Value-based behaviour and management

Policies and guidelines

At Jyske Bank we have policies and guidelines to ensure that the Group and our employees act in accordance with our values, applicable legislation and with regard to clients, employees and shareholders.

Policy on sustainability and corporate social responsibility

Compliance

Policy on the prevention of money laundering, financing of terrorism and violation of sanctions

Jyske Bank runs a high, inherent risk of being abused for purposes of money laundering or financing of terrorism. The reason is our size as well as our business model, which involves a number of products and clients with high inherent risk.

Therefore our efforts to prevent money laundering and the financing of terrorism have been given the highest priority. We aim in all respects to prevent money laundering and financing of terrorism in order to fulfil the expectations of our clients, government authorities and society in this area. Such prevention is ensured through, among other measures, continuous training and education of employees, clear processes and guidelines, systematic monitoring and reporting.

Anti-bribery and anti-corruption policy

At the Jyske Bank Group, we accept no forms of corruption or other improper business practices. Corruption includes bribery, fraud, embezzlement and extortion and does not necessarily involve transaction of money. Corruption can also comprise the performance of services to gain benefits, such as preferential treatment and shorter processing times.

Similarly, as applies to the rest of the financial sector, there is a risk that the Jyske Bank Group can be exposed to corruption and our employees can also make use of corruption.

The purpose of our anti-bribery and anti-corruption policy is to clearly set out our expectations as regards the conduct of all employees encountering bribery or corruption in their working lives. Our anti-bribery and anti-corruption policy fulfils our obligations in relation to UN Global Compact.

Read our anti-bribery and anti-corruption policy [PDF]

Policy on insider dealing

The Jyske Bank Group has established detailed policies and business procedures for handling internal knowledge. Training in risks, rules and procedures is mandatory for employees in functions involving high risk for contact with clients who may be involved in insider dealing.

Jyske Bank’s policy on insider dealing is accessible for all persons internally in the Group.

Whistleblower policy

The Jyske Bank Group has created a whistleblower programme under which employees can anonymously file reports in the event of – or suspicion of – violations of EU law, the financial regulation, other serious violations as well as other serious matters to be investigated further by the Jyske Bank Group.

Jyske Bank’s whistleblower policy is accessible for all persons internally in the Group.

Read an extract from our whistleblower policy.

Tax policy

The Jyske Bank Group’s Tax Policy

Behaviour

Responsible marketing policy

Read our Responsible marketing policy [PDF]

Policy promoting a healthy corporate culture

The purpose of our policy promoting a healthy corporate culture is to ensure and further a healthy corporate culture characterised by high ethical and professional standards.

At the Jyske Bank Group, we will, for instance, not accept that Jyske Bank is in any way abused for white-collar crime. It is our ambition to run a business that acts responsibly.

No client or any business partner is so valuable or important that we will compromise on these principles, which are for this reason put above earnings. Therefore Jyske Bank does not wish to enter into client relationships, where no clear and natural purpose of the cooperation has been established.

Read our policy on corporate culture [PDF]

Competence requirements, good practice and ethical conduct

Read our guidelines for competence requirements, good practice and ethical conduct [PDF]

Human rights

International human rights – which are firmly established in Denmark’s labour-market model and laid down in international conventions, standards and values – constitute a natural foundation for the Jyske Bank Group’s activities and endeavours.

In specific terms, this means that we observe human rights internally in the Group, because they form the basis on which a safe, just and fair society rests, where the values of equal rights, inclusion, labour rights, safety and health are embedded in our policy.

Externally, we observe human rights via our screening of investments for our clients, based on ESG principles, and through our supplier management, in which compliance with human rights is a key marker.

HR policy

In the Jyske Bank Group, we want to be a workplace that creates lasting relationships in a productive, trusting and informal work environment characterised by well-being and positive energy. It is an important principle for us to show corporate social responsibility within the limits set by the market economy under which we operate.

In a cooperation between management and employees, we continuously develop new initiatives to ensure a good and healthy workplace. We want to give our employees the opportunity to develop professionally, personally and in terms of leadership, making them attractive and valuable in the job market. We are aware that our corporate social responsibility is largely about providing access to jobs and training, including for young people.

We believe that diversity in the workforce creates results and development. Our undertaking largely reflects the surrounding world, by virtue of the fact that our employees represent a multitude of educational backgrounds, ages, genders, dwellings, personalities, cultures and experience.

We work with and involve our employees’ union representatives in important employee matters, both ad hoc and via the formal cooperation bodies, and we fully respect employees’ right to organise.

Policy for handling conflicts of interest

The objective of the policy for handling conflicts of interest is to ensure that conflicts of interest are identified, prevented and managed to safeguard the interests of our clients in the best possible way. This in connection with the Jyske Bank Group providing investment services and ancillary services.

Read our policy for the handling of conflicts of interest (in Danish) [PDF]

Diversity policy

The objective of Jyske Bank’s diversity policy is to ensure that the Group always has the best possible managers and employees with both good personal qualities and necessary professional competencies.

The Group strategy is based on the acknowledgement that committed, competent, dynamic and responsible employees are important prerequisites for the success of the Jyske Bank Group. The diversity policy supports the strategy by ensuring that all competent candidates can come into play when filling vacancies without regard to gender, age, ethnicity, religion or other factors that have no bearing on the candidate’s ability to perform the duties of the job.

According to Danish law, the policy and the activities related to it focus especially on improving opportunities for the underrepresented gender and on efforts to increase the number of female managers at all levels until both genders are equally represented.

Read our diversity policy [PDF]

Policy for Data Ethics

Data is to a high extent a basis of the Jyske Bank Group’s business and is part of most interactions with our stakeholders. Our policy for Data Ethics must render visible that the data ethical values are anchored in our business processes and in the management’s and the employees’ use of data.

The data processed by the Jyske Bank Group consists to a high extent of personal data of which the major part derives from clients whereas a minor part derives from employees and other groups. The use of client data compared with data on products and services, prices and business rules is a basic condition for our business model. Therefore, it is crucial for the Jyske Bank Group that clients must feel confident that our processing of these data takes place with respect, diligence and in accordance with legislation.

Data ethics must balance many considerations against each other, and it is our declared target that our clients are confident that the Jyske Bank Group balances the considerations against each other in a way which is appropriate for the client.

The Jyske Bank Group’s policy for data ethics is accessible for all persons internally in the Group.

Procurement

Green procurement of IT hardware

The Jyske Bank Group has ambitions of ensuring that all IT hardware is Energy Star qualified.

Get an overview of IT hardware at Jyske Bank [PDF]

Supplier Code of Conduct

The purpose of "Aftale om ansvarlig leverandøradfærd" (Supplier Code of Conduct) is to establish a formal framework agreement between the Jyske Bank Group and its suppliers. The agreement shall make it possible for both parties to cooperate and endeavour to show responsible supplier conduct throughout the entire distribution chain involved in the procurement of the products and/or the payments to the purchaser.

Aftale om ansvarlig leverandøradfærd (in Danish)

Investment

Policy for responsible and sustainable investment

At the Jyske Bank Group, we consider it our primary responsibility, in the best way possible, to optimise the return for our investors. We assume corporate social responsibility in relation to its investments, which means that environmental, social and governance (ESG) issues are taken into consideration in the investment decision process.

The basis of the Jyske Bank Group’s work with responsible investment is UN PRI’s Principles for Responsible Investment (PRI). UN PRI is a joint declaration on taking corporate social responsibility in connection with investments and compliance with six central principles for responsible investments.

Read about our policy for responsible investment

Statement of changes to policy for responsible and sustainable investment

Sustainability considerations relating to Jyske Bank's own investments

Jyske Bank will always need a large, strategic investment portfolio. The primary purpose of the portfolio is to have a large statutory liquidity buffer. However, every now and then, the investment portfolio will be larger than the statutory liquidity buffer. This will be the case, especially when the bank’s deposits significantly exceed loans and advances. Therefore, when the bank has an ample liquidity, investment will also be made in securities that are not directly included in the statutory liquidity buffer. Such investments comprise various types of securities.

Liquidity buffer
The majority of Jyske Bank's liquidity buffer consists of investments in Danish mortgage bonds. The majority of these primarily finance Danish properties, secondarily Danish agriculture and a small proportion shipping industry. Because of the focus on Danish mortgage bonds, our liquidity buffer will generally be at a relatively low level in relation to CO2 emission intensity. We integrate CO2 in our investment decisions by considering the exposures on a sector basis, of course under due regard to current liquidity requirements. Our projections indicate that CO2 emission relating to our investments in Danish mortgage bonds can be reduced by 40% over the period from 2019 to 2030. The reduction is primarily expected to be achieved because of lower emission factors from the Danish housing stock due to improving Energy Performance Certificates and a higher degree of renewable energy supply. If the projection is realised, no significant changes are to be expected in the bank’s exposure to mortgage bonds.

The remaining part of the liquidity buffer is invested in bonds issued by European governments or other public sector entities. Therefore, the portfolio generally supports societal needs. Moreover, to a modest degree, the portfolio includes specifically sustainable bonds.

The remaining part of the strategic investment portfolio
The part of the strategic investment portfolio in excess of the bank’s liquidity buffer consists mainly of corporate and mortgage bonds in the form of CLOs, which are portfolios of underlying corporate loans selected and managed by an external fund manager. In connection with new investments, the fund manager’s handling of ESG issues is an important component. Hence it is a condition for investments that fund managers, by using either external or internal sustainability ratings, structurally address all three components of sustainability when composing a portfolio.

The investment portfolio contains a limited number and to a limited extent corporate bonds. In the specific cases, the same standards will apply when assessing ESG issues as the ones applied to the Group’s loans and advances.

Jyske Bank has made the strategic choice not to include individual shares in its investment portfolio, and therefore no sustainability guidelines apply to shares, and as Jyske Bank has generally opted out of such investments, exposures to controversial sectors and companies will be avoided.

For risk management purposes, Jyske Bank may now and then have limited positions in equity indices. Due to the nature of exposures at index level, the bank uses the most liquid indices and, for the time being, there is no particular sustainability focus on this part.

IT security

IT security policy

The purpose of Jyske Bank’s IT security policy is to ensure that a high level of IT security is implemented and maintained at the Jyske Bank Group, also entailing that principles and requirements of IT security management and IT risk management are defined to ensure that the level of IT security and the desired risk profile in the IT area can be adhered to.

The IT security level must be based on the Jyske Bank Group’s ambition to obtain and to maintain a level of security that is sufficient to handle the current cyber threat with elements that are ‘best in class’. In addition, the security level must ensure that the risks that are assumed and expected to be assumed in consequence of the IT use are at a level that is acceptable to the Jyske Bank Group.

Read our IT security policy [PDF]

Privacy policy

When processing data given to the Jyske Bank Group, confidentiality is ensured in accordance with the Danish Financial Business Act, the General Data Protection Regulation, the recommended guidelines of the Danish Data Protection Agency and Dealing with Jyske Bank - General Terms and Conditions. The data are used exclusively to comply with the client’s enquiries and requests and to offer the best possible service. You can rest assured that we will not ask you for more information than required for the particular purpose.

Read our privacy policy

Credits

Credit policy

Financial enterprises constitute an important part of the Danish economy, and the Jyske Bank Group therefore has a responsibility when granting credit. We are in the money lending business, but we also need to have the money repaid. In other words, our interests converge with our clients’ interests.

Before making products available to our clients, we identify our clients’ needs and requirements. If this involves a loan, we conduct a credit rating of the client’s financial situation to ensure that the client can repay the loan.

We base our assessments on the Jyske Bank Group’s credit policy, specifying principles as to how to ensure that credit decisions are adequately based on the soundness of the client’s future earnings and liquidity. This means that we do not simply wish to sell the largest possible loan. It must be granted within a realistic framework, whereby the clients can repay the loan, but also have a disposable amount which is enough to live on. The above principle is not just good business ethics, but also responsible credit granting.

The Jyske Bank Group’s credit policy is accessible for all persons internally in the Group.

Remuneration

Remuneration policy

The objective behind the Jyske Bank Group’s remuneration policy is that leaders and employees have a mutual understanding and acceptance of the fairness of the level of remuneration.

The purposes of the remuneration policy are to:

reward value-creating, competent and responsible conduct,
support productivity and job satisfaction,
promote sound and efficient risk management,
ensuring proper focus on sustainability and corporate social responsibility,
prevent conflicts of interest and strengthen the obligation to act in the best interest of the clients,
ensure equal pay for equal work.

Moreover, the remuneration policy and the way in which it is implemented observe all relevant demands laid down in legislation in force from time to time.

Read our report on remuneration [PDF]

Read our remuneration policy [PDF]

Description of changes to the remuneration policy [PDF]

Policy for freedom of association and collective agreements

88% of the employees of Jyske Bank in Denmark are covered by the collective agreement which describes employees’ basic rights and deals with issues such as working hours, salary compensation, holiday leave, illness, etc. Add to this a further 8% whose individual contracts have provisions referring to the terms and conditions of the collective agreement.

Read the collective agreement here (in Danish) [PDF].

Code of conduct