Komplett Bank annual report 2019

with the aim of reducing absence due to illness, including closer follow-up and dialogue with employees who are on sick leave. The Board of Directors’ view is that the working environment is consistently good. External environment Komplett Bank does not carry on activities which pollute the exter- nal environment beyond what is considered normal for banking, which has limited environmental impact. Komplett Bank is also a fully digitalised bank, with the Bank’s products being offered via the Bank’s website, so reducing the consumption of paper and the need for travel. The Bank has not prepared any specific guidelines relating to the external environment, but consideration for the environment is largely addressed through the Bank’s business model. Combatting corruption Komplett Bank has adopted guidelines which stipulate that the Bank’s operations must be carried out with high standards of ethics and integrity. The Bank’s ethical guidelines impose require- ments on employees, elected representatives and the Bank’s con- duct, including a ban on the receiving, requesting or acceptance of offers of undue benefits and a ban on the Bank offering financial benefits or gifts to the Bank’s business connections or others which could be perceived as an undue benefit. Requirements are also imposed on employees and elected representatives regard- ing competence, due diligence and whistleblowing. The Bank’s guidelines and procedures also include a description of measures and business processes which are intended to prevent acts such as fraud, identity theft and corruption. Prevention of money laundering and terrorist financing Komplett Bank is dedicated in the work to prevent financial crime including money laundering and terrorist financing. In 2019, as part of the Bank’s core processes, it established a more comprehensive framework on how money laundering and terrorist financing can be prevented. This includes onBoarding and risk assessments of new customers, review of high risk customers and accounts, running customer and transaction monitoring and reporting and follow-up processes. Komplett Bank organises the practice of the Boards of Directors, management and employees to enhance awareness and build expertise on how to prevent financial crimes. Komplett Bank will continuously develop and improve its framework to prevent money laundering and financial crime. Komplett Bank Annual Report 2019 19