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.
Fighting financial crime
Continuing to strengthen and improve our efforts to preserve the integrity of our business and uphold our societal responsibility is a key priority for us.
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.