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Code of Conduct

SEK’s mission is to conduct financial operations in Sweden and internationally on commercial terms, and within the scope of the objective set out in the Articles of Association, with the aim of promoting operations with Swedish interests that pertain directly or indirectly to the Swedish export industry, including Swedish infrastructure, and otherwise strengthen the internationalization and competitiveness of Sweden’s business sector.

As an employee or consultant representing SEK and as a Board Member, you are expected to follow SEK’s Code of Conduct to help maintain the confidence of our operating environment. The Code of Conduct guides us in terms of ethical behavior in daily activities and in our interactions with external parties. Any breach of the Code of Conduct could lead to proceedings.

Our core values

At SEK, we act professionally, simplify difficulties and build sustainable relationships.

SEK wants to be perceived as proactive, agile and committed. Our actions are imbued by core values and guide us in how we interact with each other, clients and customers, external business partners, job applicants and others.

Regulatory compliance

SEK complies with laws, statutes and other regulations applicable to its operations. To make things simpler, we issue internal rules, procedures and methodological working papers. You will find all of the internal rules 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. You have a duty of loyalty to SEK, which means you are not permitted to act in a way that could cause harm for SEK. The respective managers are responsible for providing information regarding the applicable rules and procedures, and for reporting any shortcoming in regulatory compliance.

At SEK, we act professionally, simplify difficulties and build sustainable relationships.

Combating bribery and corruption

Corruption encompasses the giving and acceptance of bribes, breach of trust and the abuse of one’s position for one’s own or someone else’s gain.

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. Your responsibility is personal and you may not, directly or indirectly, offer, promise, give, ask for or accept a bribe.

Act restrictively when giving gifts and hospitality

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.

Combat money laundering and terrorism financing

Money laundering aims to conceal or transform money or other assets derived from criminal activities. Financing of terrorism consists of providing financial support for terrorism.

SEK has a responsibility to apply risk mitigation methods to thereby actively prevent and combat money laundering and financing of terrorism. You must remain 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.

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.

You are personally responsible for informing your manager if you believe any conflict of interest exists. When the need arises, managers are responsible for identifying, analyzing, taking action and documenting conflicts of interest and for ensuring adequate separation of assignments. Events that could entail a conflict of interest arise in the case of a reorganization, a decision on a new product or the acceptance of a new business assignment, the recruitment or engagement of suppliers or consultants, and the procurement of services other than audit assignments from the company’s auditor.

Respect rules on confidentiality

Confidentiality applies by law and means that information about SEK’s operations may not be unduly disseminated to other parties. The company’s own internal information and information about SEK’s customers is always confidential. Confidentiality may only be breached with the customer’s written agreement or if SEK is legally obliged to disclose such information. Confidentiality also applies after termination of employment with or assignment for SEK.

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 transferable securities. Separate rules prohibiting short-term trading and on compliance with reporting requirements could apply to you.

Treat information and resources with care

Information covers everything from individual employee knowledge to information that is handled by IT systems.

The company’s information is a valuable asset that needs to be protected in line with its conservation value, risk and legal requirements. This applies for all information regardless of its format or where it has been used.

In the processing of personal data, you are expected to safeguard personal integrity through responsible management of personal data.

IT resources, both physical and digital, should be used for work-related purposes and treated with care.

Treat others with respect

We respect human rights and do not participate, directly or indirectly, in any violations of such rights.

You should contribute to a safe and inclusive work environment that promotes good health and diversity. 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 be a member, or not be a member, of labor unions, to form labor unions and to negotiate collectively.

Communicate with respect and good judgment

All employees act as representatives for SEK and must communicate responsibly with external parties and in a manner that is consistent with our values. Only those individuals who are most suitable should act as spokespersons with the media following contact with the Press Officer.

Social media is a natural form of communication but keep in mind that it should not be used in a manner that could harm SEK. Bear in mind that you not only impact your own image but also that of SEK. Therefore, always maintain a professional tone with respect.

Promote reduced climate and environmental impact

In your daily work, you are expected to act responsibly to reduce the risk of a negative impact on the climate and the environment for the company, for example, when purchasing on SEK’s behalf or traveling for business, by choosing products and services that entail a reduced climate impact.

Note 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 this Code of Conduct — you are urged 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.

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.

Advice and support

If you have any questions or need advice and support in questionable situations, please turn to your immediate manager, HR or the Compliance function.