(30 January 2018)

The ethical guideline is an essential part of the foundation’s operations, and apply to all employees and members of the governing bodies at Sparebankstiftelsen DNB including its subsidiaries.

1. In general

Sparebankstiftelsen DNB acts independently, long-term and transparent. The foundation acts in accordance with laws and regulations, and the foundation’s resolutions. Employees and representatives must perform their duties, and act in a manner, that does not damage the foundation's reputation and public trust.

The foundation expects its collaborators, grantees and suppliers to act ethically - hereby in compliance with applicable laws and regulations, respecting human rights and following international standards regarding the environment and employee rights.

2. Management of funds

The foundation's funds ensures the foundation's purpose, and should benefit many people over a long time. Finances are to be managed in accordance with guidelines set by the Board of Directors.

The foundation's use of funds must be economical and rational. Expenses for events etc. should be moderate. Misuse and waste of funds must not occur.

Decisions related to charitable donations shall be based on an assessment of which projects best contribute to realize the foundation's purpose.

3. No personal benefits

Employees and representatives are not to gain personal benefits from the foundation's funds, other than those related to employment contracts and agreed fees.

Employees and representatives should also not receive undue benefits from the foundation's suppliers, collaborators or beneficiaries. Personal gifts should not be accepted unless these are purely attentive gifts of negligible value.

As for participation at conferences and the like, the foundation will primarily cover its own travel and accommodation expenses.

4. Avoid conflicts of interest

No one should participate in making decisions directly affecting the interests in favor of one self or someone closely related, or other circumstances that might be liable to weaken the trust in someone’s independence. Everyone who participates in making decisions are responsible for avoiding conflicts of interest. Employees must notify superiors of incapacity and doubt. Board members must address possible incompatibility with the board, which determines the eligibility.

In order to highlight the most relevant areas of conflict, the foundation keeps an overview of important and relevant relations between board members and management and the foundation’s connections and areas of activity.

Employees and representatives must exercise caution when investing in areas where the foundation has an engagement, in order to avoid uncertainties related to self-benefit as to the foundation's investment decisions.

5. Harassment is not accepted

The foundation is to have a safe and inclusive work environment where discrimination and harassment is not accepted.

Employees and representatives should not act in a way that colleagues or others might perceive as harassment, or should not be subjects to such behavior.

6. Transparent communication

Sparebankstiftelsen DNB communicates openly about its operations and donations. Communication should be objective and truthful.

7. Alerts

In case of events of blameworthy conditions within the foundation, this should be addressed for improvements to be made.

Notifications should go to one’s immediate superior, the general manager or to the Chairman - based on the nature of the case. The person receiving an alert should inform his or her superior of the notification and of the measures taken.

In addition, the foundation has established a whistleblowing channel for anonymous alerts, which is also available to external parties.

8. Personal responsibility

Employees and representatives have an individual and independent responsibility to follow these ethical guidelines.

Employees should raise issues of doubts with their immediate superior. Employees have the right to refuse to follow commands that are illegal or violate these regulations.

Violation of the ethical guidelines can cause consequences regarding the employee situation.