Code of Conduct

Code of Conduct

SEK’s mission is to ensure access to financial solutions for the Swedish export industry on commercial and sustainable terms. As employees, including consultants representing SEK, or Board Members of a state-owned company, we act to ensure we retain the confidence of our operating environment.

SEK’s Code of Conduct guides us in terms of ethical behavior in daily activities within the company and in our interactions with external parties. You are expected to follow the Code of Conduct and any breach will lead to proceedings.

Our core values

Our core values guide our internal interaction as well as our interaction with external parties.

• Solution orientation entails that we strive to attain long-term holistic solutions and to resolve challenges efficiently. Moreover, that we act professionally and are proactive and endeavor to see opportunities.

• Collaboration means we share information and ask colleagues to share their skills. It also means talking to colleagues, listening and talking frankly, helping colleagues to achieve their targets and taking responsibility for the results of the unit.

• Professionalism means we strive for simplicity, efficiency and quality in everything we do. It also entails taking responsibility for the big picture, offering our skills and showing great commitment to SEK’s objective of having satisfied clients and a profitable business.

Regulatory compliance

SEK complies with laws, statutes and other regulations applicable to its operations. In order to facilitate compliance, internal rules and routines are issued, and methodological working papers are established. The company’s applicable internal rules are avaliable on the intranet.

We are all responsible for complying with the applicable laws, ordinances, regulations and internal rules. You must observe not only the express rules as written, but also the spirit and principles underpinning those rules. The respective managers are responsible for providing information regarding the applicable rules and procedures, and for reporting any shortcoming in regulatory compliance.

Combating corruption and bribery

Corruption is defined as the abuse of one’s position for one’s own or someone else’s gain. The payment of bribes is also a form of corruption.

SEK does not tolerate any form of corruption or bribery, including improper offers of payments or backhanders to speed up the processing of a case. You may not, directly or indirectly, offer, promise, give, ask for or accept a bribe.

Hospitality is intrinsic to our operations and must be clearly connected to our mission. As a state-owned company we have a responsibility to ensure that hospitality is not inappropriate. SEK is very restrictive regarding gifts. Receiving or giving av gift can only occur in exceptional cases and to a symbolic value.

Gifts or donations to political parties are not acceptable.

Combating money laundering and terrorism financing

Money laundering is a process aimed at concealing or transforming money or other assets derived from criminal activities. Financing of terrorism consists of providing financial support for terrorism. Money laundering and terrorism financing are gobal problems with major negative consequenses.

As a member of the financial sector, SEK has a responsibility for actively preventing and combating all forms of financial crime. We all carry individual responsibility for being alert to circumstances that could lead to the company’s funds being used to finance terrorism or to SEK being used to launder money.

Avoid conflicts of interest

A conflict of interest arises when two or more parties have opposing or potentially opposing interests.

All relationships, services, activities and transactions can give rise to conflicts of interest. You are not permitted to administer or take decisions on behalf of the company on matters in which you, or any of your close family or friends, may have a personal interest. Managers are responsible for identifying, analyzing, taking action and documenting conflicts of interest within their own area of responsibility, for example achieving adequate separation of assignments.

Any conflict of interest must be separately identified prior to the implementation of a reorganization, a decision on a new product or line of business, the acceptance of a new business assignment, the engagement of a new supplier, the procurement of services other than audit assignments by the company from the company’s auditor, the recruitment of new employees or the engagement of consultants, and otherwise whenever the need arises.

You are not permitted to conduct business or hold other assignments in addition to your employment with SEK without special permission from your manager and your manager’s immediate superior.

Never use inside information

Inside information is information that is not public and which, if disclosed, may materially affect the value of securities.

You are not permitted, directly or through nominees, to use inside information or influence other parties to use such information. Nor is it permitted to circumvent these rules by the use of derivatives or a combination of various transferrable securities.
All employees are subject to rules prohibiting short-term trading and on compliance with reporting requirements.

Communicate with respect and good judgement

External communication is an important part of SEK’s business giving us valuable views and the opportunity to reach out with our messages. SEK is positive to employees communicating through different channels including social media, and expects them to act carefully and responsibly to protect SEK’s and their own image and reputation. Always maintain a professional tone with respect for the SEK brand. The company’s own internal information and information about SEK’s customers is always confidential. Professional secrecy may only be breached with the customer’s agreement or if SEK is legally obliged to disclose such information. Professional secrecy also applies after termination of employment with or assignment for SEK.

Treat others with respect

SEK respects human rights. This means that our operations do not promote any such violations and that we act to prevent the occurrence of such violations.

SEK aims toward a work environment that promotes good health and diversity and to create the preconditions necessary for everyone to, both wish to and be able to, contribute their skills. Therefore, everyone is to be treated with respect and everyone has the right to a safe work environment. SEK accepts no form of discrimination, bullying or harassment. Nor are any reprisals permitted against any person who has reported or participated in an investigation into the above.

You have the right to establish and be members, or not be members, of labor unions and to negotiate collectively.

Environmental responsibility

SEK promotes reduced climate and environmental impact.

We are all accountable for acting in a responsible manner to minimize the company’s risk of negative climate and environmental impact. In our professional roles, we take the initiative and challenge ourselves to contribute to a fossil-free Sweden and reduced global environmental impact.

Noting improprieties

If you experience or if circumstances come to your attention that involve or could lead to a breach of the law, unethical behavior, infringement or suspected breach of the Code of Conduct – you are obligated to report these circumstances. A report can be submitted to the Compliance function, to your direct superior or to HR, or even be submitted anonymously through our “SpeakUp system,” which is available on the intranet and on the website.

SEK is obliged to process your report. Reports of suspected rule violations or breaches of the Code of Conduct will be treated confidentially by the company. SEK does not accept discrimination against or punishment of any individual who reports such information.

When in doubt

When in doubt or when you would like advice, please turn to your immediate manager, HR or the Compliance function.

This is an English translation of the Swedish original. In the case of discrepancies between the English translation and the Swedish original or in the event of a dispute, the Swedish original takes precedence.

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