Nordea's Code of Conduct
The Code of Conduct describes Nordea’s high-level ethical principles that guide our business, how we treat our customers, and the conduct we expect from our employees. It includes aspects such as care for the environment, labour rights, how we treat our customers, commitment to human rights, the right to privacy, and anti-bribery and corruption.
The Code of Conduct applies to all employees and everybody working on behalf of Nordea, and is supported by specific and concrete policies to ensure compliance with everyday business.
Download our Code of Conduct (pdf, 523 KB).
Policies and group directives
Our principles guide our behaviour in our daily work and when making business decisions. We take these principles and all other relevant environmental, social and governance principles into consideration when evaluating business risks and opportunities. We expect our business partners and suppliers to adhere to these principles too.
The Nordea Sustainability Policy
The Nordea Sustainability Policy sets out the principles for how Nordea ensures the long-term sustainability of its operations and, in so doing, strengthens long-term customer relationships and Nordea’s contribution to a greater good. The policy aims to support Nordea and its employees in performing their work and decision-making.
Download our Sustainability Policy (pdf, 1 MB)
The Nordea Responsible Investment Policy
With assets under management exceeding EUR 217 billion, Nordea has a tremendous responsibility to deliver good returns by supporting international norms and being a responsible investor. Because of this, we have developed policies, procedures and investment products to ensure that all the companies in which we invest fulfil various criteria. We have also signed the UN Principles for Responsible Investment and are thus committed to integrating ESG factors into our investment analysis, decision-making processes and active ownership practices.
Download our Responsible Investment Policy (pdf, 77 KB)
The Nordea Supplier Code of Conduct
The Nordea Supplier Code of Conduct outlines Nordea’s expectations to suppliers and is aligned with the Nordea Code of Conduct and the UN Global Compact. We expect our suppliers to not only abide by the laws and regulations of the countries in which they operate, but also work to move beyond compliance. By encouraging suppliers to share our standards and continously collaborate on improvements, we believe that we can have a significant impact and at the same time mitigate risk.
Download our full Supplier Code of Conduct (pdf, 4 MB)
The Nordea Tax Policies
Nordea’s policy is to pay taxes in accordance with local regulations in all our countries of operation and, in so doing, to make an appropriate contribution to each society. We manage tax costs and risks carefully, and by paying and reporting taxes in due time, we aim to maintain a good local tax reputation.
Download our Tax Policy (pdf, 79 KB)
Download the extract from Tax Policy on Customer advice (pdf, 99 KB)
Preventing Financial Crime
Nordea Financial Crime-related policies and practices are summarised in the following documents and statements
Nordea Anti-Money Laundering/Terrorist Financing Practices Letter (pdf, 34 KB)
Nordea Internal Policies (Sanctions Risk Management) (pdf, 61 KB)
Nordea Sanctions Practices Letter (pdf, 41 KB)
Nordea US Patriot Act Certificate (pdf, 585 KB)
Nordea US Patriot Act Appendix (pdf, 7 KB)
Wolfsberg Financial Crime Compliance Questionnaire (pdf, 37 KB)
Position statements & sector guidelines
Nordea Sector Guideline for the Forestry Industry
The Sector Guideline for the Forestry Industry sets out the principles for Nordea’s business with the Forestry industry.
Nordea Sector Guideline for the Real Estate Industry
The Sector Guideline for the Real Estate Industry sets out the principles for Nordea’s business with the Real Estate industry.
Nordea Sector Guideline for the Gambling Industry
The Sector Guideline for the Gambling Industry sets out the principles for Nordea’s business with the Gambling industry.
Nordea Sector Guideline for the Fossil Fuels Industry
The Sector Guideline for the Fossil Fuels Industry sets out the principles for Nordea’s business with the Fossil Fuels industry.
Nordea Sector Guideline for Shipping Industry
The Sector Guideline for the Shipping Industry sets out the principles for Nordea’s business with the Shipping industry.
Nordea Sector Guideline for the Defence Industry
The Sector Guideline for the Defence Industry sets out the principles for Nordea’s business with the defence industry. It includes references to the international and national laws, regulations and standards Nordea expects companies in the defence industry to follow.
Nordea Climate Change Position Statement
On 30 November 2017, we launched our position statement on climate change. This position statement sets out the scope and principles of Nordea’s climate change agenda. Therein, we take into account the nature of our business, whereby investments, credits and purchases can have both a local and global impact. The position statement was updated in May 2019.
Endorsed external charters and initiatives
We have endorsed a number of important international treaties that help guide us and live up to our overarching commitments. In addition to the conventions below, in its operations and business, Nordea follows the United Nations’ Universal Declaration of Human Rights, ILO conventions and the OECD Guidelines for Multinational Enterprises.
Carbon Disclosure Project (CDP): Nordea is a signatory to the CDP, a project that aims to collect and share information on greenhouse gas emissions and climate change strategies. The CDP is a cooperation arrangement between 655 institutional investors with a combined asset holding of USD 78 trillion. We use the database information in our ESG analysis. We are also represented on the CDP Water Advisory Council.
Climate Action 100+: Nordea Asset Management has joined Climate Action 100+, a collaborative five-year global initiative led by investors to engage with the world’s largest corporate greenhouse gas emitters to improve governance on climate change, curb emissions and strengthen climate-related financial disclosures.
Collective Commitment to Climate Action: Nordea has, together with the 30 other signatories having over $13 Trillion in assets, announced a Collective Commitment to Climate Action. The commitment sets out concrete and time-bound actions the banks will take to scale up their contribution to and align their lending with the objectives of the Paris Agreement on Climate.
Institutional Investors Group on Climate Change (IIGCC): IIGCC provides investors with a collaborative platform to encourage public policies, investment practices, and corporate behaviour that address long-term risks and opportunities associated with climate change.
Net-Zero Asset Owner Alliance: Nordea Life & Pensions has joined the UN-convened initiative Net-Zero Asset Owner Alliance, committing to transitioning the investment portfolio to net-zero emissions by 2050. The alliance till develop models and frameworks to use as industry standards for measuring alignment with the target of keeping global warming under maximum 1.5°C increase.
Principles for Responsible Banking (PRB): The Principles for Responsible Banking have been designed by a core group of 30 founding banks, of which Nordea is one, together with the UN Environment Programme’s Finance Initiative. The principles create a better and easier way for banks and financial institutions to align with society’s goals. This, in turn, helps the industry to demonstrate how it can be a change-maker to count on in society.
Task Force on Climate-related Financial Disclosures (TCFD): Both Nordea Bank Abp and Nordea Asset Management supports TCFD. The recommendations provide a foundation for climate-related financial disclosures for all companies, aiming at encouraging companies to report on the climate-related risks and opportunities that are most relevant to their business activities.
The Access to Medicine Index: The index analyses the top 20 research-based pharmaceutical companies on how they make medicines, vaccines and diagnostics more accessible in low- and middle-income countries. It highlights best and innovative practices; and areas where progress has been made and where action is still required.
The Antimicrobial Resistance Benchmark: The AMR Benchmark tracks how pharmaceutical companies are responding to the increase in drug resistance. Nordea is a member of the Expert Committee.
The Corporate Human Rights Benchmark (CHRB): The CHRB is the first ever ranking of the world’s largest publicly listed companies on their human rights performance. The Corporate Human Rights Benchmark will rank the top 500 globally listed companies on their human rights policy, process and performance, harnessing the competitive nature of the markets to drive better human rights performance. Nordea is a founding member and on the CHRB Advisory Board.
The Equator Principles: Nordea was the first Nordic bank to adopt the Equator Principles, endorsing them in 2007. It is a set of guidelines on how to prevent, manage and mitigate environmental and social risks in project financing. The Equator Principles apply globally to projects across all sectors, where total project capital costs exceed USD 10mn and the project is assessed to have a potential adverse social or environmental impact.
The Montreal Carbon Pledge: Nordea signed the Montreal Pledge in 2014 as one of the first signatories. By signing this pledge, we commit to measuring and publicly disclosing the carbon footprint of our investment portfolios on an annual basis.
The Responsible Ship Recycling Standards (RSRS): RSRS voluntary principles for financial institutions active in ship financing. The RSRS aim to promote responsible ship recycling and to minimise the dangers associated with hazardous materials on board. The standards form guiding principles in the dialogue about responsible ship recycling between the financial sector and the stakeholders in the shipping industry. Download Nordea Responsible Ship Recycling Standards (pdf, 49 KB)
The World Benchmarking Alliance (WBA): Nordea is part of the WBA which seeks to generate a movement around increasing the private sector’s impact towards a sustainable future for all. The WBA brings together a broad, balanced group of stakeholders with SDG 17 (Partnership for the Goals) at its core. Allies represent a large mix of voices aligned with the universality of the SDGs. These range from civil society and business networks, to financial institutions and multilateral organisations.
UN Environmental Programme Finance Initiative (UNEP FI): Nordea signed the UNEP FI in 1994. It is a partnership between United Nations Environmental Programme and the global financial sector created in the wake of the 1992 Earth Summit with a mission to promote sustainable finance. More than 200 financial institutions, including banks, insurers, and investors, work with UNEP FI to understand today’s environmental, social and governance challenges, why they matter to finance, and how to actively participate in addressing them. In 2017, we were elected as Social Issues representative for the UNEP FI Banking Committee and member of the UNEP FI Social Issues Advisory Board.
UN Global Compact (UNGC): UNGC was initiated by the UN to encourage businesses to align their strategies and operations with ten universal principles building on UN conventions in the fields of human rights, labour standards, environment and anti-corruption. Nordea became a signatory to the UN Global Compact in 2002, first through Nordea Bank Finland. From December 2004 the coverage was extended to the whole Group.
UN Guiding Principles on Business and Human Rights (UNGP): UNGP from 2011 is the first global standard for preventing and addressing the risk of adverse impacts on human rights linked to business activity and continue to provide the internationally accepted framework for enhancing standards and practice regarding business and human rights.
UN Principles for Responsible Investments (PRI): As one of the first major banks in the Nordic countries, Nordea Asset Management signed PRI in 2007. The PRI is the world's leading proponent of responsible investment. It works to understand the investment implications of environmental, social and governance (ESG) factors and to support its international network of investor signatories in incorporating these factors into their investment and ownership decisions.
Nordea is member of a number of associations (see examples in the table below). Besides holding a position as a board member, we also often participate in working groups and committees.
|Association/Forum||Type of engagement|
|Swedish Bankers Association||Board member|
|Finance Denmark||Board member|
|Finance Finland||Board member|
|Finance Norway||Board member|
|European Banking Federation||Nordea is represented via the local bankers’ associations which are members|
|GFMA – Global Financial Markets Association||Board member|
|AFME – Association for Financial Markets in Europe||Member|
|Swedish Securities Dealers Association||Board member|
|FEAM – Forum of European Asset Managers||Member|
|EFAMA – European Fund and Asset Management Association||Board member|
|ICMA – International Capital Markets Association||Member|
|ISDA – International Swaps and Derivatives Association||Member|