Swedbank's Code of Conduct serves as a framework to clarify the guidelines that employees must follow, as well as the bank's expectations in terms of each individual employee's judgement and responsibility. The Code of Conduct is an integral part of the Swedbank Group Framework, which comprises Swedbank’s governance structure and includes the Group-wide internal regulations. The Code of Conduct has been adopted by the Board of Directors, and the CEO is Group Framework Owner. All employees are expected to comply with the Group Framework.

The Code of Conduct is sent to all new employees as part of a welcome email from the HR department. In 2020, Swedbank's employees completed the Swedbank Knowledge Update mandatory e-training, which includes ethics. The Code of Conduct is available to all employees on the bank's intranet.

Compliance audits are conducted on some areas that are covered in the Code of Conduct, for example an annual review and reporting of conflicts of interest for members of the management team and Key Position Holders. 

In addition, Swedbank has a widespread internal control system covering the entire Group, including a directive on the handling of labour-law actions in conjunction with employee regulatory breaches; checklists for internal investigations in the case of employee regulatory breaches; working groups and sustainability committees; and local HR groups. Managers are also responsible for reporting incidents in an internal risk and compliance platform. 

Process for Internal Fraud Investigations 

Swedbank has a clear five-step process for how the bank proceeds when a notification is made of 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 that a decision on how to handle the incident is made. 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 labour-law actions, and the manager together with grandfather (so-called grandfather principle) decides on the actions.
5. The manager executes the decision, and the appointed investigator registers 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 on key activities to improve our work in the area of business ethics in the bank. 

Training

Swedbank offers widespread skills development through internal training. Mandatory trainings are applicable for all employees (including those in wholly owned subsidiaries) in the areas of business ethics, sustainability, anti-money laundering and counter-terrorist financing. In addition, specific e-trainings for managers are offered in the area of gender and diversity, including how to counteract discrimination and harassment in the workplace.

Whistleblowing

Swedbank has a group-wide whistleblower process that enables employees and other stakeholders to report irregularities within the organization, such as breaches of the Code of Conduct, non-compliance with legislation, or deviations from Swedbank's policies. If an employee or another person discovers unethical or illegal behaviour, they can report it to the Head of Group Compliance or the Head of Group Internal Audit, or completely anonymously via a web-based reporting and communication channel provided by an external supplier. Depending on who is identified in the report, either Group Compliance or Group Internal Audit's whistleblower unit will investigate the matter.

Swedbank's web-based reporting and communication channels are available in all languages on the bank's home markets and in English. The messages are encrypted and allow the whistleblower to submit reports openly or anonymously and remain anonymous in further dialogue. The group has developed guidelines for handling whistleblower reports. All reports and messages are treated strictly confidentially.

The Board of Directors are informed about whistleblower cases in connection with quarterly reports, and cases concerning Group Compliance, the CEO, or any member of the Group Executive Committee are also addressed by the board's Audit Committee.

Human rights

Swedbank acts with due diligence to avoid infringing on the rights of others in our business activities and operations; however, we also acknowledge that despite concerted efforts, abuse can occur. If our activities entail a direct violation of the human rights of others, we shall take action to rectify the situation, taking into account the interests of those whose rights are being violated. We also expect the same of the companies we invest in and finance, and of the suppliers and consults employed by Swedbank.

Swedbank's Sustainability Committee

Swedbank’s Sustainability 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 to minimise sustainability risks and any negative impacts for the bank. The Sustainability Committee replaced the Business and Ethics Committee in 2021.