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The International Corporate Governance Network (ICGN) appreciates the opportunity to 
comment on the Proposal to update the Dutch Corporate Governance Code (2016). We believe 
this review is timely given the ongoing rise in the application of environmental, social and 
governance (ESG) considerations for companies, investors, and stakeholders and subsequent 
updating of codes, laws, and regulations around the world to promote sustainable business 
approaches generating long-term value creation and enhanced accountability.

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