05.08.2019
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

From the principles of Corporate Social Responsibility document that guide as through all this important work:

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.

Humane rights is included in the 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 we sign must include documentation
concerning the supplier’s corporate social responsibility and HSE work. The documentation
must confirm that the supplier complies with all local, national and international laws, rules and
other industry principles. The same requirements apply to the supplier’s subcontractors.

Humane rights is also included in the Fund Selcetion Process. 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.
We will prioritise fund managers who give consideration to issues such as responsible
management of our common resources, for example water resources, fisheries and aquaculture,
forests and timber, the extractive industries, responsible oil recovery and refining of petroleum
products, and other issues that are included in the industry assessments.

Sparebanken Vest requires its suppliers to respect human rights, as described in the UN
Universal Declaration of 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)

We require our suppliers to comply with all local, national and international rules concerning
proper working conditions, including pay, working hours, non-discrimination in the employment
process and in the workplace, freedom of association, the right to engage in collective
bargaining and health, safety and the environment. We require that our suppliers under no
circumstances benefit from working conditions in their own organisations, or in their partners or
subcontractors, that are based on exploitation, unfairness or abuse of any kind. Foreign workers
must be ensured the same working condition as other Norwegian employees, and, for suppliers
of cleaning services, we require that the supplier can document that it is authorised and
registered in the Labour Inspection Authority’s register of cleaning companies.

Humane rights is also included in the Fund Selcetion Process. 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.
We will prioritise fund managers who give consideration to issues such as responsible
management of our common resources, for example water resources, fisheries and aquaculture,
forests and timber, the extractive industries, responsible oil recovery and refining of petroleum
products, and other issues that are included in the industry assessments.

In addition to satisfactory guidelines for investment, ethical management also comprises
1. systems, procedures and processes for uncovering and identifying incidents that can
indicate breaches
2. procedures and processes for investigating breaches
29
3. procedures for involvement and active ownership in the individual companies involved
4. defined processes for terminating ownership in cases where matters warranting criticism
are uncovered and they are not remedied within a reasonable period after dialogue with
the Company.

As part of the assessment of relevant risks relating to ethics and sustainability, the bank has
prepared 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.
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 will be carried out where relevant.
Such analyses are used to assess risks relating to money laundering, corruption, financing of
terrorism, the environment, labour and human rights.

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, either directly or
indirectly via subcontractors, contribute to breaches of human rights, or 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 to have zero tolerance for discrimination,
including verbal, physical and sexual harassment, and that they do not discriminate or offer
unequal opportunities based on age, gender, religion or sexual orientation.
We expect the companies to have no involvement in discrimination, forced or child labour, or
any activity that, either directly or indirectly through subcontractors, breaches human rights. This
also means that we expect them to take into account that women and men face different risk
with respect to violation of their human rights.

We will not continue to distribute products where the requirements for processes for following up
corporate social responsibility issues are not followed up in an acceptable manner. In our
contact with potential fund managers, we will therefore look for and comment on any
weaknesses we see in exclusion criteria, procedures and process descriptions.
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

Customers:
We emphasise having expedient processes in place when customer relationships are first
established, but we are also responsible for following up customers throughout the relationship.
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.

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 (as described in the UN Guiding Principles on Business and
Human Rights)
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.
We revise our assessments of the individual fund suppliers’ systems at least once a year, and we expect to see real improvement in fund managers’ follow-up systems where there are shortcomings.
Documentation of compliance with requirements concerning corporate social responsibility,
ethics, money laundering rules, transparency, sustainability, corporate governance in all
companies in which we have ownership interests, and fund managers’ corporate governance,
shall be reviewed and audited at least once a year. The next review and audit will take place in
autumn 2018. The audit also includes reviewing and following up necessary improvement
measures relating to processes and procedures.

From the principles of Corporate Social Responsibility document that guide as through all this important work:

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.

Labour Rights are included in the 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 we sign must include documentation
concerning the supplier’s corporate social responsibility and HSE work. The documentation
must confirm that the supplier complies with all local, national and international laws, rules and
other industry principles. The same requirements apply to the supplier’s subcontractors.

Labour rights is also included in the Fund Selcetion Process. 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.
We will prioritise fund managers who give consideration to issues such as responsible
management of our common resources, for example water resources, fisheries and aquaculture,
forests and timber, the extractive industries, responsible oil recovery and refining of petroleum
products, and other issues that are included in the industry assessments.

The World Business Council for Sustainable Development describes corporate social
responsibility as follows: ‘Corporate Social Responsibility is the continuing commitment by
business to behave ethically and contribute to economic development while improving the
quality of life of the workforce and their families as well as of the local community and society at
large.’
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.
Our commitments are based on recognised international guidelines such as:
● The UN Universal Declaration of Human Rights
● The UN Global Compact
● The OECD Guidelines for Multinational Enterprises
● The UNEP FI Statement
● The UN Principles for Responsible Investment (PRI)
● The UN Guiding Principles on Business and Human Rights

A source of financing for projects and businesses in Western Norway
Our customers must be able to trust us to give advice and financing that contribute to
long-term and sustainable growth for both individual businesses and projects and also
for Western Norway as a region. We contribute to this by advising customers to make
sound financial choices, and by ensuring that we finance businesses that operate within
the bounds of the law. We are in the process of establishing guidelines for assessing
operational risk factors, such as human and labour rights violations, corruption, serious
environmental harm or other actions that can be perceived as unethical.

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).

Our Procurement Policy:
As a minimum, we require all our suppliers to comply with Norwegian laws and binding
international agreements. The requirements, which are enshrined in our procurement policy, can
be summarised in the following main categories:
● Human rights
● Working conditions
● Environmental management
● Ethical practices
● Reporting
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. The documentation
must confirm that the supplier complies with all local, national and international laws, rules and
other industry principles. The same requirements apply to the supplier’s subcontractors.

Sparebanken Vest requires its suppliers to respect human rights, as described in the UN
Universal Declaration of 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)

We require our suppliers to comply with all local, national and international rules concerning
proper working conditions, including pay, working hours, non-discrimination in the employment
process and in the workplace, freedom of association, the right to engage in collective
bargaining and health, safety and the environment. We require that our suppliers under no
circumstances benefit from working conditions in their own organisations, or in their partners or
subcontractors, that are based on exploitation, unfairness or abuse of any kind. Foreign workers
must be ensured the same working condition as other Norwegian employees, and, for suppliers
of cleaning services, we require that the supplier can document that it is authorised and
registered in the Labour Inspection Authority’s register of cleaning companies.

When selecting fund suppliers and funds that will be offered through our channels, we asses a
number of criteria, including the investment philosophy, universe and mandate, the return over
time, fund managers and their historical record, the size of the management organisation and
criteria for corporate social responsibility and corporate governance. Each individual fund must
also be seen in conjunction with the total offering of funds.
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.
We will prioritise fund managers who give consideration to issues such as responsible
management of our common resources, for example water resources, fisheries and aquaculture,
forests and timber, the extractive industries, responsible oil recovery and refining of petroleum
products, and other issues that are included in the industry assessments in this document.
The management team, the size of the organisation and its reputation are also part of the
assessment. Reliable and robust fund managers are a precondition for creating trust in
distribution through our channels, and are necessary if we are to trust the managers to follow up
our requirements for ethics and sustainability in their fund management.
We only distribute funds where the manager manages the funds themselves. We also carry out
further investigations if a potential fund has underlying products and deliveries from other
parties, to ensure that it has been clarified what the actual risk is and who the real counterparty
is.

9.1.2 Labour rights
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, either directly or
indirectly via subcontractors, contribute to breaches of human rights, or that operate in breach of
the principles set out in the Working Environment Act
Companies must ensure safe working conditions and respect employees’ freedom of
association and right to take part in collective bargaining, and they must have maximum limits
for working hours and the employees must be paid a living wage. We recommend that
companies work to promote gender equality, equal career and professional development
opportunities and equal pay for men and women in the workplace. Child or forced labour must
35
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.
9.1.3 Equality and child labour
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 to have zero tolerance for discrimination,
including verbal, physical and sexual harassment, and that they do not discriminate or offer
unequal opportunities based on age, gender, religion or sexual orientation.
We expect the companies to have no involvement in discrimination, forced or child labour, or
any activity that, either directly or indirectly through subcontractors, breaches human rights. This
also means that we expect them to take into account that women and men face different risk
with respect to violation of their human rights. 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.

Fund monitoring:
Assessment tools
As part of the assessment of relevant risks relating to ethics and sustainability, the bank has
prepared 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.
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 will be carried out where relevant.
Such analyses are used to assess risks relating to money laundering, corruption, financing of
terrorism, the environment, labour and human rights.
8.5 Follow-up of customers
We emphasise having expedient processes in place when customer relationships are first
established, but we are also responsible for following up customers throughout the relationship.
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.

Follow-up of customers
We emphasise having expedient processes in place when customer relationships are first
established, but we are also responsible for following up customers throughout the relationship.
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.

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.
The document Principles of CSR describes our principles for 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 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.

We became a Climate Neutral Bank in 2019, and we have commited to work towards a platform where all Our Suppliers are Climate Neutral within ultimo 2020.

We have introduced a new Sustainiablity strategy this summer, commiting to work With a 365 degree perspective to sustainability issues: ourselves, Our Clients, Suppliers, Funds and other offered Products as well as Our donations. We have set several ambitious goals to ourselves, among them to only have fossile free cars by the end of 2020 and to cut Down on flight transport dramatically.

We became a Climate Neutral Bank in 2019, and we have commited to work towards a platform where all Our Suppliers are Climate Neutral within ultimo 2020.

We have introduced a new Sustainiablity strategy this summer, commiting to work With a 365 degree perspective to sustainability issues: ourselves, Our Clients, Suppliers, Funds and other offered Products as well as Our donations. We have set several ambitious goals to ourselves, among them to only have fossile free cars by the end of 2020 and to cut Down on flight transport dramatically, cut down on waste and energy and make Sparebanken Vest a more bicycle friendly working place.
We have cut Our CO2 emissions dramatically the last 2 Years, and we aim to cut half the CO2 emissions by 2025.
All this is included in a communication strategy to be rolled Our in the fall of 2019.

Our two main external Projects for 2019 will be the following:
1. To roll out "Klimanjaro" - claiming climate neutrality from all Our Suppliers.
2. To get a complete overview of all the main industry that we Finance in terms of CO2 emissions.

Internally:
We produce yearly a Climate Accounting report of Our own emissions, produced by Cemasys, published interally and externally by Klimapartner.
We are certified by "Miljøfyrtårn", With a yearly exteranl audit.

Externally: We are starting now to claim Climate neutrality and therefore also a climate accounting by all Our Suppliers.

We are measuring the CO2 emissions of the main industries that we Finance, and we will start to include this Insight in Product Development and further work together With Our customers.

The anti corruption work is of the upper most importance in the bank. It is integrated in risk management, AML and anti corruption policies and strategies, and described in our principles of CSR document - for 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.
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.

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.

Our customers must be able to trust us to give advice and financing that contribute to
long-term and sustainable growth for both individual businesses and projects and also
for Western Norway as a region. We contribute to this by advising customers to make
sound financial choices, and by ensuring that we finance businesses that operate within
the bounds of the law. We are establishing guidelines for assessing
operational risk factors, such as human and labour rights violations, corruption, serious
environmental harm or other actions that can be perceived as unethical.

Ownership structure, taxation and attitude to
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
13
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 clear guidelines for cooperation with third
parties. 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.
We require our fund managers to have procedures in place to ensure that they invest in
companies that are open about their ownership structure, in addition to disclosing how much
they pay in tax in all countries in which they operate. If separate law and regulatory
requirements for international taxation and trade have not been established, we require
compliance with the Wolfsberg Principles. All fund managers must also comply with the
Wolfsberg Principles in connection with efforts to prevent money laundering, concealed
ownership and transactions capable of being used for money-laundering purposes. We refrain
from involvement in giving investment advice where the object is to evade tax. This also applies
to the distribution of services from other advisers or products on behalf of fund managers who
encourage tax evasion or money laundering.

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.

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.
We will prioritise fund managers who give consideration to issues such as responsible
management of our common resources, for example water resources, fisheries and aquaculture,
forests and timber, the extractive industries, responsible oil recovery and refining of petroleum
products, and other issues that are included in the industry assessments in this document.

Assessments of ethics, the environment, corporate
social responsibility and sustainability in connection
with granting credit
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 through a selfdeclaration
that they comply with this requirement, and confirm that they are not aware of
corruption or trading in influence taking place or having taken place in their own organisation,
among the intermediaries they use, or their suppliers or subcontractors.
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.

Assessment tools
As part of the assessment of relevant risks relating to ethics and sustainability, the bank has
prepared 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.
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 will be carried out where relevant.
Such analyses are used to assess risks relating to money laundering, corruption, financing of
terrorism, the environment, labour and human rights.

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 (as described in the UN Guiding Principles on Business and
Human Rights)
● The Working Environment Act
ILO Declaration on Fundamental Principles and Rights at Work
● 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
Some requirements are absolute, while others must be assessed in relation to the size and
location of the enterprise. For example, we expect all our customers and the enterprises we
invest in to comply with Norwegian laws and international conventions, but we believe that it is
necessary to take the companies’ size into consideration when making requirements for
documentation of procedures and reporting. In the fund management context, the investment
universe will often be dominated by larger companies than is the case for many of our loan
customers, who are primarily based in Western Norway. At the same time, the bank is closer to
the individual investments for which loans are furnished and is therefore in a position to assess
the companies and projects in more detail from case to case. We do not want to finance or
invest in companies that violate the principles described below. Any deviations from or
differences between the requirements are described separately.

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.
The new Money Laundering Act entered into force on 15 October 2018. The purpose of the act
is to prevent and expose money laundering and terrorism financing. Sparebanken Vest has
established strict procedures and a framework for complying with our statutory duties and
preventing the bank from being used for money laundering of the proceeds of crime or from
contributing to terrorism financing. Any transaction or situation that raises suspicion of money
laundering or terrorism financing will be reported and forwarded to the National Authority for
Investigation and Prosecution of Economic and Environmental Crime (Økokrim).
There must be transparency about the company’s ownership, including for part-owned
subsidiaries and joint ventures, and about transactions between the company and the
company’s management. It must be determined whether there are beneficial owners in addition
to the customer. If there are beneficial owners, information must be obtained to sufficiently
determine their identity. Information about the identity of beneficial owners must be confirmed by
means of suitable measures and registered in the bank’s systems.
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 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.