Komplett Bank Annual Report 2020

Komplett Bank recognises its responsibility of managing the data collected and processed about its customers in a responsible manner and keeping consumer data safe. Komplett Bank is subject to laws and regulations that stipulate how consumer data can be collected and processed, such as GDPR. Back in 2018, when GDPR came into force, the Bank appointed a Data Protection Officer (DPO). The Bank has implemented strict guidelines and procedures to ensure compliance. This involves regularly reviews and develop- ment of the Bank’s internal control systems and risk management processes to continuously improve and address existing and emerging data security and privacy threats. Employees and consultants who collect, process or have access to customer data on behalf of the Bank receive mandatory training in data privacy facilitated by the DPO on regular basis. All manag- ers are responsible for ensuring that employees with access to personal data have the necessary competence and are suitably qualified to secure our customers’ personal data rights, through following our procedures for information security. Any breaches to data security and consumer privacy are reported and followed up immediately. Komplett Bank registered one data and GDPR breaches and one wrongful sharing of personal customer data incidents in 2020. Whistleblower routines Komplett Bank has established procedures for whistleblowing, adopted by the Board of Directors, and implemented both internal and external channels for whistleblowing to facilitate reporting of any irregularities. The procedure shall safeguard both the whistleblower and the person(s) reported on and is available for all the Bank’s employees in both Norwegian and English. The external whistleblowing channel is operated by KPMG, and information on any reported cases is according to process forwarded to CCO, Legal advisor and Head of the Audit and risk committee to the Board of Directors. In 2020, no reports were received. Ethical business behaviour Komplett Bank has adopted ethical guidelines, which set out a framework for helping the Bank’s representatives perform their duties in an ethically responsible manner and in line with the standards established by the Bank through its other procedures and guidelines Komplett Bank’s ethical 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. The current version of the guidelines was last updated 23 September 2020. Anyone who represents Komplett Bank must always strive to exercise good judgement, caution and consideration. The Bank’s risk management recognises that unethical actions or omissions in breach of human rights represent a potential operational risk factor. The Banks guidelines and other procedures have been put in place to help ensure that Komplett Bank does not become involved in business transactions and other projects which constitute unethical actions or omissions. Environmental footprint Komplett Bank’s activities are concentrated to the Nordic consumer credit market with the Bank having limited influence on what the credit is used for. The environmental impact of Komplett Bank’s activities is mainly related to energy consumption and waste from its premises, and some travelling. Being a fully digitalized bank, with the products offered online through the Bank’s website, consumption of paper and the need for travel is minimised. The Bank has not prepared any specific guidelines relating to the external environment but encourage employees to reduce consumption and waste generated from their daily activities, e.g. food waste in the cantina which was effec- tively reduced during 2020. In order to reduce business travel, employees are encouraged to use digital solutions such as video conferencing and travelling by public transport when travel is necessary. For data storage, Komplett Bank uses Microsoft Office 365 and Azure Compute, which are between 80-98 per cent more energy efficient than traditional on-premise datacentres. In 2021, Komplett bank will take further steps towards measuring and disclosing its overall environmental impact. The employees Komplett Bank wants to be an attractive employer which offers a good working environment for the employees, which are consid- ered the Bank’s most important resource. Komplett Bank relies on motivated and engaged employees to reach its business goals, and wants to provide its employees opportunities to develop, enhance their skills and assume new responsibilities. To ensure value creation for all stakeholders, the Bank also need individuals that complement each other and work well together. Komplett Bank’s employment practices ensure compliance with internation- ally recognised human rights and labour rights. Diversity and equal opportunities Komplett Bank believes a diverse and inclusive workforce is fun- damental to ensure innovation and value creation over time. As a general principle, all employees shall be treated equally, regardless of age, gender, disability, cultural background, religious beliefs Komplett Bank Annual Report 2020 27