Corporate governance

Overview of organizational and administrative measures taken for prevention of conflicts of interest

General

This is an oveview of the Swedbank policies and procedures for prevention of conflicts of interest, use of insider information and market manipulation in transactions with financial instruments and in relation to investment advice.

Code of Ethics

The objective of the Ethics Policy is to set out the general basic principles of ethics by which the Swedbank companies, and their employees, in Latvia and other countries shall be guided in their daily activities. This policy serves as the basis for the Swedbank instructions and procedures, which define in details the application of this policy across various structural units and areas. All the principles of the policy and the duties defined there apply to each and every employee of the Swedbank.

Key values and principles, on the basis of which the Swedbank Ethics Policy has been developed are:

• conformity with law
• openness and transparency
• directness and unambiguity
• focus on customer's interests
• cooperation and mutual respect
• professionalism
• quality
• responsibility
• integrity
• self-control
• good financial institution practice.

Commercial Secret

All the employees must observe strict secrecy of all the information, which is a commercial secret and which they have become aware of in the course of fulfilling their professional duties. A commercial secret includes the Swedbank secrets, business secrets and professional information. The requirement to preserve commercial secrecy extends to all employees for an unlimited period of time, also after the termination of their labour relations.

Conflict of Interest

Each employee must avoid situations, where the employee has to exercise their authority in matters where, along with the Swedbank interests, there are economic or other personal interests of his or her own or that of his or her relatives. On the commencement of labour relations with the Swedbank, each employee fills out the declaration of economic interests.

Prevention of the Use of Insider Information

If, in the course of fulfilling their professional duties, an employee gains access to an insider information, he or she will have no right to disclose such insider information to any person apart from the employees, who require this information for performing their job duties. The employees are prohibited from entering into transactions with financial instruments in or on the behalf of the Swedbank or themselves, in or on the behalf of persons related to the employee or third parties, relying on the insider information about the financial instruments involved in the transaction, or to conduct speculative transactions on the financial markets.

Investment Advisory

The Swedbank distributes investment advice prepared by Swedbank Group.

Employees, who have access to information on consultation for a customer concerning investments in financial instruments, may not enter into transactions with the respective financial instruments on behalf of the Swedbank or the Swedbank's customer (if the employee manages such customer's funds) until the information in question has been disclosed to the public.

Research analysts, who are responsible for the preparation of investment advice, receive compensation on the basis of a range of factors, including the quality and accuracy of their research, references from customers, as well as competition-related factors.

Information about Swedbank Group analysts' investment advice for the period from 01.07.2016 till 05.08.2016

Indicative conditions for recommendations are as follows:
- Buy or Strong buy recommendations are given when share target price is higher than the market price.
- Neutral recommendations are given when share target price is equal to or slightly higher than the market price.
- Reduce recommendations are given when share target price is lower or slightly higher than the market price.
- Sell recommendations are given when share target price is lower than the market price