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, regulations, 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 Ǵ Established internal guidelines for responsible sales practices and product labelling Ǵ Ensure messaging, channels and scope of marketing efforts are suited to attract creditworthy individuals Ǵ Ensure to avoid misleading marketing Ǵ Ensure that 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 The Norwegian Financial Services Complaints Board (Finansklagenemda) Result: No cases lost in Finansklagenemnda in 2022, corresponding to 2021. 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 Approximately 80% of all applications were declined based on the Bank’s credit policies and score cards, the remaining applications got a conditional offer. An additional 20 % manually declined when reviewing detailed info and documentation provided by the applicants Ǵ The Banks has refinancing product; a prerequisite for offering this solution is that it reduces the customer’s total loan costs 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 Anti-corruption and Money Laundering (AML) Exposure to corruption and money-laundering and terror financing 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. 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 transaction 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 laundering has the highest priority. The Dir. Compliance is the Bank’s AML Officer (“Hvitvaskingsansvarlig”). The bank has also established a so-called “AML compliance officer” in line with the money laundering regulations, who is responsible for second-line controls and reports to the Board of directors on a quarterly basis. 24 ESG/Sustainability/CSR report
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