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Code of Conduct

As an employee, consultant or board member representing SEK, you are expected to adhere to SEK’s Code of Conduct in order to maintain the trust of external stakeholders. The Code of Conduct guides our ethical behavior in daily operations and in interactions with others. You are expected to act as a role model and comply with all applicable laws and regulations governing SEK’s business activities, with particular regard to the company’s public role, state ownership and the regulatory framework governing the financial sector.

If you have questions or require advice or support in uncertain situations, you are encouraged to contact your immediate manager, HR, or the Compliance function.

Our values

Together, we form a high-performing team. Our mission and our ability to make a difference inspire pride and engagement. At SEK, we are proactive, committed and team players.

  • Proactive: We are courageous and curious. We work in an agile manner and contribute to continuous development.
  • Committed: We are customer-focused, business-oriented and accountable. We make a difference through our expertise and drive.
  • Team Players: We are open, inclusive and trust one another. We all share responsibility for achieving our goals.

Our values guide our conduct and influence how we interact with one another, with clients, external partners, job applicants and others.

Compliance with laws and regulations

Each of us is individually responsible for complying with applicable laws, regulations, regulatory requirements and internal policies. This includes not only written rules but also the spirit and principles behind them.

Managers are responsible for informing their teams about the relevant rules and procedures within their area of responsibility, as well as reporting any cases of non-compliance.

To facilitate compliance, SEK issues internal policies, procedures and method documents, all of which are available on the intranet.

You have a duty of loyalty to SEK, meaning you must not act in a manner that could harm SEK, even outside of working hours.

At SEK, we are proactive, committed and team players.

Anti-bribery and anti-corruption

Corruption includes giving or receiving bribes, breach of trust, and exploiting one’s position to gain undue advantage for oneself or others.

As a representative of SEK, you are expected to promote ethical conduct in all interactions, both internally and externally. Your actions can help prevent corruption and financial crime, both in our financed transactions and within our operations.

SEK has zero tolerance for any form of bribery or corruption. You are personally responsible for ensuring that you do not, directly or indirectly, offer, promise, give, request, or accept a bribe.

Gifts and hospitality

Representation is a legitimate part of our business and must be clearly linked to our mission. It should always be moderate and appropriate.

SEK maintains a highly restrictive stance on gifts. Giving or receiving gifts is only permitted in exceptional cases and must be of symbolic value. Gifts or donations to political parties are strictly prohibited.

Anti-money laundering and counter-terrorism financing

Money laundering refers to concealing or converting the proceeds of crime. Terrorism financing refers to the financial support of terrorist activities.

SEK has a responsibility to actively prevent and combat money laundering and the financing of terrorism through risk-reducing measures. You are expected to remain vigilant and act to ensure SEK’s resources are not used for illicit purposes.

Avoid conflicts of interest

A conflict of interest arises when an individual’s private interests risk conflicting with the interests of the organization.

You must always prioritize SEK’s interests. This means that in any decision-making, you must aim to act in SEK’s best interest.

You must not process or make decisions on behalf of SEK in matters where you or a close relative may have a personal interest.

You must obtain written approval from both your immediate manager and their superior before engaging in any secondary employment or external assignments.

You are personally responsible for informing your manager if you believe a conflict of interest exists. Managers are responsible for identifying, assessing, mitigating and documenting conflicts of interest when needed, and ensuring appropriate separation of duties. Situations that may give rise to conflicts of interest include organizational changes, product decisions, acceptance of new assignments, recruitment, or procurement of suppliers, consultants or non-audit services from SEK’s auditor.

Confidentiality

Confidentiality is required by law and applies to all information regarding SEK’s clients and transactions. Such information must not be disclosed unless the client has been given written consent, or SEK is legally obliged to do so. Confidentiality obligations continue even after termination of employment or assignment.

Other internal company information should generally not be disclosed externally, especially if it could harm SEK. Use sound judgment to determine whether and how internal information may be shared. If in doubt, consult the Communications function.

Insider information

Insider information refers to non-public information that, if disclosed, could significantly affect the value of a financial instrument.

Trust in SEK relies on our professional handling of information. If you have access to insider information, you must handle it responsibly.

You may not use insider information for personal gain or advise others to do so. Rules regarding short-term trading apply to all employees.

Obligation to report transactions in financial instruments

Special reporting requirements are governed by the Swedish Securities Market Association’s rules on personal account dealing by employees, contractors and their related parties. The Personnel Instruction specifies whether you are subject to this reporting obligation and how the rules apply at SEK.

Communicate with discretion

You are always an ambassador for SEK — professionally and personally. Communicate respectfully and responsibly in social media and other public forums.

Always communicate with external parties in line with our values and with professionalism.

Handle information and resources with care

Information includes everything from employees’ knowledge to data processed in IT systems.

Information is one of SEK’s most important assets and must be handled with care and protected according to its sensitivity, associated risks and legal requirements. This applies regardless of format or where the information is processed. Publicly available information via SEK’s website or social media channels may be freely used.

You are expected to access only internal information that is intended for you and necessary to perform your work.

When processing personal data, you are expected to safeguard individuals’ privacy by handling such data responsibly.

IT resources, whether physical or digital, must be used for work-related purposes and handled with care.

Treat others with respect

We respect human rights and shall not contribute, directly or indirectly, to violations thereof. Our guidance includes the UN Declaration of Human Rights, the UN Global Compact, and the UN Guiding Principles on Business and Human Rights — all of which SEK has committed to observe in its lending activities.

You are expected to help create a safe and inclusive work environment that promotes well-being and diversity. SEK does not tolerate discrimination, bullying or harassment in any form, nor retaliation against anyone who reports or participates in the investigation of such issues.

You have the right to join or refrain from joining trade unions, to form a union and to engage in collective bargaining.

Promote environmental and climate responsibility

As a representative of SEK, you are encouraged to serve as an ambassador for reducing negative climate and environmental impacts.

You are expected to act responsibly in your daily work to minimize SEK’s environmental and climate footprint — for example, by choosing environmentally friendly products and services when making purchases or traveling for business.

Report misconduct

SEK encourages you to report any known or suspected violations of law, unethical behavior or breaches of this Code of Conduct. Reports may be made to the Compliance function, your manager, HR, or anonymously through the “SpeakUp” system available on the intranet and website.

All reports of suspected violations are treated confidentially. SEK does not tolerate retaliation against anyone who submits a report in good faith.