Applicable laws and regulations set requirements for the monitoring, assessment, and decision-making concerning related party transactions as well as for 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 on the same criteria and terms as those of comparable transactions with external parties of similar standing. With the exception of compensation, certain loans and other commitments to the key management, all related party transactions are made on the same criteria and terms as those of comparable transactions with external parties of similar standing. The decision-making processes have furthermore been structured in order to avoid conflict of interests 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 client responsible units and other relevant business units and group functions, are informed of the list of related parties and thereto 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 ensuring that credits and comparable financing granted to such persons, as well as any investments into an entity belonging to the close circle, are done in accordance with applicable laws and rules.
Pursuant to the Company’s conflict of interest policy, Nordea’s employees, management and members of the Board may not handle matters on behalf of Nordea in cases where he/she 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 interests.
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 related thereto. The BAC shall assist the Board in respect of monitoring and assessing how related party transactions meet the requirements of ordinary activities and 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 of the Board to carry out the related party transaction, unless required otherwise based on 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 preparation and decision making have carefully considered the conflict of interest policy; and (iii) the preparation of related party transactions contain adequate reports, statements, and/or assessments. Furthermore, Nordea publicly discloses its related party transactions, in accordance with applicable laws and regulations.