Code of conduct
Our position on market abuse and conflicts of interest
It is imperative that we prevent market abuse from occurring, so we have set up internal rules and measures to prevent it.
They include guidelines for registering inside information and identifying insiders. We maintain and continually update an internal list of employees with access to inside information. We also have guidelines for the disclosure, treatment and storage of inside information in order to ensure that inside information is accessible only to persons who need it to perform their professional duties.
All employees’ personal account transactions in securities are governed by guidelines. The Group has general guidelines for all employees and more restricted guidelines for employees in sensitive functions. Control activities, which entail additional monitoring, are predominantly preventative.
Conflicts of interest
Conflicts of interest may arise when the interests of Danske Bank or its employees contradict those of a customer or vendor.
To ensure that we always make independent decisions, we have a policy for dealing with conflicts of interest. The policy is intended to enable us to identify circumstances that lead or may lead to conflicts of interest and that may entail a significant risk of adversely affecting our customers.
We have adopted rules for gifts and hospitality, both given and received by employees, in order to mitigate possible conflicts of interest as well as allegations of bribery.
In accordance with our policy, we have implemented procedures, systems and controls to identify and deal with conflicts of interest in order to remove any doubt about our integrity and the expertise and behaviour of our employees.
Anti-money laundering policy
We make substantial efforts to comply with regulations and prevent criminals from exploiting the Group for money laundering or other financial crimes.
We have implemented precautionary measures to mitigate these activities, including measures to prevent the violation of international sanctions.
Anti-money laundering, prevention of terrorism financing, and financial sanctions
We have implemented a set of rules and a number of requirements that apply to all our activities to ensure that we comply with the fourth EU AML Directive.
Our employees are regularly trained to identify money laundering so that they understand its current forms. For instance, it is important to follow the recommendations issued by the Financial Action Task Force and other international bodies such as the Wolfsberg Group.
We are required to know our customers and their expected use of our products and services. This includes the following:
- Verifying a customer’s identity
- Gathering information about the scope and purpose of the customer relationship
- Paying attention to atypical transactions and identifying suspicious transactions
- Informing the appropriate authorities if a suspicion cannot be dispelled
This means that we may ask our customers to verify their identity or to answer detailed questions about certain transactions.
The requirements made on financial institutions to prevent money laundering also help to prevent the financing of terrorism. A number of circumstances can arouse suspicion and prompt investigation, for example specific persons or organisations.
Read our completed Wolfsberg Questionnaire, which provides a good foundation for preparing a KYC analysis of Danske Bank here.
Financial sanctions and requirements for international money transfers
Danske Bank complies with financial sanctions imposed by the UN, the EU and US (OFAC), and we have clear procedures in this area.
We have various processes in place to ensure compliance with international financial sanctions, including restrictions related to payments that involve certain countries.
Requirements for international money transfers
We require complete information about the sender of international payments. This means that several pieces of information about the sender must follow the transaction throughout the payment process. The purposes are to prevent, investigate and trace money laundering and the financing of terrorism and to ensure that international payments are secure.