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. All employees will, during 2020, complete the mandatory e-training, Swedbank Knowledge Update, which includes ethics. The Code of Conduct is also 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.