Rules of conduct

The rules of conduct regarding competition issues are part of a compliance programme implemented by the Group to ensure compliance with competition rules. Here you can read an excerpt from the rules of conduct:

"Rules of conduct regarding competition issues
General rules of conduct:

• Comply with all applicable laws regardless of where in the world you work; this includes both general and local competition rules.
• You must know the Group's rules of conduct so that you act in accordance with our policies on competition issues.
• When you represent the Group, you must behave in a way that outsiders cannot misconstrue as a possible violation of competition rules or an invitation to such a violation.

Rules of conduct
- prohibition against abuse of a dominant position
A business may not abuse a dominant market position. The Danske Bank Group is a large enterprise, and it therefore cannot be ruled out that the competition authorities might consider the Group to be dominant in certain products.

Abuse is considered to have occurred if a business uses means other than those of normal competition. Here are some examples:

• unreasonable prices or terms
• making different conditions for the same services to similar customers without professional or objective justification in cost savings or in a specific competitive situation for the Group
• combination sales - for example, requiring that a customer have a budget account if the Bank is to provide a mortgage loan
• restriction of technical development or investment by limiting the use of or access to the Bank's technology

It is therefore the Group's policy that we

• do not set unreasonably high prices for customers
• do not give discounts or bonuses that are not professionally and objectively justified on the basis of cost savings or a specific competitive situation for the Group
• do not require that customers contract additional services when they enter an agreement with us on a primary service
• do not restrict technical development or investment in a way that could be considered abuse

Rules of conduct
- prohibition against anti-competitive agreements
Businesses may not enter into anti-competitive agreements with other companies. We therefore may not enter into agreements with competitors to do any of the following:

• to fix prices or other business terms
• to divide up the market
• to give different terms for the same services to similar customers without professional and objective justification
• to restrict or control technical development and investment

It is therefore the Group's policy that we

• do not enter agreements on prices, dividing up the market, discounts, offers and the like with the Group's competitors
• not discuss strategic considerations with the Group's competitors
• not give information about prices - which is not publicly known from the interest rate board or price book, for example - discounts, market conditions, market strategies and the like to competitors or industry organisations (for example, the Danish Bankers Association, the Danish Association of Mortgage Banks, the Danish Insurance Association, and the Danish Securities Dealers Association)
• immediately refuse to discuss prices, the division of the market, discounts and the like if a representative of a competitor attempts to begin a conversation about such topics, for example at meetings, receptions, professional gatherings or other occasions, including private events (if the attempt to discuss such topics does not cease, we must leave the meeting and report the incident to the Board of Directors Secretariat)

Competition authorities
The competition authorities - that is, staff from the Danish Competition Authority or the European Commission - are authorised to obtain the information that they believe is necessary when they investigate whether a business is violating competition legislation or is participating in the violation of the competition legislation by others.

The authorities can retrieve such information by letter or by control investigations at a business. It is the Group's policy that we be accommodating and willing to co-operate with the competition authorities in such situations."



Last updated/revised on October 12, 2007