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Code of ethics and business conduct

This document defines ethical guidelines for Sbanken ASA ('the bank'), cf. the code of ethics and business conduct.

1. Purpose of the guidelines

The purpose of the guidelines is to promote sound activities and maintain public trust in the financial institutions.

2. Ethics and core values

The guidelines apply to all employees of Sbanken ASA.

When appointed to a position, employees must be informed about the guidelines and confirm in writing that they are encompassed by and will comply with them. At least once a year, all managers must review the rules with their staff and discuss how they can be adapted and how they affect activities in their own section. This should take place at a meeting with all staff.

The above also applies to consultants who for long periods or in connection with large individual projects are affiliated to the bank. Clients and consultants who are subject to public laws/regulations (e.g. auditors and lawyers) are not required to give written confirmation that they are encompassed by these regulations.

Sbanken's core values:

In its encounters with customers, Sbanken shall be:


  • We are open and honest
  • We provide freedom of choice and have no hidden costs or agendas
  • We communicate why we do what we do


  • We make people's everyday lives simpler
  • We understand people's needs and provide the right assistance at the right time
  • We make it simple to make smart choices


  • We treat everyone fairly and as equals
  • We believe in a fair deal that benefits customers, employees, owners and society

A friendly rebel

  • We are bold and challenge established truths
  • We are playful and dare to make mistakes
  • We are different and develop the best solutions in partnership with others
  • We confront dishonesty head-on

3. Duty of secrecy and confidentiality

Duty of secrecy

On appointment, all employees will be informed about the rules that apply to confidentiality and the duty of secrecy. Employees must confirm that they have received this information and undertake to comply with the rules by signing the form 'DECLARATION OF SECRECY'.

The duty of secrecy also applies after termination of the employment relationship. When an employee leaves the bank, they are under no circumstances permitted to keep or take sensitive material, such as information about the bank's customers, with them. Employees who leave their position must confirm in writing that they have not kept or taken any sensitive material with them.

Breaches of the duty of secrecy/insider rules

The bank will continuously assess the employment relationship of employees who in breach of the applicable rules and without authorisation have distributed sensitive information. Such an act will in certain cases also represent a criminal offence on the basis of legislation intended to protect trade secrets, cf. the Financial Undertakings Act.

The Securities Trading Act sets out prohibitions subject to penal sanctions that apply to persons who on the basis of non-public information at their own or another's cost have traded in financial instruments before this information has been made public in the market.

Information about the bank's customers

Confidentiality must be exercised in the bank's activities in accordance with the applicable laws (e.g. the Financial Undertakings Act, the Personal Data Act (GDPR)); see also section 5.3. Confidential information must not be disclosed or mentioned to unauthorised persons or stored in a manner that makes it available to unauthorised persons.

Confidential information about customers must only be disclosed to:

  • The customer it applies to
  • Employees of the bank who need the information in order to perform their work
  • The authorities, assuming this concerns the duty to provide information in accordance with law

Information about the bank

It is most often in the bank's interest to provide information about the bank and to provide as comprehensive answers as possible to various questions about our activities from customers, the general public and mass media. Information in publicly available material such as annual reports and customer material can always be disclosed.

It is not permitted to disclose available information that contains sensitive information. This may be financial or market information as well as information about new products. Sensitive information must be stored in a manner that ensures that it is not available to unauthorised persons. Internally, such information must only be disclosed to employees who need it to perform their work. In general, it must nonetheless be considered that employees should have access to the best information possible in order to do their jobs well.


Data protection legislation, including the GDPR, contains special rules for the processing of personal data. All personal data that are processed in the bank are confidential. The data protection officer and data protection specialists can be contacted for more details.

Information to the authorities

As a rule, the bank must only disclose information to the authorities if provided for in laws/regulations or if the information is publicly available. This applies as much to information about customers as to information about the bank and its business activities. This principle must be consistently complied with and adapted even in cases where the requests do not concern information deemed to be sensitive.

4. Relations with the bank's employees

To ensure that the bank attracts and retains highly skilled employees, the bank will create a working environment characterised by job satisfaction, where employees can evolve and combine their expertise with customer focus and commitment.

4.1 Bribery and corruption

Bribery and corruption mean giving something of value with the corrupt aim of influencing someone's performance of their work. The person who accepts or requests such an advantage and the person who offers such an advantage are guilty of bribery. Bribery is considered a serious violation in Norway.

Bribery and corruption are basic obstacles to a free and well-functioning market economy and are completely unacceptable in the bank's activities. It is therefore under no circumstances permitted for the bank's employees to accept or give gifts that could be considered bribes or other improper rewards. This applies even if valuable business is lost to someone who accepts such conduct. Employees must report attempts at bribery to their immediate superior. The bank will participate in and comply with practice that is developed in this area.

Employees in the bank will receive the bank's anti-corruption guidelines.


General discounts given to all employees of the bank are permitted. Discounts that are only given to individual employees or to employees in individual departments are deemed to be bribes.

4.2 Sidelines

Employees of the bank must show caution in relation to sidelines. This also applies to non-commercial sidelines. HR must always be contacted to clarify sidelines.

The following must not occur:

Sidelines that can harm trust, unlawful/dubious sidelines – Activities that are unlawful or dubious or that resemble such activities, or other activities that can harm trust in the bank or the employee or that undermine the employee's personal or financial integrity.

Competing sidelines – Activities that compete with the bank's activities or that are operated by someone who is a supplier or customer of the bank. Caution must also be shown as regards contributing as a speaker at external conferences so that competitors do not obtain information that is valuable to the bank.

Time-consuming sidelines – Activities that take up so much time or are so demanding that they are to the detriment of work for the bank. Such work must not be carried out during working hours or on the bank's premises or using the bank's property or in other ways that can be related to the bank. Employees who are uncertain about whether such work is permitted must always obtain written consent from their immediate superior or from HR. The immediate superior/HR can also in special cases grant some degree of exemption from the above-mentioned rules. If the bank so requires, the employee must provide information about sidelines of such a nature.

4.3 Personal conduct

In order to win and maintain trust and respect, the bank places great requirements of its employees in terms of ethics and personal conduct.

Personal integrity

Employees of the bank must have a great degree of personal integrity. Employees must be able to resist undue pressure regardless of where it comes from.

Financial matters

Employees of the bank should not take part in gambling, speculation business or similar, or accept liability that could place their personal finances at risk.

Drugs and alcohol

Employees of the bank should not use drugs. This also applies to outside work. Alcohol (light beer is not considered alcohol) should not be consumed during working hours. Exceptions can be made in relation to hospitality. In such cases, consumption should be moderate.

Criminal offences

The bank does not accept criminal offences on the part of its employees. Employment relationships will be continuously assessed for employees who are guilty of a criminal offence in the bank's service or violations aimed at the bank. The same applies to employees who have been sentenced to stricter punishments than fines outside the bank's service.

Membership in or sympathising with certain organisations

The bank does not accept that its employees are members of or are active sympathisers with organisations that are undemocratic, racist or violent or that in other ways are connected with criminal activities.

Sexual harassment

The bank does not tolerate any form of gender discrimination, including verbal, physical and sexual harassment.

Special requirements of managers in the bank

Managers in the bank are subject to particularly strict requirements as regards ethics. Managers should be an example to the other employees. A manager must always comply in full with the rules and norms that apply to the other employees. It is not acceptable that managers breach internal rules and norms and abuse the trust that the bank has invested in them.

4.4 Whistleblowing procedures

Employees have a right to provide notification of matters that warrant criticism at work but must be conscious of not unnecessarily harming the employer, working environment or colleagues (see the Guidelines for Whistleblowing). In some cases, employees may also have a duty to provide notification.
If an employee wishes to notify of a matter, their immediate superior or other member of the management can be a contact person for the whistleblowing procedure or in discussions on ethical matters. Employees are encouraged to use the bank's document 'Guidelines for Whistleblowing' and the pertaining form to notify of a matter.

4.5 Ethical committee

Sbanken makes many decisions of an ethical nature. The committee discusses and makes decisions relating to what the bank believes is necessary to be a socially responsible bank and what measures must be used to achieve this.

4.6 Monitoring compliance with the ethical guidelines

The persons responsible for their respective sections are responsible for compliance with the ethical guidelines in their section. The same managers are also responsible for immediately informing the bank's chief executive of matters of principle or other important ethical issues that affect their own activities and/or employees' conduct.

5. Basic considerations

The following basic considerations characterise the bank's relationships to its customers and other external stakeholders as well as internal relations between the bank's employees:

Quality and a long-term perspective

The bank and its employees shall represent high quality and act on the basis of a long-term perspective.

Objectivity, fairness and consistency

The bank and its employees shall be objective, fair, decent, honest and consistent.

Speed, availability and clarity

The bank and its employees shall be quick and active, be available in external as much as internal contexts, and communicate in a simple, quick and clear manner.

Helpfulness and respect

The bank and its employees shall be helpful, objective and show respect for the individual with an understanding of each customer's situation.


The bank and its employees shall have a great degree of integrity and resist undue pressure.

Financial advice

Financial advice must be provided in an objective and responsible manner and on a case-to-case basis. The bank must provide sufficient information to the customer on matters that are important to the specific context. They must among other things be informed about any risks that are linked to individual services and products.


Credit must be granted on the basis of the customer's financial situation. Credit should not be granted in cases where we are aware that the purpose is not in accordance with the bank's credit policy and credit manual.

5.1. Knowledge of laws, regulations etc.

The board and management shall ensure that the bank complies with laws, regulations etc. that relate to its activities. The bank must comply with the decisions and recommendations that the bank's industry association has adopted.

The bank's management is responsible for ensuring that employees' knowledge of the above-mentioned laws and guidelines is maintained at a satisfactory level.

The bank shall, in general, conduct its activities in a manner that promotes the basic considerations listed above. Ethical assessments are made on the basis of good reputation and each person's sense of right and wrong. Ethical assessments must always be made by a decision-maker in the bank. A good indication of whether a decision or decision of principle meets the ethical requirements posed is whether the decision can be justified and explained to superiors, customers and outsiders.

The bank shall have and effectively use sufficient resources and procedures that enable the bank to operate as described. Initiatives that can raise ethical awareness are encouraged.

Working environment

The bank must take active steps to protect the working environment.


The bank must prevent discrimination both in relation to its employees (see section 4.3) and its customers.

Marketing and sale

The bank's marketing shall be serious and factual. This also includes verbal marketing by individual employees. The market or individual customers must never be given a wrong or exaggerated impression of the bank or its products.

The bank's marketing shall promote healthy competition. Information about and comparisons with competitors must be objective and not contain derogatory or misleading information. Competitive information must not be misused.

In its marketing, the bank must provide relevant information to its customers about the services and products it offers. This includes providing information about any pertaining risks.

The bank must be particularly diligent in marketing aimed at children and young people.

Contact with the mass media

The bank's contact with the mass media shall be characterised by transparency, objectivity, honesty, and respect and understanding of the media. However, this must not lead to sensitive information about the bank or its customers being disclosed. If employees receive an enquiry from the media concerning the bank's activities in general, they should, as a rule, be referred to the bank's public relations officer, chief executive or his or her deputy. This is to ensure that the information provided is correct and identical. If the matter concerns product terms and conditions or similar, however, the question may be answered by the employee directly.

5.2. Anti Money laundering

Sbanken endeavours to prevent and expose money laundering and financing of terrorism. All employees shall at all times have basic expertise in countering money laundering and in the requirements set by the bank. This is ensured through good efforts in the organisation and annual compulsory E-learning. Special attention must be given to attempts at money laundering relating to the bank's activities. The regulations on this matter can be found in the Money Laundering Act and the Money Laundering Regulations.

5.3 Privacy

Correct processing of personal data is important to the bank. All employees must have basic expertise in the topic both in relation to what data are considered personal data and how they are to be processed. This is ensured through good work in the organisation and annual compulsory E-learning.

5.4 Employees' own or connected persons' securities and currency trading

Trading in financial instruments shall take place in a manner that maintains general trust in the securities market. The way in which the bank handles its customers' securities trading is of major importance to public trust in the bank.

Those involved must therefore comply with the applicable guidelines provided by the Financial Supervisory Authority or by the relevant industry association (the Norwegian Fund and Asset Management Association VFF) concerning securities and currency trading etc. performed by employees in securities companies at their own or a connected person's cost.

More detailed procedures for affected persons' duty to report etc. are set out in the bank's instructions for employees' proprietary trading in financial instruments.

6. Relations with the authorities

The bank shall act transparently and with respect in relation to supervisory authorities and other official bodies. Enquiries from official bodies shall be answered correctly and promptly.

6.1 Tax and tax reporting of the bank's products

Tax and tax reporting for the customers of products being developed and marketed must always be mapped before they are launched.

The bank's contact with the tax authorities shall be characterised by honesty and respect.

6.2 Employees' taxes

Employees of the bank must show great care in relation to their own tax planning and conduct that could be considered tax evasion. This particularly concerns employees who have management positions in the bank.

7. Conflicts of interest

Conflicts of interest that arise from matters over and above normal customer relationships must be avoided. If they should nonetheless occur, the customer must be treated fairly.

An employee should not consider cases in which he/she has a personal interest, or where his/her related parties have an interest or that involve companies in which the employee or his/her related parties have interests.

8. Suppliers, partners and other business contacts

The bank supports transparent, honest and fair competition between free market stakeholders. The bank will therefore:

  • Not deal with suppliers that are known to not comply with their obligations to their business partners, employees or society at large or, for example, do not pay taxes or breach contracts entered into
  • Not deal with suppliers where it is known that they themselves or their owners have violated the provisions on liquidation
  • Not deal with suppliers whose owner relationship is unclear
  • Carefully comply with international and national competition rules

Cooperation agreements must be established between the bank and its business partners.

The bank must ensure that businesses with which the bank cooperates act in accordance with applicable laws and regulations, and with regulations imposed by the authorities. The cooperation agreement should state that the bank has a right to terminate the agreement if the business does not comply with the applicable rules.

9. Relations with the supervisory authorities

The bank must act transparently and with respect in relation to supervisory authorities. Enquiries from the authorities must be prioritised and answered correctly and promptly. However, it is important to check that the authorities are entitled to information on the matter in question before disclosing information and answers.