Whistle Blower Procedure

Swedbank recognise the importance of frank discussion of problems and ethical issues and encourage employees to communicate legitimate concerns regards non-compliance and questiable practises.

Swedbank maintain a process for reporting submission of suspected wrongdoing (whistleblowing) by any employee of Swedbank. In accordance with the procedures the reporting could be done anonymously to the Group Compliance Officer.

The process is established in Swedbanks policy on Ethics.

Internal irregularities, breaches of this or any other policy, instruction or rule, other illegal, unethical or doubtful actions are referred to as violation of duty in the text below.

All employees have a possibility, but also an obligation, to report justified suspicion of violations of duty. Investigations of violations of duty are lead by Group Compliance Officer. All employees reporting justified suspicion of violations of duty are, as far as possible, offered anonymity. The terms of employment shall not be affected by a report.

Reporting of violations of duty shall be done by e-mail, telephone or letter, which can be use anonymously, to the Group Compliance Officer. The Group Compliance Officer shall proceed with necessary actions without delay. The employee shall, when reporting, be prepared to provide necessary information to the cause of suspicion, state of affairs and involved parties to make an investigation possible.

Violation of duty can lead to employment actions including dismissal.

Head of internal audit and Group Compliance Officer shall immediately report serious violations of duty to CEO and the Board.