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Our Code of Conduct - Swedbank

Our Code of Conduct - Swedbank

Our Code of Conduct - Swedbank

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1<strong>Our</strong> <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong>


Why is our<strong>Code</strong> <strong>of</strong> <strong>Conduct</strong>important?The financial system is dependenton public trust in us as a bank.Few things are more impactful than the impressionan individual employee <strong>of</strong> the bank can make on acustomer.The <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> therefore is in place to serve as aframework to clarify the guidelines you have to followas an employee <strong>of</strong> <strong>Swedbank</strong> and the expectations thebank has on you in terms <strong>of</strong> 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 <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> 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 <strong>of</strong> us.That’s why this <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> folder is necessaryand is important to read and use, but also why weneed your opinions to improve the next version.2 3


Your responsibility<strong>Our</strong> contactsThe <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> is a part <strong>of</strong> the <strong>Swedbank</strong> Group Framework.The Group Framework is <strong>Swedbank</strong>’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 <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong>- Learn the details <strong>of</strong> 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 <strong>of</strong> compliance with theGroup Framework- Personally lead compliance efforts- Build the infrastructure in your area <strong>of</strong> responsibility in accordancewith directions given in the Group Framework to prevent, detect andrespond to any issues <strong>of</strong> non-complianceSuppliers<strong>Swedbank</strong>CommunityFirst 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 employee<strong>of</strong> <strong>Swedbank</strong>As an employee <strong>of</strong> <strong>Swedbank</strong>, 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 <strong>of</strong> interest, real or potential,between personal and pr<strong>of</strong>essional relationships.SimpleWe maintain effective procedures to prevent the misuse <strong>of</strong>confi-dential information, including insider information.We make it explicitly clear that we will not tolerate any abuse<strong>of</strong> confidential information.When the situation requires it, we prevent information frombeing leaked between parties that are conducting business ifthere is a potential conflict <strong>of</strong> 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 <strong>of</strong>fer, 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 <strong>of</strong> 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 <strong>of</strong>life. They may be facing the biggest financial decision<strong>of</strong> their life or they may just be doing some routinebanking. Every customer is unique, <strong>of</strong> 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 <strong>of</strong>fering 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 pr<strong>of</strong>essional. 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 workenvironments<strong>Swedbank</strong>’s success is dependent on competent employees with arange <strong>of</strong> 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 <strong>of</strong>diversity in recruiting andin dealings with employees.We try to create inspiring workenvironments that encouragecommitment and co-operation.<strong>Our</strong> workplaces are clean,healthy and safe.In contacts with colleagues,we celebrate their talents and fostertheir pr<strong>of</strong>essional development.We <strong>of</strong>fer 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 <strong>of</strong> internal or externallaws and regulations or unethical behaviour.10 11


On delivering value andcommunicating with stakeholders<strong>Swedbank</strong> 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 onpr<strong>of</strong>itability and cost efficiency.We protect the interests<strong>of</strong> all our shareholdersand investors.We adhere to the code <strong>of</strong> corporategovernance and communicate withthe companies we invest in as part <strong>of</strong>our normal investment routine andopenly debate any departures from<strong>Swedbank</strong>’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 <strong>of</strong> goods or services, we send a messagethat <strong>Swedbank</strong> 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 <strong>of</strong> 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 <strong>of</strong> payment when ordering goods or services, and we pay inaccordance with those contractual terms.14 15


On doing business in andfor our communities<strong>Our</strong> 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 <strong>of</strong> thecommunities where we are active.We work actively to minimise the environmental impact <strong>of</strong>our business.We make an effort to respect the cultural and social traditions<strong>of</strong> 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 help<strong>Swedbank</strong> encourages all employees to raise integrity concerns ifdeemed necessary. If you observe violations <strong>of</strong> internal or externallaws and regulations or unethical behavior it is your obligation toraise your concern. Use one <strong>of</strong> the following ways <strong>of</strong> 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 <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> andwill be followed by a mandatory e-learning module. The e-learningwill be a hands-on, pedagogical training that helps you understandwhat the <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> means in your pr<strong>of</strong>essional role.22 23


24ART NR 999 100 20

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