Code of Conduct at BN Bank

We follow the laws and regulations and comply with the bank's strategic decisions
This applies to both laws, rules, agreements and strategic decisions. This applies to internal processes, routines/procedures, powers of attorney and agreements, as well as external regulations.

As an employee of the bank, we are responsible for getting into training materials and keeping track of updates that apply to our work area and field. We are expected to comply with the training and information provided and seek advice if we have any doubts.

We're going to have a headroom for different opinions, but once the bank has made a strategic decision, we're loyal to it. Feedback on decision-making provides the route of service.

If we are aware of violations of laws and regulations, or that the bank's internal policies are not satisfactory, this shall be reported/recorded in accordance with the bank's incident and deviation reporting. By recording the discrepancy/event, the responsibility is placed at the correct level in the organization. If the discrepancy does not become the register, the responsibility lies with the person who discovered the discrepancy.

For managers, there is a special responsibility to keep up to date with laws, rules and strategic decisions, as well as to ensure that their own employees have the opportunity to stay up to date. With the role of manager, there is a responsibility to take care of their own employees if they report a breach.

We behave properly and do the right thing – to all
Making decisions that are in the best interests of the customer and society should be our way of banking. It means acting orderly and appropriately towards competitors, governments, owners and society otherwise.

We shall communicate openly, honestly and at the right time both internally and externally, without compromising confidentiality, confidentiality or our other obligations.

This principle also applies in the workplace. When everyone behaves properly and does the right thing to everyone, the result is that BN Bank is a good place to work. We have no tolerance for bullying and harassment, this also includes sexual harassment, both during working hours, on travel and events where we participate.

How we make difficult decisions in everyday life
If there is a situation where there is any doubt about what is the right decision, discuss the matter with your manager or a colleague before the matter is decided. We will be a good sparring partner for our colleagues. We will take the time to listen, discuss, and find answers together. Not least support colleagues who make the brave and proper everyday choices.

When it is difficult to find the right answer to a dilemma in working life, we will ask the questions:

• Is it legal?
• Can it be justified?
• Is it consistent with our values?
• Is that right?
• Do we retain our credibility?
• Is it okay for the decision to be known to colleagues and managers, or be featured in the media?

Critical relationships

At BN Bank, we report errors, deficiencies and criticisms, and we use the channels we have to notify them of it. Having a culture of alerting is important, so we can handle challenges and problems in a timely manner.

For more information see your bank's notification routine

Example of notification areas:

• Culture, corruption and other illegalities
• Economic crime
• Unethical or harmful activity
• Violation of the Working Environment Act's protection against unfair dismissal and other job protections
• Violation of other ethical norms
• Possible problem in relation to compliance with bank policies or ethical and other policies
• Errors or deficiencies in the workplace and/or breaches of Osh rules (danger to life and health, injuries and/or illnesses incurred in work, as well as
  harassment or discrimination that goes on gender, sexual orientation or age)

All notifications should be treated with respect and taken seriously, and retaliation is not acceptable as a result of speaking out or notifying when this has been carried out in good faith. The one against which it is notified shall also have similar protection.

We employees should always feel safe when alerting and should be protected from retaliation or similar as a result of the notification. We may notify anonymously and to an independent party. In whistleblowing cases, we shall have access to personal support and guidance from an independent party.

Equality, equality and diversity in the workplace
At BN Bank there is going to be equality and we want a diversity among our employees. We recognize that all people are unique and have respect for the abilities, characteristics and vision of individuals. Gender equality and diversity shall apply to all aspects of the employment relationship. We have a shared responsibility to ensure that the working environment is perceived as safe for everyone.

BN Bank accepts no form of discrimination or harassment, including unwanted sexual attention. This applies to customers, suppliers, employees and others we come into contact with.

Discrimination means discrimination based on gender, age, ethnicity, cultural background, religion, social affiliation, disability, sexual orientation, marital status or political conviction. Harassment means that over time someone is subjected to negative actions from one or more people.

At BN Bank, reward and recognition shall be given based on our deliveries, behaviour and attitudes, and not who we are.

Respect for the opinions of others
BN Bank wants engaged employees who speak their opinion, discuss and make improvement proposals.

We're going to have a ceiling for different opinions, but once the decision is made, we're loyal to it. We value transparency and appreciate honest feedback. That's why we'd rather talk to people than talk about them. We assume good intentions with colleagues and management, and if anything is unclear then we ask. This shall ensure that our employees have the right attitudes and behaviours.

A safe workplace
BN Bank aims to be a great place to work. All employees shall have a good and health-promoting working environment, physically, mentally and socially.

We will have a drug-free workplace and no one should be under the influence of alcohol or other drugs while they carry out work for BN Bank. In social contexts, and during events where appropriate and acceptable, alcohol can be served.

BN Bank wants to help employees who may have problems with, among other things, substance abuse, debt and gaming problems. If we have a problem with this, we will raise it with the manager, the manager's manager or the bank's HR department. At BN Bank, such problems should be treated confidentially and taken seriously.

Legal stimuli, such as prescribed drugs, tobacco smoking and snooping, are not seen as drugs in this context.

Through documented procedures, we will have a good readiness and effective response that prioritizes life and health in the event of such a crisis. In the event of a serious incident or crisis, the HSE contingency plan shall contribute to the least impact possible. The goal is to prevent escalation of events and take the organization controlled back to a normal situation.

Use of company assets
Employees have access to use BN Bank's assets to perform tasks. This includes equipment, systems and the like owned by the bank. Such assets shall be used and taken care of with accountability. The same applies to the use of the bank's apartments.

We shall refrain from using the bank's assets in a manner that may be linked to illegal gambling, pornography, racism or other purposes that may be perceived offensive or that violates laws or internal rules

Protect bn bank's values and information
Most of BN Bank's economic and business values are digitised and available as data in different ways and in different systems, and these should be protected from unauthorized persons.

We shall be familiar with and follow the rules and procedures for information security that apply to our work. The bank's rules for correct and safe processing of information should always be followed. Security requirements enshrined in policies and procedures shall be followed. Any breaches of information security shall be reported to the nearest manager immediately.

We do not distribute or take with us values and information outside the bank without a serviceable need and use the bank's values and information only for the purpose for which they are intended.

Business conduct
We will interact with a number of stakeholders, including customers, suppliers, other business partners and governments in an ethical and lawful manner, and demonstrate integrity in everything we do.

We shall only speak publicly about matters concerning BN Bank if we are appointed to speak out on behalf of the bank.

We should generally be aware of the use of social media. The environment can associate us with BN Bank even if we are private on social media. We shall not share content that violates the bank's policies and requirements governing the bank's activities.

We will provide information about our business and services in an open and understandable manner.

Customer care
With us, all customers shall be treated with respect and in line with good business practices and industry worms.
In order to build trust and maintain their reputation, it is important that customers are satisfied with the treatment we give them.

We want our customers to perceive us as fast, predictable, skilled, friendly and personal.

BN Bank shall be characterised by high integrity, availability and transparency in customer care. We provide the customer with information in accordance with good business practice and actively contribute to the customer's knowledge of the consequences of their choices.

We must constantly assess our ability and ability to a fair and impartial treatment of each customer. Our motives from the outside should not be in doubt. Our customer care shall always take place on the basis of the customer's needs and financial situation, as well as the bank's guidelines, applicable laws and regulations.

Privacy and confidentiality
BN Bank shall be characterised as a company that takes privacy and confidentiality seriously. We will do our utmost so that customers, suppliers, employees and owners can rely on us to safeguard our privacy and confidentiality.

Privacy and confidentiality apply in all contexts, both at work and privately. The duty of confidentiality applies not only to the outward, but also internally to all other employees and partners for whom the information must be deemed unauthorized.

We never share personal data or other confidential information unless there is a legitimate and appropriate need for it. We refrain from actively seeking information about other employees, customers or outsiders via BN Bank's systems when it is not necessary to carry out the work.

The duty of confidentiality shall also be respected after the end of working relationships with BN Bank.

Customer complaints should be taken seriously
Any complaints from customers should be taken seriously and handled in accordance with the complaint handling procedures. All complaints shall be treated confidentially.

As an employee, we shall be familiar with and follow procedures for processing customer complaints.

Transparency and accountability
Everything we do shall withstand the light of day. It is important that we can explain what we have done, how we have considered and what decisions we have made. This may be documented in accordance with the bank's guidelines.

We will encourage our customers and other partners to provide transparency and good management models, including transparency around ownership structures, transactions and compliance documentation.

As an employee of BN Bank, we are role models in the economic area, it commits that we have an orderly economy and seek help from HR or the nearest manager if we end up in a difficult situation.

Confidentiality
BN Bank is entrusted with values and information about our customers. In order to maintain this trust, the safety and protection of customers' values and information shall come first.

We handle the customer's information with care. We store and store customer information securely and securely both physically and digitally. The duty of confidentiality is absolute and applies in all contexts, both at work between colleagues and privately.

Laws applicable to the processing of customer information shall be followed, this applies to both personal data and company information.

Conflicts of interest and habilitation
A conflict of interest may arise when BN Bank's interests and our personal interests do not coincide. This may be due to close relationships, e.g. girlfriends, spouse/cohabitant, children, parents or other relatives and friends. The same applies when we as an employee are also a customer of BN Bank. Holding a position in self-employed enterprises or on a voluntary basis in teams or associations may also result in a conflict of interest.

A conflict of interest can also arise between government requirements and expectations, customers' needs and interests, as well as the bank's business goals and the owners' expectations.

We will seek to avoid conflicts of interest. We avoid situations, professionally and privately, where our independence, integrity or loyalty can be questioned.

We are open about positions, investments and other obligations we have outside the bank that may result in a conflict of interest. Employees of the bank must have written acceptance from BN Bank in order to have board positions in self-employed enterprises without regard to whether fees are received for the position. The same applies to private business.

As employees, we shall be particularly cautious and aware if our own or our loved ones' private interests do not match the interests of the bank or customers. The employee must exercise great care when trading financial instruments in companies that are customers of BN Bank. The nearest manager shall be informed when the company is a customer in the business area the employee is affiliated with or if the employee sits with knowledge of the company through his/her employment.

When a conflict of interest arises, we shall be open about it and resolve it in a prudent manner. The nearest manager should be informed immediately if there is incapacity or that it is natural that questions of habilitation must be clarified in more detail.

We address current issues with the manager if we are uncertain.

We speak to colleagues
We speak to our workplace and our colleagues. Any criticism we take internally, directly with whoever in question, the immediate leader or leader of the leader.

Competition
BN Bank treats all suppliers and competitors neatly, and competes fairly and in accordance with competition regulations.

Corruption
Corruption is when one gives or receives an undue advantage in connection with his position, office or in the performance of an assignment. For example, an advantage can be money, discounts, cost coverage, travel or participation in events.

BN Bank has no tolerance for corruption. We will have procurement processes and customer relationships that can withstand the light of day, and we are open and clear about our attitude towards corruption towards customers and partners.

BN Bank will build good relationships with customers, suppliers, authorities and others. Within the retail market, the goal is to be a relationship bank combined with a digital bank. Within the corporate market we are a typical relationship bank. For both areas, we will strive to create good customer experiences. Here there are limits that must not be exceeded. This is especially true when it comes to providing something extra to a person who is going to make a decision or close people who may influence them. At worst, it could be about corruption.

Under no circumstances shall no employees exercise their position to obtain personal benefits, or act in such a way that it may damage the reputation of the bank. We shall report offers of gifts from customers or suppliers in accordance with the stipulated rules and procedures.

Inside information
As an employee, we may gain access to information that is not publicly available and that may affect the price of a share or other financial instrument, etc. Such information may be inside information to be processed in a correct and lawful manner.

BN Bank aims to counter financial crime, both in society and within the bank, and we have rules and procedures for handling inside information.

Reporting of financial and non-financial information
BN Bank emphasizes dialogue with various interest groups where transparency, predictability and transparency are put into focus. Complete, accurate and objective reporting is essential to safeguarding the bank's credibility and reputation. Reporting shall take place at the right time, to facilitate instances and have the correct content.

The reporting is carried out in accordance with legal and regulatory requirements, recognised standards and the bank's financial and non-financial reporting guidelines.

Money laundering and terrorist financing
Money laundering and terrorist financing and/or similar actions are a societal problem we are responsible for countering.

The financial industry has a special social responsibility for preventing economic crime. We are responsible for ensuring that our business is not exploited for illegal matters through our services and products. Combating financial crime, such as money laundering earned by criminal activity (AML) or financing for terrorist activities (CTF), is a demanding and important work that is statutory.

BN Bank has a comprehensive framework with guidelines required to prevent the bank from being used for money laundering, tax evasion or terrorist financing. The framework shall ensure that we comply with legal requirements in various processes through guidelines, customer measures, electronic monitoring, sanctions regulations and procedures for internal control. Training plans have been made for all employees and we are aware of the consequences if claims under the Money Laundering Act are not complied with. In addition to advocating for good compliance with legal requirements, we are continuously working to prevent our customers from being exposed to financial crime.

BN Bank shall actively work to prevent money laundering and terrorist financing, and we shall not contribute to such activities.
We employees will:

• be familiar with and follow the rules and routines of AMLog CTF within our area
• know our customers and be able to identify suspected money laundering or terrorist financing
• report on suspicion of money laundering or terrorist financing in accordance with the bank's procedures

For employees, violation of the Code of Conduct may have consequences for the employment relationship, e.g. in the form of warning, dismissal or dismissal.

Based on the code of conduct, specific requirements are made to employees.

In BN Bank:

1. we have a duty of confidentiality
2. we should have arranged private finance
3. under no circumstances shall we exercise our position to obtain personal benefits or act in such a way that it may damage the bank's reputation
4. we will work actively to achieve a good working environment with trust and respect for each other
5. we shall know and follow the bank's information security policy
6. we shall show caution in relation to habilitation
7. none of us may conduct private business or participate in commercial boards of any kind without the bank being informed in writing and approval
8. separate guidelines have been drawn up for notification
9. the CEO has the overall responsibility for all communication with the media
10. there may be consequences for the employment relationship if the bank's code of conduct is not complied with