Komplett Bank Annual Report 2020

Both departments report directly to the COO. The CCO is responsi- ble for second-line controls, and report quarterly on AML-activities and status to the Board of Directors. A dedicated AML manager joined the Bank’s legal department late 2019 responsible for ensuring compliance and implementation of regulatory changes. During 2020, two new employees joined the AML team, and by the end of 2020 the team consisted of six fulltime resources. Below is an overview of Komplett Bank’s organisation and line of responsibilities. In addition to the AML framework, the Bank has also established guidelines and procedures which describe measures and business processes to secure proper onboarding KYC-processes. The bank’s KYC processes includes pre-fraud, AML and credit evaluations intended to prevent acts such as various categories of fraud, identity theft and corruption. All routines are maintained on a continuous basis and subject bi-annual review. The bank developed and implemented a pre-fraud tool in 2020, which helps identifying potential fraudsters and identity thefts. During 2020, the bank managed to detect and prevent fraud on 444 credit applications, preventing potential losses exceeding NOK 70 million. The Bank places great emphasis on organising the practice of the Boards of Directors, senior management and employees to enhance awareness and build expertise on how to prevent financial crimes. Regular training of all employees in AML related guidelines and procedures is a core element in the Bank’s risk management system. All employees at all levels, including Board of Directors and full-time external consultants working for the bank for extended periods shall complete annual training related to anti-corruption and money-laundering (AML). In 2020, 100 per cent completed such training, compared to 100 per cent in 2019. Komplett Bank will continue to prioritise developing and improving its framework to prevent money laundering and financial crime by maintaining policies and guidelines in accordance with regulations and best practice, by leveraging innovation and technology to monitoring and reporting suspicious transaction as through regular AML training of its employees. Data security and customer privacy In a digital world, personal data is increasingly at risk of being misplaced, stolen or shared without consent. At the same time, with intelligent use of personal data, Komplett Bank can better understand its customers and develop more relevant and more customer-centric banking products and services. Therefore, Board of Directors CEO Jan Haglund Internal Audit (EY) The Nomination Committee The Audit and Risk Committee The Compensation Committee Compliance Eivind Bagås Risk Control Ove Holstangen Credit Risk & Collection Annika Ramstedt Finance Henning Fagerbakke Commercial Director Loans & POS Enok Hanssen Commercial Director Cards Eirik Holtedahl HR & Legal Wilhelm Thomassen Operations Christina Pedersen IT, Marketing, Business development Steffen Ryengen External Audit (PWC) 26 ESG/Sustainability/CSR report 2020