Code of Conduct

1. Purpose

Kommunalbanken (KBN) seeks to be characterised by trust, and the organisation is committed to having high ethical standards as its foundation. This Code of Conduct sets out standards for how KBN’s employees are to behave at work and in their interactions with colleagues, as well as in their interactions with third parties when acting on behalf of KBN.

2. Scope

The Code of Conduct applies to KBN’s Board of Directors, its permanent and temporary employees, consultants hired in by KBN and other persons who act on behalf of KBN (hereinafter collectively referred to as ‘employees’) unless stated otherwise.

The CEO may issue more detailed rules regarding the scope of this Code of Conduct in relation to hired-in consultants and others who act on behalf of KBN.

The person responsible for KBN’s relationship with any external person required to comply with this Code of Conduct must notify HR of the person concerned.

3. Basic principles

• Employees must comply with all applicable regulations and KBN’s governance documents.
• Employees are required to demonstrate high ethical standards and to act in a trustworthy manner in their work for KBN. KBN expects its employees to help each other comply with legislation and regulations and to report censurable matters.
• Employees must be familiar with KBN's current Code of Conduct. KBN will provide employees with training on the rules at least annually. All employees must annually confirm in writing to Compliance that they are familiar with the rules.
• KBN’s managers must be good role models. Through their words and actions they must promote compliance and responsible business practice. KBN’s managers should also help create an environment of openness around questions about ethical issues and the working environment.
• KBN's managers must ensure that employees familiarise themselves with KBN's Code of Conduct and its other internal rules. They must also contribute to ensuring that employees complete the necessary training activities so that they can actively comply with the Code of Conduct.
• Violations may ultimately lead to employment law, contractual law and criminal law consequences.

4. Sustainable operations and development

The Norwegian Transparency Act requires that KBN must work actively to combat human rights violations and to ensure decent working conditions. KBN’s employees are required to contribute to the sustainable development of society as well as to long-term value creation by adopting responsible business practices.

5. Customer relations

Employees must interact with and treat KBN’s customers in a professional manner. This is important in order to build and maintain trust in KBN and its reputation. KBN’s treatment of its customers will be characterised by respect, a high level of integrity and transparency. Feedback from customers will be taken seriously and processed in accordance with special procedures.

6. Secure assets

KBN possesses assets¹ that have the potential to cause a high or very high level of damage in the event of loss or unauthorised alteration. Employees are required to help protect KBN’s assets, and therefore must be aware of and comply with the rules that are intended to protect KBN’s assets.

7. Confidentiality and Privacy

Employees have a duty of confidentiality. Employees must be familiar with and comply with the rules for handling information. Employees must exercise necessary caution in handling information, and they have an independent responsibility for assessing whether its disclosure should be limited. This applies to internal and external disclosure. Unless otherwise agreed, the duty of confidentiality continues to apply after the end of an employee’s employment relationship.

Unlawful disclosure and misuse of inside information are criminal offences. Employees must be familiar with the rules for handling insider information.

All individuals about whom KBN has information should be able to trust that their information is secure. Employees must know how personal data should be handled.

8. Communication

Communications from KBN must be reliable and accurate.

KBN's operations require the exchange of information and data both internally and externally. This must take place in accordance with the applicable rules for information management.

Employees must adhere to the rules regarding who speaks externally on behalf of KBN. Employees must exercise caution when making statements in the public domain, including on social media.

9. Own account trading

Employees may trade financial instruments for their own account within the framework of the relevant guidelines.

10. Financial crime

KBN is committed to ensuring that it is not exploited for, and does not contribute to, financial crime. KBN will, by means of high-quality compliance and good business practices in its interactions and meetings with external parties, help prevent financial crime. All employees must report any suspicious circumstances.

10.1. Money laundering, terrorist financing and sanctions regulations

KBN will work actively to counteract being used for the purposes of money laundering or terrorist financing. KBN will operate in accordance with the relevant sanctions regulations. All employees must therefore be aware of their obligations as set out in the relevant regulations and governance documents. Suspicious matters must be reported to KBN’s head of anti-money laundering as soon as possible.

10.2. Corruption

Corruption is prohibited. This prohibition applies both to the person who gives or offers an undue advantage, and to any person who requests, receives or accepts such an advantage. It is sufficient that a request or offer of an undue advantage is made for the act to be illegal.

Employees must not accept, request or give any undue advantage. This also applies if the benefit accrues to KBN, other persons or companies.

These guidelines do not prevent employees from giving or receiving gifts of insignificant value, or moderate hospitality or entertainment that is commercially justified. Any gift received by an employee that is worth over NOK 500 must be reported to HR, and it will become the property of KBN.

10.3. Conduct in respect of tax

It is important for trust in KBN that KBN’s accounting, tax reporting and payment of tax are correct.

KBN must be able to comply with the tax regulations, whilst refraining from avoidance.

KBN must also act openly with regard to tax and its accounts. KBN’s tax policy must be available on the company's website.

10.4. Competition

The Norwegian Competition Act requires that KBN must not inappropriately exploit its market power or take part in agreements restricting competition, such as price collusion, market sharing or cooperation with competitors in tender processes.

In order to ensure that KBN is trusted, employees must exercise a high degree of caution. Information that may be competitively sensitive is processed in accordance with applicable guidelines.

11. Conflict of interest

A conflict of interest may arise if an employee's personal interests do not coincide with KBN's interests, or when an employee must be considered to have a prominent personal or financial special interest in a matter. A conflict of interest also arises when an individual has interests that could affect their objectivity or impartiality in a given situation. It is crucial that decisions and actions are not influenced by extraneous considerations.

• KBN's employees must not participate in the processing or decision of questions that are of particular importance to the employee himself or someone close to them, where this means that the person concerned must be considered to have a prominent personal or financial special interest in the matter.
• Employees cannot participate in the processing or decision of cases where there are other special circumstances which are likely to undermine trust in the person concerned or KBN.

KBN will maintain an established practice for identifying conflicts of interest. Conflicts of interest must be managed to the greatest extent possible.

Employees have an independent responsibility for assessing whether there is a conflict of interest and must report any such conflict to their immediate manager. In cases of doubt, employees can discuss with their immediate manager whether there is a conflict of interest, or request an assessment by the manager. Requests for such assessments from employees must be documented. All decisions are submitted to the CEO.

The question of whether the CEO has a conflict of interest in relation to any matter is assessed and determined by the Board of Directors. Board appointments and secondary employment positions undertaken by the CEO must be approved by the Board of Directors.

If there could be doubt about whether a board member has a conflict of interest, the question is decided by the Board of Directors without the relevant board member being present.

11.1. Other commercial activities, secondary employment and external appointments

Employees may not run other business activities, take up paid part-time work or hold board positions at other companies without the written approval of the CEO. This prohibition does not apply to KBN's external board members.

Provided there is no conflict of interest, employees may hold appointments on housing associations, teams or clubs, etc. without specific approval. The CEO is authorised to determine additional rules relating to such positions held by employees. Employees’ external appointments, paid secondary jobs and other commercial activities must be registered with HR in accordance with the internal routines.

12. Working environment

KBN is committed to providing a high-quality and physically, mentally and socially healthy working environment. Employees must, through their actions and behaviour, demonstrate respect for colleagues and other people KBN interacts with.

KBN does not tolerate bullying or harassment of any kind, including unwanted sexual attention or hostile or degrading comments or behaviour.

KBN values diversity and is committed to promoting greater diversity. KBN does not accept discrimination or harassing behaviour on the basis of gender, pregnancy, parental leave in connection with the birth or adoption of a child, care responsibilities, ethnicity, religion, beliefs, disability, sexual orientation, gender identity, gender expression, age or other essential characteristics of an individual.

No one should be under the influence of alcohol or other intoxicants while performing work for KBN. In social settings and at events outside of working hours, alcohol may be served. In such settings, employees must exercise moderation.

Employees must report any harassing or discriminatory behaviour or instances of intoxication that are in contravention of this Code of Conduct.

13. Whistle-blowing

KBN strives to ensure a climate of expression in which employees can whistle-blow without risking any form of reprisal.

Employees must report any situations that are not acceptable. KBN processes such whistle-blowing reports in accordance with the relevant legislation and regulations, and employees should ensure that they are aware of KBN’s processes. There are no specific requirements in respect of the format in which such whistle-blowing must be undertaken, and it can be done anonymously. KBN has an internal whistle-blowing channel with pre-determined procedures, as well as an external whistle-blowing channel.

Employees should be open about personal matters that could affect their ability to complete their work to a significant extent, or that could put them in a vulnerable situation that others could exploit.

14. Compliance

The ethical standards set out in this Code of Conduct must be tested and assessed regularly, and at least every three years.

15. Delegated authority

The CEO is authorised to determine additional rules within the framework of this Code of Conduct.

16. ENTRY INTO FORCE

This Code of Conduct enters into force with immediate effect.

¹ This comprises information, IT systems and equipment, access to electronic services, office premises and fixtures.