Scope

Swedbank's Policy on Conflicts of Interest applies for Swedbank AB and all its subsidiaries (the “Group”).

Policy in brief 

Swedbank’s Policy on Conflicts of Interest establishes the roles and responsibilities for identification, assessment, documentation, management and disclosure of conflicts of interest.

The policy also contains non-exhaustive examples of conflicts of interest and mitigating actions which may affect parts of the Group.

The Group must always pay attention to conflicts of interest that can arise and should act in a way to prevent damage to the Group or to customers’ interest including reputational risk to the Group.

Conflicts of interest can arise between any two or more of the following groups:

• Customers of the Group
• Shareholders and any other person directly or indirectly linked to the Group by control
• Members of the Management Body, the executive committee, and their closest family members
• Subsidiaries
• Employees, and their closely related persons
• Suppliers, tied agents and business partners
• Other related parts of the Group, including partly owned entities and/or joint ventures

The Group shall implement procedures to prevent and avoid any type of material conflicts of interest. When identifying and managing conflicts of interest, the general conduct principles set out in the Group’s Code of Conduct shall also be applied.

The Policy on Conflicts of Interest also sets requirements for the approval of employees’ assignments outside the Group.

The Policy on Conflict of Interest is clarified and made concrete through more detailed instruction and guidelines.