Code of Conduct

Adopted by the Board of Directors of Nordea AB (publ) (the "Group Board of Directors") on June 20, 2007.

Introduction

Nordea's values are based on our Nordic heritage of freedom, equal opportunities, care for the environment and good citizenship including ethics, honesty and sincerity. They are articulated in our Corporate Citizenship Principles that the Board approved in December, 2002.

Nordea's long-term success is based on trust and confidence. To uphold trust and confidence we must ensure that our behaviour supports the values we stand for. This is what we mean by a high standard of business ethics.

The Nordea Code of Conduct describes in general terms the ethical principles for guiding our business, treating our customers, and the behaviour we expect from our employees. The code is intended to support the Group and its employees in performing their assigned tasks and decision-making. In cases of uncertainty, the rule is to seek advice and guidance from your nearest supervisor.

By following this code employees will strengthen Nordea's reputation and contribute to our goal of being the leading financial services group in the Nordic and Baltic Markets.