Sustainability

As a responsible financial group, we take a proactive approach to environmental and climate challenges. We are constantly striving to be a resource-saving and environmentally-efficient organisation by setting requirements for our own organisation, suppliers, and partners. We are working to become a climate neutral group and continually seeking to reduce the environmental impact of our operations. We use, develop and invest in technology in order to reduce our environmental impact. We also want to enable employees to reduce their environmental impact and make environmentally friendly choices. Improving skills in this area could help to ensure that employees become more aware of their impact on the climate and environment, both through their personal actions and through their work in the bank.

In 2018, we registered energy and climate accounts based on the international “Corporate Accounting and Reporting Standard” for the first time. This standard was developed by the Greenhouse Gas Protocol Initiative – the GHG Protocol.
The climate accounts show tonnes of CO2 that are direct and indirect emissions related to the group. These are greenhouse gas emissions that come from consumption due to, for example, travel, waste management, and energy use. Based on the climate accounts, the group can identify which sources impact the external environment and implement concrete measures to minimise them. Given that this is the first year we have kept records based on the GHG Protocol, it will not be possible to see the development from previous years

All of our activities take place in Norway and are subject to Norwegian law and international conventions incorporated into Norwegian law. We respect fundamental human rights, labour rights and basic social needs. The requirements concerning labour rights also apply to our suppliers.

Gender equality

We are actively striving to achieve gender equality between men and woman in the group. A gender equality committee was established in 2017 and tasked with ensuring the group focuses on gender equality work. The gender equality committee reports to the group's liaison committee, which is composed of representatives of the executive management team and trade unions. 

Corruption puts long-term value creation at risk and createsdistrust in society’s systems. It can lead to court cases and fines, or other sanctions, as well as the loss of market access, assets, and the right to operate banking operations. There are many different forms of corruption and our code of conduct is intended to contribute to, among other things, fighting corruption, extortion, bribery, whitewashing, fraud, terrorist financing, and the financing of other criminal activities. The code of conduct is intended to make people aware of the potential dilemmas and ensure that all of our employees maintain high ethical standards.

The group has its own ethics committee, which regularly assesses whether the code of conduct satisfies the requirements and expectations of customers, suppliers and society as a whole. The ethics committee includes representatives of several business areas: the EVP, Communications and Sustainability, the EVP, HR and Business Support, legal, corporate market, retail market, compliance and AML, organisation and HR, credit activities, and union representatives from the Finance Sector Union of Norway. The committee met twice in 2018.

All employees must sign the code of conduct every year. Annual refreshers on ethics are also provided via the authorisation scheme for financial advisers and the approval scheme for salespersons and advisers in non-life insurance.

The anti-corruption work includes ensuring new employees read and sign the code of conduct. This is also included as a topic in Ethics Week. We completed an anti-corruption training module for SR-Bank’s managers in 2016 and new training is planned for 2019, as part of the bank’s three-year skills-cycle. The group will also base its compliance control work on the ISO 37001 standard for anti-corruption. The control model complies with the ISO standard and the group prepares routines and control actions for the work. We review specific transactions and activities, planned and existing business connections, and various categories and groups of 23 employees. The assessments take a risk-based approach and the inspections include financial and non-financial control actions. Reporting lines have been established and any measures are followed up in line with existing routines.

Whistleblowing routines have been established for anonymous, written and verbal reports.
The routines specify:
• that whistleblowers are protected against reprisals
• how reports should be submitted – externally anonymously or not anonymously via multiple channels, including via an application that uses an untraceable QR code
• the requirements that apply for processing reports

The bank has established an external whistleblowing agreement with the law firm EY. The information will be treated confidentially by dedicated case offices in EY

Asset management is performed directly through the group’s own investment activities and indirectly through SR-Forvaltning. Every company in which we invest in connection with asset management is checked to see whether they are involved in tobacco production, nuclear weapons, or serious environmental destruction, based on guideline for observation and exclusion issued by the Norwegian Government Pension Fund Global. Before now, environmental and social factors have not been discussed with the companies in the investment portfolio as part of the ownership dialogue, but in the future we will prepare guidelines for responsible ownership in relation to our own investments.

SR-Forvaltning has produced guidelines for responsible investments that will be incorporated into the company’s investment strategy. The guidelines are based on, among other things, the internationally recognised principles in the UN Global Compact (UNGC) and the OECD’s guidelines for multinational companies. In 2019, we will develop a procedure for incorporating ESG into all investment processes in SR-Forvaltning. SR-Forvaltning is a member of the Norwegian Sustainable Investment Forum (Norsif). SR-Forvaltning will work to ensure it is eligible to sign up to the UN Principles for Responsible Investment (PRO) in 2019.

Highlighting and refining the company’s management of ESG risk will be a priority area in 2019.

80% of our purchases are made through the SpareBank 1 Alliance, the remaining 20% are made by SR-bank. The largest purchasing categories are marketing, IT systems, property operation, external consultants, and contracted personnel. In total, we spend around NOK 1 billion on goods and services. All of the purchases made are covered by SR-Bank’s purchasing policy. This specifies that purchases must be as sustainable as possible, and bidders must submit information about their sustainability and corporate social responsibility as part of their tender. Sustainability is one of the five evaluation criteria for the awarding of contracts.

In 2019, new responsible purchasing guidelines were prepared that include a clear requirement for mandatory compliance with laws and rules concerning human rights, working conditions, the environment, and decent operations. Maintaining a dialogue with suppliers and monitoring them will help to ensure that our suppliers and partners are conscious of the importance of sustainability.

Credit is the bank’s core business area and corporatecustomers constitute an important part of this. Our credit strategy stresses that corporate customers must have along-term perspective and their companies must be comply with applicable laws and regulations, which includeenvironmental considerations and human rights. Ourcorporate market portfolio is well-diversified with anemphasis on commercial property, oil and gas, agriculture, and traditional industry.

As a bank, we primarily finance small and medium-sized Norwegian enterprises. We aim to be a positive contributor and sparring partner in order to improve companies’awareness and practices related to sustainability. Overarching guidelines specifying sustainability were adopted for the corporate market in 2018. The guidelines require sustainability to be assessed as part of our credit processes and the purpose of the guidelines is to provide corporate advisers with a framework for assessing a company in relation to sustainability and ensuring that we carry out an assessment of the extent to which a customer’s business model is sustainable.

In 2019, SR-Bank will develop and implement furtherguidelines for granting credit that take account of global climate challenges. According to the guidelines, the group should not give loans to organisations that extract, or produce power based on, coal or nuclear power.

All employees who are in contact with our corporatecustomers must be familiar with our sustainability guidelines for credit and review them annually. They provide guidanceon the type of customers we want, what we expect of our customers, and what we lend money for.

Read our sustainability guidelines for the corporate market (pdf)

Fighting financial crime, which includes preventing the proceeds of criminal activities being laundered and terrorist financing, is demanding and important work. Ensuring that the industry is not misused for illegal activities through our services and products is part of the financial services industry’s social mission. SR-Bank has an extensive framework of guidelines intended to prevent us being used for moneylaundering, tax evasion or terrorist financing. The framework is there to ensure that we comply with the statutory requirements in various processes through guidelines,customer measures, electronic monitoring, sanctions regulations, and procedures for internal control. We have committed to complying with the framework and guidelines in the Wolfsberg principles for combatting financial crime. The Wolfsberg principles establish requirements for, for example, transparency in customer transactions and how information on these is monitored and managed in line with the authorities’ requirements.

SR-Bank produces an internal and business-specific risk assessment for money laundering and terrorist financing every year, along with the associated risk mitigation measures. In 2018, we significantly strengthened our efforts within the area of combating money laundering and terrorist financing, from one and a half FTEs to five FTEs. The group has produced a detailed training plan to ensure that all employees can perform their duties with up-to-date and relevant knowledge. In 2018, the internal audit reviewed the work against financial crime and suggested improvements were followed up.

Our anti-money laundering and sanctions policy provides a general description of the group's approach, including guidelines and principles that apply to the company's management and control environment, as well as to how the organisation is structured in order to comply with statutory requirements. 

In order to provide our customers with enhanced protection against ID theft, attempted fraud and other forms of economic crime, we comply with the requirements of the Norwegian authorities, the Money Laundering Act adopted by the Storting (Norwegian parliament) at any given time, to ensure that all customer information and identification is up-to-date. Togheter we can prevent money laundering (in norwegian).