Position statement Danske Bank September 2018

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1 Human rights Position statement Danske Bank September

2 Introduction About Danske Bank Group Danske Bank is a Nordic universal bank with strong regional roots and close ties to the rest of the world. For more than 145 years, we have helped people and businesses in the Nordics realise their ambitions. Today, we serve more than 3.2 million personal, business and institutional customers in 16 countries, and in addition to banking services, we offer life insurance, pension, mortgage credit, wealth management, real estate and leasing services and products. Our vision is to be recognised as the most trusted financial partner. Societal impact and sustainability at Danske Bank Group Danske Bank Group has a responsibility and sizeable societal impact as one of the largest Nordic financial institutions. By being solid, balanced and predictable, we aim to conduct our business in a responsible and transparent manner and contribute to financial stability and economic growth. We are driven by an ambition to create value for all our stakeholders and use our expertise to drive sustainable progress and a positive impact in the societies we are part of. We are committed to respecting human and labour rights, mitigating adverse environmental impacts and eliminating corruption in all of its forms throughout our business. Internationally recognised principles dealing with environmental, social and governance (ESG) aspects of business lay the foundation for how we conduct our business in a responsible and transparent manner. Further, they provide a shared framework for our relations and dialogue with stakeholders. Danske Bank Group observes and supports the following international agreements, guidelines and voluntary standards: Purpose and scope of position statements 2030 Agenda and the UN Sustainable Development Goals1 UN Global Compact2 OECD Guidelines for Multinational Enterprises3 UN Guiding Principles on Business and Human Rights4 UN-supported Principles for Responsible Investment (PRI)5 The Universal Declaration of Human Rights6 UN Environment Programme Finance Initiative (UNEPFI)7 The ILO Declaration of Fundamental Principles of Rights at Work8 Danske Bank Group works continually to improve its responsible business practices, and we expect the companies we work with to do the same by integrating ESG in their business practices. Our position statements clarify how Danske Bank Group operates and outline our expectations to companies we actively invest in, lend to and procure from. They establish a shared framework for a constructive and forward-looking dialogue about risks and opportunities. 2

3 The statements apply to all markets we operate in and encompass all the operations of Danske Bank Group. Existing policies and position statements The internationally recognised principles that Danske Bank Group has endorsed lay the foundation for several of our policies and procedures. We have sectorspecific position statements on agriculture, arms & defence, fossil fuel, mining & metals and forestry. These position statements are complemented by cross-sector position statements on climate change and human rights. In addition to the position statements, we have Responsibility Policy, Code of Conduct Policy, Whistleblower Policy, Responsible Investment Policy, Supplier Code of Conduct and Credit Policy as well as Credit Directives on ESG risks in specific industries. We also publish an annual statement of carbon neutrality and annual statement on the steps taken to eradicate and prevent modern slavery in the supply chain and any other parts of our business in the past financial year. Engagement, feedback and contact For more information about how we work in this area, please visit our website at Please contact Kristina Øgaard, Head of Sustainability Strategy & Governance, Danske Bank with any questions or comments. 1) 2) 3) 4) 5) 6) 7) 8) wcms_ pdf 3

4 Human rights POSITION STATEMENT DANSKE BANK 1. Introduction In a globalized world, companies can have a major impact on human rights, both positive and negative. The UN Guiding Principles on Business and Human Rights stress that states have a duty to protect against human rights abuses and that businesses have a corporate responsibility to respect human rights. At Danske Bank, we work to protect and respect human rights across our business. We refer to human rights as the internationally recognised human rights including labour rights as stated in the International Bill of Human Rights and the International Labour Organisation s Declaration on Fundamental Principles and Rights at Work. While we see operating in line with the UN Guiding Principles on Business and Human Rights as an imperative, we also see human rights due diligence as a tool for improving business performance amongst ourselves, our customers, our suppliers and the companies we invest in and lend to. 2. Our approach We acknowledge that Danske Bank can directly cause or contribute to human rights impacts through our operations and indirectly through our business relationships with the companies, we invest in, lend to and procure from. We therefore work to identify, assess and address potential and actual adverse human rights by focusing on our employees, suppliers and the companies we invest in and lend to while taking into account the severity and probability of the impacts. 3. Implementation To ensure we respect human rights, we have implemented a number of measures. We will continue to increase and monitor our efforts in order to meet our own high standards as well as our customers and stakeholders needs and expectations in the best possible manner. To this end, we report annually on our progress to the UN Global Compact, PRI and in accordance to the Danish reporting requirements on non-financial information, which include disclosures on human rights, social responsibility and treatment of employees, as well as gender diversity at company board and management level. 4

5 We are guided by international standards and principles Our business conduct is guided by a number of international standards and principles related to human rights, which we also expect the companies we invest, lend to and procure from to adhere to whenever relevant: UN Global Compact9 OECD Guidelines for Multinational Enterprises10 UN Guiding Principles on Business and Human Rights11 The Universal Declaration of Human Rights12 The ILO Declaration of Fundamental Principles of Rights at Work13 Global Framework Agreement on Human Rights and Corporation with Unions14 Minimum Age Convention (No 138)15 Worst Forms of Child Labour Convention (No 182)16 Free, Prior and Informed Consent (FPIC) as covered in the ILO Convention No and the UN Declaration on the Rights of Indigenous Peoples18 We foster a responsible and diverse workplace As an employer, Danske Bank uses its five core values being expertise, integrity, value, agility and collaboration as the foundation for how we train and develop our employees, foster a culture on diversity and inclusion and maintain a safe and healthy working environment. Specific measures include, but are not restricted to: Zero-tolerance regarding any type of discriminatory behaviour and harassment, human trafficking or any type of forced labour as stated in our Code of Conduct Policy and internal Human Rights Guidelines HR management procedures in all countries where we operate to ensure that employees are treated fair, according to our ethical standards and in accordance with applicable regulation Close collaboration with unions and local representatives Working environment management system that enables identification of cases involving working environment issues, discrimination and the like Employee training and professional development programmes to ensure that employees adhere to our policies and procedures, and continuously develop their competencies On-going efforts to prevent illness among employees and to ensure a healthy workplace both physically and mentally A whistle-blower scheme for employees to report possible wrongdoings As part of our efforts to improve gender equality, we have set 2020-targets for the gender composition of our Board of Directors, Executive Management and management positions and aim to have at least 38-40% participation and equal access of women at senior level positions by To realise these targets, we have a range of initiatives, including Diversity & Inclusion Committees and management training to raise awareness of unconscious bias. We have also launched a pilot project within our business unit Corporates & Institutions focusing on attraction, retention and development of female employees and nurturing of an inclusive culture by setting up a Think Tank with internal and external experts. Furthermore, we address gender equality by working actively with equal pay, often in collaboration with unions, through collective agreements, disclosure of data or dialogues in our European Works Council or local working councils. We monitor this area internally and report our data and statistics annually to the relevant organisations and authorities in the markets where we operate. Additionally, we carry out an annual pay gap mapping to ensure that we live up to our strategy and targets. 5

6 We consider social risks On the basis of the international standards and principles we support, and our Responsibility Policy, Responsible Investment Policy, Credit Policy and Supplier Code of Conduct, we analyse and consider environmental, social and governance (ESG) risks in our investment, lending and procurement practices. We integrate social matters into the investment process as factors alongside financial factors. Based on external data and information, and internal expertise and advice, we assess portfolio companies performance as well as identify risks and opportunities related to social matters based on industry best practice, international norms and voluntary frameworks for corporate responsibility. We seek to be active owners and influence companies directly through dialogue, voting and collaboration with peers, like-minded investors and stakeholders on material social matters. Based on our assessment and company dialogue, we may decide to divest or restrict investments in a company, in a specific investment strategy or across multiple strategies. As part of our general credit process, we consider the purpose for which the funds will be used and assess possible social risks associated with our lending in collaboration with customers. If our assessments show that a customer relationship is contrary to our policies, we engage with the customer and recommend another approach. If this process is fruitless and our only remaining option is a termination of the credit agreement, we do so in a controlled process that takes all legal aspects into consideration. We conduct an ESG assessment of suppliers with elevated risk profiles together with our external partners and we clarify our expectation of responsible business conduct based on recognised international standards in our Supplier Code of Conduct. In the Supplier Code of Conduct we have also clarified that suppliers are responsible for setting the same or comparable standards for their subcontractors. If a supplier cannot live up to the requirements, we initiate a constructive dialogue with the company to find a better solution. We expect companies we lend to and invest in to follow international guidelines Some sectors are more prone to human rights risks than others and our sector-specific position statements within agriculture, arms and defence, forestry, fossil fuel, mining and metals address these specifically. Generally, we expect these companies we lend to and invest in to follow the below international recognised standards specifically related to human rights whenever relevant: Respect human rights as stated in the Universal Declaration of Human Rights19 and the ILO Declaration of Fundamental Principles of Rights at Work20 Adopt policy commitment to respect human rights Establish human rights due diligence processes to identify, prevent, mitigate and account for adverse human rights impacts Establish procedure to handle complaints by individuals and communities and ensure access to remedy for affected persons or notify the appropriate authorities Ensure equal treatment and working conditions for all employees, including women and migrant workers Have management systems or processes that deal with employee complaints, labour law violations and conflicts, and monitor and ensure compliance with labour laws 6

7 Adopt policy commitments on health and safety Mitigate the risk of accidents and have contingency plans in place Respect the rights of children and do not use exploitative forms of child labour, such as labour that damages children s physical or mental health or prevents them from going to school as stated in the Minimum Age Convention21 and Worst Forms of Child Labour Convention2 Respect indigenous people and their right to customary lands by obtaining acceptance when entering such land as described in the principles of Free, Prior and Informed Consent (FPIC)23 9) 10) 11) 12) 13) wcms_ pdf 14) 15) 16) CODE:C182:NO 17) INSTRUMENT_ID:312314:NO 18) 19) 20) wcms_ pdf 21) 22) CODE:C182:NO 23) INSTRUMENT_ID:312314:NO 7