NIB is committed to the integrity of markets and to following relevant international standards in the areas of compliance and business ethics. The Bank is also committed to acting without bias or prejudice.
Any risks related to prohibited practices – including corruption, fraud, bribery, money laundering and terrorist financing – are regarded as material, as they are linked to a wide range of negative impacts, such as undermining the rule of law and damage to the environment.
Prevention is at the forefront of NIB’s efforts, and the Bank has controls in place to avoid or mitigate and manage integrity risks in its operations and activities. NIB also complies with the sanction regimes relevant to its operations.
NIB’s Integrity & Compliance Office (ICO) works to address integrity and reputational risks in the Bank’s daily business in accordance with the Integrity and Compliance Policy.
The Bank publishes annual Integrity Reports on its activities.
Links to the related policies can be found below.
Codes of Conduct
The Bank has established Codes of Conduct for its staff and the members of its governing bodies. The codes provide guidance on maintaining a respectful workplace, handling conflicts of interest and exercising good judgement in ethical matters.
Integrity Due Diligence
A critical element of preventative work is the scrutiny of NIB’s borrowers and other counterparties in the Integrity Due Diligence (IDD) process. The IDD process establishes Know-Your-Customer (KYC) principles and supports the identification and management of the compliance risks that arise in the context of NIB’s lending activities, trust fund activities, treasury operations and internal procurement processes.
NIB’s Integrity Due Diligence includes identification of beneficial owners, screening against sanctions and adverse media, review of anti-money laundering and counteracting terrorist financing controls when applicable, and consideration of international tax standards.
Market Integrity
Integrated, efficient, and transparent financial markets are crucial for the sustainable growth of the Nordic–Baltic region. NIB is committed to the integrity of markets and to preventing market abuse in all of its activities and operations to maintain high ethical standards and to support fair trading practices and equal access for all market participants.
Speaking-up and Whistleblowing
NIB encourages and is open to receive any reporting in good faith of allegations or suspicions of prohibited practices, misconduct or any other type of wrongdoing occurring in connection with the Bank’s operations or activities.
Reports are confidential and can be submitted anonymously. NIB’s Speaking-Up and Whistleblower Protection Policy outlines the process for raising concerns, and grants protection against retaliation.
Investigations
NIB investigates suspected or alleged cases of prohibited practices and misconduct occurring in its activities and operations in accordance with the Investigation Policy. These investigations are primarily based on reports the Bank receives from internal and external stakeholders about alleged wrongdoings. Investigations may lead to actions against external parties or NIB employees engaged in the wrongdoing in accordance with the Enforcement Policy or the Staff Regulations respectively.
Project Accountability
To support NIB meeting its own standards with regards to transparency, predictability, accountability, responsibility and disclosure, NIB has established a process to ensure accountability of NIB through a review of its activities. Individuals or organisations who believe to have suffered, or are likely to suffer, harm in connection with a NIB financed activity can file a report with ICO.
Reports of non-compliance by NIB can be filed and will be handled in accordance with the Project Accountability Policy.
Data Privacy
NIB is committed to the proper handling of the personal data of its employees and external stakeholders.
The Bank has appointed the Chief Compliance Officer as the Data Protection Officer, who monitors the processing of personal data at NIB and acts as the main point of contact for data subjects in matters regarding personal data.