Statement according to the Transparency Act
As a 100% owned Norwegian subsidiary of Nordiska Kreditmarknadsaktiebolaget (Nordiska), Nordiska Financial Partner Norway AS (Nordiska FPN) being a licensed credit institution, have an obligation to conduct responsible business in order to contribute to a sustainable development of our society. Being a part of the Nordiska group the sustainability perspective is therefore integrated into everything we do and measure in Nordiska FPN.
Following the acquisition by Nordiska at the end of 2021, Nordiska FPN started to implement Nordiska's business strategy focused on the Norwegian market in 2022. Nordiska has established an infrastructure and platform that facilitates opportunities for growth and development through partnerships with other financial institutions. Through the launch of the first Partner in Norway in 2022 Nordiska FPN provides loans to the customers mediated by the Partner who functions as the distribution channel towards the customers utilizing Nordiska’s infrastructure and platform. Nordiska FPN’s management is located in Oslo while certain company functions are carried out by Nordiska as the main business activities are run primarily in the parent company. Nordiska FPN business is as such to a degree integrated with Nordiska utilizing the company's functions, infrastructure and suppliers.
Nordiska's Code of Conduct shall ensure that values and ethical guidelines are integrated in all companies in the Nordiska group. Nordiska will make the same demands towards the suppliers and their subcontractors. The Code of Conduct for suppliers applies to all companies that supply products and/or services to Nordiska and Nordiska FPN.
In this memo, we will elaborate on the company's work related to human rights, decent working conditions and ethical trading in line with the requirements of the Transparency Act. As always for these matters, the Company will work on these and strive for continuous improvement.
Sustainability - the company's guidelines and routines
As an integrated company within the Nordiska group the sustainability work is focused towards the three perspectives Environment, Social and Governance (ESG goals). The environmental perspective relates to the impact on the environment and climate to counter global warming, while the social aspect is to take into account issues related to social responsibility, such as human rights and labour rights. The corporate governance perspective includes governance issues concerning shareholders' rights and accountability for senior executives.
We consider ESG objectives in our lending and credit assessment, inter alia, in accordance with the guidelines of the European Banking Authority (EBA). Sustainability in our lending means, among other things, that we identify, as applicable, sound lending as well as climate-related and environmental risks are taken into account in our business.
Diversity and gender equality
We see that having a diverse workforce is advantageous for Nordiska. Employees who come from different backgrounds add further perspectives and contribute with new angles and analyses thus positively contributing to Nordiska's success.
It is therefore a matter of course that everyone who works or has assignments within the Nordiska group - regardless of ethnicity, gender, belief, age, sexual orientation or disability - must have equal opportunities when it comes to the selection and appointment of Board members, leading executives and other roles. There is ongoing work to uphold the equal rights, obligations and opportunities for all people in all areas of work which will continue in the years to come.
Risk Control and Compliance
Risk control and compliance are organized in accordance with the Financial Supervisory Authority general advice on governance and control. The control organization consists of three lines of defense;
The first line of defense consists of the Board, the General Manager and the company. They are responsible for the business being managed within the framework for established risk exposure and internal governance and control and in accordance with established external and internal rules applicable to Nordiska FPN.
The second line of defense consists of the Risk Control Function and the Compliance Function. The Compliance Function supports and gives advice to the Board, the General Manager and the operational activities to ensure compliance with the Norwegian regulations. The Risk Control Function is responsible for monitoring that all significant risks to which Nordiska is exposed or may be exposed to is identified and handled by the relevant functions as well as overseeing that the internal regulatory framework is appropriate and effective and proposes changes to this if necessary.
The third line of defense in Nordiska FPN consists of the Audit & Risk Committee which functions as the Board's tool for meeting the requirements for good and efficient internal governance and control.
Management of Nordiska's sustainability work
Nordiska has signed the UN Sustainability Initiative Global Compact. This means that we commit ourselves to following their ten principles of responsible business. The principles, which are divided into the areas of human rights, labour, the environment and anti-corruption, aim to contribute to achieving the global sustainability goals. Today, Nordiska works with 10 of the UN's 17 global goals. The intention is to integrate additional goals into our operations over time in 2023 and forward. Nordiska is also a gold supporter of the children's rights organization BRIS, which works for a society where children’s rights are met.
During 2022, Nordiska established a Sustainability Group that is responsible for reviewing the existing sustainability processes as well as creating and implementing new processes in Nordiska's operations which also includes Nordiska FPN.
The procurement process and risk assessments of suppliers are important parts in the work to promote respect for basic human rights and decent working conditions. The main base for Nordiska’s operations including suppliers and financial partners is the Nordics and as such the overall risk for serious breaches within the industry Nordiska operates is regarded to be limited. Nordiska is however aware that risks exists and that irregularities may occur.
As part of the work in the Sustainability Group risk mapping, categorization and evaluation of Nordiska and Nordiska FPN’s main suppliers are planned to start in 2023 and will be an important focus area in the coming years. Risks related to own business and suppliers will be assessed on the basis of follow up and actual reporting, while risk assessments linked to the value chain backwards after the first line of suppliers needs to be based on desktop research. Nordiska plans to conduct supplier review (due diligence) of the largest suppliers and subcontractors based on turnover to Nordiska including Nordiska FPN. Further long-term goal will be defined to carry out supplier reviews (due diligence) for a defined number of suppliers with a special focus on human rights in accordance with new legal requirements. It will be key to communicate clear expectations and requirements when recommending and choosing responsible suppliers and collaboration partners going forward. Also training of the operational personnel involved in the procurement process with focus on human rights and due diligence assessments will be a priority area.
Respect for human rights
Nordiska's main business consists of lending to both private individuals and companies in several different markets. So far Nordiska FPN’s lending in Norway has been focused towards the SME segment, but also plans to broaden the business towards private individuals. With this comes a great responsibility, not only that lending is subject to authorization and is under the supervision of Finanstilsynet, but also because Nordiska FPN has a social responsibility in conducting responsible lending towards customers in order to protect financial stability and contribute to sustainable social development. When lending is conducted towards the business segment account must be taken of physical environmental and climate risks, restructuring risks and ESG factors in the credit assessment.
When analyzing risks relating to social sustainability, guidelines for anti-money laundering measures are applied to combat financial crime. During 2022, Nordiska has actively invested in increasing the exposure towards sustainable financing which will be continued in 2023.
Code of Conduct and good business ethics
As part of the Nordiska group Nordiska FPN follows the company's internal governing document for Code of Conduct. The Code of Conduct aims to clarify the importance of a responsible and professional behavior and how the company’s employees in the daily work are expected to behave and act in accordance with the established values, vision and goals as well as external regulatory requirements. Nordiska stands for good business ethics wherever we operate. Each supplier agreements shall be preceded by an assessment of how it fulfills them.
Nordiska may not enter into an agreement for services on terms other than those that are normally applied or on terms that are not business-related in favor of any person in the circle. From an ethical point of view, Nordiska believes that employees or contractors may not handle matters and transactions that concern themselves or matters and transactions that concern a legal person in which the employee or contractor has an interest.
In addition, employees or contractors must also take into account whether there may be other circumstances that could lead to the suspicion that a fraud situation may arise.
It is a matter of course that Nordiska's employees, contractors or its Board members may not accept bribes or participate in bribery. Nordiska must have a restrictive attitude to for example, gifts, travels and representation, and avoid what could be considered inappropriate.
Guiding in this area shall be the business code administered by the Institute for Bribery (IMM), see: Näringslivskoden - Institutet Mot Mutor - IMM
Nordiska has a clear whistle-blowing policy. The employees can report irregularities anonymously. To guarantee the anonymity reporting is available via a digital third-party system.
Reduced climate impact
The climate crisis is one of the world's biggest challenges and everyone needs to take responsibility in the matter. To reduce energy consumption and climate impact, all companies and individuals can choose to make active choices that are more beneficial to our planet. Nordiska has reviewed the processes that enable reduction paper consumption and thus a reduced climate pressure, as well as in its new offices ensured a more climate friendly environment and footprint. Majority of the documents that have previously been handled in physical form has been digitized in the form digital signing and storage in 2022. These improvements are also applicable for Nordiska FPN. It will be a continuous work where the processes constantly are reviewed in order to move towards digital handling instead of physical actions in all parts of the business.
The work with anti-corruption continues to be led by a strong internal governance and control as well as accuracy in the groups processes, including engaging suppliers, employment procedures and collaboration partners. On an organizational level, the company works dedicatedly against money laundering and financing of terrorism, which includes increased system support in countermeasures, recruitment of personnel resources, training and improved processes. In 2022, the position Head of AML has been appointed to continue strengthen the continuous work against money laundering and financing of terrorism and to evaluate and improve the company's existing skills and processes.
Existing governing documents such as Instructions for measures against money laundering and financing against terrorism and General risk assessment forms the basis of the company's processes and routines. Nordiska’s AML unit works operational in the first line to prevent Nordiska and Nordiska FPN from being used for fraud and money laundering through a risk-based approach. It includes training of employees, monitoring transactions and working closely with partners and internal departments to identify and mitigate risks.
In its operations, Nordiska must observe ethically impeccable behavior with regard to tax matters. Employees and contractors must therefore not participate in business or transactions where the sole or predominant reason for the business or transaction is tax related, unless such action is legal and accepted practice in the market.
Inquiries and questions related to Nordiska and Nordiska FPN's work with human rights and decent working conditions can be addressed to firstname.lastname@example.org and will be answered no later than three weeks after the inquiry is received.