14th of July 2020
To our stakeholders:
I am pleased to confirm that [ Company Name ] 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

Our principles of CSR states:
Sparebanken Vest requires its suppliers to respect human rights, as enshrined in the 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.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
 Climate requirements
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.

Fund selection:
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 CSR 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 CSR 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.

Customers:
One criterion that applies to all customer relationships is that customers must comply with the laws and agreements that apply in Norway and the countries where the customers are present. This includes supporting and respecting the protection of internationally recognised human rights and not being party to breaches of such rights, striving to achieve equality and exercising zero tolerance of racism and other discrimination in the workplace.

Suppliers:
All suppliers must sign a CSR declaration in order to become our supplier, as described above.

Fund Selection:
We expect managers to follow up breaches of human rights and their own code of ethics 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.

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) and others.

We require companies we finance or invest in to have clear guidelines for preventing weapons being exported to areas where human rights violations are known to occur or where there is a high probability of such violations. The companies must not profit from selling weapons to countries where weapons investments come at the expense of people's welfare and primary needs. As a minimum, this is defined as countries and areas subject to an arms embargo imposed by the UN, EU or the USA.

Customers:
We have defined the following process for new and existing customers:
1. The companies must not be included on Norges Bank’s list of excluded companies, also known as the exclusion list
2. In the credit assessment, we look for particular risk relating to ethics, the climate, the environment, ownership structures, breaches of labour and human rights, and corruption. This is done by using relevant questions and assessments described in a dedicated question guide, and a country risk assessment where relevant. If the risk is deemed to be low and the assessment concludes that the bank will not be in breach of the principles for social responsibility, the customer will be assessed pursuant to the bank’s credit strategy. Credit will be disbursed if the decision is positive.
3. Where the risk is deemed to be medium or high, a separate risk assessment is carried out of relevant risk factors, and documentation of the assessment must be included in the credit documents. 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. The estimated severity of the negative impact will be a decisive factor in the decision to offer financing and whether to impose requirements for measures and remediation of non-conformities within a suitable time period. If the risk and assessment indicate that the bank will be in breach of CSR principles, the process will be stopped.

As part of the assessment of relevant risks relating to ethics and sustainability, the bank has prepared a guide containing questions about issues such as ethics, the climate, the environment, ownership structures, labour rights and corruption. These questions are used as a guidance 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 must be conducted when relevant. Such analyses are used to assess risks relating to money laundering, corruption, financing of terrorism, the environment, labour and human rights.

Our document - Principles of CSR - describes our principles for ethical conduct and for exercising corporate social responsibility (CSR) 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.

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.

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).

Suppliers:
Sparebanken Vest requires its suppliers to respect human rights, as enshrined in the 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 in accordance with the ILO Minimum Age Convention
 sexual abuse of children
 forced labour in accordance with the ILO Forced Labour Convention (No. 29) and the Abolition of Forced Labour Convention (No.105)

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 have established guidelines intended to assess operational risk factors such as violations of human rights or labour rights, corruption, serious environmental harm or other actions that can be perceived as unethical.

Suppliers:
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 enter into must include documentation concerning the supplier’s climate efforts, CSR 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.
Our suppliers must under no circumstances benefit from working conditions in their own organisation, or with their partners or subcontractors, that are based on, among other things, financial exploitation, unfair working conditions, gender-based harassment 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.

Fund Suppliers:
We require our fund suppliers to have a good and conscious approach to CSR 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.

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 grant financing to customers/businesses that directly or through subcontractors contribute to human rights violations, or operate in breach of the principles set out in the Working Environment Act.
Companies must ensure safe working conditions, respect employees’ right to organise and to collective bargaining, have maximum limits for working hours and pay their employees a living wage. We expect our customers, investments and subcontractors to ensure compliance with statutory minimum wage requirements in their respective sectors (the Norwegian Labour Inspection Authority), and we actively disapprove of undeclared work. We encourage the companies to work towards equality, equal opportunities for careers and professional development, and equal pay for men and women in the workplace. Child labour or forced 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.

Everyone has a right to equal treatment and dignity, and we expect the companies we finance and invest in to respect this right. We expect the companies to have zero tolerance for discrimination, including verbal, physical and sexual harassment, and to not discriminate or offer unequal opportunities based on age, gender, religion or sexual orientation.
We expect the companies not to be involved in discrimination, forced labour or child labour, or matters that contribute to human rights violations, either directly or through subcontractors. This also entails that we expect them to take into consideration the different risks men and women face in terms of violation of their human rights. We expect all our customers and the companies we invest in to make active efforts to achieve equal pay for equal work and equal education, and to prevent discrimination in the labour market and in contact with customers. 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.

Customers:
We have defined the following process for new and existing customers:
1. The companies must not be included on Norges Bank’s list of excluded companies, also known as the exclusion list
2. In the credit assessment, we look for particular risk relating to ethics, the climate, the environment, ownership structures, breaches of labour and human rights, and corruption. This is done by using relevant questions and assessments described in a dedicated question guide, and a country risk assessment where relevant. If the risk is deemed to be low and the assessment concludes that the bank will not be in breach of the principles for social responsibility, the customer will be assessed pursuant to the bank’s credit strategy. Credit will be disbursed if the decision is positive.
3. Where the risk is deemed to be medium or high, a separate risk assessment is carried out of relevant risk factors, and documentation of the assessment must be included in the credit documents. 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. The estimated severity of the negative impact will be a decisive factor in the decision to offer financing and whether to impose requirements for measures and remediation of non-conformities within a suitable time period. If the risk and assessment indicate that the bank will be in breach of CSR principles, the process will be stopped.

As part of the assessment of relevant risks relating to ethics and sustainability, the bank has prepared a guide containing questions about issues such as ethics, the climate, the environment, ownership structures, labour rights and corruption.

A country risk analysis must be conducted when relevant. Such analyses are used to assess risks relating to money laundering, corruption, financing of terrorism, the environment, labour and human rights.

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.

‘Everything we do, we do to make life in Western Norway even better.’

Our goal is to contribute to the western Norwegian region becoming the leading Norwegian region in climate technology and climate cuts by 2030.
We aim to integrate sustainability in all activites and divisions in the bank.

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.
This document describes our principles for ethical conduct and for exercising corporate social responsibility (CSR) 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.

In 2019 and 2020, Sparebanken Vest adopted a sustainability strategy that affects all areas of the bank
- Cut own climate footprint in half by 2025 from 2018
- Requirements for climate neutrality at all our suppliers and major sponsorship
- Framework for green bonds according to EU taxonomy standards, a launch of green bonds in July 2020 and a framework for sustainability linked loans.
- Measurement of the carbon footprint in the portfolio within shipping /marine sector, small power plants and construction/real estate. This represents almost 70% of the bank's corporate Portfolio. We have set ambitious goals for all main sectors of the Portfolio for such a reduction in foot print.
-NOK 200 million in social dividend for projects that promote sustainability, a clean ocean, new green technology and green restructuring

Ourselves:
- We are a lighthouse certified Company and climate neutral bank since the Autumn 2017.
- We have set ambitious goals of cutting our climate footprint in half by 2025. A range of activities such as cuts in flight transport, a conversion to fossile free cars etc are lined up towards reaching this goal.

Our Suppliers:
- by the end og 2020 all Suppliers must demonstrate that they are climate neutral in a order to be Our supplier.

Our customers:
- we will continue to monitor Our main sectors, address sustainability as a climate risk factor in all risk assessment

We will continue to develop our reporting structuring in order to demonstrate and evaluate all activitites as described above.

Please read more about all our activities within climate work and other sustainabilty work here:
https://www.spv.no/english/about-sparebanken-vest/csr/sustainability-library#!BFC6FE25C5CE472FBD26565DBE86C66A

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 CSR principles document describes our principles for ethical conduct and for exercising corporate social responsibility (CSR) 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.

Sparebanken Vest works on CSR 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 are committed 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 have established guidelines intended to assess operational risk factors such as violations of human rights or labour rights, corruption, serious environmental harm or other actions that can be perceived as unethical.

An important part of the bank’s CSR 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.

Fund selection:
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 abbreviation ESG is defined in Chapter 3.

We require our fund suppliers to have a good and conscious approach to CSR 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 new Money Laundering Act entered into force on 15 October 2018. Its purpose is to prevent and reveal money laundering and financing of terrorism. Sparebanken Vest has established strict procedures and a framework in order to comply with our statutory obligations and prevent the bank from being used for laundering of the proceeds of crime or contributing to terrorist financing. Sparebanken Vest verifies information about potential customers when establishing customer relationships, and ensures that customer relationships are regularly followed up. Risk assessments must be regularly carried out for transactions in relation to money laundering and terrorist financing, and the bank’s guidelines must ensure that non-compliance will entail clear consequences and that breaches have a consequence for distribution and financing. All transactions or situations that give grounds for suspicion of money laundering or terrorist 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 ownership structures, including for partly owned subsidiaries and joint ventures, and about transactions between the company and the company’s management. It must be clarified whether there are beneficial owners in addition to the customer. If there are beneficial owners, sufficient information must be obtained to identify who they are. Information about the identify of beneficial owners must be verified through 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 or terrorism financing purposes. Steps should be taken to ensure that counterparties in transactions and customer relationships are identified.
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.

Sparebanken Vest does not wish to be associated with industries that have consequences we believe to be in conflict with ethical norms. They include the pornography industry, the tobacco industry and parts of the weapons industry. We actively disapprove of and do not finance, invest in or cooperate with arms manufacturers that are involved in violations of fundamental humanitarian principles, or export to countries with widespread corruption, armed conflict, civil war or where there is a high probability that weapons could end up in such areas. This includes manufacturing, sale and transport.

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. The companies we finance must confirm that they comply with this requirement through a self-declaration, and that they are not aware of any corruption or trading in influence, present or past, in their own organisation, with the intermediaries they use or with 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.

We have defined the following process for new and existing customers:
1. The companies must not be included on Norges Bank’s list of excluded companies, also known as the exclusion list
2. In the credit assessment, we look for particular risk relating to ethics, the climate, the environment, ownership structures, breaches of labour and human rights, and corruption. This is done by using relevant questions and assessments described in a dedicated question guide, and a country risk assessment where relevant. If the risk is deemed to be low and the assessment concludes that the bank will not be in breach of the principles for social responsibility, the customer will be assessed pursuant to the bank’s credit strategy. Credit will be disbursed if the decision is positive.
3. Where the risk is deemed to be medium or high, a separate risk assessment is carried out of relevant risk factors, and documentation of the assessment must be included in the credit documents. 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. The estimated severity of the negative impact will be a decisive factor in the decision to offer financing and whether to impose requirements for measures and remediation of non-conformities within a suitable time period. If the risk and assessment indicate that the bank will be in breach of CSR principles, the process will be stopped.

As part of the assessment of relevant risks relating to ethics and sustainability, the bank has prepared a guide containing questions about issues such as ethics, the climate, the environment, ownership structures, labour rights and corruption. These questions are used as a guidance 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 must be conducted when relevant. Such analyses are used to assess risks relating to money laundering, corruption, financing of terrorism, the environment, labour and human rights.