[2018/06/30

To our stakeholders:

I am pleased to confirm that Carnegie Investment Bank AB reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,


Mr. Björn Jansson

CEO

Our responsible investment policy covers and applies mainly to our actively managed funds and the portfolios and funds in which Carnegie or an external fund
manager makes direct investments in equities and corporate bonds. By supporting the UN Principles for Responsible Investment (UNPRI), Carnegie avoids investing in companies that abuse human rights

Carnegie excludes investments in companies violating human rights. A large portion of assets under management are managed by external fund managers and Carnegie has a clear and established process in this regard. I

In addition, external suppliers and partners are a key component of the business. Each year, Carnegie purchases supplies and other products and services such as IT systems, office supplies, consultancy services and external management services from numerous suppliers. Several policy documents, including the conduct and ethics policy and the purchasing policy, exist to support careful purchasing

Carnegie checks fund exposure from a sustainability perspective in partnership with the external adviser ISS-Ethix. They perform an ESG screening of the funds’ holdings and the manager is required to submit an explanation of any non-conformances. When there are shortcomings, engaging in dialogue is Carnegie’s first resort, with a view to achieving improvement. If the manager’s sustainability work is deemed inadequate or if the manager does not demonstrate willingness to improve, the business relationship may be terminated.

Our responsible investment policy covers and applies mainly to our actively managed funds and the portfolios and funds in which Carnegie or an external fund
manager makes direct investments in equities and corporate bonds. By supporting the UN Principles for Responsible Investment (UNPRI), Carnegie avoids investing in companies that abuse labour rights.

Carnegie excludes investments in companies violate labour rights. A large portion of assets under management are managed by external fund managers and Carnegie has a clear and established process in this regard.

In addition, external suppliers and partners are a key component of the business. Each year, Carnegie purchases supplies and other products and services such as IT systems, office supplies, consultancy services and external management services from numerous suppliers. Several policy documents, including the conduct and ethics policy and the purchasing policy, exist to support careful purchasing

Carnegie checks fund exposure from a sustainability perspective in partnership with the external adviser ISS-Ethix. They perform an ESG screening of the funds’ holdings and the manager is required to submit an explanation of any non-conformances. When there are shortcomings, engaging in dialogue is Carnegie’s first resort, with a view to achieving improvement. If the manager’s sustainability work is deemed inadequate or if the manager does not demonstrate willingness to improve, the business relationship may be terminated.

As a service company, Carnegie’s operations have limited direct environmental impact. Nevertheless, we prioritise the issue because we know it is important to run the business in a way that minimises our ecological footprint. Carnegie has chosen to integrate environmental protection with business and due diligence processes in
which all aspects are considered from the risk and added value perspectives.

Internal environmental management involves continuous adaptation of operations, improved procedures and continuous updates of knowledge and information management related to environmental issues. Our car and travel policies have an explicit environmental focus. For example, train travel is required for all
business trips of less than four hours travel time. Office premises, IT equipment, supplies and travel are examples of the direct environmental impact resulting from our operations.

The greatest environmental impact is indirect and is linked to our clients’ investments in the Private Banking business. Making responsible investments is an important aspect of the management mandate. We take environmental, social and governance aspects into account through an established process for ESG investments.
In the investment context, this is a matter of reducing risk.

A large portion of assets under management are managed by external fund managers and Carnegie has a clear and established process in this regard.

In addition, external suppliers and partners are a key component of the business. Each year, Carnegie purchases supplies and other products and services such as IT systems, office supplies, consultancy services and external management services from numerous suppliers. Several policy documents, including the conduct and ethics policy and the purchasing policy, exist to support careful purchasing

Carnegie checks fund exposure from a sustainability perspective in partnership with the external adviser ISS-Ethix. They perform an ESG screening of the funds’ holdings and the manager is required to submit an explanation of any non-conformances. When there are shortcomings, engaging in dialogue is Carnegie’s first resort, with a view to achieving improvement. If the manager’s sustainability work is deemed inadequate or if the manager does not demonstrate willingness to improve, the business relationship may be terminated.

The banking and financial services industry is heavily regulated and authorisation is mandatory; good organisation and clear processes are essential to maintaining trust and, by extension, be permitted to operate. In order to maintain trust, good business ethics and professionalism must characterise everything that Carnegie does. Our
clients’ interests must always be put before our own.

Carnegie’s corporate ethics work is based on clear allocation of responsibility, as well as policy documents, such as the conduct and ethics policy and the purchasing policy. The purchasing process and choice of suppliers must always be managed according to a consistently ethical and competition-neutral perspective. Carnegie
also has rules for how gifts and employees’ outside activities and share ownership must be managed in order to avoid conflicts of interest. Violations of Carnegie’s policies, business principles, ethical standards and other irregularities must be reported through a whistleblowing system.

Proactively addressing risks, especially those connected to money laundering and terrorism financing, is an essential component of the responsibility that Carnegie assumes in relation to providing advice to clients.

Our work to continuously to minimise these risks in operations is accomplished through supportive systems, KYC processes and regular training.