Komplett Bank annual report 2019

Declaration concerning corporate social responsibility Komplett Bank’s work relating to corporate social responsibility permeates the Bank’s strategic plans, values, guidelines and procedures. Komplett Bank has adopted ethical guidelines, which set out the framework that will help representatives of the Bank to perform their duties in an ethically responsible manner and in line with the standards established by the Bank through its other procedures and guidelines. An account is given below of the Bank’s efforts to ensure that corporate social responsibility forms an integral part of the Bank’s operations. Responsible credit practice Komplett Bank is required to ensure that it operates honestly and fairly and in accordance with generally accepted business practice, as well as the requirement to safeguard the interests of consumers. As a provider of unsecured financing to private customers, the Bank has an overall goal and strategy to pursue responsible credit practice. The Board of Directors has adopted specific guidelines and procedures for the lending business, which are intended to ensure compliance with this objective. In addition, the Bank’s internal procedures and processes are aligned with applicable laws, regulations and other regulatory requirements. All customers must be subject to a credit assessment based on supplementary information obtained from the customer them- selves concerning income, expenses, debt and wealth, as well as information from other relevant databases. Komplett Bank does not grant loans or issue credit cards to customers who do not have sufficient debt servicing capacity. Marketing of the Bank’s products is aligned with statutory and regulatory requirements and the Code of Practice of the Association of Norwegian Finance Houses (Finansieringsselskapenes Forening) regarding the marketing of credit cards and consumer loans. Human rights The ethical guidelines set out the framework that will help representatives of the Bank to perform their duties in an ethically responsible manner and in line with the standards established by the Bank through its governing documents. The guidelines supplement laws, rules, instructions and provisions which apply to the Bank’s activities and establish principles for conduct and actions in areas which other regulations otherwise do not cover. The guidelines provide a framework for what the Bank considers to be responsible conduct, but they are not exhaustive. Anyone who represents Komplett Bank must always strive to exercise good judgement, caution and consideration. Risk management and internal control form an integral part of Komplett Bank’s strategy and business processes, and also encompass measures and the management of operational risk. Operational risk includes events which have a negative impact on the Bank, including unethical actions or omissions in breach of human rights. The Bank’s risk management and internal control thus integrate human rights by ensuring that the strategy and business processes are aimed at minimising operational risk and ensure the implementation of measures in the event of exposure to such risk. The above shows that human rights are an integral part of Komplett Bank’s operations. The Bank’s guidelines and other procedures help to ensure that Komplett Bank does not become involved in business transactions and other projects which constitute unethical actions or omissions. Workers’ rights and social relationships Komplett Bank aims to be an attractive employer which offers a good working environment. Every year, the Bank’s HR manager conducts a review of issues such as absence due to illness and gender equality. In 2019, an employee survey was conducted amongst the Bank’s employees. This review forms an integral part of the Bank’s internal control and provides a basis for implement- ing improvement measures as and when necessary. The annual review indicates that the Bank’s employees are gener- ally happy at their workplace and believe that their working envi- ronment is good, a view which is underlined by low turnover rates amongst employees and generally low levels of absence due to illness. The survey shows that there are some areas where there is potential for improvement, and measures have been implemented by the Bank in order to bring about improvements. Komplett Bank has implemented measures to ensure that employees continue to remain satisfied with the Bank as their employer, including the planning of social events and more frequent employee develop- ment reviews. Komplett Bank strives to promote gender equality and ensure that all genders have equal opportunities. In 2019, Komplett Bank had an absence due to illness rate which the Bank considers to be low, but the Bank is striving to reduce absence levels further. The Bank has implemented various measures 18 Declaration concerning corporate social responsibility

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