Compliance

Danske Bank has an independent compliance function - Group Compliance - that is responsible for controlling whether the Group complies with applicable laws, market standards and internal rules and for providing advice on mitigating key compliance risks. The head of Group Compliance reports directly to the Executive Board and the Board of Directors.
Read our Compliance Policy

Code of conduct

The Code of Conduct is a collection of internal rules intended to assist employees in their daily decision making. It offers guidelines on how to act towards customers and suppliers. It is not exhaustive but rather focuses on areas that pose special compliance risks.

Our position on market abuse and conflicts of interest 

  • Market abuse

    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

  • Financial sanctions

    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.

Whistleblowing

Employees have the opportunity to be whistleblowers. We have an interest in establishing and maintaining an environment that encourages the free flow of information. This also applies to the security of employees who report a suspicion; they are protected against retaliatory measures. Reports and questions received through the whistleblower system are treated as strictly confidential, and they are forwarded to Group Compliance and the Board of Directors' Audit Committee.

About Danske Bank

We are a Nordic bank with strong local roots and bridges to the rest of the world. Our 19,000 employees serve customers in 16 countries.
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Corporate Governance

We work continually to improve our corporate governance and implement best practices.
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Responsibility

We want to run a strong, sustainable business that creates value for all our stakeholders.
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