Code of Conduct

PURPOSE

The purpose of this Code of Conduct is to clarify the Bank of Åland’s focus areas as part of the Bank’s sustainability work. The Code of Conduct deals with our relationships with our customers, our actions as employers and employees and our relationships with our owners, investors, suppliers and business partners.

The Bank of Åland’s strong values as a responsible actor have been a guiding factor in our actions and our operations ever since 1919. A great awareness and broad commitment to sustainability among employees in the organisation give us good potential for continuous improvement in this field, as well as compliance with it.

Our values, the regulations in force and the principles and initiatives below that we have adopted are the platform for our conduct as a responsible actor.

  • The United Nations Principles for Responsible Investments (UNPRI), which mean that the Bank pays heed to evaluations and reviews of environment, social and governance (ESG) factors in compliance with the PRI principles.
  • The United Nations Principles for Responsible Banking, part of the UN Environmental Programme’s Finance Initiative (UNEP FI), whose purpose is to adapt the global banking sector to the Paris Climate Agreement and the UN’s global sustainability goals.
  • Climate Action+, in which the Bank of Åland together with other investors lobbies the 100 corporations with the largest emissions to change their business model in order to reduce their emissions.
  • The Swedish Banking Association’s initiative for responsible lending, which calls for transparency towards consumers concerning sustainability criteria in lending to businesses.

BACKGROUND

For more than a century, the Bank of Åland has built up its business centred on long-term customer relationships, low risk-taking, deep environmental awareness and strong cost consciousness. These form the basis of successful banking operations that are run in a responsible and sustainable way. The success of the Bank of Åland rests on enjoying the confidence of our customers, employees, owners, public authorities and other stakeholders. This confidence is based on ethical behaviour and responsibility for long-term and sustainable financial, social and environmental development. In order to retain this confidence, the Group needs to show transparency in its sustainability work and to promote continuous dialogue and communication with its stakeholders.


GOVERNANCE

This Code of Conduct applies to the entire Bank of Åland Group, its operations and employees, and encompasses all activities with customers, suppliers and business partners.

The Code of Conduct will be revised yearly or as needed. The Executive Team is responsible for producing guidelines and instructions in specific areas and sectors as required. The Executive Team shall also ensure sufficient structure in the organisation to enable this Code of Conduct to be implemented in practice.

The Code of Conduct is based on:

  • Our strategic goals: environment responsibility, social responsibility, sustainable investments and sustainable lending
  • Our materiality analysis, which takes into account the expectations and demands of our stakeholders as well as the 17 UN Sustainable Development Goals (SDGs) and their 169 associated targets
  • Our action plans including targets, activities and key ratios

FOCUS AREAS

Sustainable investments, sustainable lending, social responsibility, environmental responsibility

The Bank of Åland Group’s ambition is to carry out its operations in ways that promote long-term sustainability – in financial as well as social and environment respects – and that contribute to sustainable development. This applies both to day-to-day operations and to lending and investment decisions, product development, advisory services and purchasing decisions. Confidence in the Bank of Åland as a serious, sustainable actor shall be maintained.

The Bank of Åland Group works according to the following sustainability strategy.

Sustainable investments:

  • ESG integration as a method – This means that in all investment decisions, we review sustainability-related risks and opportunities affecting the company in question, based on a sustainability analysis from MSCI, which includes the UN’s Global Compact principles.
  • Exclusions – companies that are involved in controversial weapons, pornography, betting, tobacco (including cannabis) and production of thermal coal. We are selective about companies that produce alcoholic beverages.
  • Continuous development of a sustainable product range and transparent reporting.

Sustainable lending:

  • Economic sustainability, including an assessment of the customer’s ability to repay the loan.
  • Funding of sound projects.
  • Continuous monitoring of the customer’s ability to repay the loan.

Social responsibility:

  • Maintain high ethical standards by complying with regulations/requirements as well as protecting internationally recognised human rights.
  • Help combat corruption, money laundering and other criminal activity.
  • Be an attractive employer that
    • Protects the rights of employees and promotes a safe and secure working environment for everyone
    • Maintains decent working conditions, with equal pay for equivalent work
    • Ensures that the experience and knowledge of both women and men are utilised and represented in all areas, roles and positions throughout the Group’s operations
    • Creates a corporate culture where differences are viewed as an asset.
  • Satisfy skill requirements for all employees based on regulations/standards and the skill needs of the Bank connected to its strategy/roadmap.


Environmental responsibility:

  • Reduce our carbon dioxide emissions by means of
    • Sustainable consumption and production
    • Sustainable energy use
    • Sustainability in travel and internal communication.
  • Expanded responsibility towards the supplier chain.
  • Help reduce global carbon dioxide emissions by increasing awareness using the Åland Index.
  • Help promote a cleaner Baltic Sea by supporting good initiatives through the Baltic Sea Project.

MONITORING AND REPORTING

The Bank of Åland measures, reports and monitors its sustainability activities. The Bank presents this work yearly in its sustainability report, which is published on its website. Our carbon dioxide emissions are included in our quarterly reports. In addition, the Baltic Sea Project reports on its awards and the Bank of Åland’s mutual funds publish a sustainability report yearly.

OBLIGATIONS OF SUPPLIERS/BUSINESS PARTNERS

When choosing suppliers/business partners, we weigh in their values and how they are observed.

Our suppliers/business partners undertake to:

  • Maintain a high ethical level by complying with regulations/standards and protecting internationally recognised human rights.
  • Help combat corruption, money laundering and other criminal activity.
  • Be a company that
    • Protects the rights of employees and promotes a safe and secure working environment for everyone
    • Maintains decent working conditions, with equal pay for equivalent work
    • Ensures that the experience and knowledge of both women and men are utilised and represented in all areas, roles and positions throughout the Group’s operations
    • Creates a corporate culture where differences are viewed as an asset.
  • Help reduce carbon dioxide emissions.

A supplier/business partner is obliged to ensure that any subcontractors comply with the same obligations.

Each supplier/business partner is responsible for regularly monitoring and reviewing its own operations and those of its subcontractors to ensure compliance with their obligations. The Bank of Åland may conduct an audit of a supplier or business partner in order to ensure compliance with the above obligations.