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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.


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


Compliance audits are conducted on some areas covered in the Code of Conduct, for example an annual review and reporting of conflicts of interest for management members and Key Position Holders.
In addition, Swedbank has a widespread internal control system covering the entire Group such as 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. The manager is also responsible for reporting the incident 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 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 as 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 2020 2019 2018
Ethics 16 797 3 693 3 070
Sustainability incl. environment* 16 149 15 896 2 837
Anti-money laundering and counter terrorist financing  17 153 15 976 23 292
Total 50 099 35 565 29 199



Swedbank has established an internal alert (whistleblowing) process for reporting of any potential or actual irregularities, to ensure availability of independent and autonomous channels that allow whistleblowing in an open or anonymized manner outside the regular reporting lines. Reporting of an internal alert can be done by employees, customers, shareholders, investors or any other business partners. All internal alerts are handled with care and integrity and the process ensures that the person reporting the internal alert is protected from any negative impact, e.g. retaliation, discrimination or other types of unfair treatment. The management of internal alerts, including the number of internal alerts reported by case type and status is quarterly reported to the Board of Directors and CEO.


Number of alerts received during 2020, by type 2020




Human Resources 21



Other issues




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 by the suppliers and consults employed by Swedbank.

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. In 2021, the Business and Ethics Committee was replaced by a Sustainability Committee.

Cases escalated to Business and Ethics Committee, number 2020 2019 2018 2017
Customer related cases  3 8    
Policy and governance related cases 5 2    
Total  8 10 13* 11 
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.