Danske Bank A/S : Human Rights Report 2023

Human Rights Report

Danske Bank Group

31 May 2024

1 Human Rights Report

About this report

This Human Rights Report covers the financial period 1 January 2023 to 31 December 2023 and encompasses the activities of the entire Danske Bank Group (Danske Bank/the Group), which includes Danske Bank A/S and all subsidiaries and organisational branches, including Danica Pension, Danske Invest Asset Management AS and Danske Bank Norwegian Branch. This report represents our duty to account for our human rights due diligence in accordance with section 5 of the Norwegian Transparency Act.1 Danske Bank A/S is subject to the Norwegian Transparency Act due to its activity in Norway through Danske Bank Norwegian Branch and Danske Invest Asset Management AS.

The report is available in English at danskebank. com/sustainability and at danskebank.com/ no/samfunnsansvar. The report is available in Norwegian at danskeinvest.no/page/ansvarlige_ investeringer_innsikt.

Pursuant to section 5 of the Norwegian Transparency Act, the report will be updated annually no later than 30 June each year or in the event of significant changes to Danske Bank's human rights risk assessment.

This report has been approved by the Danske Bank Board of Directors.

Our duty to inform

If you have any enquiries about how Danske Bank works to cease, prevent and mitigate potential and actual adverse impacts on human rights and decent working conditions, please contact us at [e-mail].

Get in touch

We welcome any comments, suggestions or questions you may have regarding our sustainability performance in general. Please contact us at [e-mail].

Follow us

You can stay up to date on the most recent developments in our sustainability work at danskebank. com/sustainability, and you can follow Danske Bank on X (formerly Twitter), LinkedIn and Instagram.

1. Act relating to enterprises' transparency and work on fundamental human rights and decent working conditions(Transparency Act)
2. Human Rights Report

Contents

Message

The Norwegian

About

Our

Human rights governance

Key focus

Measures

Own

Value

Combatting human trafficking

Grievance mechanisms

Looking

from our CEO

Transparency Act

Danske Bank

commitment

and executive oversight

areas

in place

operations

chain

as a financial crime

and remediation

ahead

Contents

Message from our CEO

• Foreword by Carsten Egeriis

Reporting on the Norwegian Transparency Act

• Description of the content this report provides to deliver on the reporting requirements of the Norwegian Transparency Act

About Danske Bank

• Danske Bank's structure, area of operations and business activities

Our commitment

1. Our commitment to respect fundamental human rights and decent working conditions
   Human rights governance and executive oversight
2. Group roles and responsibilities and governing documents

Key focus areas within human rights

13 Brief description of Danske Bank's most severe potential adverse human rights impacts

Measures to cease, prevent and mitigate adverse human rights impacts

17 Managing potential adverse impacts in our own operations: Danske Bank as employer and service provider

21 Managing potential adverse impacts in our value chain: Danske Bank as lender, investor and procurer

Combatting modern slavery and human trafficking as a financial crime

1. How human trafficking is investigated as an underlying crime to money laundering
   Grievance mechanisms and remediation
2. Our group whistleblowing scheme and reporting platforms for employees Customer complaints management

Looking ahead

31 Future actions to be taken to strengthen our human rights efforts

3 Human Rights Report

Contents

Message

The Norwegian

About

Our

Human rights governance

Key focus

Measures

Own

Value

Combatting human trafficking

Grievance mechanisms

Looking

from our CEO

Transparency Act

Danske Bank

commitment

and executive oversight

areas

in place

operations

chain

as a financial crime

and remediation

ahead

Message from our CEO

Dear reader,

As one of the largest Nordic financial insti- tutions, Danske Bank plays a pivotal role in supporting the sustainable development of societies and businesses. Our mission extends beyond serving our 3.2 million customers to serving societies we are part of. We aim to be a leading bank in the Nordic region in facilitating the sustainability transition. Our efforts to support a sustainable transition involve safeguarding human rights and decent working conditions. With this report we aim to provide transparency of our approach to human rights.

In 2023, we updated our Position Statement on Human Rights and published our first Human Rights Report. We implemented a human rights module for our ESG credit risk assessment to help advisers identify ESG risks associated with corporate lending activities. We also conducted enhanced sustainability screenings of selected companies potentially

involved in human rights controversies, and we excluded 26 companies due to forced labour risks. Furthermore, we developed an ESG supplier risk assessment framework to manage potential adverse human rights impacts among our suppliers.

Internally, we led a transformation of our efforts towards diversity and inclusion, creating ownership in both leadership and the business, and we set new gender diversity goals to achieve a 40% representation of the underrepresented gender across our leadership.

We are continuously striving to enhance our
human rights due diligence across all activ-
ities. As we progress with our Forward '28
strategy, we will refine our focus on human	Carsten Egeriis
rights and aim for continuous development of	Chief Executive Officer
our human rights due diligence efforts.	Danske Bank

4 Human Rights Report

Contents

Message

The Norwegian

About

Our

Human rights governance

Key focus

Measures

Own

Value

Combatting human trafficking

Grievance mechanisms

Looking

from our CEO

Transparency Act

Danske Bank

commitment

and executive oversight

areas

in place

operations

chain

as a financial crime

and remediation

ahead

Reporting on the Norwegian Transparency Act

This report outlines Danske Bank's human rights due diligence efforts following section 5 of the Norwegian Transparency Act2 (the Act), coordinated at Group level and applicable to all entities, including Danske Bank Norwegian Branch and Danske Invest Asset Management AS. The report includes content beyond the Act's scope, notably relating to Danica Pension. Activities of Danske Bank Norwegian Branch are reflected in all activities described in the report, except for those referring specifically to Danica Pension. Activities of Danske Invest Asset Management AS are covered specifically in the sections 'Danske Bank as Employer', 'Investments' and 'Procurement'.

The report captures our ongoing progress in implementing measures to prevent and mitigate adverse impacts on human rights and working conditions whilst acknowledging that there are areas in which we can improve.

Pursuant to section 5a of the Act, the 'About Danske Bank' section provides a general

description of the structure and area of operations of Danske Bank A/S, Danske Invest Asset Management AS and Danske Bank Norwegian Branch. Guidelines and procedures for handling adverse impacts on fundamental human rights and decent working conditions can be found in 'Human rights governance and executive oversight', and their applicability in relation to ceasing, preventing and mitigating adverse human rights impacts is described in 'Managing potential adverse impacts in our own operations', 'Managing potential adverse impacts in our value chain', 'Combatting human trafficking as a financial crime' and 'Grievance mechanisms and remediation'.

Pursuant to section 5b of the Act, the report addresses significant risk areas identified through due diligence. These are described as our most severe potential adverse impacts on human rights. The 'Key focus areas' section provides more details on this aspect. While we continue to evaluate all human rights im- pacts, our primary attention is on mitigating

the most severe potential risks. Upon identifying any actual adverse impacts, we act on our awareness (section 5c of the Act). This report includes case studies of incidents that have been identified and resolved in 'Managing potential adverse impacts in our value chain'. Regarding actual adverse impacts within our organisation, we identify and assess these through internal processes such as our twice-yearly employee engagement surveys, detailed in 'Managing potential adverse impacts in our own operations'.

Pursuant to section 5c of the Act, the report outlines measures in place to cease actual adverse impacts or mitigate significant risks of adverse impacts. Detailed information about these efforts and measures can be found throughout the report, including case descriptions in 'Managing potential adverse impacts in our own operations', 'Managing potential adverse impacts in our value chain' and 'Combatting human trafficking as a financial crime'.

The report also provides information about both expected and achieved results of these measures. Tracking specific results related to human rights impacts can be challenging, and we are exploring ways to address this. Future measures the Group plans to implement are detailed in the 'Looking ahead' section.

2 Act relating to enterprises' transparency and work on fundamental human rights and decent working conditions (Transparency Act)

• Human Rights Report

Contents

Message

The Norwegian

About

Our

Human rights governance

Key focus

Measures

Own

Value

Combatting human trafficking

Grievance mechanisms

Looking

from our CEO

Transparency Act

Danske Bank

commitment

and executive oversight

areas

in place

operations

chain

as a financial crime

and remediation

ahead

About Danske Bank

Danske Bank is one of the largest financial institutions in the Nordic region and has for 150 years been helping to enable growth and development across society. Over this period, we have developed in tandem with the societies we are part of, and with long-term sustainable development as our ambition, we work every day to be the best possible bank - for the benefit of our customers, employees, shareholders and the greater society.

Today, Danske Bank has over 20,000 employees in ten countries and serves more than 3.2 million personal and business customers in eight countries.3 In addition to banking services, the Danske Bank Group provides life insurance and pension products (including health insurance), mortgage finance, asset management, real estate agency services and leasing.

• Denmark, Sweden, Norway, Finland, UK, Ireland, Poland and USA.

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Danske Bank in numbers:

3.2 million+	2,000+	20,000+
personal and business	large corporate and	employees in 10 countries
customers	institutional customers
Deposits:	Assets under Management:*
>DKK 1,100 billion	>DKK 1,200 billion
Loans:	Active suppliers:	* Includes Danske Invest Asset Management AS
>DKK 1,700 billion	2,000+
and Danica Pension's assets under management

All figures are per end of 2023.

Contents

Message

The Norwegian

About

Our

Human rights governance

Key focus

Measures

Own

Value

Combatting human trafficking

Grievance mechanisms

Looking

from our CEO

Transparency Act

Danske Bank

commitment

and executive oversight

areas

in place

operations

chain

as a financial crime

and remediation

ahead

Danske Bank's organisation

CEO

Group Legal

Internal Audit

Company

Secretariat

Group Sustainability,

Stakeholder Relations,

Communications & Marketing

Personal	Business	Large Corporates	Technology &	CFO Area	Group Risk	Group	Group
Customers &	Customers	& Institutions	Services		Management	Compliance	HR
Financial Crime
Risk & Prevention

7 Human Rights Report

Contents

Message

The Norwegian

About

Our

Human rights governance

Key focus

Measures

Own

Value

Combatting human trafficking

Grievance mechanisms

Looking

from our CEO

Transparency Act

Danske Bank

commitment

and executive oversight

areas

in place

operations

chain

as a financial crime

and remediation

ahead

The following section describes three specific entities of Danske Bank. Two of these, Danske Bank Norwegian Branch and the Danske Bank subsidiary Danske Invest Asset Management AS (DIAM), are specifically highlighted in this report because they are independently subject to the Norwegian Transparency Act. Information about Danica Pension is also included here and throughout the report to reflect how we work with human rights from an insurance perspective. We provide examples of this in the 'Providing Services' section of this report under

'Own operations'.

CEO

Personal

Customers &

Business

Large Corporates

FC Risk & Prevention

Customers

& Institutions

Personal

Customers

Business Customers

Institutional

Large Corporate

Norway

Norway

Banking

Banking

Norway

Norway

The organisational charts depict how the activities of these three entities are governed as part of the Group.

Danske Bank Norwegian Branch

In Norway, Danske Bank is the third-largest bank and serves personal and business customers as well as large corporations from 28 branches and four regional finance centres across Norway.

Head of Personal Customers Norway reports to Group Head of Personal Customers & Financial Crime Risk & Prevention. In June 2023, Danske Bank announced that it

had initiated a process that will result in Danske Bank exiting the Norwegian personal customer market.

Business Customers Norway consists of six organisational units, each reporting to its respective Nordic Head, who then reports to Group Head of Business Customers. Head of Advisory Banking NO is responsible for coordinating Business Customers activities in Norway.

Large Corporates and Institutions Norway consists of Institutional Banking and Large Corporate Banking. Both ultimately report to Group Head of Large Corporate and Institutions. Head of Large Corporate Banking Norway is responsible for coordinating the activities of Large Corporates & Institutions in Norway.

8 Human Rights Report

Contents

Message

The Norwegian

About

Our

Human rights governance

Key focus

Measures

Own

Value

Combatting human trafficking

Grievance mechanisms

Looking

from our CEO

Transparency Act

Danske Bank

commitment

and executive oversight

areas

in place

operations

chain

as a financial crime

and remediation

ahead

Danske Invest Asset Management AS Danske Invest Asset Management AS (DIAM) is a Norwegian subsidiary of Danske Bank and is a licensed fund manager

of UCITS (Undertakings for Collective Investment in Transferable Securities) and AIFs (alternative investment funds). DIAM manages funds of approximately NOK 130 billion on behalf of its Norwegian customers. DIAM follows Group policies and instructions in all daily contact with institutional and professional customers. Local adaptations of policies and instructions are developed where necessary to accommodate specific local regulatory requirements.

CEO

Large Corporates

& Institutions

Danske Invest

Asset Management

Danica Pension

Danica Pension is a wholly owned subsidiary of Danske Bank, operating in Denmark and specialising in providing pension schemes, life insurance policies and health insurance cover. At year-end 2023, Danica Pension had 747,315 customers and managed pension funds of DKK 440 billion. The annual contributions to pension savings amounted to DKK 38.6 billion in 2023.

Danica Pension aims to foster a healthier society with reduced sick leave through its healthcare services which include preventive measures and treatments for physical and mental illnesses. Offerings involve health insurance, income protection, critical illness cover and the Danica Health Package. Additionally, Danica Pension enhances customers' financial security by providing personalised pension services tailored to diverse individual needs.

As part of the Danske Bank Group, Danica Pension follows Group policies and collaborates closely with other Group entities through sharing of platforms, processes and knowledge.

Danske Bank CEO

Danica Pension CEO

Sustainability

& CEO Office

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Contents		Message		The Norwegian		About	Our	Human rights governance		Key focus
	from our CEO		Transparency Act		Danske Bank	commitment	and executive oversight		areas

Our commitment

Measures		Own		Value		Combatting human trafficking		Grievance mechanisms		Looking
in place		operations		chain		as a financial crime		and remediation		ahead

Danske Bank is committed to respecting fundamental human rights and ensuring decent working conditions4, both internally and through our business relationships. We recognise our potential to cause, contribute to or be linked to adverse human rights impacts, such as how employees are treated and through our suppliers' adherence to labour rights. This extends to our lending and investment activities.

We work to identify, prevent and mitigate risks of adverse impacts on human rights, including all human rights as stated in the International Bill of Human Rights, the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. In doing so, we follow the UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises.

Moreover, as a signatory of the UN Global Compact, the UN Principles for Responsible Investment and the UN Principles for Responsible Banking, we implement commitments laid out in these frameworks. We also take note of other international frameworks

such as the Equator Principles and the UN Women's Empowerment Principles.

Beyond this, we observe state duties to protect human rights a laid out in documents such as the ILO Global Business and Disability Network Charter, Global Framework Agreement on Human Rights and Corporation with Unions and ILO Convention No 169 on Free, Prior and Informed Consent, and the UN Declaration on the Rights of Indigenous Peoples.

We continuously strive to improve our sustainability practices to meet international expectations. Key to this is safeguarding human rights by implementing measures to prevent adverse human rights impacts in our operations and business activities. We use our leverage to drive action to cease any harm we become aware of.

Our employees are expected to respect human rights in line with our Code of Conduct Policy and sustainability-related guidelines. Danske Bank's Human Rights Position Statement outlines our approach to human rights.

4 Throughout this report, all references to human rights cover fundamental human rights and labour rights, including decent working conditions.

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