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Code of Conduct and Business Ethics

Swedbank's ambition is to demonstrate its adherence to integrity, governance and good business practices as well as to be transparent in reporting to all stakeholders. 

Swedbanks Code of Conduct serve as a framework to clarify both the guidelines the employee of must follow as well as the expectations the bank has on him or her in terms of each individual’s judgement and responsibility. It is an integral part of the Swedbank Group Framework comprising Swedbank’s governance structure and contains the Group wide internal regulation. The Code of Conduct is adopted by the Board and the CEO is Group Framework Owner. All employees are expected to comply with the Group Framework.


To ensure this Swedbank has a widespread internal control system covering the entire Group. This includes a directive on the handling of employment law measures in conjunction with employee regulatory breaches, checklists for internal investigations in the case of employee regulatory breaches, working groups and sustainability committees as well as local HR groups. In the Baltic countries the manager is responsible for reporting the incident in an internal risk and compliance platform. This will also be implemented in the Swedish operations during 2019.


Process for Internal Fraud Investigations 

Swedbank has a clear five-step process for how the bank proceeds when a notification is made about a violation or breach of the Code of Conduct in the Swedish operations. The process owner is Human Resources. However, other business units are also involved such as Compliance, Group Security Investigation and Customer complaints.

1) An incident occurs - a first point of contact with the local HR unit is made.

2) An investigation unit is involved to ensure a decision on how to handle the incident is made and other units such as Compliance or Risk are involved if relevant.

3) Interviews with the employee are coordinated by appointed investigators and trade unions are informed where relevant.

4) The appointed investigator submits proposals for decisions on labor law measures and the manager together with grandfather (so-called grandfather principle) decides on the labor law action.

5) The manager executes the decision and the appointed investigator register and files the incident.


Reporting on breaches and business ethics activities  

Transparency is important for Swedbank. We regularly monitor and report on breaches as well as key activities es to improve our work in the area of business ethics in the bank. 



Swedbank offers a widespread skills development through internal training. Mandatory trainings are applied for all employees in the areas of business ethics, sustainability, anti-money laundering and counters terrorist financing.

Internal training on the business ethics theme, number 2019 2018
Ethics 3 693 3 070
Sustanability incl. environment* 15 896 2 837
Anti-money laundering and counter terrorist financing  15 976 23 292
Total 35 565 29 199
*A new training was launched in 2019

Internal alert reports

It is important that risks and irregularities are detected and addressed as soon as possible. An internal alert (whistleblowing) process is established where employees and other stakeholders can openly or anonymously report potential or actual irregularities or failures to comply with external and internal rules or regulations.


Whistleblowing cases, by type 2019 2018


3 8


8 15
Code of Conduct 6  

Regulatory non-compliance

3 34*


10 1


30 58
*Out of the 34 cases 24 concerned the same issue. 

Swedbanks business and ethics committee

Swedbank’s Business Ethics Committee addresses issues where the environment, human rights, social responsibility, business ethics or corruption are a critical factor in business decisions. The committee’s role is to guide the entire organisation in order to minimise sustainability risks and any negative impacts for the bank.

Cases escalated to Business and Ethics Committee, number 2019 2018 2017
Customer related cases  8    
Policy and governance related cases 2    
Total  10




The cases submitted to the committee in 2018 involved ethical dilemmas related to e.g. defence material, the banks participation i various types of funding structures, cryptocurrencies, cannabis and gambling.