This year being our first as signatories of the UN Global Compact, this is also our first year reporting on our progress towards meeting the principles of human rights, labor, environment and anti-corruption stipulated in the UN Global Compact.

Last year, in 2016, I had the pleasure of announcing our participation in this important initiative. It is therefore my pleasure to confirm our continued support for the UN Global Compact and our ambition to continuously raise the bar in our work on these important issues. I also want to announce our commitment to sharing this report with stakeholders through Intrum Justitia’s relevant communication channels. This report outlines the current status of our policies and actions, as well as defining the targets for 2017.

Mikael Ericson
CEO and President, Intrum Justitia AB

Intrum Justitia has set ambitious goals with regards to creating and maintaining a safe and fair workplace with equal opportunities for all and with working conditions that exceed minimum standards. All new employees are also carefully instructed on their rights and obligations in terms of vacation, working hours, overtime, parental leave and salary. The Intrum Justitia Group follows applicable national legislation in regards to salary, parental leave, vacation and working hours. All countries shall adhere the Group Human Resources policy and maintain the standard stipulated as minimum requirements. It is mandatory for all employees to complete a training program on our Code of Conduct. The course contains instructions on how to interact with different stakeholders in our daily operations, including clients, end-customers (debtors), business partners and society. We take pride in being an adviser to individuals in difficult situations and being able to offer an alternative
route to finding economic stability. Accordingly, we set high demands for our staff members in terms of ethical
behavior and have been in the forefront of our industry in the development of ethical debt collection.

Intrum Justitia works actively to safeguard the protection of our customers’ personal data. This is regulated internally in the Internal Rules, in our Data Protection Instructions. Intrum Justitia handles large quantities of sensitive personal information and compliance with European and national legislation in terms of data protection is crucial to our business. We have therefore initiated a group-wide project to ensure compliance with the European Data Protection Regulation within all of our operational entities with opportunities for follow-up and control at the group level going forward.

• All employees shall adhere to Intrum Justitia’s Code of Conduct.
• Improved Personal Data Protection by implementing the European Data Protection Regulation within all of our operational entities in order to safeguard customer data and data related to our employees.
• Disseminate our financial education across our markets in order to raise awareness on the importance of a sound household economy and equipping youth for a financially complex reality.
• Identify possible risks regarding human rights in relation to our partner networks.
• Update and clarify instructions in our Code of Conduct Hotline to clearly include human rights matters. Inform and encourage our employees to raise and report human rights matters, e.g. anonymously to our Code of Conduct hotline.

All companies within the Intrum Justitia Group have appointed compliance and data protection officers who report to the Group Compliance Officer. In 2016, all 23 of our compliance and data protection officers were required to participate in an extensive training program carried out by the Group Compliance Officer to ensure that all countries become compliant with regards to our Code of Conduct as well the Group’s internal rules in other compliance-related areas, such as data protection, anti-money laundering and counter terrorism financing.

THIS TRAINING HAS INCLUDED:

1. Training of all local compliance officers in compliance
related areas such as;

• Treating customers fairly (focus on end-customer protection, fair
debt collection practices, handling of client/customer complaints,
safeguarding of customer/client assets, customer/client marketing,
information and documentation etc.);
• Regulatory licenses (permits, approvals and notifications required
by any financial supervisory authority, data protection authority,
company registrar, national bank or the equivalent);
• Internal governance (Internal governance (clear and documented
organizational structure specifying reporting lines, approval
levels/mandates, functions, incl. the management of outsourced
activities);
• Market conduct (ethical aspects such as customer/client
confidentiality and integrity, market abuse, insider trading and
disclosure of major shareholdings, gifts, entertainments, antibribery,
anti-corruption and anti-trust provisions);
• Conflict of interests (shall be broadly interpreted, e.g. in relation
to customers and clients, third parties, external assignments, board
and management decisions);
• Anti-money laundering and counter terrorist financing (know your
customer – “KYC”) procedures, monitor customers and transactions,
investigations and reporting requirements);
• Data protection (compliance with requirements from local
data protection authorities and implementation of robust internal
controls and routines).

2. Training of local compliance officers in compliance
risk analysis with regards to the areas stated above,
and setting annual compliance programs accordingly
(risk-based approach).

3. Implementation of “know your customer”
procedures in order not to take on any clients/
customers with illegal, questionable or doubtful
activities or practices (which are not in accordance
with our values).

4. Implementation of procedures for analyzing
overall risks when changing our business (company
acquisitions, entering new markets, introducing
new products or services).

5. Implementation of routines for business continuity
and crisis management, appointing local- and Group
crisis management teams.

6. Enforcement of governance procedures for
steering our subsidiaries and for the nomination and
appointment of subsidiary Board members and key
functional members.

As a catalyst for a sound economy, Intrum Justitia stands for economic sustainability, and responsible consumption. We firmly believe that a part of respecting human rights is to help our customers achieve the best financial circumstances and a sustainable economic future. We are committed not only to improving businesses’ cash flows throughout Europe, but also to ensuring that a new generation is equipped for a financially street smart existence in a complex financial reality. Accordingly, we have introduced the Spendido initiative, an interactive teaching tool that helps teachers educate their students in household economy and the dangers of over-consumption. To date, Spendido has been applied in Sweden, reaching some 3,000 students. It will now be introduced in additional countries in 2017. We see an immense need for this type of knowledge, as many lack basic financial skills while purchases on credit, installment plans and quick loans are more readily available now than ever before. In Belgium, we are involved in the education of uppersecondary pupils to increase their awareness of how important it is to manage debt in a sound manner. In France, we support the CRESUS organization, which focuses on supporting those who have accrued too much debt. In Germany, we partner with the Caritas organization to help people with too much debt return to a debt-free existence. Here too, we work extensively with education.

Intrum Justitia respects workers’ rights, guaranteeing freedom of association, the right to collective bargaining and we comply with national labor law in all countries of operation. We have no appetite for practices or behaviors that lead to staff being harmed at work.

• To start measuring the composition of management throughout the various operations in terms of diversity factors, such as gender and age.
• To clarify our recruitment process to secure an objective evaluation and equal opportunities with regard to diversity factors such as gender, age, ethnicity, religion and sexuality.
• Update and clarify instructions on harassment and discrimination in the Intrum Justitia’s Human Resource Policy.
• Update our Human Resource Policy with a clear statement on the principle of equal pay for equal work, independent of gender, ethnicity, religion and sexuality.

Intrum Justitia promotes fair and equal working conditions for all and strives to be an employer where all staff members feel welcome, appreciated and fairly treated. All Intrum Justitia managers bear a responsibility for
ensuring that employees are informed of their rights and obligations, as well as securing equal and fair treatment in recruitment, promotion, wage-setting and opportunities for in-company training. In a service-oriented company such as Intrum Justitia, the labor-related risks are primarily associated with fair treatment. Intrum Justitia’s Human Resource Policy applies to all managers in all countries and all operations. Working towards safeguarding compliance with the Human Resource Policy is an important mission. In each country, the local Managing Director and the local Human Resource Manager share the responsibility of implementing, complying with and reporting breaches of, the Group Human Resource Policy to the Group Human Resource Manager.

HIGH SET STANDARDS

Intrum Justitia has high set standards on workers’ rights and guarantees the freedom of association, the right to collective bargaining and the legal minimum wage in our respective countries. We take the safety of our staff members seriously. Threats are an unfortunate part of the industry in which we work. Our staff handles calls from some 50,000 consumers daily across Europe, many in a very difficult and exposed situation. All of our employees working with sensitive cases are trained in handling both the mentally tough aspects of having an impact on the lives of exposed individuals, and are also trained in how to best act as an advisor – thus helping people reach a better economic starting point.

INDIVIDUAL PERFORMANCE
MANAGEMENT ASSESSMENT

Intrum Justitia Sweden has taken a lead in preventing and reducing the number of incidents in relation to threats as well as creating a routine for a safer working environment for staff members. This includes a checklist
for incidents, and carefully planned safety routines to limit the risk of incidents. All employees are entitled to an annual Individual Performance Management Assessment. This is an opportunity for employees to evaluate their immediate manager as well as get feedback on individual performance and set an individual development plan as a result of the immediate manager’s assessment of the employee. We strongly believe that if our Code of Conduct is followed, we will be able to deliver on our promise; to be a catalyst for a sound economy. However, in all companies and organizations there are times when policies and guidelines are not followed as intended. All employees at Intrum Justitia are informed of this shared responsibility to safeguard our integrity by following the Code of Conduct. An employee who has discovered a breach shall turn to their immediate manager. However, to ensure that all employees feel confident and secure in reporting any incident, grievance, bad conditions or unethical behavior, Intrum Justitia maintains a Code of Conduct Hotline. The hotline is a multilingual communication channel through which all employees can anonymously report a breach of the Code of Conduct. The issue will then be forwarded to Intrum Justitia’s Group Compliance Officer who interacts with the Ethical Committee and determines any measures to be taken. The employee is given a unique case number in order to be able to track progress.

EQUAL OPPORTUNITIES

Intrum Justitia is a company that cherishes diversity. Some 4,000 people with backgrounds in 75 different countries come to work for us every day. Women and men are afforded equal opportunities and our objective
when recruiting is to find the most qualified candidate regardless of diversity factors. We conduct an annual employee survey to understand how employees perceive their work. The survey addresses the company’s reputation, local management, employees’ immediate managers, cooperation between teams and countries, day-to-day work procedures, salary benefits and development opportunities. Combined, these driving forces determine the extent of the employee’s satisfaction, motivation and loyalty at work. During 2016, a dedicated action plan was defined, implemented and followed up in all of our countries to continuously enhance satisfaction and motivation in our teams.

Intrum Justitia’s environmental work is stipulated in the Group Environmental Instruction. The instruction
constitutes the minimum baseline for all respective countries in terms in reducing our environmental footprint.
Furthermore, Intrum Justitia meets the demands of all applicable laws in each respective country as well as European Union regulations. The Group Marketing and Communications Director is responsible for the implementation of and compliance to the Environmental Instruction.

• To implement internal awareness-raising and training on our environmental policy for management and employees.
• To start measure the environmental impact and carbon footprint in relation to travel.
• To set targets for waste reduction.
• To set a requirement for business partners to adhere to Intrum Justitia’s environmental policy.

We shall pursue an active role to retain a clean and healthy environment in a way that is maintainable given the nature of Intrum Justitia’s business. We believe this creates a more attractive company for employees, clients, suppliers as well as shareholders, and at the same time as we take responsibility for a sustainable future. The Group operates in the service sector and our operations have a limited environmental impact. In each country, operations comply with relevant national legislation. We work to systematically improve the efficiency in energy consumption and travel, thereby reducing the company’s environmental footprint. The Group’s instruction includes encouraging alternatives to transport and travel, such as the possibilities for telephone and video conferences. There are however legal requirements for our industry that for example makes the reduction of paper consumption difficult. Legislation require that the main form of communications with end-customers must be through physical documents. We further limit our environmental impact by requiring that all vehicles owned by Intrum Justitia do not have emissions exceeding 130 g CO2/km, and we promote the efficient use and recycling of office materials.

BREEAM CERTIFICATION

Intrum Justitia takes pride in its environmental commitments. In 2012, Intrum Justitia’s Head Office and Intrum Justitia Sweden moved in to new offices. The building was then BREEAM certified with four BREEAM stars out of five possible. BREEAM certification is the highest environmental certification available and applicants are evaluated according to the BRE Environmental Assessment Method (BREEAM). The BREEAM certification takes a holistic approach to measuring a buildings’ environmental impact. For example, it takes into consideration the construction itself, the local environment and the proximity to public transportation. Besides the BREEAM certification, Intrum Justitia Sweden and Intrum Justitia AB are also ISO certified.

In accordance with BREEAM Intrum Justitia has:

• Water taps with lower flow for
reduction of water use.

• Better waste sorting and more waste
is now being recycled.

• Stringent demands on entrepreneurs
regarding waste management – some
have had to change their procedures
for accounting for waste in order to
gain a contract.

• Stronger focus on environment
and working environment during
construction, as well as measuring
all energy and water consumption
during construction.

• A run-through of Intrum Justitia’s
travels was conducted prior to
construction, and use as a basis for
the projection.

• An ecologist made a thorough inquiry
and submitted proposals for action
that was taken into consideration and
subsequently followed.

• Run-through of the in-house
climate in order to have an effect
on the building design in regards to
working environment and energy
consumption.

• Low usage of energy and the
possibility of follow-ups give us high
scores on energy efficiency.

• District heating and district cooling
are used for less impact on the
environment.

• The immediate proximity to public
transportation lessens employees’
need for cars.

• Car pools and communal use of
parking space as well

The Group is committed to a high level of compliance with relevant legislation, regulation, industry codes
and standards as well as internal policies and sound corporate governance principles. We have no appetite for
deliberate or purposeful violations of legislative or regulatory requirements and we should always strive for full
compliance with applicable laws and regulations. The Group has no appetite for any corruption or fraud perpetrated by its staff. We take all allegations of suspected breaches of our Code of Conduct very seriously and
expect our clients, suppliers, consultants or their representatives to do the same.

Our anti-bribery commitments are stipulated and regulated in the Intrum Justitia Group’s anti bribery
instructions. The Group Compliance Officer is responsible for the implementation-and follow-up of the anticorruption. These instructions are based on principles derived from the Swedish Anti-Corruption Institute; www.institutetmotmutor.se/en/about-us/.

Furthermore, Intrum Justitia meets the demands of all applicable laws in each respective country, as well
as European Union legislation. The instruction also applies to anyone who represents Intrum Justitia, for
example independent contractors, agencies/consultants.

• Top-quality governance (enhanced, robust implementation and follow-up of Group-internal rules, e.g. Code of Conduct and Anti-Corruption Policy).
• Enhanced model and structure of Group-internal rules and implementation thereof (by appointing a local rule owner, and annual follow-up on implementation of Group-internal rules).
• Follow-up on all employees having attended the Code of Conduct course (including information and questions on our core values and anti-corruption practices).
• Having our suppliers signing our Code of Conduct, which includes anti-corruption requirements.
• Improved compliance in risk management (risk assessment, establishment of a robust compliance function, including local compliance officers handling compliance risks on the local level).
• Mitigation of AML/CTF risks (improved handling of Anti-money laundering and counter terrorism financing).

We strongly believe that if our Code of Conduct is followed, we will be able to deliver on our promise; to be a catalyst for a sound economy. In order to safeguard compliance with this policy, and the anti-bribery instructions, and to guarantee that employees feel comfortable in reporting breaches, Intrum Justitia maintains a hotline for anonymous reporting, or “whistle-blowing”. The hotline is a multilingual communication channel through which all employees can anonymously report a breach of the Code of Conduct. The issue will then be forwarded to Intrum Justitia’s Ethical Committee, which determines the measures to be taken. The employee is given a unique case number to be able to track progress on mitigating actions.

Intrum Justitia has a zero tolerance for for bribery and corruption, our view can be summarized as follows:

Gifts, benefits, reimbursements
and entertainment

No Intrum Justitia employee or anyone representing Intrum Justitia may offer or accept gifts, benefits, reimbursements or entertainment to or from a third party that would constitute a violation of laws or that could affect, or appear to affect, the professional judgement in the performance of the respective work of duties for Intrum Justitia or a third party.

Bribes, kickbacks etc.

No one may, directly or indirectly, demand or accept, offer or give any kind of bribe, kickback or any other unlawful or unethical benefit to employees or other representatives or associates of Intrum Justitia or any third party. Any such offer or proposed arrangement shall be reported immediately to the Group Compliance Officer or the Intrum Justitia Code of Conduct Hotline.

In case of breaches

of the antibribery instructions, the Group Compliance Officer must report said breaches to the CEO and the Board
Directors of Intrum Justitia AB and, at the same time, submit a statement covering the measures taken.