4:78 In principle, an assessment of expertise always relates to an individual. However, when the assessment relates to a position in a multi-member body, account must also be taken of the composition and operation of this body as a whole[1]. This means that it must be checked whether the expertise within the body is sufficiently guaranteed with the person concerned, in view of his/her knowledge, experience and skills. The same applies to the senior management in cases where the company does not have a management committee.

4.3.5.1 Areas of collective suitability

4:79 The board of directors and the management committee should collectively be able to understand the company’s business, including the main risks to which it is exposed.

4:80 The collective knowledge, skills and experience that must be present in the relevant body depend on the characteristics of the company. In determining the areas of collective suitability to be present in the board of directors and the management committee, account should be taken of the company’s business model, strategy, risk appetite and risk profile and of the nature, scale and location of its activities.

4:81 In accordance with the EIOPA Guidelines, collective suitability should at least cover the following areas:

1. insurance and financial markets;
2. the company's strategy and business model;
3. the governance system;
4. financial and actuarial analysis;
5. the regulatory context and requirements.

4:82 These are minimum criteria. The NBB recommends also considering the following areas, unless the company can demonstrate that they are not relevant:

• risk management, compliance and internal audit;
• information technology and security;
• climate and environmental risk;
• local, regional and international markets;
• where applicable, money laundering and terrorist financing risk; and
• where applicable, the management of (inter)national groups and risks related to group structures.

4:83 In this context and taking into account the proportionality principle, the NBB pays particular attention to the following 3 components of the assessment of collective suitability: (i) information technology and security; (ii) environmental and climate risk; and (iii) money laundering and terrorist financing risk (for companies carrying out life insurance business). 

4:84 These areas must be specified in the company's suitability policy. 

4.3.5.2 Assessment

4:85 When assessing collective suitability, companies should assess the composition of the board of directors and that of the management committee separately. While the management committee should collectively have a high level of managerial skills, the board of directors in its policy/strategy and supervisory function should collectively have sufficient management skills to organise its tasks effectively and to be able to understand and challenge the management practices applied and decisions taken by the management committee.

4:86 The collective suitability of the board of directors and the management committee should be assessed using a matrix. Companies should use either:

1. the suitability matrix template used in the fit & proper form; or
2. their own appropriate methodology in line with the criteria set out in this Manual.

4:87 The company also assumes responsibility for identifying gaps by conducting continuous self-assessments of its board of directors and management committee.

4:88 Based on the information provided by the company, the NBB assesses the extent to which the applicant contributes to collective suitability.

4:89 Finally, it should be noted that companies are required to inform the NBB of any distribution of tasks between members of the management committee and non-executive directors, as well as of any significant changes thereto.

^{[1] In this respect, Article 273(3) of Delegated Regulation 2015/35 provides the following: “The assessment of whether members of the administrative, management or supervisory body are fit shall take account of the respective duties allocated to individual members to ensure appropriate diversity of qualifications, knowledge and relevant experience to ensure that the undertaking is managed and overseen in a professional manner”.}