INTRODUCTION

Eika Boligkreditt AS (EBK) is dependent on public trust and a good reputation. A great responsibility therefore rests on both the company and the individual employee to behave ethically towards customers, owner banks, investors, partners, colleagues and society in general. The purpose of these guidelines is to describe EBK’s ethical standards.

All employees must behave and work in compliance with applicable legislation, statutory regulations and internal guidelines. They are all expected to perform their work in an ethical and socially acceptable manner, and in line with the company’s core values of being reliable, engaged and brave.

This document sets out guidelines for ethical behaviour but cannot cover every eventuality. In each individual situation, employees must use their best judgement when assessing what is the ethical course of action. In the event of any doubt about whether an action complies with the company’s Ethical, Guidelines, the employee must refrain from taking that action or raise the matter with their immediate supervisor.

In any given situation, the ethical response is often not entirely clear cut. A useful test could be to evaluate whether the following questions may be answered with an unqualified “no”:

• Would I dislike it if management and my co-workers found out about this?
• Could this in any way undermine trust in Eika Boligkreditt or the alliance if it were to be reported in the media?
• Could the action conflict with the interests I am charged with protecting as an employee of EBK, or be perceived as a benefit I am receiving by virtue of my position?

The guidelines set out in this document apply to the company and to all employees in EBK. They also apply to directors and others with an elective office, contract personnel, consultants and others acting on behalf of EBK (in the following referred to collectively as employees). The guidelines apply to ethical issues related to commercial practice, risk-based thinking and personal behaviour.

Each employee undertakes to familiarise themselves and comply with the ethical guidelines, and has an independent responsibility to behave in a manner which accords therewith.

THE WORKPLACE AND COMMERCIAL BEHAVIOUR

For EBK, it is important to have a strong culture which promotes risk-based thinking. This is reflected in the company’s strategy, the purpose of which is to provide – in part through high-quality risk management – long-term and competitive financing to the owner banks, and thereby reduce their risk exposure.

The company’s framework for management and control will lay the foundation for the desired risk culture.

COMMUNICATION AND TRANSPARENCY

The company is dependent on good communication in order to establish a good working environment and to lay the foundation for good decisions. That means honesty and clarity and a high degree of openness. Representatives of EBK are expected to use clear and simple language in all their contacts with the owner banks, end customers, investors and partners. However, openness must not be pursued at the expense of the necessary confidentiality.

The basic rule is that the CEO will deal with the media on matters concerning the company. However, the CEO can decide that the matter will be dealt with by others. The CEO can appoint other senior executives to comment, for example, on the company’s transactions, funding work and so forth. The CEO is responsible for ensuring that clear parameters are established for dealing with the media.

What we do in EBK must stand up to close scrutiny. It is therefore important that assessments are documented to enable any choices and decisions to be explained at a later date.

Reporting to the authorities and rating agencies is intended ensure transparency and is conducted in accordance with legislation, industry standards and the company’s reporting policies. Complete, accurate and objective reporting is important for maintaining the reputation of and trust in the company.

DUTY OF CONFIDENTIALITY

Confidentiality is an important precondition for trust. Rules on the duty of confidentiality are intended to ensure than confidential information is not misused or goes astray. Unless otherwise provided by law or regulation, the duty of confidentiality applies to all employees.

Employees have a duty of confidentiality concerning all matters which they become aware of relating to customers, as well as to EBK internally and sensitive information about EBK’s business operations. Confidential information must therefore be obtained and stored in a way which minimises the threat of it being disseminated. The duty of confidentiality also applies internally, which means employees are not permitted to disclose more information to colleagues than those individuals need to do their jobs.

Confidential information must be obtained and stored in a way which minimises the threat of it being disseminated.

Both the duty of confidentiality and the employee’s duty to act in good faith require that internal matters must not be discussed externally in a manner which appears disloyal or harmful to EBK or the alliance. Employees’ duty to act in good faith also requires them to refrain from making unwarranted negative comments about their employer or the business. The above does not impact an employee's right to report suspicions of wrongdoing within the organisation (whistleblowing).

The employee’s duty of confidentiality continues to apply after the employment relationship has come to an end.

The scope of the employee’s duty of confidentiality is set out in the non-disclosure agreement they signed when they joined the company. If an employee has any doubts concerning the extent of their duty of confidentiality, they should contact the Legal Affairs Department/General Counsel for advice.

REPORTING OF WRONGDOING (WHISTLEBLOWING)

Openness and good communication in the organisation strengthen its work culture. EBK therefore wishes to facilitate a corporate culture where wrongdoing (also known as censurable conditions) and irregularities are reported, discussed and resolved. Internal whistleblowing procedures help to reinforce a culture of openness, characterised by trust and dialogue between management and staff. EBK recognises that there is a risk its ethical guidelines may be breached, and depends on employees reporting suspected wrongdoing and irregularities so that the company can maintain a high ethical standard. All employees must be aware of, and if necessary utilise, the company’s guidelines for reporting suspected wrongdoing (whistleblowing).

DATA SECURITY AND PRIVACY

All employees must be familiar with the company’s guidelines for the use of information technology, including the ICT instructions and guidelines for data security. Caution must be exercised with respect to how, where and with whom information is shared.

EBK primarily processes personal data about the company’s residential-mortgage holders and its own staff. Employees who process personal data must do so in a way that safeguards the privacy of the data subject in accordance with prevailing law. They must be aware of and undertake to comply with the company’s guidelines and routines for processing personal data.

CORPORATE SOCIAL RESPONSIBILITY AND THE ENVIRONMENT

The Eika Alliance comprises several local banks, Eika Gruppen and Eika Boligkreditt AS. As an important player in the Norwegian financial market, the Alliance has a responsibility to be conscious of its corporate social responsibility (CSR). The banks exercise this responsibility by being an important contributor to their local communities.

EBK can contribute by making sustainable choices as a bond issuer. Employees must be aware of the impact that their behaviour and decisions may have on the environment. Environmental assessments and costs should be taken into account where they are relevant.

MEASURES TO COMBAT MONEY LAUNDERING AND THE FINANCING TERRORISM

As part of its CSR, EBK must have effective measures in place to combat money laundering and the financing of terrorism. The purpose of these measures is to protect the integrity and stability of the international financial system, undermine the funding of terrorism and make it more difficult for criminals to profit from their crimes. EBK has established a programme of measures to combat money laundering and the financing of terrorism in line with the legislation governing this area.

PERSONAL BEHAVIOUR

RESPECT, COURTESY AND LOYALTY

All employees are expected to behave politely and respectfully to each other in order to create the best possible working environment, free from gossip, bullying, undue pressure or other negative aspects. EBK does not accept any form of harassment, discrimination or other behaviour which could be perceived as threatening or demeaning. It is also important that employees behave in good faith, which means that EBK, the owner banks or Eika must not be spoken of in a negative manner or in a way that does not accord with the alliance’s strategy and culture.

[Representatives of EBK are expected to use clear and simple language in all their contacts with the owner banks, end customers, investors and partners.]

Managers in the company have a particular responsibility where ethical issues are concerned. They must be extremely self-aware and conscious of their own actions. They must also behave in such a manner that no employee is given justifiable grounds for feeling aggrieved due to the way they are treated or breaches of established rules and norms.

FINANCIAL MATTERS AND TRADING IN FINANCIAL INSTRUMENTS

Employees must keep their private financial affairs in order.

Neither employees nor any closely related party may receive loans from EBK except on market terms. Employees must not carry out transactions or make changes to their own loan accounts or to loan accounts of which they are a co-holder. The same applies to loan accounts belonging to employees’ related parties.

In the Guidelines for Handling Conflicts of Interest, EBK has imposed certain restrictions on employees’ trading in financial instruments. The purpose of these restrictions is to achieve compliance with the above, as well as to avoid potential conflicts of interest and ensure that the company and its employees comply with applicable rules relating to securities trading. This also includes insider trading. Employees must not engage in any trading activities in violation of these guidelines or the prohibition on insider trading laid down in the Norwegian Securities Trading Act (Verdipapirhandelsloven).

COMPETITION AND ELECTED OFFICES

Employees are not permitted to engage in activities in competition with EBK or businesses in the Eika Alliance. Nor are employees permitted to engage in other private commercial activities or be a responsible officer or director of a company which engages in such activities, without specific consent having been granted. Employees may not take paid employment outside the company, unless they have been granted specific consent to do so.

EBK supports its employees taking on voluntary roles/elected offices in associations or clubs in their spare time, as long as this does not interfere with their work for the company.

FINANCIAL CRIME

Pursuant to Norwegian law, fraud, embezzlement, corruption and influence peddling, as well as aiding and abetting in these activities, are criminal offences.

Corruption covers the offering and receiving of an improper benefit by virtue of one’s position, office or assignment. Influence peddling covers both providing/offering and demanding/receiving/accepting an improper benefit for the purpose of influencing how a person undertakes their work. Such illegal influence peddling may occur in situations where a person claims to be able to influence a decision-maker, and uses this position to demand or receive improper benefits.

Any employee who becomes aware of or legitimately suspects that someone in EBK’s service is involved in financial crime has a duty to immediately report the matter to their supervisor.

GIFTS

No employee may give or receive any form of improper benefit – directly or indirectly – on the occasion of or in connection with EBK’s financial business activities or by virtue of or in connection with their employment with or any assignment for EBK.

An improper benefit could be of financial value or have some other utility value. These guidelines apply equally to gifts given to employees’ related parties if the gift or benefit must be presumed to relate to the employment status of the employee.

This does not apply to gifts given by the employer or other employee benefits negotiated by EBK or Eika Gruppen.

Particular caution must be exercised in connection with road shows, investor or broker contacts, bidding processes and negotiations, and/or transactions.

Anyone who is uncertain where the boundaries are set in this connection should raise the matter with their immediate supervisor. Examples from Appendix 1 may be used as an aid in assessing what constitutes an improper benefit. Employees must be open about gifts received, and gifts and benefits which fall into the category “Need careful consideration” in Appendix 1 must be reported to the Compliance Department.

Gifts/benefits must also be reported in accordance with applicable tax rules.

Gifts that have been received and deemed improper must be returned to sender. If it is not possible to return the gift, it must be surrendered to the employer.

Bonus/loyalty points or the like earned in connection with business travel or work-related expenses are expected to be applied, as far as possible, to the payment of job-related expenses.

IMPARTIALITY AND CONFLICTS OF INTEREST

Employees have a duty of loyalty to the company, including a duty to behave in conformity with EBK's interests. No employee may participate in or seek to influence a decision if conflicts of interest could arise or if their impartiality could be called into question. Conflicts of interest may arise when the company’s interests and those of the individual do not coincide. That could occur as the result of a family relationship, close personal ties or financial or other interests, including shareholdings or a directorship in the company, team or association concerned in the matter. A fundamental norm is that the company's interests shall motivate any decision that is made.

Employees must not consider or make decisions on matters concerning their related parties,[1] or matters in which related parties have financial interests. Employees must also exercise caution when making decisions relating to people whom they know personally.

Senior executives must report to the board if they have a significant interest, directly or indirectly, in a contract or agreement being entered into by the company.

Employees who are related parties to each other must not have positions where one is the direct supervisor of the other. Situations in which one employee exercises control functions over a related party must also be avoided.

Should doubt exist about whether a loss of impartiality or a conflict of interest could arise, the employee must always submit the issue to their immediate supervisor. That is not only to protect EBK’s interests, but also to protect the individual from unjustified suspicion of improper behaviour. Employees must be aware of and undertake to comply with the company’s guidelines covering conflicts of interest.

[1] Related parties as defined in section 2-5 of the Norwegian Securities Trading Act.

REPRESENTING THE COMPANY

All contact with customers, representatives of the public authorities and business associates must be linked to EBK's business operations and be characterised by professionalism, integrity and respect. There must be no occasion to doubt either the employees’ impartiality or EBK’s motives and integrity. Employees who act on behalf of EBK must do so in a way that reflects EBK’s values and that does not undermine EBK’s reputation. When employees are travelling in connection with their work, they are deemed to remain a representative of EBK after the end of normal working hours.

REIMBURSEMENT OF EXPENSES

As a general rule, EBK pays for its own employees’ travel expenses (transport, accommodation, food and beverages).

An exception may be made, with the agreement of the employee’s immediate supervisor, in connection with assignments of a purely professional nature. Examples include speaking or course-holding engagements where the commissioning entity defrays all the costs, light refreshments provided in connection with work-related meetings, and anniversary-related events/celebrations.

As a general rule, customers and business associates pay for their own travel and accommodation. An exception may be made in cases where the individual concerned is contributing to competence or business development at EBK.

Certain gifts/trips will be taxable for the recipient. This will typically occur when a trip does not have a sufficient amount of professional content and therefore more closely resembles a holiday, as well as prizes/gifts that are of a private nature. Any benefit obtained through work is taxable. A careful assessment must be made of whether the recipient will be taxable for any gift/trip/expenses paid. The recipient must always be informed in advance of any potential tax liability.

The payment of expenses must always be approved in advance by the employee’s immediate supervisor.

All payment of expenses must be recorded via Eika’s expenses portal.

FOLLOW-UP

The effectiveness of the company’s ethical guidelines depends entirely on each individual employee continuously assessing their circumstances in relation to the rules. All managers have a special responsibility for ensuring that their own behaviour and that of their subordinates complies at all times with the ethical guidelines set out in this document. Executive management conducts continuous assessments of the appropriateness of these rules, and proposes amendments when these are considered necessary.

The Compliance Department has a responsibility to monitor compliance with the guidelines, maintain a register of reported gifts and benefits, and ensure that breaches of the guidelines are reported to the board.

Violation of the ethical guidelines and/or non-compliance with prevailing laws and statutory regulations may incur civil (employment law) or criminal liability.

APPROVAL OF THE ETHICAL GUIDELINES

This guideline was approved by EBK’s board of directors on 12 November 2024 and are made applicable for all employees from the same date.