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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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