Ethics and anti-corruption
Ethics and anti-corruption
The ethical guidelines are about attitudes and values, and aim to contribute to awareness of and compliance with the ethical standard required of employees and elected officers across the Group.
SpareBank 1 SMN operates in an industry posing a risk of internal illegalities. In light of the nature of the business and the scale of assets that are managed, the inherent risk of internal illegalities in banking is considered to be high.
Internal illegalities may arise in the form of infiltration attempts by criminal elements, pressure exerted by staff and illegalities motivated by personal gain. Hence it is important that the bank has implemented controls both to prevent and to identify irregularities. The bank must throughout maintain adequate and appropriate procedures for work sharing, restrictions and limits to authorisations, secure dual controls, satisfactory access controls and sound procedures for handling changes in IT systems.
The bank’s ethical guidelines describe the bank’s attitudes and values with a basis in four overarching principles: confidentiality, financial independence, loyalty and personal integrity. The banks’ employees, business partners and elected officers must have a conscious awareness of the bank’s ethical guidelines in their day-to-day decisions. Each manager is duty bound to familiarise his staff with the ethical guidelines and to take up the theme in departmental meetings on a regular basis. The guidelines apply to the entire Group including the subsidiaries and are a feature of the bank’s contracts with its suppliers.
The guidelines regulate each staff member’s relationship to customers, suppliers, competitors and the world at large. Each staff member must avoid in any way entering into a relationship of dependence with the Group’s customers and business connections, and must have a conscious awareness of any of any attempt to corrupt or to offer facilitation payments. The ethical guidelines require zero tolerance of corruption, and staff members may in no circumstance receive gifts in the form of money or cash letter in the course of their work.
All new staff members are required to review the ethical guidelines as part of the introduction programme, and ethics is a theme at seminars for new staff members. The bank’s Group management team in particular and employees in general have received coaching in ethics and anti-corruption. (GRI 205-2)
The bank adopted updated ethical guidelines (pdf) in 2017.
In addition to the ethical guidelines the bank has established a procedure for whistleblowing. This procedure accommodates the requirements of the Working Environment Act as regards notifying censurable circumstances at enterprises. The whistleblowing procedure is designed to reduce the risk of internal illegalities and to ensure employees’ right and duty to submit an expression of concern, or to warn about censurable circumstances.
The whistleblowing procedure cites examples of censurable circumstances that may provide a basis for expressions of concern, mentioning circumstances related to for example unprincipled conduct, corruption, illegalities, economic crime, unethical or harmful activity or violations of other ethical norms.
The whistleblowing procedure also enables employees to notify the bank’s external reception centre for whistleblowers and to report anonymously if the whistleblower so wishes.
The bank conducts an annual survey of the organisation. The survey gives respondents the opportunity to report cases of bullying and harassment in their own department. Any such instances brought to light in any department will be acted on by the HR department.
Instructions for dealing with conflicts of interest with customers were also revised and approved by the Group executive board in 2018.
Follow-up of quality deviations
The bank’s procedure for following up on quality deviations is designed to ensure a uniformity of response, reporting, filing and follow-up of censurable circumstances among employees across business lines.
The bank initiated in 2017 a process to establish a new system of event reporting in collaboration with an external supplier. The new system was implemented in 2018. The system enables an improved overview of events in all areas and documentation of how the events are responded to.
The sanctions committee is responsible for following up on deviations. The committee consists of the Group legal officer, the head of lending at Corporate Banking, the head of lending at Retail Banking, the head of security and the head of HR. Sanctions are considered based on internal controls carried out in the business areas and on reported and registered deviations in general. The committee meets in principle every quarter, but acute cases can be handled as they arise.
The bank’s board of directors, Group management team and all staff have been informed of the bank’s policy on anti-corruption and its ethical guidelines. It has not however been on the Supervisory Board’s agenda. Business partners have not been specifically informed of the bank’s policy, but an annex covering corporate social responsibility accompanies all supplier contracts, and applies to the entire SpareBank 1 Alliance. Read the annex here. (GRI 205-2). The bank takes into account ethical issues when it enters into contracts with customers. The bank has in some cases chosen not to establish customer relationships in the real estate industry due to suspicion of social dumping. This is steered by the bank’s policy on responsible credit practices described in a separate chapter.
The bank responds in a consistent manner to violations of guidelines, and in 2018 it issued three warnings in writing as a result of two conflicts of interest and one case of harassment. The bank has not witnessed dismissals/resignations, litigation or breaches of contract as a result of corruption or violations of ethical guidelines. (GRI 205-3)