Social Decency Policy

Social Decency Policy of DTM and Interroyal (the Policy)

The Dutch Central Bank (“DNB”) has published a policy on social decency for trust offices which entered into force on 16 January 2020. The Policy implemented by DNB establishes rules regarding the way in which it assesses to what extent trust offices prevent the risk of involvement of the trust office or its employees in acts that go against what is appropriate in society in accordance with unwritten law, that subsequently can seriously damage confidence in the trust office or in the financial markets in general.

DTM and Interroyal (herewith to be referred to as “DTM”) as a trust office with its registered seat in the Netherlands declares its obligation to comply with Dutch national legislation including DNB Guidelines, therefore, a Policy on Social Decency has been developed and adopted by DTM  and Interroyal as prescribed by DNB.

In relation to the implemented Social Decency Policy, we confirm that DTM and Interroyal do not wish to cooperate with companies/persons which are involved in socially inappropriate activities. Therefore we identified the specific kinds of clients/countries/activities, which will be rejected as  clients by DTM.

DTM does not provide services to individuals and/or entities active in the following lines of business:

  • Arms related business;
  • Banking sector;
  • Exploitation of persons, such as child labor;
  • Violation of human rights;
  • Gambling industry (unless accepted under Dutch law, as currently the legalization thereof in the Netherlands is discussed);
  • Trade in illegal or undesired goods (for instance ivory, blood diamonds, rare animal species).

Furthermore, DTM does not provide services to individuals and/or entities (read: the UBO or the Object Company) convicted for particular illegal or criminal activities, such as financial crime (for instance money laundering, tax fraud and any terrorism financing). The reason hereof is that the integrity of such persons is not beyond doubt and DTM does not want to render services to such persons and/or entities, which may also damage the reputation of DTM.

DTM reserves the right to reject clients or refuse to provide services to other individuals or entities if case-by-case analysis on the basis of DTM policies shows that they are socially inappropriate.

Feel free to contact us for more details.