External auditor PwC 3. Customer service Ǵ Well-established internal process mapping, routine descriptions and yearly training schedule to ensure good service towards the Bank’s customers and applicants Ǵ Komplett Bank’s customer service is available through e-mail and a manned phone service. The customer service teams are followed up on KPIs based on best practices regarding response- and waiting time as well as quality measures 4. Default Ǵ Established credit policy that governs treatment of defaulted loans Ǵ Received a limited number of forbearance requests in 2021, focus on temporary assisting existing customers to overcome short-term challenges during pandemic Ǵ Norwegian customers with Flexible Loan-agreements are contacted on a regular basis to encourage down-payment plans and ensure customers have a plan on how to repay their loans Ǵ If a customer is in default, Komplett Bank ensures that it’s collection partners adheres to the standards of Komplett Bank and that the partners are equally or better equipped to assist the Bank’s customers in servicing their loans Anti-corruption and Money Laundering (AML) Exposure to corruption and money-laundering is considered a material risk for Komplett Bank and its license to operate. The Bank has established systems to identify and report potential AML activity and provides frequent training of employees within AML/ terrorist financing. These activities represent Komplett Bank’s support to achieving UN SDG 16, sub-targets 16.5 and 16b.d Komplett Bank has established a comprehensive framework for preventing money laundering and terrorist financing. This includes onboarding and risk assessments of new customers, review of high-risk customers and accounts, running customer and transac- tion monitoring and reporting and follow-up processes. The AML Risk Assessment and Policy are subject to yearly revisions by the Board of Directors. Work and procedures related anti-corruption and money-laun- dering has the highest priority. The COO is the Bank’s AML Officer (“Hvitvaskingsansvarlig”). The Credit and AML departments are responsible for customer onboarding and KYC-processes (Know Your Customer), as well as the ongoing due diligence and continu- ous monitoring and follow-up on suspicious customer behaviour. Both departments report directly to the COO. The Compliance area is responsi- ble for second-line controls, and report quarterly on AML-activities and status to the Board of Directors. Towards the end of 2021 the Bank started the process of further strengthening the AML area and in Q1-22 established a Financial Crime Prevention unit consisting of the former AML and Fraud units. Below is an overview of Komplett Bank’s organisation and line of responsibilities. Board of Directors CEO Øyvind Oanes Internal auditor (EY) Nomination committee Risk and Audit committee Compensation Committee Compliance Eivind Bagås Risk Control Ove Holstangen CCRO Annika Ramstedt CFO Eirik Holtedahl CCO Enok Hanssen COO Wilhelm B. Thomassen CTO (interim) Martin Valland Komplett Bank / Annual Report 2021 25
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