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
sreichert@opfvb.eu
Tel.: 0032 2 647 02 00

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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 States’ efforts to strengthen the adequacy of pension
systems? 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 learning
and 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 the
sustainability 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 Directive‟s
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-border
IORPs.
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 6
What 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. We‟d 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 7
Should 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 wealth – and a high future tax claim – could face a
substantial 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 the
following 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 involved
and 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 a forward-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: Be proportionate to the nature, complexity and scale of the inherent risks
without imposing disproportionate compliance costs.
Flexible: Have flexibility to adapt to changing conditions.

4
See „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: Be practical 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 of
pension 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 schemes – should 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 Commission‟s 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 in
getting 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 stage – if 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 are – rightly so – permitted 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 which
case 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
7
See 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 scheme
members)
B. Follow the disclosure principles IORP about the information given to members and beneficiaries
that 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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