Ethical business conduct and compliance with applicable laws and regulations are fundamental aspects of Nordea’s corporate culture.
Compliance risk is the risk of business not being conducted according to legal and regulatory requirements, market standards and business ethics. Proper compliance is one of the main guardians of the conscience and ethics of a financial services business.
We look at compliance not just as something we have to do to earn and retain our “licence to operate,” but as something we want to do, because ultimately, it builds trust with our customers and makes society safer.
Operational risk management and compliance are an integral part of everyday business at Nordea. The substantial amount of new directives and regulations aimed at securing banks’ stability and customer protection demonstrate how vital strong and well-functioning banks are to society. For us, making sure that we carry out all necessary steps to secure compliance in every customer interaction is the only possible way to ensure strong relationships.
The Board of Directors of Nordea Bank AB bears the ultimate responsibility for the Group’s compliance with laws and regulations, with the Board Risk Committee overseeing the management and control of these risks. The Committee regularly reviews the bank’s overall risk management approach, including risk profiles, control framework and assessment of material risk issues.
Managers are responsible for day-to-day oversight of compliance risks. Supported by the Group’s Operational Risk and Compliance function, they identify, assess and mitigate compliance risks. The most significant risks reported from all parts of the Group are consolidated into a Group Risk Map presented to Group Executive Management, the Board Risk Committee and the Board of Directors.
One area of particular importance is the prevention of financial crime. This is an escalating challenge all over the world, driven by factors such as political instability and terrorism. Consequently, authorities are imposing more stringent regulations, and we have a crucial role in protecting our customers, our bank and society from these illegal activities. A financial crime is an offence by or against an individual or corporation that results in a financial loss. The two main types of financial crime that affect our business are money laundering and bribery and corruption.
This is the process by which criminals attempt to conceal the true origin and/or ownership of the proceeds of criminal activities. If successful, the money can lose its criminal identity and appear legitimate. Criminals do this by disguising the source, changing the form or moving the funds so they are less likely to attract attention.
While knowing our customers helps us to provide them with better service, it’s also part of our responsibility as a member of the global banking community. Nordea’s Anti-Money Laundering (AML) work is based on international regulations with the ultimate goal of ensuring that funds from illegal sources cannot be laundered through the banking system or used to finance terrorism or illegal operations of any kind. The purpose of AML is to protect not only the financial system and our customers, but also society at large.
Within Nordea there exist Know Your Customer (KYC) instructions. These provide the framework for ensuring we know whom we are doing business with, where their money comes from, and the purpose of the transactions. A robust KYC process is the key element in Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) control activities and a key element in establishing and maintaining our customer relationships.
We recognise that customers react differently to questions about the origin of cash and the purpose of their business activities. Still, we firmly believe in the importance of requesting such information, and after explaining this to customers, the vast majority are more than happy to cooperate. When difficult situations do arise, branch managers hold debriefing sessions.
Bribery is a specific offence which concerns the practice of offering something, usually money, to gain an illicit advantage. Corruption is an abuse of a position of trust in order to gain an undue advantage.
Nordea expects all employees and other partners acting on behalf of Nordea to act with integrity and high ethical standards. Nordea’s Code of Conduct states the bank’s commitment to ethics, honesty and sincerity. In 2011, Nordea issued an Anti-Bribery and Corruption policy with an appendix on gifts, benefits and events. The policy has been written to meet international requirements and national laws such as the UK Bribery Act.
Ensuring awareness - training
At Nordea, we run two group-wide risk and compliance awareness programmes. The aim is to ensure high awareness among our people about risk and compliance requirements and expectations both in the financial industry in general and at Nordea specifically.
Compliance awareness programme for senior management
The objective of this programme is to outline the responsibilities of a senior manager. The programme enables the senior managers to understand relevant requirements and expectations so that they may identify the actions needed within their area of responsibility.
Operational risk and compliance awareness programme
The objective of this programme is to make all employees understand their responsibilities in connection with operational risk and compliance. The programme enables the participants through e-learning to:
1) Understand external and internal regulatory requirements
2) Gain awareness of a range of operational and compliance-related risks, threats and challenges
3) Be able to identify the need to act accordingly
We are committed to conducting business with the highest ethical standards and according to applicable laws, rules and regulations. Nordea’s internal control and operating procedures are designed to detect and prevent misconduct and fraudulent actions; however, even the most efficient controls cannot fully safeguard against all possible circumstances. For this reason, we encourage all customers, partners as well as our own employees to always report any suspected fraudulent or unethical behaviour.
Create report: https://report.whistleb.com/Nordea
What should you report?
Our whistleblowing procedure is intended solely for reporting suspected misconduct or irregularities, such as fraudulent, inappropriate, dishonest, illegal or negligent activity or behaviour. The whistleblowing procedure should not be used for customer complaints or to report on issues related to personal disputes. If you wish to make a customer complaint, please visit our local sites: nordea.dk, nordea.fi, nordea.no or nordea.se.
How should you report misconduct?
We encourage you to report openly, by providing your own name and contact details, as all reports are handled with strict confidentiality. However, you may also choose to report anonymously by using our system, which is managed by an external party. The system is separate from Nordea’s IT systems and does not track IP addresses or other data that could identify a person sending a message.
Should you choose to, you have the right to request and receive a complete list of information stored regarding your case, and if needed, have the right to request Nordea to correct incomplete or incorrect information.
Reports can be made in English, Danish, Finnish, Norwegian and Swedish; reports made in other languages will not be handled.