Our Code of Conduct - Swedbank

1Our Code of Conduct

Why is ourCode of Conductimportant?The financial system is dependenton public trust in us as a bank.Few things are more impactful than the impressionan individual employee of the bank can make on acustomer.The Code of Conduct therefore is in place to serve as aframework to clarify the guidelines you have to followas an employee of Swedbank and the expectations thebank has on you in terms of each individual’s judgementand responsibility.No rules can replace personal responsibility. The ruleshave to be followed, but more importantly they shouldencourage us to openly discuss conflicts that arise onthe job.The Code of Conduct assumes that we all have an innercompass that helps us to distinguish between rightand wrong. How successful we are in transformingthis into a sound culture and good behavior dependson each and every one of us.That’s why this Code of Conduct folder is necessaryand is important to read and use, but also why weneed your opinions to improve the next version.2 3

Your responsibilityOur contactsThe Code of Conduct is a part of the Swedbank Group Framework.The Group Framework is Swedbank’s governance structure andcontains our Group wide internal regulation. All employees areexpected to comply with the Group Framework. What this meansfor you personally differ if you are employee or manager.CustomersAs an employee you should- Understand the policy statements made in the Code of Conduct- Learn the details of the rules and procedures that are relevant toyour job- Raise any concerns or questions regarding compliance with yourmanager or a Compliance OfficerCompetitorsEmployeesAs a manager you should- Contribute to create a culture of compliance with theGroup Framework- Personally lead compliance efforts- Build the infrastructure in your area of responsibility in accordancewith directions given in the Group Framework to prevent, detect andrespond to any issues of non-complianceSuppliersSwedbankCommunityFirst and foremost, use your common sense. In situations whereyou are uncertain what to do, ask for guidance from your immediatesupervisor or the Compliance Officer in your unit. You can also turnto these individuals to report a wrongdoing.AuthoritiesShareholders4 5

On being an employeeof SwedbankAs an employee of Swedbank, you are expected to comply with thebank’s values. Simple, open and caring are the watchwords thatguide us in how we act on a daily basis. In practice, this means that:We conduct ourselves honestly and ethically. We use effectiveprocedures to manage conflicts of interest, real or potential,between personal and professional relationships.SimpleWe maintain effective procedures to prevent the misuse ofconfi-dential information, including insider information.We make it explicitly clear that we will not tolerate any abuseof confidential information.When the situation requires it, we prevent information frombeing leaked between parties that are conducting business ifthere is a potential conflict of interest.OpenWe comply with all applicable laws and regulations in the countrieswhere we do business. We are especially careful to follow the lawsgoverning anti-money laundering and counter-terrorist financing.We do not offer, and will not accept, money or improper gifts, andwe ensure that our employees’ personal investments do not affecttheir independence when they make decisions on behalf of the bank.We are committed to preventing, detecting and mitigating anymaterial risks that arise in our business.Caring6 7

We meet our customers in every possible stage oflife. They may be facing the biggest financial decisionof their life or they may just be doing some routinebanking. Every customer is unique, of course, and theway we communicate with them should be adaptedaccordingly. If you abide by a few overarching guidelines,you will have a good foundation to work from.We handle complaints promptly and effectively.We correct any errors straight away wheneverpossible.On offering serviceWe manage our customers’ personalinformation cautiously and confidentially,unless we are required to disclose certaininformation or the customer has given hisor her prior consent.When we meet customers, we are responsive,efficient, transparent and professional. We takethe time to listen. We clearly show the customerthat we take them seriously. Their opinion isultimately what counts.We communicate in a straightforward,uncomplicated manner appropriate toeach customer’s situation, whetherverbally or in writing.8 9

On colleagues and workenvironmentsSwedbank’s success is dependent on competent employees with arange of experiences. To attract the right people, we have to createand maintain appealing work environments. The first step is to complywith a few fundamental guidelines:We understand andrecognize the benefits ofdiversity in recruiting andin dealings with employees.We try to create inspiring workenvironments that encouragecommitment and co-operation.Our workplaces are clean,healthy and safe.In contacts with colleagues,we celebrate their talents and fostertheir professional development.We offer a work environmentwith appropriatecompensation levels.We never toleratediscrimination orharassment.We do not tolerate drug use in the workplace andsupport and encourage employees with alcoholor drug problems to seek help.We promote a work climate where employeesare comfortable voicing their concerns andreporting any violations of internal or externallaws and regulations or unethical behaviour.10 11

On delivering value andcommunicating with stakeholdersSwedbank has a responsibility to generate a return for its shareholders.This includes clearly communicating financial information and making itaccessible for anyone. Among other things, this means that:We keep accurate accountingrecords, and when communicatingfinancial information we alwaysrelease the same information toeveryone simultaneously.We strive to provide our shareholders with asustainable, long-term return by continuouslyimproving our services, our products and ourbusiness processes with maintained focus onprofitability and cost efficiency.We protect the interestsof all our shareholdersand investors.We adhere to the code of corporategovernance and communicate withthe companies we invest in as part ofour normal investment routine andopenly debate any departures fromSwedbank’s values.We maintain effective structures and systemsfor risk management, internal control andcorporate governance.12 13

On buying goods and servicesWhen we contract a supplier of goods or services, we send a messagethat Swedbank trusts this company or person. This means that wemust be completely certain we want to be associated with thecompany in question.We encourage the use of suppliers whose values agree with ours.We don’t do business with suppliers that could damage the bank’sreputation.We never accept improper personal gifts or money, we set theterms of payment when ordering goods or services, and we pay inaccordance with those contractual terms.14 15

On doing business in andfor our communitiesOur overall purpose is to help our customers achieve financialsustainability. By committing to this goal, we believe we canhave a positive impact on society in general.We contribute to the social and economic well-being of thecommunities where we are active.We work actively to minimise the environmental impact ofour business.We make an effort to respect the cultural and social traditionsof the communities where we conduct business.16 17

On competingWe compete vigorously but honestly and do not engage in unlawfulor anticompetitive conduct.18 19

On contacts with authoritiesIn dealings with regulators and authorities, we communicaterespectfully, clearly and honestly.20 21

Where to turn for helpSwedbank encourages all employees to raise integrity concerns ifdeemed necessary. If you observe violations of internal or externallaws and regulations or unethical behavior it is your obligation toraise your concern. Use one of the following ways of contact:1. First and foremost, contact your immediate supervisor or theCompliance Officer in your unit.2. If you do not get appropriate response on local level, contact theGroup Compliance Officer.3. If you prefer to be anonymous, send an anonymous letter to theCompliance Officer in you unit.NotesThis folder contains the overall principles in our Code of Conduct andwill be followed by a mandatory e-learning module. The e-learningwill be a hands-on, pedagogical training that helps you understandwhat the Code of Conduct means in your professional role.22 23

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