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, 74 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)
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 (pdf, 127 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 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.
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.
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.
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.
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, in which total project capital costs exceed USD 10m and the project is assessed to have a potential adverse social or environmental impact. However, the long-term trend to reduce project finance activities has continued and only one new Equator Principles transactions were signed by Nordea in 2018.
Sustainable investment forums
Nordea actively participates in local sustainable investment forums – ‘SIFs’ – which are independent national forums that promote responsible investment. Nordea became a member of SWESIF in 2008 and DANSIF in 2010. Furthermore, we were a founding member of FINSIF launched in June 2010 and NORSIF launched in February 2013.
The Montreal Carbon Pledge
Nordea signed the Montreal Pledge in 2014 as one of the first signatories. The Pledge commits us to disclose the carbon footprints of our equity funds.
Nordea signed the UN Environmental Programme Finance Initiative (UNEP FI) in 1994. UNEP FI is a partnership between the 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 current environmental, social and governance challenges, why they matter to finance, and how to actively participate in addressing them. The UNEP Statement of Commitment by Financial Institutions on Sustainable Development represents the backbone of the initiative. By endorsing the statement, financial institutions openly recognise the role of the financial services sector in making economy and lifestyles sustainable and committing to the integration of environmental and social considerations into all aspects of operations.
The United Nations Global Compact (UNGC) was initiated by the UN to encourage businesses to align their strategies and operations with ten universal principles that build 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 entire Group as the signatory role was transferred to Nordea Bank AB (publ.).
The United Nations Guiding Principles on Business and Human Rights (UNGP) from 2011 are 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 recognised framework for enhancing standards and practice regarding business and human rights.
As one of the first major banks in the Nordic countries, Nordea signed the United Nations Principles for Responsible Investment (UN PRI) in 2007. At the same time, we also launched our own responsible investment policy. The policy shows how we adhere to these principles, report on our activities and progress in implementing the PRI. The report is public and available on the PRI website.
Association membershipNordea 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.
Type of engagement
Swedish Bankers’ Association
FFI – Federation of Finnish Financial Services
European Banking Federation
Nordea is represented via the local bankers’ associations that are members
GFMA – Global Financial Markets Association
EFR – European Financial Roundtable
EBG – European Banking Group
AFME – Association for Financial Markets in Europe
Swedish Securities Dealers’ Association
FEAM Forum for European Asset Managers
EFAMA – European Fund and Asset Management Association