes and the consequences for the macro economy

and the financial system. Too prudent pension security rules can also lead to pro-cyclical

consequences for the economy, a more counter-cyclical approach seems more desirable.


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Next to having balanced supervision of pension security, conduct of business supervision is

also very important and should be balanced with the prudential supervision. Conduct of

business is very important since this should be in line with or the form in which supervising

disclosure is organised.

Although it is the European Commissions role to set the timetable for the possible next steps,

we can imagine that discussing about the principles defined by OECD, CEIOPS and Groupe

Consultatif would be a good starting point. Surveying how the elements5 quoted in the

Groupe Consultatif report are organised and shaped in Europe would be very helpful ingetting a better understanding of the diverse landscape of European pensions. If, at the same

time pension schemes would work on better disclosure of current practice and pension

benefits, we see room for ample improvement. At a later stageif and when needed!the

next steps could be to work on a separate solvency regime for funded pension schemes

IORP II, like Basle III for banks and Solvency II for insurers. The formulas and calibration of

such a system would come as one of the last stages, like the calibration of Solvency II is

currently getting shape via the various Quantitative Impact Studies."

Another survey that would be useful and can be used to give guidance is investigating the best

practices in Europe.

QUESTION 11

Should the protection provided by EU legislation in the case of the insolvency of pension sponsoring

employers be enhanced and if so how?

An important risk in occupational pension provision is a bankruptcy of the sponsoring

employer. Article 8 of the IORP Directive recognises this by imposing a legal separation

between the sponsor and the pension fund to safeguard the assets in the interest of the plan

members. However, pension funds arerightly sopermitted recovery periods, which means

that assets may be insufficient to cover technical provisions for periods of time. Some

countries apply relatively strict funding standards permitting funding ratios below 100% only

to a limited extent and for a limited time period. Other countries apply more lenient funding

5 See the Groupe Consultatif report Survey of pension security in some European countries.


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standards or may even allow book-reserving, but such is often combined with mandatory

participation in insolvency protection schemes.

We are not in favour of promoting pension benefit guarantee systems in the Member States,

possibly coordinated or facilitated at EU level to address failures in sponsor-backed DB

schemes, book-reserve schemes or excessive losses in DC schemes, as suggested in the

Green Paper. However, there is a real danger (moral hazard) that DB and DC plans would

engage in excessive risk-taking when risks can be shifted to collective guarantee

arrangements, both when such arrangement would be funded by the government (in whichcase also a discussion on a public support aspect could arise) as well as when funding would

be delivered by companies in the same business sector.

The existing Insolvency Directive requires Member States to ensure that guarantee institutions

guarantee payment of employees outstanding claims resulting from contracts of employment

or employment relationships. However, it is left to the discretion of individual Member States

to exempt supplementary occupational pensions from its scope.

Specifically with regard to the Netherlands, it can be mentioned that occupational pensions

are delivered by pension funds which are legally separated from the sponsoring company.

Furthermore a strict financial supervisory regime is applicable for these pension funds. As a

result insolvency or a bankruptcy will not have a material impact on the rights to occupational

pensions of the employees.

QUESTION 12

Is there a case for modernising the current minimum information disclosure requirements for pension

products (e.g. in terms of comparability, standardisation and clarity)?6

The current IORP directive states that proper information for members and beneficiaries of a pension

scheme is crucial.7

This is of particular relevance for requests for information concerning the financial

health of the institution, the contractual rules, the benefits and the actual financing of accrued pension

entitlements, the investment policy and the management of risks and costs.

6 See Annex 1 : Project niet opgevraagde pensioenen

7Seewww.uniformpensioenoverzicht.nl
http://www.uniformpensioenoverzicht.nl/http://www.uniformpensioenoverzicht.nl/http://www.uniformpensioenoverzicht.nl/http://www.uniformpensioenoverzicht.nl/


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In our view, people should be informed in writing when joining the pension scheme and they should

receive a pension statement regularly in order to stimulate financial education. Moreover,

communication about life events that may affect accrued pension entitlements such as divorce or

marriage should be mandatory.

Clear language is also of the utmost importance. Due to the great variety of pension schemes and

systems within the EU, we would not recommend a standardized approach that goes beyond the

suggestions mentioned above. The risk of down levelling the relatively high communication standards

that apply in some Member States might occur in case of harmonization and standardization.

QUESTION 13

Should the EU develop a common approach for default options about participation and investment

choice?

Presence of default options in Dutch occupational schemes

On scheme level, default is not an option in the Dutch occupational pension system. Dutch

occupational schemes are characterized by a mandatory participation leading to high participation

levels and a decent pension accrual.

Apart from this standard there are additional optional arrangements, where individual choice can be

expressed. These optional arrangements are occupational as well (covered by collective bargaining,

fiscally facilitated and complying with technical provisions of the standard scheme). Through these

optional arrangements default options are present in our system.

EU relevance of developing a common approach

A common approach for default options about participation and investment choice might have a

positive influence seen from the perspective of protection of beneficiaries. In this respect, disclosure

and decent information provision to the individual member are essential.

When assessing a common approach for default options about participation and investment choice we

are convinced that this approach should be principle based. There are substantial differences between

member states regarding occupational pensions as part of basic income security and stability. A

principle based approach would comply better with these differences. These principles should imply

the following:


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A. Protection of beneficiaries principle (zorgplicht, duty to have regard for the welfare of schememembers)

B. Follow the disclosure principles IORP about the information given to members and beneficiariesthat indicate proper information provision concerning:

financial health of the institution,

the contractual rules,

the benefits and the actual financing of accrued pension entitlements,

the investment policy

the management of risks and costs

When these principles are met, the development of a common EU wide approach for default options is

worth assessing.

QUESTION 14

Should the policy coordination framework at EU-level be strengthened? If so, which elements need

strengthening in order to improve the design and implementation of pension policy through an

integrated approach? Would the creation of a platform for monitoring all aspects of pension policy in

an integrated manner be part of the way forward?

With respect to policy coordination, the Dutch pension funds regard subsidiarity as key condition:

differences between pension systems and schemes in the EU member states are phenomenal. Well-

functioning and proven practices in pension fund governance as well as pension fund management are

worthwhile to be shared amongst member states through the existing Open Method of Co-ordination.

The Dutch pension fund Organizations also stipulate the potential role of the EU Pension Forum that

was created by the European Commission in 2001. This forum consists of experts, representatives

from the Member States, social partners and associations of pension funds and it addresses the issue of

pensions and mobility in that context. We advocate for continuing the holistic approach taken with the

Green Paper meaning that pensions need to be looked at from a macro-economic, social policy and

internal market policy point of view.

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