Respect for and compliance with the law takes the highest priority for Danske Bank Group. By complying with the various legal and regulatory frameworks that apply to the Group in the jurisdictions where it operates, the Group can protect its integrity and reputation. It is therefore very important that every employee understands and complies with the Code of Conduct.
Purpose of the Code of Conduct
The Code of Conduct is a collection of rules and policy statements intended to assist employees in their daily decision making. It sets forth guidelines for how to behave in relation to customers, suppliers and the authorities. It is not exhaustive but focuses on instances of misconduct that are of particular concern to the Group and its main stakeholders.
In some areas the Group has prepared policies and internal business procedures to ensure that it meets its ambitions and goals.
The Code of Conduct applies globally to all entities and employees (both full- and part-time) in the Group as well as to non-permanent staff.
To ensure that every employee in the Group is familiar with the Code of Conduct, each manager is responsible for seeing that it is known and adhered to within his or her unit. Managers are also responsible for determining whether more detailed rules are necessary at their units.
Violation of the Code of Conduct
Failure to comply with the Code of Conduct may expose employees and the Group to reputational damage as well as to legal and regulatory sanctions. Disciplinary proceedings by a regulatory body in the case of severe compliance misconduct may result in a reprimand, fine, withdrawal or suspension of the authorisation to conduct business.
If employees are uncertain about how to conduct themselves, they should always discuss the issue openly with their manager or team leader in order to act properly and prevent difficult situations from arising.
Group Compliance is obliged to report major findings and issues related to the Code of Conduct directly to the Group’s Executive Board.
Relations with employees
The Group sees its employees as its greatest asset. Each employee is valuable to the Group, and together they form the foundation for the Group’s success.
Dignity and respect
It is important that employees treat everyone with dignity and respect. The Group does not accept discrimination based upon ethnic background, gender, religion, age or sexual orientation. Discriminatory behaviour or harassment of any kind is not tolerated.
Gifts and entertainment
From time to time in the normal course of business relations, gifts (including entertainment) are offered, given and received. All employees must exercise great care with respect to gifts to and from customers, suppliers or others with whom they come into professional contact. The Group has prepared detailed internal business procedures for how to handle gifts and entertainment.
Dealing with conflicts of interest
Conflicts of interest can cast doubt on the integrity and professionalism of the Group and must be avoided. A conflict of interest may arise in any of the Group’s business units in the course of providing customers a service which may benefit the Group (or its employees or another customer on whose behalf the Group acts) or may adversely affect the Group’s customers.
The Group has issued a specific policy, the conflict of interest policy, to prevent and handle conflicts that may arise.
Dealing with confidential information
All employees have a legal duty to safeguard confidential information, regardless of whether it is obtained from customers, associates, suppliers or sources within the Group. Confidential information must not be disclosed to third parties without the owner’s consent or used improperly for the benefit of the Group, its customers, associates, suppliers or employees. The Group has prepared internal business procedures for dealing with confidential information.
Dealing with inside information
It is a criminal offence for employees to buy or sell listed shares or certain other securities or debt instruments if the employee has information that is not generally known that – if it were generally known – could affect the value of the securities or instruments. Danish law also prohibits passing on inside information about factors that affect pricing.
To limit the risk of violating the laws, the Group has organised its operations so as to ensure that only employees who need the information have access to inside information. All employees can safely make transactions in Danske Bank shares as long as the transaction is in compliance with the Group’s internal business procedures regarding inside information.
All employees are entitled to manage their own affairs in privacy. Employees must at all times maintain a high standard of personal conduct and courtesy, however, and must act with honesty and integrity in all personal and business dealings in order to ensure that the Group cannot be brought into disrepute. Employees should refrain from actions that could seriously jeopardise their own financial positions.
The Group values an environment that encourages the free flow of information. To ensure that no critical information is withheld, the Group has set up a function to enable employees to report serious irregularities that come to their attention.
If it is legally possible, reports and questions received through the whistleblower system are treated confidentially and passed on to Group Chief Auditor, the Group General Counsel and the Board of Directors' Audit Committee. The Group will protect employees who report irregularities and ensure that they are treated with the respect they deserve. The Group does not accept reprisals against such employees.
Relations with external partners
In compliance with the legal framework for financial institutions and sector guidelines, the Group constantly strives to improve and develop the manner in which it acts in society and works with customers. For such efforts, the Group has set up five core values:
- Integrity – in business affairs and as part of society
- Expertise – through high standards of quality and professionalism
- Value creation – for shareholders, customers and employees
- Commitment – to customers’ financial affairs
- Accessibility – electronic, physical and by telephone
These core values serve as a compass and a general code of conduct for the employees to follow in the effort to act responsibly in society and serve customers in the best possible way – both ethically and professionally.
Relations with customers
The key values of the Group’s advisory services are integrity, accessibility and transparency. The aim is to ensure that customers trust the Group and experience a welcoming atmosphere and value-creating relations.
Employees have a particular responsibility for ensuring that customers are given information in keeping with sound business practices. Employees should endeavour to ensure that customers know the consequences of their financial decisions, including any risk of loss. Furthermore, employees should never recommend that customers buy Danske Bank shares.
All communications through all channels to all target groups should be open, truthful and unambiguous. Employees must commit themselves to providing clear and transparent information to customers.
The Group has issued a more detailed policy, the customer policy, to support these principles.
The Group must deal with complaints from customers or former customers promptly and fairly and in accordance with applicable laws and regulations. The Group has developed detailed procedures to support this process. The complaint procedures are described thoroughly on the Group’s website.
Anti-corruption and bribery
The Group condemns corruption in all its forms and does not tolerate it in its business or with its business partners. If employees are involved in bribery or corruption, they may find themselves personally criminally liable and subject to disciplinary action.
The Group has set forth detailed procedures, the Anti-Corruption and Bribery Business Procedures, for how employees should behave and what they should do if they are confronted with corruption. These procedures also help the Group identify activities that might be related to money laundering and the financing of terrorism. The Group cooperates with the authorities to prevent such activities.
In the Group’s work against corruption, the three following principles apply:
- The Group and its employees do not accept or solicit bribes in any form.
- The Group strongly discourages facilitation payments.
- The Group’s employees do not give or receive gifts above token value.
The line between right and wrong can sometimes be difficult to draw because of variations in local culture, customs and habits. If in doubt, employees should refer their concerns to the Group Compliance department.
Socially responsible investing
The Group and its employees must ensure that customers’ funds are not placed in companies that violate internationally recognised standards. The Group has prepared a policy to prevent this, see the responsibility policy.
Relations with suppliers
The Group wants to help promote social and environmental improvements at our suppliers.
The Group expects that our suppliers comply with national laws and internationally recognised standards and conventions for ethical, environmental and social conditions. The supplier policy, which is a part of the responsibility policy applies to all purchases of goods and services at all business units and subsidiaries throughout the Group, is intended to achieve this end.
Relations with authorities
The Group is regulated by various bodies, for example, financial supervisory authorities, other public authorities, regulated markets and other markets of which it is a member.
The Group respects these authorities and wants to maintain good relations with them in all the countries where it operates. The business units operate in various jurisdictions and consequently, their obligations may differ in accordance with national rules and regulations. In case of a conflict between the Group’s policies and national rules, the latter will always prevail.
The Group wants to report important issues to the regulators promptly, in the right manner and with correct and sufficient information. With regard to compliance issues, all employees must always contact the local compliance function or the Group Compliance department.
Last updated on 5 January 2012.