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This Investor Relations Policy ("IRP") is established to ensure that Sbanken ASA ("Sbanken") complies with rules and regulations relevant for financial reporting and communication in the Norwegian financial market, and meets market participant's expectations for timely and equal information.

Sbanken will in its reporting to the market, and during contact with investors and analysts, observe the following principles:

• All information from Sbanken, relevant to the pricing of financial instruments issued by Sbanken, will be published simultaneously to all market participants.
• To the extent possible, every publishing of new information will be made outside opening hours at the Oslo Stock Exchange.
• All financial information will be published in both English and Norwegian, and after the publication it will be made available on Sbankens website in both languages.
• The quarterly result presentations will be held in English and will be available as a web cast. An English conference call will be held in the afternoon (CET) on the same day as the results are published.
• All presentation material used for meetings and conferences with investors or analysts will be prepared in English, published by use of a stock exchange report before they are introduced and made available on the investor relations website.
• Sbanken may use presentation material in investor or analyst meetings based on previously published material, provided that there are no material deviations from previously published material.
• Sbanken will have internal policies in place to ensure that investors and analyst are given equal oral information, based on previously published material, during meetings and other direct contact.
• The CEO, the CFO and the Investor Relations Officer are the only spokespersons who, on a regular basis, are approved for contact with investors and analysts. Skandiabanken may appoint other spokespersons during special activities like roadshows and capital market days.
• Sbanken will not guide the market on future performance or results, but it will publish selected financial targets, report progress accordingly and update such targets when appropriate.
• Meetings and other communication with investors and analysts will, to the extent possible, be avoided for a period of 30 days before quarterly financial reporting.
• Price sensitive information which will have an extraordinary impact on profits will normally be disclosed when they occur to ensure that the entire market receives the information simultaneously.
• Sbanken will refrain from comment on any rumors or speculations related to financial performance or other price-sensitive developments.
• Sbanken will not use social media for dissemination of financial information or investor- or analyst-contact.

Sbanken complies with the Oslo Stock Exchange (Oslo Børs) "Code of Practice for IR", dated 1 March 2017.