Applicable laws and regulations set requirements for the monitoring and assessment of as well as the decision-making concerning related party transactions and the disclosure of executed related party transactions.
Generally, the Company’s transactions with its related parties are part of the Company’s ordinary course of business and carried out according to the same criteria and terms as those of comparable transactions with other parties of similar standing. The decision-making processes have furthermore been structured in order to avoid conflicts of interest and to comply with the statutory decision-making requirements.
The Company has defined its related parties in accordance with the applicable laws and regulations and keeps an up-to-date record of its related parties. Relevant internal stakeholders, such as customer responsible units, other relevant business units and Group functions, are informed of the list of related parties and the related restrictions in order to monitor transactions with such parties.
Nordea is also bound by applicable close circle rules and has processes in place for identifying the persons belonging to the close circle of Nordea and for ensuring that any credits and comparable financing granted to such persons as well as any investments in an entity belonging to the close circle are granted in accordance with applicable laws and rules.
Pursuant to the Company’s Conflict of Interest Policy, employees, management and the members of the Board must not handle matters on behalf of Nordea in cases where they or a closely associated person or company may have an interest that conflicts with the interests of Nordea or its customers. Nordea’s business areas and Group functions are obliged to identify, prevent and manage actual and potential conflicts of interest.
The Board has the ultimate responsibility for ensuring proper processes for the identification, reporting and supervision of related party transactions as well as the proper decision-making in this respect. The Board Audit Committee must assist the Board in monitoring and assessing how related party transactions meet the requirements of ordinary activities and the arm’s length terms.
Related party transactions that are not part of the Company’s ordinary course of business or are made in deviation from customary commercial terms require a decision by the Board for the related party transaction to be carried out, unless otherwise required by applicable laws and regulations. In respect of such related party transactions the Board must ensure that:
(i) the relevant transactions have been appropriately identified, reported, and controlled
(ii) the Conflict of Interest Policy has been carefully considered in the preparation and decision-making process and
(iii) the preparation of related party transactions includes adequate reports, statements and/or assessments. Furthermore, Nordea publicly discloses its related party transactions in accordance with applicable laws and regulations.