Processes for promoting and developing the corporate
culture and business conduct
conduct and ensure ongoing employee training, all
year and acknowledge that they have read and
understood it. The guidelines for corporate culture and
internal employee handbook, which is also part of the
In addition, the bank gives priority to communicating the
corporate culture and business conduct to all new
employees during onboarding, when the employees
policy on conditions for employees and code of conduct,
which they must read and understand. All new employees
must also read the employee handbook.
Material information on changes, new initiatives or
culture and business conduct is communicated to the
that all employees are kept informed and up to date.
play an important role in promoting and influencing the
corporate culture and business conduct on a daily basis.
These people are responsible for taking the lead, being
good role models and open to dialogue on how
employees should respect the principles in the code of
conduct, employee handbook and policies, which
business conduct.
metric, the annual job appraisal interviews, customer
department and HR department as a basis for evaluating
onduct and
implementing any initiatives, should the evaluation call
for action.
report on compliance with the policy for a sound
corporate culture to the board of directors for
consideration and evaluation of whether any action
should be taken in relation to corporate culture and
busines
board of directors to the annual general meeting on
behalf of the board about implementation of the policy
for a sound corporate culture policy and compliance with
it.
Processes regarding conduct violating the bank’s code
of conduct or other internal rules
Through its policies etc. regarding corporate culture and
business conduct, the bank has established principles
and guidelines for what conduct it considers acceptable
and unacceptable among its employees and
management to avoid any violation of applicable law etc.
By complying with applicable law and other rules, the
bank endeavours to protect the integrity and reputation of
the bank and its employees.
The bank has introduced concrete procedures for
handling/examining violations and potential violations of
applicable law so as to ensure immediate, independent
and objective handling of them.
The bank has also established clear procedures to foster
open communication about any suspicions of violation of
financial rules etc., internally and towards the authorities.
If an employee raises a concern about unlawful and/or
inappropriate conduct in the bank, there must be no
negative consequences for the employee. However, if the
employee personally has violated rules and/or guidelines,
legal consequences and/or sanctions may be imposed
on the employee under employment law. In general, it is
decisive for the bank that information is never withheld,
internally or from the authorities.
Employees who become aware that they themselves or
conduct and/or other internal rules must at once inform
their immediate superior, the HR department and the
compliance function. HR and Compliance have an
obligation to report serious violations and related issues
directly to general management. Employees may also
scheme.
internal whistleblower scheme, the authorised individual
under the scheme, immediately examines concerns and
incidents relating to conduct which conflicts with
al rules.
Should a state of dependency exist or arise between the
parties, mitigating actions will be implemented. The
person conducting the examination has an obligation to
always report serious violations and related issues
directly to the general management, unless the report
involves a general management member, In which case
the matter must be reported directly to the chair of the
board of directors.
Violations of applicable law and/or failure to comply with