Statement of continued support
08.08.2018

To our stakeholders:
I am pleased to confirm that Sparebanken Vest 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,

Jan Erik Kjerpeseth
CEO

Sparebanken Vest works on corporate social responsibility at the strategic level, in day-to-day operations and by making good reporting available. Sparebanken Vest has endorsed the UN Global Compact, and we make active endeavours to ensure that our operations are compatible with global sustainability. Through our endorsement of the initiative, we have committed ourselves to basing our strategy and operating processes on principles concerning human rights, the working environment, the natural environment and corruption.

- Human rights requirements are enshrined in our procurement policy. The purpose of our procurement policy is to promote responsible supplier chains in order to safeguard human rights and labour rights, sustainable development and responsible environmental management. All the supplier agreements (Suppliers and subcontractors) we sign must include documentation concerning the supplier’s corporate social responsibility and HSE work.

Sparebanken Vest requires its suppliers to respect human rights, both in their own organisations and down through the value chain. Suppliers that enter into supplier agreements with us must adhere to principles for ethical trade, and the following points are regarded as particularly important:
Ethical trade shall promote:
● safe workplaces
● regular employment with employment contracts
● regulated working hours
● a living wage
Ethical trade shall prevent:
● child labour
● sexual abuse of children
● forced labour
● discrimination of groups of people (women, minorities, political orientation)

Regarding Selection of fund suppliers:
Managers must not invest in companies involved in weapons production, human rights or labour rights violations or breaches of environmental criteria and anti-corruption work. We will prioritise fund managers who give consideration to issues such as responsible management. We expect managers to follow up breaches of human rights and their own ethical guidelines and environmental requirements relating to already communicated guidelines for such follow-up. We do this by monitoring the media, statements made by organisations, publicly available exclusion lists and warnings. In the event of concrete indications of breaches of our expectations, we will ask for the fund manager’s assessment of the incident and what plans they have to become involved. Involvement processes and active ownership can go on for a prolonged period, and Sparebanken Vest routinely follows up the individual fund managers’ documentation of follow-up over time. Where a manager is unable to present documentation, or the follow-up is not satisfactory in our view, we will stop new sales of the product through our distribution channels and inform customers with units in the fund purchased via our channels about our findings and follow-up process.

As part of the assessment of relevant risks relating to ethics and sustainability, the bank has started implementing a guide containing questions on issues such as ethics, the environment, ownership structures, labour rights and corruption. Such analyses are used to assess risks relating to money laundering, corruption, financing of terrorism, the environment, labour and human rights. In order to follow up customers and our ownership interests, the bank will ask for documentation if we suspect that circumstances have arisen that are in breach of our principles.

Sparebanken Vest is obliged to manage societal and environmental risk and to ensure that the companies we finance have familiarised themselves with and take steps to reduce the negative effects of their activities in a responsible way. The bank has developed a set of general criteria for what we believe should be included in the assessment of companies that apply to us for financing, that will be part of our investment universe or that are being considered as suppliers to the bank’s internal processes. Human right principles are included here.

Individual customer relationships will be reviewed at least once a year. The audit also includes reviewing and following up necessary improvement measures relating to processes and procedures.

In all customer relationships, Sparebanken Vest applies the criterion that customers must comply with the laws and agreements that apply in Norway and the countries where the customers are present. This includes zero tolerance for racism and other forms of discrimination in the workplace. Sparebanken Vest will not finance customers/businesses that operate in breach of the principles set out in the Working Environment Act.

Everyone has a right to equal treatment and dignity, and we expect companies we finance and invest in to respect this right. We expect companies not to discriminate or offer unequal opportunities based on age, gender, religion or sexual orientation.
When minors are employed, we expect companies to take responsibility beyond the minimum requirement prohibiting child labour and to comply with the Convention on the Rights of the Child. All children have a right to education and schooling, and education is an important means of evening out differences and creating sustainable societies. We expect employers to facilitate education when they employ minors.

Ethics training is important in order to strengthen the bank’s expertise and raise awareness of ethical risks. Everyone who is directly involved in the granting of loans or credit to businesses or in investment decisions must be familiar with our principles for socially responsible financing. The principles govern what we grant loans for and invest in, and how the bank should act and influence joint investment decisions in companies where we do not hold a dominant position. Ethics and good advisory practices are also a key part of the authorisation scheme for financial advisers.

Companies we work with must ensure safe working conditions and respect employees’ right to organise, they must have maximum limits for working hours and the employees must be paid a living wage. Child labour must not be used, and vulnerable workers such as refugees and labour migrants must not be exploited. It is also a requirement that subcontractors respect labour rights. Sparebanken Vest does not want to finance or invest in companies that do not respect employees’ right to organise, that obstruct trade unions or take reprisals against employee representatives.

Sparebanken Vest aims to be an attractive workplace, and we see our employees as important resources who enable us to provide quality services to our customers. We shall treat our customers with trust and respect and give professional and ethically justifiable advice based on the necessary qualifications and knowledge of the customer’s situation.
Sparebanken Vest shall endeavour to prevent discrimination in accordance with applicable regulations. This will be done for example in connection with recruitment, pay and working conditions and development opportunities.
We are an Inclusive Workplace (IW) enterprise and work to achieve an inclusive working environment and to reduce sickness absence. In addition to the work on inclusion, we carry out extensive work on health, safety and the environment (HSE), which the bank discusses with safety delegates, the occupational health service, employee representatives and the Norwegian Labour and Welfare Administration (NAV).

Working conditions are also included in our Procurement policiy for suppliers and subsuppliers.
The purpose of our procurement policy is to promote responsible supplier chains in order to safeguard human rights and labour rights, sustainable development and responsible environmental management. All the supplier agreements we sign must include documentation concerning the supplier’s corporate social responsibility and HSE work.

Working environment
We follow up all employees with an annual organisational survey has a very high response rate (85%) and shows a high degree of ownership, commitment and satisfaction with Sparebanken Vest as an employer.

Gender equality
Sparebanken Vest makes determined efforts to promote gender equality. Men and women shall have equal opportunities for development, pay and a career in the bank. In 2017, 52% of the bank’s total workforce, 57% of the corporate management team and 40% of board members were women. In addition to the gender balance, we also keep track of and report on the pay distribution between men and women in our annual report. In 2017, women on the top two pay levels had slightly higher pay than men, while women in the lowest pay grades had slightly lower pay than men on average.We are making active efforts to develop and retain more women at all levels of the bank’s management. One of the measures taken to ensure further development is a dedicated management development programme for female managers in the bank. We have also developed separate guidelines for our remuneration systems, and paid parental leave is included in the basis for calculating bonus payments. We endeavour to promote gender equality through active measures relating to recruitment, pay, promotion processes, development opportunities and protection against harassment. A gender equality group has been appointed and a gender equality policy is being drafted that will be implemented in 2018.

The bank has good whistleblowing procedures in place for matters that warrant criticism and any breaches of the ethical guidelines. Employees have easy access to the procedures for how whistleblowing shall take place through the bank’s HSE manual and the bank’s intranet. Such matters must be reported to the employee’s immediate superior using the dedicated non-conformity form on the intranet, which goes to the Director of Organisation and Development, or to the chief safety delegate or the Chief Compliance Officer. In addition to its internal whistleblowing procedures, an agreement has been entered into with an external third party that can receive and consider notifications. The purpose is to ensure impartiality. Notifications of breaches are treated confidentially, and employees are protected against reprisals etc. as a result of such whistleblowing. In parallel with whistleblowing about matters that warrant criticism, the Organisation and Development department also assists in cases concerning other conflicts and issues between employees.

Sparebanken Vest’s vision is to help to make life in Western Norway even better. We want to set an example for how businesses can contribute to social development in Western Norway, and we recognise that our task as part of society goes further than the statutory requirements we are subject to. Sparebanken Vest will contribute through our own processes, the projects and customers we choose to finance and how we conduct ourselves in relation to customers, society and the environment.
Our document of principles of CSR describes ethical conduct and for exercising corporate social responsibility in our business operations and in our dealings with our customers, through the businesses we invest in, the requirements we make of our suppliers, and what we emphasise to ensure that our operations, corporate governance and ownership are sustainable. These guidelines are intended to ensure that Sparebanken Vest does not contribute to violations of human rights or labour rights, money laundering and terrorism financing, corruption, serious environmental harm or to other actions that can be perceived as unethical.

Throughout our history, we have endeavoured to ensure that the local community has the best conditions for growth and that it develops in a sustainable way. We will continue with these efforts, which means taking responsibility for both the local and global environment.
This work involves many different roles and themes. Among other things, we will take good care of our employees and their working environment, we will have thorough procedures to prevent corruption and money laundering, and we will make active efforts to reduce both our direct and indirect environmental footprint. This document describes how Sparebanken Vest will make use of its opportunities to influence societ. As a company, we need to see the connection between our business activities, society and the environment. Our most important contribution is to develop a responsible, profitable business through banking operations and to help businesses and individuals to gain access to resources, make use of technology and create jobs, revenues and prosperity. To ensure that this is economically sustainable, however, we also need to take social and environmental considerations into account. In this document, these considerations are defined as ethical and sustainability considerations and criteria, particularly within the topics of ethics, the environment, ownership structures, labour rights and financial crime.

Through the UN Global Compact initiative, Sparebanken Vest has undertaken to apply the ‘better safe than sorry’ principle in relation to environmental challenges, to take the initiative to promote increased environmental awareness and to encourage the development and use of environmentally friendly technology. In the Paris Agreement in 2015, the world’s leaders agreed that global warming must be kept well below 2 degrees – and we will aim for 1.5 degrees – to be able to prevent dangerous climate change. This means that we will have to change and adapt in many areas of society.
Work on reducing greenhouse gas emissions is an important part of our global responsibility. Our region will be particularly affected by changes in the global climate.

Sparebanken Vest works systematically on environmental measures in its day-to-day operations, and it has taken a number of measures to reduce its own direct and indirect greenhouse gas emissions. The head office in Jonsvoll was certified as an Eco-Lighthouse in September 2017. The Eco-Lighthouse certification is an external verification of Sparebanken Vest that confirms that the bank meets a set of criteria and implements measures to achieve more environmentally friendly operations and a good working environment.

Jonsvoll is a modern building in a central location in Bergen city centre that is easy to get to using public transport. When choosing solutions for the building, it was emphasised that the architecture should be attuned to the city district and the local environs, and stringent energy and environmental requirements were applied. All heating is supplied by district heating radiators and water-borne underfloor heating. Cooling is ventilation-based using seawater as the coolant. The building is connected to the city’s underground waste disposal network and waste is handled in large recycling stations in all parts of the building. One hundred per cent of Sparebanken Vest’s electricity consumption comes from renewable sources, and we make sure that the power supplied can be traced to specific power stations through certificates.

We have also included environmental management in our procurement policy for Suppliers and subcontractors.
Sparebanken Vest focuses on ensuring the lowest possible environmental load in connection with procurement processes. Our suppliers must at all times meet or exceed official environmental requirements, and ensure that they have energy-efficient and raw material-efficient production methods. In connection with the Eco-Lighthouse certification, we have used the ‘Mapping of suppliers’ tool and have integrated it into our procurement system. Mapping is carried out continuously. It gives us an overview of suppliers who are certified pursuant to the Eco-Lighthouse criteria, ISO-14001, EMAS, the Nordic Ecolabel or similar. We will also endeavour to persuade our regular and most important suppliers to seek environmental certification.
We require our suppliers to map all potential environmental risks associated with their business, and to ensure that their operations are in compliance with local and national rules and laws for environmental management. The suppliers must have adopted an environmental policy that is adapted to their industry, and that contains clear goals for environmental management and for addressing the most important challenges associated with these goals.
Suppliers must also work proactively to reduce any negative effect their business has on the environment, with particular focus on reduced consumption, waste recycling and the introduction and use of environmentally friendly technology in production processes, and they must be able to document steady improvement through reporting and follow-up systems.
Goods and services supplied to Sparebanken Vest must be produced in a manner that preserves biodiversity and that ensures that land areas and natural resources are managed in the most sustainable manner possible. When evaluating tenders in connection with invitations to tender, we will give strong emphasis to whether suppliers are environmentally certified.
The bank requires that its suppliers do not offer or supply products made from tropical timber. Supplies of copy paper, envelopes and other printed material must satisfy the environmental labelling requirements of the Nordic Ecolabel or the EU Ecolabel. ICT equipment delivered to the bank must not contain chemicals that are harmful to health or the environment, and it must have low energy consumption.
When purchasing cars, Sparebanken Vest has the following requirements:
● Purchases and leasing of new passenger cars, vehicle group M1: CO2 emissions must not exceed 130 g/km
● Purchases and leasing of new delivery vans, vehicle group N1: CO2 emissions must not exceed 210 g/km
● When purchasing and leasing new vehicles for business use, the vehicle with the lowest possible CO2 emissions will be chosen. This could be hybrid vehicles, cars with CO2 emissions lower than or equal to 120 g/km or other environmentally friendly alternatives on the market.

Sustainable Investments:
We wish to contribute to ensuring that our own and our customers’ investments that are made through our channels are with companies that do more than just meeting the minimum requirements for sustainability, the environment and responsibility.

Requirements for fund suppliers:
All funds and fund suppliers that are offered to customers through Sparebanken Vest’s channels must have well-documented strategies and processes for ethical fund management, and for following up ethics, corporate social responsibility, sustainability and the environment by voting actively at general meetings. We are concerned with ensuring that the fund managers do not themselves participate in lobbying aimed at weakening cooperation on international standards for the environment, corporate governance, sustainability and corporate social responsibility, but that they contribute in a positive and open way.

Enviornment criterias s a part of assessment criterias related to individual industries:
Certain industries are associated with a special risk of negative environmental and social impact on nature areas and protected areas. If expedient measures are not implemented, this can lead to increased financial risk, legal risk and, in part, conflicts of interest. Sparebanken Vest has therefore established different assessment criteria for certain relevant industries in addition to the general criteria. Risk assessments relating to corporate social responsibility decide the process and scope of the analysis and the decision level. They are described in particular in the guidelines for general requirements and industry-specific assessments. As part of the assessment of relevant risks relating to ethics and sustainability, the bank ihas started implementing a guide containing questions on issues such as ethics, the environment, ownership structures, labour rights and corruption.

Sparebanken Vest is obliged to manage societal and environmental risk and to ensure that the companies we finance have familiarised themselves with and take steps to reduce the negative effects of their activities in a responsible way. The bank has developed a set of general criteria for what we believe should be included in the assessment of companies that apply to us for financing, that will be part of our investment universe or that are being considered as suppliers to the bank’s internal processes.
They include principles laid down in:
● Human rights
● The Working Environment Act
● The Personal Data Act
● The UN Convention against Corruption
● The Money Laundering Act
● The Taxation Act
● The Equality and Anti-Discrimination Act
● The Natural Diversity Act and the Svalbard Environmental Protection Act
● The Wetlands Convention
(the Ramsar Convention)
● The Pollution Control Act
● The Accounting Act
● The Animal Welfare Act

Energy production and clean energy
Sparebanken Vest expects all industries and enterprises to take responsibility for climate challenges, to display an active attitude to the use of clean energy and to implement measures to reduce their carbon footprint.
The bank plays a key role as a driving force and facilitator of social development and the green transition. We wish to promote the production of clean and green energy. Companies engaged in energy production and distribution are expected to participate in this by endorsing international agreements promoting green energy and to implement measures to reduce their climate and environmental impact. The companies’ role and responsibility shall be described in their governing documents and strategy.

Energy production and clean energy
Sparebanken Vest expects all industries and enterprises to take responsibility for climate challenges, to display an active attitude to the use of clean energy and to implement measures to reduce their carbon footprint

Mining and metal extraction
Sparebanken Vest applies the principle that encroachments on nature must be kept to a minimum in connection with both mining and processing industry relating to the production of metals. Plans for the purification of discharges, the restoration of nature and reclamation of encroachments on nature after the decommissioning of operations must be documented, irrespective of local legislation. Run-off and environmentally harmful waste must be dealt with in an acceptable manner, and the employees must have good working conditions that entail a low risk to health. Particular caution must be exercised if operations take place in areas with especially vulnerable nature. If there is a risk of permanent harm to the environment as a result of accidents or external impacts, mining must be avoided. Encroachments on nature shall not be carried out in a way that affects indigenous peoples’ rights and traditional way of life more than necessary, and we expect companies to endeavour to engage in dialogue in order to arrive at good solutions. We do not finance open cast mining operations in oil sands/tar sands, operations that entail the extraction of uranium or mountaintop removal mining.

Coal-fired power, coal extraction and other controversial energy production
Sparebanken Vest does not wish to finance coal-fired power production or the operation of coal mines, and it therefore does not finance companies involved in coal extraction and coal-fired power. This principle also applies to companies involved in controversial energy sources such as nuclear power.
The Government Pension Fund Global’s exclusion list will be used as a guideline to exclude companies with a high proportion of revenues from or operations linked to coal-fired power. We expect further measures to be taken than to adapt the company structure to meet the requirement for maximum 30% of revenues or operations linked to coal-fired power. Fund managers we use or whose products we distribute must make sure that they do not invest in companies that use structural adaptations to circumvent exclusion criteria. We also want fund managers to apply the principle of reducing the proportion of coal-fired power and dependence on coal-fired power in companies that are within the Government Pension Fund’s limits for the proportion of revenues from and operations linked to coal-fired power. We want fund managers to encourage investment in other, purer sources of energy production.
The oil industry has been and is one of the most important drivers of economic growth in Western Norway, and Sparebanken Vest therefore grants credit to companies that are subcontractors to the oil industry. Large-scale recovery of oil and gas will in all probability decrease in future, but it is currently an important employer and contributor to the economy. The oil industry only accounts for a small proportion of our total lending portfolio.
As regards large hydroelectric power plants, we require enterprises we finance or invest in to meet the seven principles of the World Commission on Dams.
Sustainable agriculture and forestry
Sparebanken Vest wishes to support sustainable agriculture and forestry. We require forestry and agriculture to give due consideration to wildlife corridors and access to water. The enterprises must take steps to prevent run-off and the depletion of soil and water resources, and measures must be taken to ensure the establishment of non-cultivation zones bordering on springs, seas and rivers. Indigenous rights must be respected, particularly access to grazing, the movement of animals and access to water sources.
Enterprises producing crops that deplete the soil or that have other very negative effects on the local ecosystem must have guidelines in place that ensure that such effects are mitigated and counteracted. We expect active endeavours to be made to address known challenges relating to nut production and plant oils/palm oil, both by the producers themselves and by enterprises that use the produce in their production. We expect crop spraying to be kept at a low level and the use of chemicals to be as low as possible and to have as little environmental impact as possible.
Sparebanken Vest wishes to ensure that animal transport is of an acceptable standard and has a maximum duration of eight hours, unless local legislation provides otherwise. We support the Five Freedoms for animal welfare, and expect very confined cages and stalls not to be used.
If timber is used as a raw material, this must be done in a sustainable way. We disapprove of the felling of virgin forest and therefore do not wish to finance industries that participate in such activity or that engage in logging operations that do not ensure sustainability. We expect biofuel production to meet the RSB standard.
Enterprises engaged in the production of paper, pulp and wood products should be certified pursuant to FSC’s value chain requirements or work towards achieving such certification. If a company’s operations have a major impact on forests, through felling or other development, the company’s footprint must be reported in accordance with the requirements in the FFD project.

Fisheries
Fish stocks are among our most important renewable resources. Sparebanken Vest expects its customers in the fishing industry to operate on the basis of official permits and to comply with the laws and regulations that apply to the industry. All companies in this industry manage natural resources on behalf of society and therefore have a responsibility to operate in a sustainable manner and with the smallest environmental footprint possible. Together with the authorities, industry associations etc., the companies must do what they can to conserve marine resources for future generations.
We will not finance companies that engage in fishing of unregulated fish stocks with a sustainability risk, fisheries that use harmful methods or fishing of endangered species, including species described in the CITES agreements. To ensure sustainable management, we expect the companies to comply with requirements and regulations set out in national and international laws, quotas etc. We also want the fishing industry to contribute to cooperation on environmental certification, and we prioritise suppliers that act in a responsible and sustainable manner.

The aquaculture industry
Sparebanken Vest expects its customers in the aquaculture industry to engage in sustainable aquaculture, to act as responsible members of society and to operate within the laws and regulations that apply to the industry. The companies must do all they can to protect the environment and ensure that it is managed in a way that also benefits future generations. Systematic efforts to prevent undesirable impact on the environment are very important, in addition to a focus on the prevention of escapes and high levels of salmon lice, efforts to combat disease and promote fish welfare. We expect the companies to focus on the use of sustainable feed and efficient utilisation of feed, and on their climate impact. Systematic work in these areas, involvement in research and development and cooperation with the authorities/the public administration, interest organisations, other fish farmers and suppliers are important in order to ensure a sustainable and profitable future for the industry.
The aquaculture industry is one of the most important food suppliers in the world and its long-term growth must take place in a sustainable and efficient manner. We expect feed producers to do what they can to develop an even more sustainable industry. A reduced proportion of wild-caught fish, increased use of marine residual raw materials and the use of vegetable ingredients could be ways of achieving the desired growth in the industry. In addition, they must endeavour to minimise the carbon footprint from their operations and from the transport of raw materials, and they must follow-up emission reduction measures taken by their suppliers.

A sustainable financial industry
A strong and sustainable financial industry forms the basis for a sustainable economy. Like the general requirement not to exploit crises or vulnerable individuals, nor shall the financial industry, financing companies or bond investments be exploited for profiteering purposes. This means that, in connection with both investment and financing activities, we must critically assess companies that are involved in financing individuals with strained finances, and it is a requirement that customers are able to understand the terms and conditions that apply to the products and services we offer. Local value creation shall not take place at the expense of people and the environment in other parts of the world. Lenders and financial institutions must comply with local rules and guidelines for consumer protection. If there is no local regulation, international standards must be complied with.
Financial undertakings must not finance projects and enterprises that violate fundamental requirements relating to human and labour rights, harm the environment or violate indigenous rights. In connection with the financing of projects or enterprises where there is deemed to be a high risk of such violations based on the industry or country risk, this risk must be assessed separately, and compliance requirements will be included in the loan agreement.

Property companies and property development
Sparebanken Vest wants companies that invest in property and property development to set goals for and implement measures to reduce emissions and energy consumption. We expect large companies to have procedures for reducing energy consumption, and we expect the company’s documents to contain environmental accounts and goals for the reduction of greenhouse gas emissions. Large groups of companies that manage property (with a balance sheet total of more than NOK 7.5 billion) should endeavour to achieve ISO 14001 certification in order to ensure that greenhouse gas emissions are reduced.
If disputes arise relating to the ownership of land or the interests of existing tenants or occupants and they are a vulnerable group, we expect caution and responsibility to be shown in relation to the balance between profit and the interests of those inhabiting the land or housing.

Transport companies and aviation
We welcome fossil-free alternatives and urge transport and aviation companies to invest in technology to reduce emissions and their negative environmental impact.

The bank plays a key role as a driving force and facilitator of social development and the green transition. We wish to promote the production of clean and green energy. Companies engaged in energy production and distribution are expected to participate in this by endorsing international agreements promoting green energy and to implement measures to reduce their climate and environmental impact. The companies’ role and responsibility shall be described in their governing documents and strategy.

In connection with the environmental certification, Sparebanken Vest has initiated an extensive mapping process and a plan for internal environmental improvements.
The head office in Jonsvoll was certified as an Eco-Lighthouse in September 2017. The Eco-Lighthouse certification is an external verification of Sparebanken Vest that confirms that the bank meets a set of criteria and implements measures to achieve more environmentally friendly operations and a good working environment.Our environmental accounting report has been made available publicly.

In order to follow up customers and our ownership interests, the bank will ask for documentation if we suspect that circumstances have arisen that are in breach of our principles.
Individual customer relationships will be reviewed at least once a year. The audit also includes reviewing and following up necessary improvement measures relating to processes and procedures.

Environmental toxins
In the event of involvement in production processes or the production of products that contain environmental toxins, a number of measures must be developed to prevent the spread of and contamination from such products. Companies where this can be an issue must have measures in place to contribute to the collection and satisfactory destruction of residues and waste from the products, measures to reduce the content of environmental toxins and general measures to reduce the negative environmental impact of the production. This also applies to activities in countries and areas that do not have statutory requirements corresponding to those in Norway.

Our "principles of CSR document" includes guidelines that are intended to ensure that Sparebanken Vest does not contribute to violations of human rights or labour rights, money laundering and terrorism financing, corruption, serious environmental harm or to other actions that can be perceived as unethical.
The principles also apply to all products and services the bank offers to private individuals, businesses and households. The guidelines are intended to ensure that failure to comply with the principles will have clear consequences, and that breaches will have consequences for distribution and financing.Throughout our history, we have endeavoured to ensure that the local community has the best conditions for growth and that it develops in a sustainable way. We will continue with these efforts, which means taking responsibility for both the local and global environment.
This work involves many different roles and themes. Among other things, we will take good care of our employees and their working environment, we will have thorough procedures to prevent corruption and money launderin.
Sparebanken Vest works on corporate social responsibility at the strategic level, in day-to-day operations and by making good reporting available. Sparebanken Vest has endorsed the UN Global Compact, and we make active endeavours to ensure that our operations are compatible with global sustainability. Through our endorsement of the initiative, we have committed ourselves to basing our strategy and operating processes on principles concerning human rights, the working environment, the natural environment and corruption.

An important part of the bank's corporate social responsibility policy is to limit the possibility of financial crime. Having a robust system and good guidelines in place to prevent and expose money laundering and terrorism financing are among the methods used to counteract this. Sparebanken Vest has zero tolerance for corruption and all other forms of financial malpractice, including accepting and offering bribes or other advantages. The bank’s business model and role in society are based on trust. It must therefore always assess the risk of corruption and distance itself from all activities that entail a risk of corruption and other malpractices. The relationships of dependency that arise in connection with corruption can have harmful effects that far exceed the direct consequences of the financial advantages. Among other things, corruption has harmful economic effect, distorts competition and undermines the social fabric.

Sparebanken Vest is in the process of establishing a robust anti-corruption programme on a scale that is adapted to the bank’s risk exposure. The objective is to ensure that Sparebanken Vest and its employees do not become involved in situations that put both the bank and the employees at risk of being held criminally liable or that damage the bank’s reputation. Through training, risk assessments and counter-measures, the anti-corruption programme is intended to ensure that Sparebanken Vest and its employees do not become involved in situations that can bring the bank’s credibility or impartiality into doubt, or that, in the worst case, can constitute grounds for criminal liability. The strategy establishes a process for how suspicion of corruption or other financial malpractices shall be dealt with, whether it is employees, suppliers or other contractual counterparties that are involved. The process is intended to ensure that suspicions of corruption or other financial malpractices are dealt with immediately.

Sustainable Investments
Sparebanken Vest shall ensure that all our investments serve to promote long-term value creation and contribute to a sustainable global financial system. We are working on including an assessment of the risk of corruption relating to potential investment objects in our procedures. This is in order to ensure that we only invest in companies with expedient procedures for handling corruption. In our own investments and in our expectations of our suppliers, we support the UN Principles for Responsible Investment (PRI). We also follow the principle that, in the absence of more stringent local legislation, companies must as a minimum comply with international standards for industries and enterprises. We endeavour to ensure that our investments and procedures for assessing and following up our investments are in accordance with the initiative’s six principles for responsible investments.

The UN Convention against Corruption is included in the assessements related to individual industries and general criteria for investment/financing.

We require our fund suppliers to have a good and conscious approach to corporate social responsibility in their investments. We also require them to have signed or to comply with investment principles corresponding to UN PRI, and to have clear guidelines for the exclusion of companies. Managers must not invest in companies involved in weapons production, human rights or labour rights violations or breaches of environmental criteria and anti-corruption work.

Sparebanken Vest has implemented systems and complies with the procedures set out in applicable anti-money laundering legislation. It is a requirement that the companies we finance or invest in are not involved in financial crime, including corruption or attempts to prevent the exposure of corruption. We are in the process of requiring companies to confirm that they comply with this requirement through a self-declaration. As a minimum, the companies must have given due consideration to corruption and the risk factors associated with it. In the case of large companies that we finance, we have a minimum requirement that they have satisfactory management and control systems in place that include measures for dealing with suspected corruption, whistleblowing procedures for internal suspicions of corruption, and that they require their suppliers and subcontractors to comply with the same criteria. We are working on including an assessment of the risk of corruption relating to potential customers in our procedures. This is in order to ensure that we only finance customers with expedient procedures for handling corruption.

Assessment tools
As part of the assessment of relevant risks relating to ethics and sustainability, the bank is in the process of preparing a guide containing questions on issues such as ethics, the environment, ownership structures, labour rights and corruption. These questions are to be used as a guide and assessment tool when necessary or expedient. The focus will be on issues that are particularly relevant to the customer’s risk. Industry specialists will be consulted when necessary, and cases that are assessed as entailing medium to high risk will be considered by the Director of Corporate Market and the Director of Risk Management.

Country risk will be included in the assessment if the customer operates or has projects in countries other than the high-income countries in the OECD. We use the OECD’s country classification as our point of departure. A country risk analysis must be carried out independently of income size, but with the emphasis on materiality, and in every case where this is required. Such analyses are used to assess risks relating to money laundering, corruption, financing of terrorism, the environment, labour and human rights.

Corporate governance, money laundering and corruption
Sparebanken Vest has zero tolerance for corruption, money laundering and terrorism financing, and we expect our customers and fund managers to have systems and procedures in place to prevent such offences. If corruption is suspected, we require full transparency from the company and participation in our investigation of the matter.
There must be transparency about the company’s ownership and about transactions between the company and the company’s management. We also expect fund managers to use their voting rights in matters concerning ownership, particularly with a view to strengthening the principles of transparency, good corporate governance and fair pay. The focus must always be on what is best for the company.
We want to counteract money laundering and terrorism financing, and expect owners and fund managers to make sure that companies they have invested in are not involved in transactions that can be used for money laundering and terrorism financing purposes. Steps should be taken to ensure that counterparties in transactions and customer relationships are identified.