Sparebanken Vest - Principles for Corporate Social Responsibility

Version 2.0 – February 2019

Principles for Corporate Social

Responsibility

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Table of contents
Table of contents 2
1. Background, purpose and scope 5
2. Our history and role 5
3. Corporate social responsibility in our business 6
4. Our role in society 7
5. Our processes 8
5.1 Organisation, capacity and expertise 8
5.2 The working environment and appointments 8
5.3 Gender equality 9
5.4 Ethics 10
5.5 Transparency and reporting 10
5.6 The environment 11
5.7 Ownership structure, taxation and attitude to corruption 12
5.8 Distribution of donations 12
5.9 Follow-up 13
6. Procurements and requirements of suppliers 15
6.1 Our procurement policy 15
6.2 Our requirements of suppliers and subcontractors 16
6.2.1 Human rights 16
6.2.2 Working conditions 16
6.2.3 Environmental management 17
6.2.4 Ethical practices 18
6.2.5 Reporting 18
6.3 Sanctions in the event of a breach of Sparebanken Vest’s procurement policy
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7. Our investments and corporate governance 19
7.1 Sustainable investments 19
7.2 Assessments of ethics, the environment, corporate social responsibility and
sustainability in connection with investments 20
7.3 Investments in the liquidity portfolio 20
7.4 Investments in the venture portfolio 21

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 7.5 About companies where we take over ownership positions through
restructuring 21
7.6 Sparebanken Vest as a distributor of securities funds 21
7.6.1 Requirements of fund suppliers 22
7.6.2 Selection of fund suppliers 22
7.6.3 Follow-up of fund suppliers and fund selection 25
7.6.4 Presentation of ethical profile and return 26
7.6.5 General description of system and follow-up requirements 26
8. Assessments related to individual industries and general criteria for
investment/financing 27
8.1 Assessments of ethics, the environment, corporate social responsibility and
sustainability in connection with granting credit 28
8.2 The assessment process for corporate customers 29
8.3 Industry-specific corporate social responsibility risks and controversial
activities 30
8.4 Assessment tools 30
8.5 Follow-up of customers 30
9. Assessments related to individual industries and general criteria for
investment/financing 32
9.1 General requirements 33
9.1.1 Corporate governance, money laundering and corruption 33
9.1.2 Labour rights 33
9.1.3 Equality and child labour 34
9.1.4 Exploitation of crises and vulnerable individuals 34
9.1.5 Water protection 34
9.1.6 Protecting natural diversity 35
9.1.7 Genetically modified organisms 35
9.1.8 Environmental toxins 35
9.1.9 Increased proportion of certified debt and green bonds 36
9.1.10 Reporting 36
9.2 Industry assessments 36
9.2.1 Controversial weapons production, pornography and the tobacco industry
36
9.2.2 Mining and metal extraction 37
9.2.3 Coal-fired power, coal extraction and other energy production 37
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9.2.4 Shipping 38
9.2.5 Sustainable agriculture and forestry 39
9.2.6 Fisheries 40
9.2.7 The aquaculture industry 41
9.2.8 A sustainable financial industry 41
9.2.9 Property companies and property development 41
9.2.10 Transport companies and aviation 42
9.2.11 Energy production and clean energy 42

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 1. Background, purpose and scope
‘Everything we do, we do to make life in Western Norway even better.’

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 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.

2. Our history and role

Sparebanken Vest was created by and for the people of Western Norway in 1823. Our heart
beats for Western Norway, for the people who live there and the work they do. Our strong ties to
the region are the driving force behind our strong involvement in society, an involvement that
goes beyond our social mission as a regional bank. We are currently the third biggest savings
bank in Norway, with more than 250,000 retail and corporate customers.

Throughout our history, we have endeavoured to ensure that the local community has the best
conditions for growth and that it develops in a sustainable way. We will continue with these
efforts, which means taking responsibility for both the local and global environment.

This work involves many different roles and themes. Among other things, we will take good care
of our employees and their working environment, we will have thorough procedures to prevent
corruption and money laundering, and we will make active efforts to reduce both our direct and
indirect environmental footprint. This document describes how Sparebanken Vest will make use
of its opportunities to influence society in its role as:
● Savings bank and employer
● An active part of society, a donor and sponsor
● An investor and distributor of securities funds
● A granter of credit and source of financing

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 3. Corporate social responsibility in our
business
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
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.

Reporting is a key part of following up goal attainment and transparency about our work on
corporate social responsibility. Sparebanken Vest’s ambition is to make relevant data available,
to introduce good indicators and report on them in Eco-Lighthouse reporting and our annual
report.

In this document, we will use various terms relating to the exercise of corporate social
responsibility. Two key terms are sustainability and ESG:

Sustainable development is defined in the Brundtland Report from 1987 as development that
meets the needs of the present generation without reducing the possibilities coming generations
have to meet their needs. The concept is based on the assumption that, in order to achieve
sustainability, due attention must be given to economic, societal and environmental
considerations in order to ensure viable and just societies in the longer term.

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ESG is an international abbreviation for Environmental, Social and Governance factors. These
factors are used to assess companies based on other criteria than just their financial
performance.

4. Our role in society

Sparebanken Vest is engaged in banking, investment, insurance and financing operations in the
counties of Hordaland, Rogaland and Sogn og Fjordane. In the following chapter, we describe
how we work on corporate social responsibility in our internal business processes and in relation
to our customers, and which projects and businesses we finance by granting credit and making
investments. Our different roles give us different opportunities to demonstrate corporate social
responsibility, which means that it is important to distinguish between the different roles and the
tools available to us. Our fundamental principles, values and attitudes form the basis for all our
assessments, but the tools we can use to exercise influence vary. This chapter describes the
different roles and how we work on corporate social responsibility:

● Internal processes and requirements of our own processes, employees and suppliers

As an organisation, we influence our customers, employees, the working environment,

climate and local environment through our day-to-day operations, for example through
our employment processes, follow-up of employees and managers, choice of suppliers
and procurements, property management and transport. Every year, the bank
distributes donations, which is made possible by profitable banking operations. Our
allocation of these funds is also part of these internal processes.

● Investments for the bank’s own account and investment products that are made
available to our customers

As an investor of assets and owner of a share portfolio, we have a responsibility to

ensure that our investments contribute to sustainable development both in Western
Norway and globally. With respect to the investment products we offer our customers, it
is important to us that they trust us to give them the best advice, and we highlight the
importance of the choices they make being sustainable in the long term. The products
we make available to our customers must have a socially responsible profile and be
managed in accordance with the UN Principles for Responsible Investment, to ensure
they do not invest in certain industries and individual companies that have a particularly
negative effect on local and global communities.

● 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.

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 5. Our processes
Internal processes in Sparebanken Vest shall be of a high ethical standard and shall ensure that
the bank contributes to sustainable development of the business, the economy, society and the
climate/environment.

5.1 Organisation, capacity and expertise

Sparebanken Vest shall have an organisation with the capacity and expertise required to make
and implement socially responsible decisions at all levels.

Ethics training is important in order to strengthen the bank’s expertise and raise awareness of
ethical risks. Everyone who is directly involved in the granting of loans or credit to businesses or
in investment decisions must be familiar with our principles for socially responsible financing.
The principles govern what we grant loans for and invest in, and how the bank should act and
influence joint investment decisions in companies where we do not hold a dominant position.
Ethics and good advisory practices are also a key part of the authorisation scheme for financial
advisers.

The bank has good whistleblowing procedures in place for matters that warrant criticism and any
breaches of the ethical guidelines. Employees have easy access to the procedures for how
whistleblowing shall take place through the bank’s HSE manual and the bank’s intranet. Such
matters must be reported to the employee’s immediate superior, using the dedicated non-
conformity form on the intranet, which goes to the Director of Organisation and Development, or
to the chief safety delegate or the Chief Compliance Officer. In addition to its internal
whistleblowing procedures, an agreement has been entered into with an external third party that
can receive and consider notifications. The purpose is to ensure impartiality. Notifications of
breaches are treated confidentially, and employees are protected against reprisals etc. as a
result of such whistleblowing. In parallel with whistleblowing about matters that warrant criticism,
the Organisation and Development department also assists in cases concerning other conflicts
and issues between employees.

5.2 The working environment and appointments

Sparebanken Vest aims to be an attractive workplace, and we see our employees as important
resources who enable us to provide quality services to our customers. We shall treat our
customers with trust and respect and give professional and ethically justifiable advice based on
the necessary qualifications and knowledge of the customer’s situation.

All of our employees have freedom of association, and the bank engages in collective
bargaining in accordance with the agreements with the different trade unions.

Sparebanken Vest shall endeavour to prevent discrimination in accordance with applicable

regulations. This will be done for example in connection with recruitment, pay and working
conditions and development opportunities.

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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).

It is very important for the bank to have competent employees, and the bank has various training
programmes in place for its employees. Despite the major changes that have been
implemented, our annual organisational survey has a very high response rate (85%) and shows
a high degree of ownership, commitment and satisfaction with Sparebanken Vest as an
employer.

5.3 Gender equality

Sparebanken Vest has zero tolerance of all forms of discrimination in employment processes
and in the workplace. This includes verbal, physical and sexual harassment.

Sparebanken Vest makes determined efforts to promote gender equality. Men and women shall
have equal opportunities for development, pay and a career in the bank. In 2017, 52% of the
bank’s total workforce, 57% of the corporate management team, 40% of other management staff
and 40% of board members were women. In addition to the gender balance, we also keep track
of and report on the pay distribution between men and women in our annual report. In 2017,
women on the top two pay levels had slightly higher pay than men, while women in the lowest
pay grades had slightly lower pay than men on average.

Sparebanken Vest’s principle of gender equality entails that that we maintain a focus on gender
equality in all our processes, including the employment and application process, and pay and
career processes. The business currently has a separate body that deals with appointments and
pay. It comprises employer representatives and employee representatives. This body is tasked
with safeguarding the principle of gender equality in these matters.

We are making active efforts to develop and retain more women at all levels of the bank’s
management. One of the measures taken to ensure further development is a dedicated
management development programme for female managers in the bank. We have also
developed separate guidelines for our remuneration systems, and paid parental leave is
included in the basis for calculating bonus payments. We take steps to enable male employees
to take parental leave beyond the stipulated father’s quota. We endeavour to promote gender
equality through active measures relating to recruitment, pay, promotion processes,
development opportunities and protection against harassment. A gender equality group has
been appointed and a gender equality policy is being drafted that will be implemented and
published during autumn 2018. Our Code of Ethics for employees shall ensure that none of our
customers are subject to discrimination based on gender.

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 5.4 Ethics
Trust is essential to our business. We are dependent on customers, public authorities and
society in general seeing Sparebanken Vest as a company with high ethical standards. All of
Sparebanken Vest’s employees shall have high ethical standards, and each employee shall
inspire confidence, be honest and fair and act in accordance with the norms, rules and laws that
apply in society. All employees are subject to a duty of secrecy, which also applies in relation to
colleagues.

Respect for our customers and for our social mission is a key element of our ethical philosophy.
We shall not take advantage of crises or vulnerable individuals for excessive financial gain. We
have thorough risk assessment procedures and systems that we adhere to before offering
customers financial products and services, and we also endeavour to ensure that our customers
understand the terms and conditions and risk associated with these products. We do not offer
credit to customers who are clearly unable to service the loan or who demonstrate undesirable
ethical conduct.

Sparebanken Vest has adopted a dedicated Code of Ethics for all employees of the bank. This
document forms part of our employment contract. The code is also discussed with all new
employees as part of their introduction to the bank’s operations. All authorised and approved
advisers also undergo an annual ethics interview as part of the annual competence updating
process. We continuously endeavour to further improve our ethical guidelines and adapt them to
the times we live in.

5.5 Transparency and reporting

The bank shall be open and honest about its business and services, and it will publish objective,
honest and relevant information about the bank’s processes.

The annual report is Sparebanken Vest's most important document for reporting on our
business. Cemasys prepares annual environmental accounts for the bank, and the result is
published in an environmental report. We have previously published a separate corporate social
responsibility report in addition to the annual report, but we are now in the process of
implementing changes in our reporting of corporate social responsibility and sustainability
issues. The goal is to better integrate the reporting on corporate social responsibility issues in
the annual report – in the same way as corporate social responsibility is integrated in the bank’s
business processes. We will define the most important topics relating to the bank’s corporate
social responsibility strategy, define quantifiable targets and ensure compliance with relevant
international standards for measurement and follow-up.

Sparebanken Vest has endorsed the UN Global Compact, and we report annually on our work
and commitments in relation to human rights, the working environment, the environment and
anti-corruption. This report is published and made publicly available.

In 2018, an external party will conduct an ESG analysis of Sparebanken Vest on assignment
from us, and we will publish our ESG score when the report is ready.

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Sustainability and the environment are a focus area for the bank going forward, and work
commenced in 2018 on developing an overall sustainability strategy for Sparebanken Vest.

5.6 The environment

Through the UN Global Compact initiative, Sparebanken Vest has undertaken to apply a
precautionary approach in relation to environmental challenges, to take the initiative to promote
increased environmental awareness and to encourage the development and use of
environmentally friendly technology. In the Paris Agreement in 2015, the world’s leaders agreed
that global warming must be kept well below 2 degrees – and we will aim for 1.5 degrees – to be
able to prevent dangerous climate change. This means that we will have to change and adapt in
many areas of society. Sparebanken Vest takes its commitment to meeting the Paris Agreement
climate goals seriously.

Our goal is therefore to reduce our own climate footprint by more than 40% (132 tonnes CO2) by
2030. In connection with this work, we have decided that our business will be climate neutral,
with effect from autumn 2018. As of 1 November 2018, we meet these obligations by complying
with the UN’s requirements of climate neutral enterprises, defined in the initiative Climate
Neutral Now.

We fulfil the climate neutrality requirements by meeting the following criteria:

• Every year, we publish approved climate accounts for our business, prepared by
CEMAsys.com AS.
• We have evaluated our consumption, and set goals for reducing emissions.
• We offset residual emissions by purchasing approved carbon credits.

Through the annual energy and climate accounts, we are able to monitor our own greenhouse
gas emissions, both directly as a result of transport, and indirectly as a result of purchased
energy. The accounts show a considerable reduction in emissions from transport, electricity and
waste over the past two years, which is the result of targeted work and measures taking effect
over time. We constantly endeavour to make further reductions.

Sparebanken Vest’s goal is to be climate neutral, also with respect to our investments, by 2020.
We also encourage our customers, suppliers and sponsorships to be climate neutral, and to
publish their emission data and climate measures. We are working on further measures to
reduce emissions in 2018-2019.

The bank’s head office in Jonsvoll was Eco-Lighthouse certified in September 2017, and a plan
is in place to certify all the bank’s local branch offices. The Eco-Lighthouse certification is an
external verification of Sparebanken Vest that confirms that the bank meets a set of criteria and
implements measures to achieve more environmentally friendly operations and a good working
environment.

Jonsvoll is a modern building in a central location in Bergen city centre, that is easy to get to
using public transport. When choosing solutions for the building, it was emphasised that the
architecture should be attuned to the city district and the local environs, and stringent energy
and environmental requirements were applied. All heating is supplied by district heating
radiators and water-borne underfloor heating. Cooling is ventilation-based using seawater as the
coolant. The building is connected to the city’s underground waste disposal network and waste
is handled in large recycling stations in all parts of the building. One hundred per cent of

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Sparebanken Vest’s electricity consumption comes from renewable sources, and we make sure
that the supply can be traced to specific power stations through certificates.

We want to give our customers the opportunity to make conscious choices for the climate and
the environment by offering them savings products that have a sustainable profile, through our
green funds for retail customers.

5.7 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
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.

5.8 Distribution of donations

Sparebanken Vest’s historical roots in the savings bank system and its ownership structure
mean that it has two distinctly different, but closely linked, objectives. The first is to engage in
commercial activities through banking operations, the purpose of which is to achieve financial
results. The other is the goal of contributing to the public benefit through the allocation of the
bank’s profit. A stronger financial result increases the potential for donations, at the same time

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as good selection and management of projects for the public benefit can strengthen our
reputation and position.

Our capacity for engagement is our most important differentiator. We are engaged in different
arenas, from contributions to local festivals to measures that support education and upbringing.
We also wish to contribute to economic growth in Western Norway by creating arenas and
meeting places across industries and by facilitating entrepreneurship and necessary
restructuring.

We have defined a set of criteria and a process for allocating donations. Everyone who wants to
can apply for donations via our website. Decisions about donations are made in consultation
between the head office and local branch offices, and they are communicated continuously via
our digital channels and at our ‘Hjertebank’ events. We are concerned with ensuring that the
projects that receive grants underpin the recipient’s sustainability and ethics efforts.

5.9 Follow-up
The documentation of compliance with requirements concerning corporate social responsibility,
ethics, money laundering rules, transparency, corporate governance and the implementation of
sustainability criteria in our own processes and credit and investment decisions shall, as a
minimum, be reviewed and audited annually. The audit also includes reviewing and following up
necessary improvement measures relating to processes and procedures.

5. 10 Consumer rights
The customer is the focus of everything we do in the bank. Our prime interest is attending to the
customers’ needs, and our procedures and in-house training are developed with that in mind.

5.10.1 Dealing with complaints

The bank has procedures in place for dealing with complaints from customers. The form for filing
complaints and claims for reimbursement is available on our website.

This procedure identifies a complaint as an expression of dissatisfaction with the bank linked to
an action or omission on the part of the bank or the bank’s employees or officers in connection
with their work or office for the bank, and that is not resolved there and then in consultation with
the complainant. It is not considered a complaint if the customer’s objective is to negotiate
terms. Claims relating to payment transactions are considered complaints if the customer does
not accept that their claim for reimbursement has been rejected. The bank is also affiliated with
the Norwegian Financial Services Complaints Board, which serves as an alternative to the
ordinary courts. In all complaints where the bank does not find in favour of the customer, the
customer is informed of their right to file a complaint with the Financial Services Complaints
Board. As a rule, Sparebanken Vest complies with decisions made by the Financial Services

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Complaints Board. Complaints received by the bank are reported to our Compliance
department, which reports to the Financial Supervisory Authority of Norway once a year. We
endeavour to constantly improve our procedures so that we can reduce the number of
complaints from customers to a minimum.

5.10.2 Safeguarding customers against payment

problems
The bank is committed to ensuring that consumers do not end up in a high-debt situation,
through our credit policy which regulates how much a customer can borrow from the bank.

If, for various reasons, the customer nonetheless ends up with payment problems/a high-debt
situation, we initiate a dialogue with the customer concerned and try to solve the problem
together with the customer. This particularly applies to customers with mortgages in our bank.

The bank obtains information about payment remarks for customers who wish to take out a new
loan. Bisnode collects the information, and the customer is informed about the use of a third
party.

5.10.3 Privacy protection

The bank respects customers’ personal data, and thorough requirements apply to dealing with
privacy protection in accordance with the GDPR.
Our procedures for processing privacy protection orders aim to ensure that Sparebanken Vest
can expediently receive privacy protection orders from customers and other registered parties,
and can safeguard security when disclosing personal data for orders that have been processed.
All employees must take a training programme on the GDPR in connection with its introduction.

5.10.4 Fraud and theft

The bank’s undesirable behaviour policy sets out the procedures and division of responsibility in
connection with fraud and theft. This policy covers criminal acts, and is handled expediently by
an employee on our fraud team, who is dedicated to handling such cases. The policy covers
fraud attempts against the bank and, if relevant, against customers.

5.10.5 Safeguarding the customer’s interests

The bank’s training programme for advisers includes strict guidelines to prevent customers
being exploited for the bank's financial gain. All our advisers therefore have to be authorised
financial analysts through autorisasjonsordningen.no. Advisers shall provide clear information
about risk and product charges, shall not recommend products that customers do not need and
refrain from offering products that will involve high debt.

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Advisers must cover these issues, which are then registered and saved in our internal RPM
systems, during all meetings with customers concerning saving. The bank also performs random
checks to ensure compliance in this area.
Advisers are also trained during the authorisation process to avoid conflicts of interest between
the bank and the customer. Advisers must be attentive to this during meetings with customers,
particularly with respect to alternative forms of saving.

5.11 Accessibility and transparency for consumers

It is important for us to be a bank that is available to its customers wherever they live and how
ever they want to reach us, within the market area in accordance with the bank's overall credit
strategy. Sparebanken Vest has decided to retain offices outside the big cities, and we have 33
branch offices across Western Norway. We focus on offering simple digital services for
everyone through the online and mobile banking solutions, but we also offer traditional banking
services through the Telephone Bank and ‘brevgiro’ (giros sent in special pre-addressed
envelopes). Customers can decide how they wish to contact us. Accessibility and having a
personal relationship with the customer are important to us, and we make great efforts to meet
customers’ needs in this area.
Our head office is based on universal design principles to ensure access for the disabled We
have begun the process of renewing the whole network of branch offices in line with up-to-date
building regulations that cover universal design to ensure they are accessible to everyone.
Our digital services are designed with simplicity, user friendliness and adaptation to different
customer needs in mind. Universal design is also important in the development of our digital
channels, which we address by involving user groups who represent the full spectrum of the
population. This is a very important part of our development work.
The bank has full transparency in relation to costs and charges, and customers are informed in
advance of any changes. Customers must always be informed in the event of banking services
accruing additional costs.
Opening an account in Sparebanken Vest is free, and our banking services are not linked to the
terms for buying other products or services.

6. Procurements and requirements of

suppliers
By Norwegian standards, Sparebanken Vest has a high annual volume of procurements. We are
our suppliers’ customers and therefore have the power to influence how our suppliers take
responsibility for sustainable value creation.

6.1 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:

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 ● 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.

6.2 Our requirements of suppliers and subcontractors

We make requirements of our suppliers and subcontractors concerning human rights, working
conditions, environmental management, ethical practices and reporting. These requirements are
specified in a self-declaration that has to be signed by all suppliers.

6.2.1 Human rights

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)

6.2.2 Working conditions

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

16
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.

6.2.3 Environmental management

Sparebanken Vest focuses on ensuring the lowest possible environmental load in connection
with procurement processes. Our suppliers must at all times meet or exceed official
environmental requirements, and ensure that they have energy-efficient and raw material-
efficient production methods. In connection with the Eco-Lighthouse certification, we have used
the ‘Mapping of suppliers’ tool and have integrated it into our procurement system. Mapping is
carried out continuously. It gives us an overview of suppliers who are certified pursuant to the
Eco-Lighthouse criteria, ISO-14001, EMAS, the Nordic Ecolabel or similar. We will also
endeavour to persuade our regular and most important suppliers to seek environmental
certification.

We require our suppliers to map all potential environmental risks associated with their business,
and to ensure that their operations are in compliance with local and national rules and laws for
environmental management. The suppliers must have adopted an environmental policy that is
adapted to their industry, and that contains clear goals for environmental management and for
addressing the most important challenges associated with these goals.

Suppliers must also work proactively to reduce any negative effect their business has on the
environment, with particular focus on reduced consumption, waste recycling and the introduction
and use of environmentally friendly technology in production processes, and they must be able
to document steady improvement through reporting and follow-up systems.

Goods and services supplied to Sparebanken Vest must be produced in a manner that
preserves biodiversity and that ensures that land areas and natural resources are managed in
the most sustainable manner possible. When evaluating tenders in connection with invitations to
tender, we will give strong emphasis to whether suppliers are environmentally certified.

The bank requires that its suppliers do not offer or supply products made from tropical timber.
Supplies of copy paper, envelopes and other printed material must satisfy the environmental
labelling requirements of the Nordic Ecolabel or the EU Ecolabel. ICT equipment delivered to
the bank must not contain chemicals that are harmful to health or the environment, and it must
have low energy consumption.

When purchasing cars, Sparebanken Vest has the following requirements:

● Purchases and leasing of new passenger cars, vehicle group M1: CO2 emissions must
not exceed 130 g/km
● Purchases and leasing of new delivery vans, vehicle group N1: CO2 emissions must not
exceed 210 g/km
● When purchasing and leasing new vehicles for business use, the vehicle with the lowest
possible CO2 emissions will be chosen. This could be hybrid vehicles, cars with CO2
emissions lower than or equal to 120 g/km or other environmentally friendly alternatives
on the market.

17
 6.2.4 Ethical practices
Sparebanken Vest requires its suppliers to ensure that their business is run in compliance with
all relevant laws and regulations for ethical business practices, and to work proactively to
monitor and reduce the risk of unethical business practices. Our requirements for ethical
business practices include the following:
● Personal and confidential information must be stored in a secure manner and not be
disclosed without permission or in breach of applicable legislation on data protection
and protection of privacy.
● Gifts or other advantages that can be perceived as bribes must not be offered to our
employees, and such practices are also unacceptable in relation to our suppliers’ own
employees.
● Suppliers must distance themselves from all forms of money laundering, and they must
take all necessary precautions to prevent others from using financial transactions with
them for money-laundering purposes.
● The suppliers’ businesses must at all times operate in accordance with applicable
competition law and they must not participate in unlawful price collusion.
● The suppliers must have a whistleblowing system whereby employees can report
concerns without fear of reprisals.

6.2.5 Reporting
We require suppliers to report and document the measures they have taken to ensure that
corporate social responsibility requirements are complied with, and that they contribute to
transparency and dialogue in the event of breaches or suspected breaches of the rules and
immediately implement necessary remedial measures. If a supplier suspects a breach of the
rules further down the value chain, this must be reported immediately. Moreover, it must also be
possible to carry out audits to ensure that suppliers’ corporate social responsibility is followed up
and complied with, and that suppliers take steps to facilitate this as far as possible.

6.3 Sanctions in the event of a breach of Sparebanken

Vest’s procurement policy
Sparebanken Vest can demand access to and audit suppliers’ procedures. Breach of the
provisions concerning corporate social responsibility is deemed to constitute breach of contract
and can form grounds for cancellation of the contract.

If the suppliers fail to comply with one or more of the requirements in this document, we are
entitled to request that remedial measures be taken. If the breach is deemed to be a material
breach, this will be seen as breach of contract, and the bank will reconsider the terms and
conditions of the contract, which can result in termination of the contractual relationship. When
assessing what constitutes material breach of contract, emphasis will be placed on the gravity of
the breach and on whether it leads to a loss of reputation or risk of loss of reputation for
Sparebanken Vest.

18
 7. Our investments and corporate governance
As an investor and distributor of securities funds to our customers, we have an opportunity to
influence which companies receive financing and how the ownership is exercised.

7.1 Sustainable investments

We wish to contribute to ensuring that our own and our customers’ investments that are made
through our channels are with companies that do more than just meeting the minimum
requirements for sustainability, the environment and responsibility. To achieve this, we must set
stringent requirements for our own investments, and we must highlight the advantages for our
customers of actively seeking products that do more than just meeting these minimum
requirements. We will use our strong regional position and distribution strength to exert influence
through the channels available to us.

Sparebanken Vest has undertaken to do what it can to support the UN Sustainable

Development Goals through the UN Global Compact. For us, this means that we actively and
continuously endeavour to contribute to more sustainable development through our own actions
and choices in connection with our operations, that we take steps to enable our customers to
choose between a set of funds and fund products that are based on principles for sustainable
investments, and that our own investments and financing activities contribute to sustainable
development both globally and locally. Companies must be able to document that they comply
with the rules for fund management.

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.

UN Principles for Responsible Investment

1. We will incorporate ESG issues in our investment analyses and decision-making
processes.
2. We will be active owners and incorporate ESG issues in how we exercise ownership.
3. We will endeavour to ensure that the companies we invest in report satisfactorily on
ESG issues.
4. We will promote acceptance and implementation of the principles in the financial
market.
5. We will cooperate in order to ensure effective implementation of the principles.

19
 6. We will report on our activities and the progress of the work of implementing the
principles.

7.2 Assessments of ethics, the environment, corporate

social responsibility and sustainability in connection
with investments
Considerations of ethics, the environment, corporate social responsibility and sustainability shall
be integral to all investment and asset management carried out on behalf of Sparebanken Vest
or the bank’s customers through our distribution channels.

In our role as investor, we make choices relating to which companies and structures we invest
in. Sparebanken Vest makes investments through its liquidity portfolio and venture portfolio. The
liquidity portfolio’s investment possibilities and limits are defined by the bank in a separate
investment mandate. Through our venture portfolio, we invest in start-up companies in Western
Norway, with the aim of supporting future value creation in our region.

In our role as a distributor of securities funds to our customers, we stipulate clear requirements
for suppliers’ management and follow-up of the investments in the securities funds. As a
distributor and adviser to our customers, we can also make responsible asset management and
corporate governance in the funds an assessment criterion for our customers when choosing
which securities funds to purchase or sell units in and when making changes to savings
agreements.

7.3 Investments in the liquidity portfolio

Sparebanken Vest has a substantial portfolio of liquid investments at all times. That is one of the
requirements we are subject to as a bank. These investments are managed through a
management mandate, which sets out clear guidelines as regards both risk and corporate social
responsibility principles. Investments are exclusively made in debt securities issued by states,
banks, financial institutions, Norwegian companies, Norwegian and Swedish municipalities,
Norwegian county authorities and companies with state/municipal/county authority guarantees,
and they are designated as certificates and bonds in the interim and annual financial
statements.

Investments in the liquidity portfolio must be in accordance with Sparebanken Vest’s general
and industry-specific requirements, and the fund manager is subject to the same requirements
as the suppliers of the funds we distribute to have systems in place for following up corporate
social responsibility in the portfolio.

20
 7.4 Investments in the venture portfolio
Sparebanken Vest is a direct investor in a number of companies that we regard as important
contributors to long-term growth in our region. Most of these companies are small, local start-up
companies, while others are bigger companies that play a key role in the development of a
sustainable Western Norway and a sustainable financial system.

We endeavour to ensure that our investments and procedures for assessing and following up
our investments are in accordance with the UNI PRI initiative’s six principles for responsible
investment. Investment decisions and expectations of the companies are largely based on the
same criteria as described for the credit granting process. The companies included in the
portfolio must sign a declaration confirming the company’s attitudes and responsibility to act in a
socially responsible manner.

7.5 About companies where we take over ownership

positions through restructuring
As a bank, we sometimes end up in situations where we take over assets that enterprises have
pledged as security, thereby taking over ownership interests without actively choosing to invest
in them. The main objective in relation to these companies is not to remain an owner in the long
term, but to help the companies to find sustainable business models and financing and then sell
our interest in the company.

We actively strive to use our ownership position to persuade the company to comply with our
principles for sustainability, ethics, corporate governance and corporate social responsibility,
thereby making the company sustainable and interesting to new investors.

7.6 Sparebanken Vest as a distributor of securities

funds
Sparebanken Vest offers investment advice and a number of securities funds to customers. The
funds we offer are managed by external fund managers who are subject to stringent legislation
that is intended to protect customers and their fund units. In addition, we also ensure that our
fund suppliers have guidelines in place for socially responsible investments. Our customers
must feel sure that the investments yield a good return, both financially and for society as a
whole.

In order to give sound advice and give customers a wide range of choice, we will offer a clear
selection of funds from several suppliers and based on different investment strategies. The
funds that are offered must give customers the option of putting together a diversified portfolio
consisting of both general and more specialised funds, at the same time as it must be possible
for our advisers to give sound, informed advice.

21
In our role as a distributor of securities funds, we can use our negotiating power and a close
dialogue with our customers to influence potential fund suppliers. As a distributor of UCITS
securities funds, we only have a limited possibility to influence the investments in the individual
funds, and because the securities funds that are purchased through the bank are the customers’
property, we cannot control ownership. Our possibility to exert influence therefore lies in our
fund manager selection and follow-up processes, and in giving the customers sound advice that
can help them to make good choices:

1. Selection and follow-up of fund suppliers and funds available from Sparebanken Vest
2. Highlight and promote ethics, corporate social responsibility and sustainability in advice
and communication
3. Direct recommendations to terminate savings agreements and reasoned
recommendations to sell units in certain securities funds
Sparebanken Vest uses all these methods in cases where we see that the fund manager is not
taking the responsibility they have communicated to us, if they fail to document their follow-up of
companies in a good way, or where follow-up does not produce results or have consequences.

7.6.1 Requirements of fund suppliers

All funds and fund suppliers that are offered to customers through Sparebanken Vest’s channels
must have well-documented strategies and processes for ethical fund management, and for
following up ethics, corporate social responsibility, sustainability and the environment by voting
actively at general meetings. Documentation requirements are met through publicly available
descriptions of the strategy and philosophy relating to negative/positive screening in the
management context, and cooperation with and use of recognised monitoring and analytics
services that offer follow-up of ESG in fund management.

Today, many Norwegian investment companies use the Government Pension Fund’s exclusion
list as a guideline in their own management. We require fund managers to also have expedient
processes in place for active ownership, and to adopt an independent stance on ownership and,
if relevant, exclusion. We want to see transparency about ethical assessments and ethical
choices, and we require suppliers to be open about their ownership processes and exclusion
lists.

We are concerned with ensuring that the fund managers do not themselves participate in
lobbying aimed at weakening cooperation on international standards for the environment,
corporate governance, sustainability and corporate social responsibility, but that they contribute
in a positive and open way. It is not enough for a manager to endorse guidelines and rules in
this area. They must also be able to document that management rules are complied with, that
changes to exclusion lists actually affect investment decisions and that they make active choices
to seek sustainable investments.

7.6.2 Selection of fund suppliers

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

22
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.

23
24
 Fund manager’s strategy
- ESG and sustainability
strategies cover all areas of
the bank’s ethical and
sustainable management
requirements
- Has a clear ESG and
sustainability strategy
-Has a clear and documented
process for identifying and
following up incidents and
non-conformities
-Can document that ethical
guidelines have practical
consequences for
management
-The Government Pension
Fund’s exclusion list and/or
stricter exclusion principles
are complied with
-Publishes the exclusion list. A
few weaknesses in the
identification and follow-up
procedures for potential
violations
-Has an ESG and sustainability
strategy
-Does not comply with the
Government Pension Fund’s
exclusion list and/or stricter
exclusion principles
-Lack of documentation for
the process and procedure for
handling non-conformities
-Does not meet ethical and
sustainability requirements in
certain areas
-Does not have an ethics and
sustainability strategy
-Does not have a statement of
compliance from
subcontractors, or
documentation of its own
control measures and quality
assurance
7.6.3 Follow-up of fund suppliers and fund selection
In addition to assessing new products, we carry out continuous assessments relating to
information and documentation of fund managers’ attitude to sustainability. We have dedicated
personnel who continuously assess social responsibility and compliance with the sustainability
strategy and processes in connection with the products we distribute. We will remove products
Bank’s assessment and Consequence
measures
-The fund manager’s products SPV recommends the fund
can be recommended, and are manager, and confirms
emphasised as ethical and compliance with the bank’s
sustainable choices in ethical, CSR and sustainability
distribution channels requirements
-Specify the areas in which the SPV recommends and
fund manager has a good distributes the fund manager’s
ethics and sustainability products, and highlights
strategy when referring to it elements of the company’s
in distribution channels work on ethics and
-Follow up fund managers to sustainability
further develop their strategy
-Follow up the fund manager SPV obtains further
and allow time to improve documentation of measures
process and strategy and processes to maintain our
weaknesses distribution and
recommendation
-Stop any further distribution SPV does not recommend or
of funds under distribution. distribute funds
Two months’ notice to fund
managers and customers
-If the fund manager does not
document that measures have
been implemented, all
customers with funds
purchased through our
channels will be offered
alternative products
-Inform the fund manager
about the identified
shortcomings and our
improvement efforts vis-a-vis
the fund manager
25
from our portfolio if we discover that the described processes are not adhered to and the fund
manager is unable to document measures for negative screening, active ownership or
exclusion. Since we are not the owners of the units our customers have purchased through the
bank’s distribution channels, it is not possible for us to sell all the units in securities funds if we
suspect or discover breaches of the ethical guidelines. We will therefore use other avenues of
influence by:

1. putting pressure on fund managers to ensure that they have expedient procedures and
processes in place for making the right ethical, environmental and sustainability choices,
and for influencing companies they have ownership interests in by exercising active
ownership.

2. requiring documentation that fund managers have followed up issues with companies
that are in breach of the manager’s ethical, environmental and sustainability principles

3. drawing attention to breaches on the part of fund managers by communicating

guidelines and the investment mandate if a company does not remedy non-conformities
and remains in the portfolio over time

4. stopping new sales of products that do not meet our requirements for sustainable
management

5. recommending customers to terminate savings agreements and switch to other

products if the fund manager does not follow up the companies and does not take the
consequences of a company’s failure to implement improvements

Our fund suppliers will receive our policy for sustainable and ethical investments once a year.
They shall be made aware that they are expected to prepare a statement on what endeavours
are made to achieve our goals and expectations in connection with each evaluation.

7.6.4 Presentation of ethical profile and return

Sparebanken Vest wants it to be possible to compare all funds in a clear and easy way, with
respect to their management, costs, the return achieved and their ethical platform. We are in the
process of assessing funds and how the fund universe is presented to our customers, and we
will consider possible ways of including corporate social responsibility. Our attitude is that,
irrespective of this, it must be clear that a fund has more stringent rules and guidelines than the
industry standard if the product is to be presented as an ethical alternative.

7.6.5 General description of system and follow-up requirements

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

26
 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

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
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.

8. Assessments related to individual industries

and general criteria for investment/financing

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 proclaimed human
rights, and not contributing to breaches of human rights, promoting gender equality, zero
tolerance for racism and other discrimination in their workplaces. Correspondingly, we expect
customers to respect regulations for the use of natural resources, activity in areas that are

27
currently used by the local population or indigenous population, or in areas with a vulnerable
environment, endangered species or water shortage. We expect compliance with the FPIC
principles on free, prior and informed consent in order to prevent conflicts concerning natural
resources and land areas, including conflicts relating to smallholdings. Sparebanken Vest
wishes to promote sustainable solutions and encourages sustainable business activity, and has
introduced guidelines in which relevant risks relating to ethics and sustainability will be assessed
on a par with other risks when granting credit. General and industry-specific assessments are
described in more depth in a separate chapter.

In accordance with the bank’s credit strategy, we shall not grant financing to
customers/businesses that:

● we have reason to believe do not comply with the bank’s Code of Ethics or in other
ways conduct their business in conflict with the generally accepted view of what
constitutes ethical conduct

● have acted dishonestly in relation to the bank or are known to have acted dishonestly in
relation to other parties, or if the company or its owners are known to have been
involved in criminal activity

● operate in conflict with laws, regulations and official environmental requirements, or

without the necessary approvals from the authorities.

The guidelines apply to all granting of credit in the corporate market. The assessments that are
made must be documented and form part of the decision basis for each individual customer and
credit case, for new customers and in connection with the renewal of agreements with existing
customers.

8.1 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 self-
declaration 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.

28
Sparebanken Vest wants the companies we finance to demonstrate that they have procedures
in place to comply with statutory requirements and that they, in word and deed, conduct
themselves in a manner that is in accordance with general perceptions of what constitutes
ethical conduct. In the event that a customer acts in conflict with the purpose and nature of the
customer relationship, we will seek to terminate the relationship.

As a bank with a strong regional position, we have a particular responsibility to exert influence
through the channels available to us. In our contact with customers, we wish to raise awareness
of corporate social responsibility among our corporate customers, which we believe can add
value to the customer relationship. As a natural part of our risk assessments, we have
established guidelines for assessing how customers handle environmental and societal
considerations and corporate governance. This applies to both small and large companies.
What documentation is required will depend on the size of the customer’s enterprise and, in the
case of large corporate customers, we will look at the company’s attitude to sustainability and
how it is followed up.

8.2 The assessment process for corporate customers

As part of the bank’s ‘Know your customer’ procedures, we always carry out a thorough identity
check of new customers, their owners and beneficial owners. Before we enter into a customer
relationship with corporate customers, we investigate matters such as the company’s tax affairs,
corporate structure and ownership structure. We refuse to be involved in tax planning processes
that appear or are perceived by us to constitute tax evasion. Corporate customers must have a
clear and transparent company and ownership structure. The bank must understand
complicated company structures, and the identity of beneficial owners will be assessed as part
of the credit assessment. We also expect customers to have a clear picture of who their own
customers are and to ensure that the business is based on lawful activity.

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 will examine whether there is a particular risk relating to
corporate social responsibility and sustainability issues. This is done by using relevant
questions and assessments described in a special questions guide, and a country risk
assessment if 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 corporate social responsibility and sustainability issues, and
documentation of the assessment accompanies the credit case. 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
negative effects will be a decisive factor for whether financing is allocated and, if
relevant, requirements will be stipulated for measures to be implemented and non-

29
 conformities to be corrected within a suitable time period If the risk and the assessment
indicate that the bank will be in breach of the principles for corporate social
responsibility, the process will be stopped.

8.3 Industry-specific corporate social responsibility risks

and controversial activities
Certain industries are associated with a special risk of negative environmental and social impact
on nature areas and protected areas. If expedient measures are not implemented, this can lead
to increased financial risk, legal risk and, in part, conflicts of interest. Sparebanken Vest has
therefore established different assessment criteria for certain relevant industries in addition to
the general criteria. They are described in more detail in Chapter 9 on guidelines for general
requirements and industry-specific assessments.

8.4 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.

30
31
 9. Assessments related to individual industries
and general criteria for investment/financing
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.

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 9.1 General requirements
9.1.1 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.

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

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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.

9.1.4 Exploitation of crises and vulnerable individuals

Sparebanken Vest is concerned with ensuring that companies do not exploit crises, dependence
or the special vulnerability of individuals or communities, or profit from war, disasters or conflicts.
Companies must not provide services or make deliveries if, by exercising normal caution, they
should have understood that this could lead to breaches of international conventions on the
treatment of civilians or prisoners of war. We do not wish to contribute to or finance businesses
that provide goods or services that are linked to occupations that violate international law and
are unlawful, unless this is necessary in order to safeguard the civilian population in the area.

We also expect fund suppliers and potential customers to have clear guidelines for gambling
and betting, and to have a responsible lending practice in the case of loans furnished to
vulnerable households. We strongly disapprove of blatant overpricing of medicines, necessities
and equipment in connection with crisis situations.

9.1.5 Water protection

We expect the companies we finance and invest in to show consideration in relation to the risk
of water contamination and the establishment of activities in areas where there is a water
shortage.

Companies must carry out an analysis of the possible consequences for the water supply and
access before starting business in areas where water shortages are a known challenge. This

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also applies to areas where there is a risk that encroachments can have a major effect on the
water level in rivers and the groundwater level. If a company’s activities consume large
quantities of water, they must not start up business in areas or regions known to suffer from
water shortages, and where the local population’s right to access to clean water could be
violated.

9.1.6 Protecting natural diversity

Sparebanken Vest expects companies we invest in or finance to show consideration for natural
diversity, natural resources, vulnerable environments and endangered species. We expect the
companies to respect the regulation of natural resources, and to show due caution and
consideration in connection with activities in areas that are currently used in other ways by the
local population or indigenous population, or in areas with a vulnerable environment or
endangered species. We expect compliance with the FPIC principles on free, prior and informed
consent to prevent conflicts with the local population or indigenous population

We support the protection of areas inscribed on UNESCO’s World Heritage List and wetlands
registered in the Ramsar Convention. Sparebanken Vest does not invest in or finance
companies that are involved in trade in animal or plant species in breach of the CITES
requirements, or that threaten stocks included on the IUCN Red List of Threatened Species.

9.1.7 Genetically modified organisms

Sparebanken Vest’s attitude to genetic modification and the use of genetically modified
organisms is fundamentally negative. If businesses use agricultural raw materials in areas
where the use of genetically modified organisms is widespread, consumers must be informed
about the proportion of raw materials of uncertain origin. We would like to see fund managers
encouraging the companies they have invested in, or the companies themselves, to take the
initiative to reduce the proportion of raw materials based on genetically modified plants and
organisms.

9.1.8 Environmental toxins

In the event of involvement in production processes or the production of products that contain
environmental toxins, a number of measures must be developed to prevent the spread of and
contamination from such products. Companies where this can be an issue must have measures
in place to contribute to the collection and satisfactory destruction of residues and waste from
the products, measures to reduce the content of environmental toxins and general measures to
reduce the negative environmental impact of the production. This also applies to activities in
countries and areas that do not have statutory requirements corresponding to those in Norway.

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 9.1.9 Increased proportion of certified debt and green bonds
Sparebanken Vest focuses on the efforts to raise environmental standards. We want funds that
invest in bonds to be driving forces for environmental labelling and certification of the
sustainability of loans.

9.1.10 Reporting
Good measurement and reporting help to raise awareness of corporate social responsibility and
goal attainment. We want all our customers to adopt an active attitude to how they can reduce
negative sustainability and societal impacts and implement measures in that connection. The
amount of reporting and documentation should depend on the size of the companies, however.
For international and multinational companies, we want to see GRI G4 or corresponding
guidelines for sustainability reporting being used.

9.2 Industry assessments

Different industries will have different risk factors relating to ethics, social influence (e.g.
lobbying) and sustainability, and the assessments of individual companies must therefore be
based on which industry they are part of. Particular assessment criteria and assessments of
individual industries are described below. The general requirements described above apply to all
industries.

9.2.1 Controversial weapons production, pornography and the

tobacco industry
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 weapons producers that are involved in violations of fundamental
humanitarian principles, or export to countries where there is widespread corruption, armed
conflict, civil war or a high probability of weapons ending up in such areas.

This includes manufacturing, sale and transport.

No form of financing shall be offered to companies that, themselves or through other companies
they control, develop, manufacture, store, maintain or trade in key components for anti-
personnel mines, cluster munitions or weapons of mass destruction (nuclear weapons,
biological weapons or chemical weapons). Weapons must not be produced that do not
distinguish between combatants and non-combatants.

Technology and goods that can be used for both military and civilian purposes (‘dual use’), shall
be deemed military if they do not serve a civilian purpose.

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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 the inhabitants’ 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.

9.2.2 Mining and metal extraction

Sparebanken Vest applies the principle that encroachments on nature must be kept to a
minimum in connection with both mining and processing industry relating to the production of
metals. Plans for the purification of discharges, the restoration of nature and reclamation of
encroachments on nature after the decommissioning of operations must be documented,
irrespective of local legislation. Run-off and environmentally harmful waste must be dealt with in
an acceptable manner, and the employees must have good working conditions that entail a low
risk to health. Particular caution must be exercised if operations take place in areas with
especially vulnerable nature. If there is a risk of permanent harm to the environment as a result
of accidents or external impacts, mining must be avoided. Encroachments on nature shall not be
carried out in a way that affects indigenous peoples’ rights and traditional way of life more than
necessary, and we expect companies to endeavour to arrive at good solutions by following the
FPIC principles on free, prior and informed consent. Mining must be carried out in a sustainable
manner Sparebanken Vest urges customers who are engaged in mining and metal extraction to
continuously improve factors relating to health, safety and the environment, and to follow best
practice and comply with international standards in the industry.

We do not finance open cast mining operations in oil sands/tar sands, operations that entail the
extraction of uranium or mountaintop removal mining.

9.2.3 Coal-fired power, coal extraction and other energy

production
Sparebanken only finances 100% renewable energy production. Our power portfolio comprises
small hydropower plants, regional hydropower plants and a number of district heating plants. We
assess, on an ongoing basis, expanding the portfolio with other renewable energy sources, e.g.
wind power.

Sparebanken Vest does not wish to finance coal-fired power production or the operation of coal
mines, and it therefore does not finance companies involved in coal extraction and coal-fired
power. This principle also applies to companies involved in controversial energy sources such
as nuclear power.

The Government Pension Fund’s exclusion list will be used as a guideline to exclude companies
with a high proportion of revenues from or operations linked to coal-fired power. We expect
further measures to be taken than to adapt the company structure to meet the requirement for
maximum 30% of revenues or operations linked to coal-fired power. Fund managers we use or
whose products we distribute must make sure that they do not invest in companies that use

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structural adaptations to circumvent exclusion criteria. We also want fund managers to apply the
principle of reducing the proportion of coal-fired power and dependence on coal-fired power in
companies that are within the Government Pension Fund’s limits for the proportion of revenues
from and operations linked to coal-fired power. We want fund managers to encourage
investment in other, purer sources of energy production.

Oil

The oil industry has been and is still one of the most important drivers of economic growth in
Western Norway, and Sparebanken Vest therefore grants credit to companies that are
subcontractors to the oil industry. emissions to air, including the production of large amounts of
greenhouse gases and toxic gas emissions such as sulphur and nitrogen oxides. We expect
companies to comply with laws, regulations and official environmental requirements, and have
the necessary approval from the authorities, so that negative social and environmental
consequences (including accidents) are kept at a minimum. Norwegian regulations on plugging,
waste management and abandonment of wells must be complied with to ensure that the
shutdown period is properly managed, and that a shutdown plan is available for the start-up of
subsequent new projects. Large-scale recovery of oil and gas will in all probability decrease in
future, but it is currently an important employer and contributor to the economy. The oil industry
only accounts for a small proportion of our total lending portfolio.

As regards large hydroelectric power plants and the development of infrastructure thereto, we
require enterprises we finance or invest in to meet the seven principles of the World
Commission on Dams.

9.2.4 Shipping
The shipping industry transports more than 90 per cent of world trade and is the biggest and most
energy-efficient means of global transport. However, the scale of the industry means that it
represents challenges for the climate and the environment, and thus has potentially negative
social consequences.

Ships that have been built and are in the process of being built will sail for many years to come. It
is therefore important that the work on improving the profile of the maritime industry has a long-
term perspective. Securing more environmentally friendly transport by means of energy-efficient
ships is a precondition for sustainable economic growth and a robust environment.

The UN International Maritime Organization (IMO) has concluded that greenhouse gas emissions
from international shipping must be reduced by at least 50 per cent by 2050. The Norwegian
authorities make additional requirements of shipping along the Norwegian coast, and zero-
emission requirements will apply from 2026 for the World Heritage fjords Aurland, the Nærøyfjord,
the Sunnylvsfjord and the Geirangerfjord. Achieving this goal will be a challenge, but Sparebanken
Vest believes it can be done, in part by using existing environmentally friendly designs and
technology and through innovation and innovative technology.

Cleaning ballast water is an important environmental measure where the goal is to prevent the
spread of marine organisms. The International Convention for the Control and Management of
Ships' Ballast Water and Sediments adopted by IMO in 2014, regulates the intake, discharge

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and treatment of ballast water and sediments. The Convention sets out requirements for all
ships to clean their ballast water before it is replaced, and its goal is to limit the spread of alien
species through ballast water. The Convention was ratified by Norway in 2006. The new
regulations that entered into force in autumn 2017 require all ships to have the necessary,
approved cleaning technology on board. We require all ships to be registered in class at all
times, and they must also therefore comply with the new requirements. A number of ship-
owners have decided to renew the IOPP certificate to postpone the main class renewal survey.
This is, however, in accordance with the applicable laws and regulations.

We urge the industry to comply with international and national industry standards and use the best
technology available in investment decisions.

It is important to Sparebanken Vest that ships are recycled in a responsible manner, without any
risk to health, safety or the environment. Shipbreaking constitutes the biggest social and
environmental risk from shipping. Sparebanken Vest is positive to the international initiative
Responsible Ship Recycling Standards (RSRS), developed by and for banks. These standards
are voluntary industry principles that promote the responsible recycling of ships, with the object of
minimising the environmental impact of shipbreaking activities. RSRS requires ship-owners to
follow ships throughout their life cycle, including preventing them from being sold to third parties
for scrap using methods that are not sustainable. Breach of the terms can potentially lead to ship-
owners’ loans ending in default.

We want to encourage more parties in the shipping industry to commit to responsible recycling of
ships, and urge our customers to follow the provisions of the Hong Kong Convention or the EU
Ship Recycling Regulation, although they have yet to enter into force. The Hong Kong Convention
deals with risk related to environmental, occupational, health and safety-related issues linked to
the recycling of ships. The Convention will enter into force when a minimum of 15 countries that
represent 40 per cent of the world’s gross tonnage and 3 per cent of the world’s recycling capacity
have ratified the agreement. When the Convention enters into force, ships registered in countries
that have endorsed it will only be able to be recycled at facilities in countries that have ratified the
Convention, that meet the requirements of the Convention and that are approved by their
countries’ authorities on that basis.

9.2.5 Sustainable agriculture and forestry

Sparebanken Vest wishes to support sustainable agriculture and forestry. We require forestry
and agriculture to give due consideration to wildlife corridors and access to water, that they
endeavour to prevent deforestation and protect areas with high preservation value, such as
indigenous forests, moorlands and mangrove forests. The enterprises must take steps to
prevent run-off and the depletion of soil and water resources, and measures must be taken to
ensure the establishment of non-cultivation zones bordering on springs, seas and rivers.
Indigenous rights must be respected, particularly access to grazing, the movement of animals
and access to water sources.

Enterprises producing crops that deplete the soil or that have other very negative effects on the
local ecosystem must have guidelines in place that ensure that such effects are mitigated and

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counteracted. We expect active endeavours to be made to address known challenges relating to
nut production and plant oils/palm oil, both by the producers themselves and by enterprises that
use the produce in their production. Sparebanken Vest wishes to ensure that animal transport is
of an acceptable standard and has a maximum duration of eight hours, unless local legislation
provides otherwise. We support the Five Freedoms for animal welfare, and expect very confined
cages and stalls not to be used.

If timber is used as a raw material, this must be done in a sustainable way. We disapprove of
the felling of virgin forest and therefore do not wish to finance industries that participate in such
activity or that engage in logging operations that do not ensure sustainability. We expect biofuel
production to meet the RSB standard.

Enterprises engaged in the production of paper, pulp and wood products should be certified
pursuant to FSC’s value chain requirements or work towards achieving such certification. We
expect enterprises to meet the requirements of relevant laws and standards. If a company’s
operations have a major impact on forests, through felling or other development, the company’s
footprint must be reported in accordance with the requirements in the FFD project.

Choosing fertilizer that has been produced with the lowest possible emissions using optimal
technology is an important precondition for being able to meet the growing global population's
need for food. Farmers also have to make sure that the amount and type of nitrogen fertilizer
they use, and when they apply it, does not increase greenhouse gas emissions as a result of
denitrification, ammonia evaporation or run-off. We expect spraying in agriculture and forestry to
be kept at a low level and the use of chemicals to be as low as possible and to have as little
negative environmental impact as possible and that the enterprises actively seek to reduce their
use of chemicals. We also expect these parties to support work to limit the use of antibiotics in
food production to minimise the development of antibiotic resistance.

9.2.6 Fisheries
Fish stocks are among our most important renewable resources. Sparebanken Vest expects its
customers in the fishing industry to operate on the basis of official permits and to comply with
the laws and regulations that apply to the industry. All companies in this industry manage natural
resources on behalf of society and therefore have a responsibility to operate in a sustainable
manner and with the smallest environmental footprint possible. Together with the authorities,
industry associations etc., the companies must do what they can to conserve marine resources
for future generations.

We will not finance companies that engage in fishing of unregulated fish stocks with a
sustainability risk, fisheries that use harmful methods or fishing of endangered species, such as
whale species on the IUCN Red List of Threatened Species, and species described in the
CITES agreements. To ensure sustainable management, we expect the companies to comply
with requirements and regulations set out in national and international laws, quotas etc. We also
want the fishing industry to contribute to cooperation on environmental certification, and we
prioritise suppliers that act in a responsible and sustainable manner.

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 9.2.7 The aquaculture industry
Sparebanken Vest expects its customers in the aquaculture industry to engage in sustainable
aquaculture, to act as responsible members of society and to operate within the laws and
regulations that apply to the industry. The companies must do all they can to protect the
environment and ensure that it is managed in a way that also benefits future generations.
Systematic efforts to prevent undesirable impact on the environment are very important, in
addition to a focus on the prevention of escapes and high levels of salmon lice, efforts to combat
disease and promote fish welfare. We expect the companies to focus on the use of sustainable
feed and efficient utilisation of feed, and on their climate impact. Systematic work in these areas,
involvement in research and development and cooperation with the authorities/the public
administration, interest organisations, other fish farmers and suppliers are important in order to
ensure a sustainable and profitable future for the industry.

The aquaculture industry is one of the most important food suppliers in the world and its long-
term growth must take place in a sustainable and efficient manner. We expect feed producers to
do what they can to develop an even more sustainable industry. A reduced proportion of wild-
caught fish, increased use of marine residual raw materials and the use of vegetable ingredients
could be ways of achieving the desired growth in the industry. In addition, they must endeavour
to minimise the carbon footprint from their operations and from the transport of raw materials,
and they must follow-up emission reduction measures taken by their suppliers.

9.2.8 A sustainable financial industry

A strong and sustainable financial industry forms the basis for a sustainable economy. Like the
general requirement not to exploit crises or vulnerable individuals, nor shall the financial
industry, financing companies or bond investments be exploited for profiteering purposes. This
means that, in connection with both investment and financing activities, we must critically assess
companies that are involved in financing individuals with strained finances, and it is a
requirement that customers are able to understand the terms and conditions that apply to the
products and services we offer. Local value creation shall not take place at the expense of
people and the environment in other parts of the world. Lenders and financial institutions must
comply with local rules and guidelines for consumer protection. If there is no local regulation,
international standards must be complied with.

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.

9.2.9 Property companies and property development

Sparebanken Vest wants companies that invest in property and property development to set
goals for and implement measures to reduce emissions and energy consumption. We expect
large companies to have procedures for reducing energy consumption, and we expect the

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company’s documents to contain environmental accounts and goals for the reduction of
greenhouse gas emissions. Large groups of companies that manage property (with a balance
sheet total of more than NOK 7,5 billion) should endeavour to achieve ISO 14001 certification in
order to ensure that greenhouse gas emissions are reduced.

If disputes arise relating to the ownership of land or the interests of existing tenants or
occupants and they are a vulnerable group, we expect caution and responsibility to be shown in
relation to the balance between profit and the interests of those inhabiting the land or housing.

9.2.10 Transport companies and aviation

We welcome fossil-free alternatives and urge transport and aviation companies to invest in
technology to reduce emissions and their negative environmental impact.

9.2.11 Energy production and clean energy

Sparebanken Vest expects all industries and enterprises to take responsibility for climate
challenges, to display an active attitude to the use of clean energy and to implement measures
to reduce their carbon footprint.

The bank plays a key role as a driving force and facilitator of social development and the green
transition. We wish to promote the production of clean and green energy. Companies engaged
in energy production and distribution are expected to participate in this by endorsing
international agreements promoting green energy and to implement measures to reduce their
climate and environmental impact. The companies’ role and responsibility shall be described in
their governing documents and strategy.

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