Sustainable business Responsible lending – throughout the credit lifecycle Komplett Bank is committed to being a responsible lender, defined as the practice of acting in customers’ best interests, ensuring affordability, transparency of terms and conditions and supporting a borrower if they experience repayment difficulties. Responsible lending is considered a material factor for the Bank. 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, regu- lations and other regulatory requirements. All customers must be subject to a credit assessment based on a complete set of data relevant for assessing the applicants’ financial situation. Komplett Bank does not grant loans or issue credit cards to customers who are assessed to lack 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. Komplett Bank has put in place the following measures to ensure responsible lending practices throughout the credit lifecycle: 1. Marketing - Ensure messaging, channels and scope of marketing efforts are suited to attract creditworthy individuals - Ensure to avoid misleading marketing - Ensure agents adhere to Komplett Bank’s selling and product - labelling practices Target: No well-founded complaints from customers on wrongful, lacking or unclear communication of terms and conditions KPI: Number of cases lost in Finansklagenemda Result: No cases lost in Finansklagenemnda in 2021 againts two cases lost in 2020 2. Onboarding Ǵ Established credit policy to ensure credit is provided only to creditworthy individuals Ǵ Strict onboarding process consisting of both automatic and manual evaluation of applicants’ credit worthiness Ǵ 46% of applications were declined based on the Bank’s credit policies and score cards, the remaining 20 % got a conditional offer. Additional 20 % manually declined when reviewing detailed info and documentation provided by the applicants Ǵ The refinancing product was launched in Norway in 2020; a prerequisite for offering this solution is that it reduces the customer’s total loan costs 24 ESG/Sustainability/CSR report
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