Årsredovisning 2025

Nordea Annual Report 2025 84
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Sustainability-focused investment offering 
As the largest financial services group in the Nordics, we 
can have a positive impact through the ESG-focused 
investment advice, products and support we offer to 
customers. 
Nordea Sustainable Selection is the name for our fund 
offering with enhanced sustainability criteria. It was estab-
lished in 2018 to help our Nordic customers navigate the 
wide variety of sustainability-focused products available in 
the market. The offering is based on a framework where 
both the product provider and the product itself need to 
fulfil a set of sustainability criteria, and includes both 
Article 8 and Article 9 products as set out in the EU 
Sustainable Finance Disclosure Regulation (SFDR). In 2024 
we launched a new product category called Sustainable 
Selection Improve. Products in this category have a strong 
focus on active ownership and the portfolio companies 
have clear and measurable engagement targets to 
improve their sustainability profiles. We will continue to 
develop and grow our sustainability-focused product 
offering as the market matures and new customer 
demands emerge. 
In 2022 we set a target for gross inflows into Nordea 
Sustainable Selection funds to reach 33% of total fund 
gross inflows by 2025 as a means of contributing to our 
2030 climate target to reduce emissions in the investment 
portfolio by 40–50% compared with 2019 levels. By the 
end of 2025 the share of gross inflows into Nordea 
Sustainable Selection funds amounted to 22%. The share 
of gross inflows into Nordea Sustainable Selection funds 
in Personal Banking was 34%, but we were not able to 
meet the target in other internal distribution channels as 
customer preferences for Sustainable Selection products 
had not developed in line with the assumptions made at 
the time the target was set. We are still on track to meet 
our climate targets for 2030. Our climate targets are fur-
ther described in “E1 Climate change”. 
Sustainability-focused investments
2025 2024 2023
SFDR Article 9 products1
AuM in EURm 12,461 12,760 13,113
Share in relation to total AuM in 
NAM (%) 3.8 4.5 5.2
SFDR Article 8 products2
AuM in EURm 227,347 199,895 160,860
Share in relation to total AuM in 
NAM (%) 70.0 69.9 64.1
Nordea Sustainable  
Selection products
AuM in EURm 93,936 82,591 60,290
Share in relation to total AuM in 
NAM (%) 28.9 28.9 24.0
Gross inflows into Nordea 
Sustainable Selection universe (%)
3 22 23 22
1) Products with sustainable investment as their objective.
2) Products that promote environmental and/or social characteristics.
3) 2025 target: gross inflows from the Nordea Sustainable Selection universe to 
account for 33% of total fund gross inflows.
Sustainable funding 
Our sustainable and sustainability-linked finance products 
are central to the incorporation of ESG factors into our 
funding and liquidity strategy as they enable sustainable 
investment options for pension funds and other bond 
 buyers. Our green funding framework and sustainability- 
linked loan funding framework define the assessment cri-
teria and practices for managing proceeds and thus fur-
ther support the integration of sustainability-related con-
siderations into our core operations. In 2025 we issued 
more than EUR 5bn in sustainable funding across five cur-
rencies, bringing the total outstanding sustainable issu-
ance to above EUR 17bn. 
Green bonds tend to have lower yields and attract 
stronger investor demand than conventional bonds. The 
cost of fund benefit or “greenium” that we receive for 
green bonds is transferred to the business areas on a 
quarterly basis.
2023–25 targets Status
Facilitate more than EUR 200bn in sustainable financing during the period 2022–25. Target met
Grow gross inflows from the Nordea Sustainable Selection universe so as to account  
for 33% of total fund gross inflows by the end of 2025. 22%

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Nordea Annual Report 2025 85
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont. 
Our value chain
Nordea
Capital and liquidity
Goods and services
Investments 
Investees
Deposits 
Customers
Funding and treasury  
Investors
Financial products  
and services
Lending 
Customers
Procurement 
Suppliers and partners
Services 
Customers
Internal functions and controls
Broader society and supervisory authorities
Upstream 
Products & services purchased
Downstream
Use of products & services 
Own operations
Internal functions, governance and controls
Workplace
Data and technology
Employees
Business model and value chain 
We are the leading financial services group in the Nordics. 
In 2025 we were present in 20 countries, including our four 
Nordic home markets – Denmark, Finland, Norway and 
Sweden. With our financial strength and strong market 
position, we can have a considerable impact through our 
operations and value chain.
As a financial institution, we act as an intermediary 
between, on the one hand, stakeholders with excess capi-
tal, such as investors and depositors, and on the other, 
households and corporates with capital needs. We create 
value by facilitating the interaction between the parties 
involved through financial services, for example payment 
solutions and advice. Efficient channelling of capital can 
support economic growth while helping our customers 
realise their dreams and aspirations. 
We have a well-diversified universal banking business 
model. As its starting point, our business model is aimed at 
enabling:
• customers to rely on us to support their financial needs
• investors to look to us to pay consistent and attractive 
dividends
• employees to enjoy productive careers with us
• local communities to benefit from the role we play in 
them.
Our upstream value chain is characterised by goods and 
services purchased by us and capital and liquidity pro-
vided to us. Own operations are characterised by internal 
functions, governance and controls – including physical 
workplaces, data and technology, and employees. Our 
downstream value chain is characterised by financial 
products and services that we provide directly to custom-
ers, including banking products, capital market products, 
savings products, asset management services, and life and 
pension products.
We maintain a broad and diverse shareholder base, 
which includes global and Nordic institutional sharehold-
ers, over 590,000 private individuals across Nordic coun-
tries, and numerous pension fund investors representing 
the interests of millions more individual investors. 
For us, close collaboration with suppliers is critical to 
our ability to provide customers with high-quality prod-
ucts and services, and thus to our success. The most 
significant supplier categories, based on the amount 
spent, are IT; people, insurance and legal; and premises 
and facility management. 
Our treasury function is responsible for funding and 
liquidity management, and the related market risks on the 
balance sheet. The aim is to ensure a strong and sustaina-
ble balance sheet that is compliant with regulations, while 
managing our net interest margin within the overall risk 
appetite and supporting the business areas’ ability to 
serve customers in the best possible way. As part of our 
funding operations, we issue long-term debt instruments, 
including green and sustainability-linked bonds, which are 
usually listed on public stock exchanges and held by vari-
ous institutional investors globally.
Each of our business areas is responsible for providing 
services to its customer segments and is fully accountable 
for its income, costs, risks, customer experience, invest-
ment decisions and capital management. The business 
areas are united under a single pan-Nordic operating 
model and share the same Group functions, which ensures 
optimal delivery and a competitive cost structure. 
Alongside increasing accountability, the model ensures we 
can effectively serve customers who may interact with us 
in different capacities – whether as private individuals, 
business owners or clients building their financial portfo-
lios. Our head count by geographical area is presented in 
“S1 Own workforce” on page 164. 
Our products and services comprise a broad range of 
household banking services, including mortgages and 
consumer loans, credit and debit cards, and a wide selec-
tion of savings, life insurance and pension products. In 
addition, we offer a wide range of corporate banking ser-
vices, including business loans; cash management, pay-
ment and account services; risk management products 
and advisory services; debt and equity-related products 
for liquidity and capital raising purposes; corporate 
finance; institutional asset management services; and cor-
porate life and pension products. We also distribute gen-
eral insurance products. Our revenue is presented in the 
financial statements on page 195.

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Nordea Annual Report 2025 86
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont. 
Interests and views of stakeholders 
We are committed to building and maintaining strong and 
trusted relationships with our stakeholders. To this end, we 
continually seek insights into their expectations and 
respond in a timely manner with relevant actions and 
engagement. Our interaction with stakeholders informs our 
sustainability priorities and related projects and changes to 
processes. For instance, we draw on stakeholder input in 
our financial materiality assessment of climate- and 
nature-related risk drivers, the outcome of which informs 
our governance, internal processes, internal rules and busi-
ness plans and thus supports the development of sustaina-
ble business strategies and risk management throughout 
the organisation. This way, stakeholder interaction ulti-
mately informs, for example, our internal capital allocation 
and the measures we implement to reduce the risk of 
customers being exposed to fraud. The double materiality 
assessment (DMA) and related stakeholder engagement 
were important input for the updated strategic sustainabil-
ity priorities developed in 2025. For more information on 
climate- and nature-related risk drivers, see “E1 Climate 
change” on page 110 and “E4 Biodiversity and ecosystems” 
on page 151. For more information on fraud prevention, see 
“G1 Business conduct” on page 175.
The interests and views of stakeholders are shared with 
the Board of Directors and the Group Leadership Team 
(GLT) as an integral part of our sustainability work. See 
pages 88–90 for further details on how sustainability top-
ics are addressed by the Board of Directors and the GLT. 
Stakeholder engagement
Who they are What they expect How we engage Our actions
Customers
• Households
•  Small and medium-sized companies
• Large corporates and institutions
• High net worth individuals
• Convenient and easy access to personalised, expert 
advice
•  A broad range of competitive financial products and 
services 
• Support in making sustainable choices 
• Sustainable financing 
• A safe and trusted financial partner 
• Collecting customer feedback through advisory and 
digital channels, including complaint mechanisms 
• Engagement with corporate customers on ESG factors in 
general and net zero transition in particular 
•  Engagement through industry organisations on sector-
specific topics
• Expanded range of products and services and improved security for customers 
• Focused on providing consistent omnichannel experience to improve customer satisfaction 
•  Provided learning opportunities in local communities to promote financial well-being and support 
customers with less digital experience 
• Engaged with and supported customers in their net zero transition planning 
•  Assessed customers’ sustainability preferences and further expanded the Nordea Sustainable 
Selection offering 
• Improved industry credit policies to address sector-specific topics
Employees
• Approximately 29,000 full-time 
equivalent employees from all over 
the world
• A responsible employer
• Fair employment terms 
• Professional development opportunities 
• A productive, healthy and safe working environment 
• A diverse and inclusive workplace 
• Recognition 
• Highly competent colleagues 
• High-quality and authentic leadership
• Quarterly People Pulse employee engagement surveys 
•  Performance, learning and development (PLD) dialogues 
and development plans 
• Cooperation with employee/union representatives 
• Employee resource groups 
• Clear expectation setting through our Code of Conduct 
• Training and learning 
•  Leaders and leadership
• Closely tracked employees’ perception of Nordea in various areas, including working conditions, 
learning and development and diversity and inclusion, through quarterly People Pulse surveys 
•  Held regular PLD dialogues, created development plans and provided relevant learning curricula to 
support professional development 
•  Maintained a hybrid working model, enabling employees to combine working together at the office 
with working from home 
• Set targets to further improve gender balance and employee perception of diversity and inclusion 
•  Continued to implement our leadership principles to guide leaders’ everyday work, including 
fostering inclusion 
•  Further improved our occupational health and safety management system to strengthen our 
approach to providing a great working environment 
• Made progress towards our ambition and carried out targeted actions to help close the gender pay 
gap

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Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Who they are What they expect How we engage Our actions
Investors
• More than 590,000 private 
shareholders across the Nordics
• Large institutional investors
• Debt investors
• Rating agencies
• Strong financial performance
• Long-term growth 
• Shareholder returns 
• Long-term business strategy 
• Timely and transparent communication 
• Sustainability commitments
• Investor calls, meetings and conferences 
• Annual General Meeting (AGM)
• Quarterly and annual reporting 
• ESG ratings
• Held our Capital Markets Day to introduce and explain our new business strategy to the investment 
community
• Held individual investor meetings, ran questionnaires and hosted our AGM to gain insights into 
expectations and needs 
• Incorporated additional sustainability disclosures into our quarterly and annual reporting 
• Improved ESG rating scores 
• Continued to implement share buy-backs, supported by our capital and dividend policies
Suppliers
• Close to 1,600 contracted suppliers • Adherence to contractual terms
• Timely payment
• Responsible buyer behaviour
• Dialogue with prospective and existing suppliers through 
contracting and monitoring 
• Clear expectation setting through our Supplier Code of 
Conduct 
•  Engagement with suppliers in high-risk and high-impact 
sectors
• Continued to work towards common targets in areas such as net zero transition, human rights and 
labour rights
•  Conducted an in-depth human rights impact assessment of the technology sector to identify and 
assess impacts on people
•  Implemented a tool to assess suppliers’ transition plans and track engagement in order to focus our 
efforts on where they have the highest impact
Authorities 
• European Central Bank (ECB)
• European Banking Authority (EBA)
• National supervisory authorities
• Market authorities
• Wide spectrum of policymakers and 
industry associations
• Adherence to evolving standards 
•  Accurate and professional implementation of regulatory 
and supervisory requirements 
•  A compliant approach to climate-related and 
environmental risk management 
•  Sound and reliable processes for preventing financial 
crime and fraud 
•  A comprehensive risk appetite framework implemented 
at the Group, business area and entity levels for a 
sufficient risk perspective in decision-making
• Interactions with supervisors at the national and EU 
levels 
• Provision of expert opinions in public consultations 
• Participation in data collections and stress test activities 
•  Engagement with policymakers and industry 
associations on regulatory changes
•  Interacted with supervisors on an ongoing basis (the ECB at the Group level and the national 
supervisors at the country level)
•  Provided our expert opinion on regulatory proposals at the national and EU levels to ensure that 
current and new regulation better takes into account impacts on the financial industry and 
customers
•  Enhanced quantification methods to assess ESG-related impacts and risk exposures more effectively 
•  Embedded insights from our materiality assessment on climate- and nature-related risk drivers in 
governance, internal processes, internal rules and business plans to support the development of 
sustainable business strategies and risk management throughout the organisation (including in line 
with the EBA Guidelines on the management of ESG risks in force since January 2026)
• Developed products and services to strengthen our measures to prevent financial crime and fraud
Broader society
• General public
• Media
• Non-governmental organisations 
(NGOs)
• Investees
• Educational institutions
• Aspiring entrepreneurs
• Accountability for the impact of operations 
• Transparent communication on actions and progress
• Presence in society and dialogue with stakeholders 
• Support to improve financial and digital literacy 
• Support for entrepreneurship 
• Support for vulnerable groups 
• Transparent processes and engagement related to 
sustainability
•  Proactive information sharing, including through media 
briefings, and availability to handle media enquiries 
•  Regular NGO meetings and systematic information 
sharing through responses to NGO questionnaires 
•  Engagement with investee companies to address ESG-
related risks and opportunities 
•  Partnerships with local and national organisations 
focusing on financial skills, entrepreneurship and social 
belonging
•  Own initiatives related to financial skills, 
entrepreneurship and social belonging
•  Shared information and facilitated dialogue on our sustainability work and its impact on the real 
economy and wider society
•  Helped build financial skills, foster entrepreneurship and champion social belonging through 
participation in own initiatives and partnerships 
•  Continued to develop our sustainability policy framework to support and challenge customers and 
investees needing to transition to a more sustainable future 
•  Promoted sustainability practices in accordance with Nordea Asset Management’s Responsible 
Investment Policy through more than 1,300 engagements and over 3,300 AGMs 
•  Considered NGO feedback in the development of our approach and improved transparency on 
topics, sectors and progress

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Nordea Annual Report 2025 88
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Active stakeholder engagement
We continually engage with all key stakeholder groups, in 
particular customers and investee companies, to under-
stand the sustainability challenges and opportunities they 
face in their business environments. This enables us to 
address material sustainability matters and turn our sus-
tainability-related commitments into concrete action. Our 
approach prioritises dialogue over disengagement as long 
as we assess the engagement as meaningful.
We measure stakeholder engagement in different ways, 
depending on our relationship with the stakeholder and 
the nature of the engagement. Selected active engage-
ment measures are presented in the table below. Details 
on our engagement with employees are presented in “S1 
Own workforce” on page 160, while our our community 
engagement is described in “S4 Consumers and end- 
users” on page 167. 
Active engagement
2025 2024
Customer preferences
Share of assessed customers 
expressing a sustainability 
preference (%) 41 43
Active ownership engagement
AGM voting 3,399 3,554
Engagements with investee 
companies 1,391 1,393
ESG ratings
S&P Global CSA Score 73 70
MSCI ESG Rating AA AA
ISS ESG Corporate Rating C+ (Prime) C+ (Prime)
Sustainalytics 13.1 (low risk) 12.3 (low risk)
Employee engagement 
Response rate for People Pulse 
survey (%) 85 85
Supplier engagement 
Suppliers subject to sustainability-
related engagement 127 98
Sustainability governance 
Board of Directors
Our Board of Directors approves our Group strategy, 
where sustainability is embedded, and has ESG oversight 
responsibilities encompassing governance, strategy, target 
setting and operationalisation. The Board of Directors is 
ultimately responsible for ensuring we maintain an effec-
tive internal control system covering, among other things, 
risks driven by ESG-related factors. The Board of Directors 
has also established our overarching policy on ethics and 
business conduct (Group Board Directive on Code of 
Conduct) and sustainability policy (Group Board Directive 
on Sustainability). 
Composition and competence of the Board
According to our articles of association, the Board of 
Directors must consist of between 6 and 15 members. The 
current Board of Directors consists of 12 ordinary members 
and 1 deputy member. Of these, 10 were elected by the 
Annual General Meeting (AGM) in March 2025. In addition 
to the Board members elected by the AGM, 3 ordinary 
members and 1 deputy member are elected by Nordea 
employees. After one stepped down in September 2025, 
we finished the year with two ordinary and one deputy 
employee-elected Board members. The Board of Directors 
considers all its members to be independent of Nordea’s 
significant shareholders and all members elected by the 
2025 AGM to be independent of Nordea in accordance with 
the Finnish Corporate Governance Code. No Board mem-
ber elected by the 2025 AGM is employed by Nordea or 
works for Nordea in an operational capacity. The employ-
ee-elected Board members are employed by the Nordea 
Group and are therefore not independent of Nordea 
according to the Finnish Corporate Governance Code, but 
all of them are considered to be non-executive members. 
The Shareholders’ Nomination Board presents to the 
AGM proposals concerning the election and remuneration 
of members of the Group Board of Directors and other tasks 
assigned in its charter. It strives to ensure that the Board of 
Directors as a whole has a fair and balanced representation 
Sustainability governance structure 
Board of Directors
Board Remuneration  
and People Committee
Board Operations and 
Sustainability Committee Board Audit Committee Board Risk Committee
President and Group CEO in the Group Leadership Team
Sustainability and  
Ethics Committee Risk CommitteeAsset and Liability  
Committee
Business areas and Group functions
Sustainable Funding 
Committee
ESG Operational  
Steering Committee
ESG Reporting  
Subcommittee
Reputational Risk  
Committee
Responsible Investment 
Committee
Subsidiary ESG  
committees
Executive Credit  
Committee
of gender and other diversifying factors. Among other 
things, the Board of Directors should have a composition 
aligned with our Diversity Policy, represent each of our 
Nordic operating countries, include different educational 
and professional backgrounds, and be age diverse.
To ensure the Board of Directors as a whole is suffi-
ciently diverse and skilled, including in sustainability mat-
ters, the Shareholders’ Nomination Board evaluates 
recruitment needs on an ongoing basis. It also takes into 
account input provided by the Chair of the Board regard-
ing competencies and skills needed.
The Board of Directors receives dedicated training in 
ESG-related topics as part of the annual plan addressing 
its collective training needs. The training takes into 
account regulatory and supervisory requirements and in 
2025 covered financial well-being and relevant risk per-
spectives, among other things.
All shareholder-elected Board members have been 
assessed to have good or expert-level skills and knowl-
edge regarding sustainability, green transition and busi-
ness conduct matters.

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89
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Geographical representation
Nordic 
countries 70%
United 
Kingdom 20% 
Europe 
(excluding 
Nordics) 10% 
Gender diversity
Male
60%
Female
40% 
Board committees 
The Board committees assist the Board of Directors in pre-
paring matters falling within its competence and making 
decisions in matters it has delegated. Their duties and 
working procedures are defined in their respective char-
ters. In general, they do not have autonomous deci-
sion-making powers, and each one regularly reports on its 
work to the Board of Directors. We follow legal require-
ments and comply with the Finnish Corporate Governance 
Code in matters related to Board committees.
The Board Operations and Sustainability Committee 
(BOSC) assists the Board of Directors in fulfilling its ESG 
oversight responsibilities and receives quarterly updates 
on the implementation of sustainability-related measures 
supporting the Group business strategy. The Board Audit 
Committee (BAC) assists the Board of Directors by moni-
toring the Group’s financial and sustainability reporting 
processes and reviewing the annual consolidated sustain-
ability reporting. The Board Risk Committee assists the 
Board of Directors in fulfilling its oversight responsibilities 
concerning risk management and frameworks, controls 
and processes relating to ESG factors as drivers of existing 
risk, risk appetite and risk materiality. The Board 
Remuneration and People Committee prepares and pre-
sents proposals to the Board of Directors regarding remu-
neration, including the integration of ESG KPIs into remu-
neration programmes. It also supports the Board of 
Directors in monitoring the impact of Group diversity and 
inclusion policies and practices.
Board committee members are appointed by the Board 
of Directors and must collectively have sufficient expertise 
in topics relating to the work of their committee. New 
committee members receive introductory committee- 
specific training and other appropriate training, and each 
committee regularly develops its knowledge and compe-
tencies. As understanding and managing ESG-related 
impacts, risks and opportunities is crucial to maintaining 
financial and capital strength, such impacts, risks and 
opportunities must always be considered in Board com-
mittee recommendations to the Board of Directors.
Board skills matrix and information on Board composition 1
Sector and product knowledge and experience1 Board members’ knowledge, skills and  experience2
Banking and finance            
Insurance industry           
Strategy and business           
ESG and green transition            
Digitalisation, IT, data and cybersecurity           
 Expert knowledge  Good knowledge  Basic knowledge 
1) Relevant subset of sectors and products assessed as part of the 2025 Nordea Board evaluation. 
2) Excluding Employee Elected Board members.
Management 
The President and Group CEO (hereafter “Group CEO”) 
leads the management of the Nordea Group in accordance 
with external and internal frameworks, which also regu-
late the division of responsibilities and interaction 
between the Group CEO and the Board of Directors. The 
Group CEO is accountable to the Board of Directors for 
managing the Group’s operations and organisation, works 
closely with the Board Chair to plan Board meetings, and 
is responsible for developing and maintaining effective 
systems for reporting and internal control within the 
Group. To help secure effective oversight and manage-
ment of Group-wide risks, the Group CEO also appoints 
Group Accountable Executives (GAEs) for specific risk 
areas. The GAEs’ responsibilities include ensuring an ade-
quate policy framework is in place for managing their 
respective risk areas.
The Group Leadership Team (GLT) supports the Group 
CEO in managing the Group. GLT members are responsible 
for the performance, operations, risks, resources and 
development of their respective business areas or Group 
functions. GLT members work together with and report 
directly to the Group CEO. 
In line with applicable regulations, the parent bank, 
Nordea Bank Abp, has a Deputy Managing Director (cur-
rently the Chief Legal Officer). The Group CEO and the 
Deputy Managing Director have been assessed to have 
sufficient knowledge, skills and expertise regarding finan-
cial services; the Group’s products; sustainability matters 
relevant to the Group’s business model, strategy and 
operations; and related material impacts, risks and oppor-
tunities. To further enhance their competence and access 
to relevant expertise, they receive dedicated training in 
ESG areas as part of their annual training. 
To ensure ESG-related items are integrated into the risk 
management cycle, a sustainability and ESG policy frame-
work is in place. The framework is based on the Group 
Board Directive on Sustainability and the Group Board 
Directive on Risk, and covers both aspects of double mate-
riality. At the management and management committee 
levels, ESG-related considerations are integrated into the 
existing processes for decision-making, risk management 
and control, and escalation.
The Chief of Staff is accountable for the development of 
our strategic sustainability priorities and the analysis of 
emerging topics, ensuring our sustainability agenda 
remains aligned with developments in the business envi-
ronment and our long-term net zero commitment. The 
Chief of Staff proposes strategic sustainability priorities 
and sustainability targets for approval by the Group CEO 
and works with the business areas to ensure their strate-
gies are consistent with the Group-level strategic sustaina-
bility priorities and sustainability targets. For an overview 
of our targets related to material ESG-related impacts, 
risks and opportunities and the related monitoring pro-
cesses, see “E1 Climate change” on page 124 and “S1 Own 
workforce” on page 163. The gender balance at our top 
management levels is disclosed in “S1 Own workforce” 
on page 165.

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Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Group-wide committees 
The Sustainability and Ethics Committee (SEC) is a CEO-
appointed committee tasked with facilitating the integra-
tion of sustainability into our business strategy and sup-
porting the Group CEO, GLT, Group Board of Directors and 
BOSC in fulfilling their oversight responsibilities concern-
ing sustainability. It supports the integration of ESG topics 
into our internal frameworks and helps ensure appropriate 
implementation to achieve the Group-level sustainability 
targets. The SEC is also responsible for influencing and fol-
lowing our status and progress regarding ethics and cul-
ture in line with our purpose and values. This involves 
advising the Group CEO on whether the Group should par-
ticipate in or withdraw from external voluntary commit-
ments related to sustainability and advising the business 
areas regarding ethical business dilemmas. The SEC is 
made up of representatives from our business areas and 
Group functions. 
The Group Risk Committee promotes interaction and 
coordination within the Group on matters related to risk. 
With respect to sustainability, it is responsible for oversee-
ing the integration of ESG risk drivers into the assessment 
of existing risks – which also supports the double materi-
ality assessment (DMA) and other processes. 
The Asset & Liability Committee and its sub-committee, 
the ESG Reporting Subcommittee, support the preparation 
of quantitative sustainability information as outlined in 
Article 8 of the EU Taxonomy, the Pillar 3 disclosure 
requirements and the Corporate Sustainability Reporting 
Directive. 
To ensure sustainability is integrated into all business 
areas and Group functions, a Group-wide implementation 
programme has been run since 2021, with dedicated work 
streams and an operational steering committee. The pro-
gramme’s progress has been monitored by the SEC, the 
GLT and the BOSC on a quarterly basis. 
Approach to sustainability matters
Our material impacts, risks and opportunities related to 
sustainability matters are identified through our annual 
double materiality assessment (DMA), which is described 
in detail on pages 91–93. The outcome of the DMA and 
proposed follow-up actions are approved by Group-wide 
committees before being presented to the GLT, BOSC and 
BAC, and are ultimately approved by the Group Board of 
Directors. The Chief of Staff is responsible for providing 
and presenting the information on the DMA to the govern-
ing bodies. 
The Board of Directors and BOSC receive annual 
updates on sustainability, including information on related 
impacts, opportunities, risks and progress. The BOSC also 
receives semi-annual updates regarding how the Group is 
delivering on its strategic sustainability priorities and pro-
gressing towards its sustainability targets. Furthermore, the 
BOSC is informed of the outcome of our annual business 
environment scanning of climate and environmental risks 
and associated follow-up actions agreed by the business 
areas, and reviews sustainability-related regulatory docu-
ments ahead of their approval by the Board of Directors. 
The SEC and GLT receive information on our sustaina-
bility-related material impacts, risks and opportunities; 
due diligence; and the effectiveness of policies, actions, 
metrics and targets adopted to address the impacts, etc. 
on an ongoing basis. The SEC is responsible for approving 
certain sustainability-related frameworks, aligning with 
the Group Risk Committee where relevant, and reviewing 
Group rules related to sustainability. 
Sustainability-related performance 
in incentive plans
We have integrated sustainability-related KPIs into our 
variable pay plans, i.e. the Short Term Incentive Plan 
(STIP) and Long Term Incentive Plan (LTIP) for the 
President and Group CEO, the GLT and selected senior 
leaders; the Group Variable Pay Pool mechanism (variable 
pay funding at Nordea); and the Profit Sharing Plan. 
Members of the Board of Directors are not offered any 
variable pay and were in 2025 compensated through fixed 
Board fees decided by the Annual General Meeting. 
In accordance with the current Remuneration Policy for 
Governing Bodies, the STIP and LTIP goals are based on 
financial and non-financial goals and targets. Financial 
goals support our long-term business strategy, generally 
measure or contribute to return and/or profitability, and 
are risk adjusted as appropriate. Non-financial goals 
include goals and targets which further support our cli-
mate strategy and ambitions and help drive a sustainable 
business. At the beginning of 2025 the Board of Directors 
decided on the goals and targets for the 2025 STIP, 2025–
27 LTIP, 2025 Group Variable Pay Pool and 2025 Profit 
Sharing Plan.
The following ESG-related goals and relative propor-
tions were applied in the 2025 STIP for the Group CEO, the 
GLT and other senior leaders:
Goals Description
Green financing 
volume (EURbn)
3.33% Measures the increase in the 
volume of green financing 
provided to our customers in 2025.
Progress on the 
strategic 
sustainability 
implementation plan 
3.33% Measures progress and delivery 
on 12 streams in our sustainability 
roadmap driving progress towards 
our sustainability and climate 
ambitions.
Improving the gender 
balance at the top 
three senior 
leadership levels
3.33% Supports progress towards our 
2025 gender balance target of at 
least 40% representation.
Employee 
engagement
5% Measured through several factors 
and objectives. Supports our 
commitment to be the preferred 
employer in the financial industry 
in our operating countries.
Risk, compliance and 
conduct
15% Measures performance on a 
number of key risk, compliance 
and conduct indicators, ensuring 
that variable remuneration is 
adjusted for all types of current 
and future risk.
The LTIP is an annually recurring fully share-based incen-
tive plan with a three-year performance period which sup-
ports our business strategy and delivery of long-term 
shareholder value. It covers the Group CEO, the GLT and 
select senior leaders. The conditional shares allocated 
under the LTIP in 2023 (LTIP 2023–25), 2024 (LTIP 2024–
26) and 2025 (LTIP 2025–27) include an ESG component 
to reflect our strategic sustainability priorities. 
The following ESG-related goals and relative propor-
tions were applied in the LTIP for 2023–25, the LTIP for 
2024–26 and the LTIP for 2025–27 for the Group CEO, the 
GLT and other senior leaders:
LTIP 2023–25
20% (each equally 
weighted)
ESG scorecard: facilitation of sustainable 
financing; doubling the share of net-zero-
committed assets under management; 
transition plans for large corporates; 
alignment with the Paris Agreement for the 
top 200 financed emissions contributors; 
gender balance; fair treatment of employees; 
and financial sustainability through 
maintaining our credit profile.
LTIP 2024–26
20% (each equally 
weighted)
ESG scorecard: emissions reductions vs 
baseline in a) lending portfolio, b) investment 
portfolio, and c) internal operations; gender 
balance; fair treatment of employees; and 
financial sustainability through maintaining 
our credit ratings.
LTIP 2025–27
20% (each equally 
weighted)
ESG scorecard: emissions reductions vs 
baseline in a) lending portfolio, b) investment 
portfolio, and c) internal operations; gender 
balance; fair treatment of employees; and 
financial sustainability through maintaining 
our credit ratings.
At the beginning of 2026 the Board of Directors reviewed 
performance with respect to the predetermined 2025 STIP 
and 2023–25 LTIP goals.

===== SIDA 92 =====

Nordea Annual Report 2025 91
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Statement on due diligence 
Our general principles for conducting sustainability due 
diligence include taking responsibility for identifying, pre-
venting, mitigating and accounting for how we address 
actual and potential negative impacts on the environment 
and people connected with our business. We continually 
develop this work in line with the UN Guiding Principles 
on Business and Human Rights and the OECD Guidelines 
for Multinational Enterprises. In addition to performing 
risk and materiality assessments, we continually work to 
improve our methodologies for identifying human rights 
risks associated with our suppliers, investments, lending 
and customers. In order to prevent and mitigate adverse 
human rights impacts, we integrate these findings into our 
processes and take suitable action.
Other examples of our due diligence processes include: 
• guidelines, policies and training available to all employees
• our know your customer process 
• ESG risk assessments of credit customers 
Core elements of due diligence
References to the 
Sustainability Statement Page(s)
a)  Embedding due diligenc e in governance, strategy and business model ESRS 2 GOV-2 
ESRS 2 GOV-3 
ESRS 2 SBM-3
90
90
93–97
b)  Engaging with a ffected stakeholders in all key steps of the due diligence process ESRS 2 GOV-2 
ESRS 2 SBM-2 
ESRS 2 IRO-1  
ESRS S1
ESRS S4
90
86–87
91–93
160
171, 173
c)  Iden tifying and assessing adverse impacts ESRS 2 IRO-1 
ESRS 2 SBM-3
91–93
93–97
d)  T aking actions to address these adverse impacts ESRS E1 
ESRS E4
ESRS S1
ESRS S4
ESRS G1
122–123
155
161–163
171, 174
178–180
e)  T racking the effectiveness of these efforts and communicating ESRS E1 
ESRS E4
ESRS S1
ESRS S4
ESRS G1
124–135
155
163–166
172, 174
178–180
Double materiality assessment process 
General approach and basis for preparation
Since the financial year 2024, we have undertaken a double 
materiality assessment (DMA) based on the Corporate 
Sustainability Reporting Directive (CSRD). In the DMA, com-
panies determine the sustainability matters that are mate-
rial for them by evaluating (i) the ESG-related impacts of 
their business activities on society and stakeholders (the 
inside-out perspective), and (ii) how ESG factors may influ-
ence their risks and opportunities (the outside-in perspec-
tive). As prescribed by the European Sustainability 
Reporting Standards (ESRS), impacts are determined via an 
impact materiality assessment, while risks and opportuni-
ties are determined via a financial materiality assessment.
The insights and experience we obtained when under-
taking the first DMA for the financial year 2024 were used 
to enhance the DMA for the financial year 2025. In addi-
tion to further detailing the value chain scope, this year’s 
DMA involved an adjustment to the process to enhance 
the quantitative and qualitative assessment. For greater 
cohesiveness, we further aligned the different approaches 
required to consider impacts, risks and opportunities. 
We also expanded our desk research, heatmaps and sce-
narios analysis. The enhancements made to the assess-
ment process in 2025 did not lead to any significant year-
on-year differences in the outcome at the topical level.
The outcome of our 2025 DMA determined the sustain-
ability matters (impacts, risks and opportunities) that 
were material for us and defined the scope of our sustain-
ability reporting for the financial year 2025. The assess-
ment covered our direct business relationships. In addition 
to own operations, we considered the asset and liability 
perspective and on- and off-balance sheet activities. 
Future reporting will evolve as our DMA experience grows 
and more regulatory guidance becomes available.
The design of our DMA reflects our interpretation of the 
CSRD, the ESRS, the European Financial Reporting Advisory 
Group’s guidance, and European Banking Authority (EBA) 
and European Central Bank (ECB) commentaries. 
Appropriate control functions are embedded within the 
methodology and process description to ensure outcomes 
are validated. The methodology and process description are 
anchored internally, and the outcome is subject to Group 
Leadership Team and Board of Director approval. 
• sustainability screening of investees and our responsible 
investment approach 
• sustainability screening and monitoring of suppliers 
• engagement with customers and investees on identified 
impacts 
• maturity assessments of our internal processes.
The table below maps the core elements of sustainabili-
ty-related due diligence presented in this Sustainability 
Statement. Due to the outcome of the double materiality 
assessment, the Sustainability Statement does not cover 
all aspects of human rights due diligence, i.e. it does not 
cover workers in the value chain or affected communities. 
Nor does it include commentary on our new 2030 target 
related to human rights impact assessments of suppliers 
in high-risk sectors or countries. We provide a more com-
prehensive disclosure of our human rights due diligence in 
our Human Rights Report, which is published annually at 
nordea.com.

===== SIDA 93 =====

Nordea Annual Report 2025 92
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Determining materiality in the DMA
We determine materiality in four steps: 1) understanding 
the context of the organisation, 2) identifying actual and 
potential impacts, risks and opportunities, 3) assessing 
actual and potential qualitative and quantitative impacts, 
risks and opportunities, and 4) determining material 
impacts, risks and opportunities by applying appropriate 
thresholds. Impact materiality is determined based on 
positive and negative impacts, while financial materiality 
is determined based on financial risks and opportunities. 
An ESG matter can be material from an impact materiality 
perspective, a financial materiality perspective, or both. 
The outcomes of the impact assessment and the risk and 
opportunity assessment are consolidated, forming our 
DMA outcome and determining the sustainability matters 
that are material for us. As part of the consolidation pro-
cess, any interdependencies between material impacts, 
risks and opportunities are formalised. 
In 2025 our DMA outcome was validated in consultation 
with internal representatives of our six main stakeholder 
groups and through a newly established stakeholder 
engagement framework. This involved drawing on regular 
dialogues with affected stakeholders and incorporating 
their considerations where applicable. 
Determining impact materiality 
We identified actual and potential impacts through extensive 
desk research using internal rules and external guidelines, 
previous materiality assessments and expert judgement, and 
applying insights gained from due diligence. We assessed 
materiality using qualitative and quantitative assessment cri-
teria, expert evaluation and materiality thresholds.
As prescribed by the ESRS, we assessed the identified 
impacts based on their scale and scope alongside their 
likelihood of materialising. In the case of negative impacts, 
irremediability was also considered. A wide range of inter-
nal expert stakeholders were involved in assessing these 
input criteria. 
To ensure we followed a standardised quantitative 
approach to assessing the scope of impacts in our down-
stream value chain, we mapped information on our lending 
and investment portfolio exposures using the UNEP FI 
impact mapping framework. This provides a comprehensive 
and standardised approach to assessing environmental and 
social impacts associated with different sectors and activi-
ties – which we complemented with a Nordea sector con-
text. As part of the assessment, we screened lending and 
investment portfolios to identify actual and potential 
impacts, including those related to climate change, pollu-
tion, water and marine resources, biodiversity and ecosys-
tems, and resource use and circular economy. 
We followed a separate approach to assess impacts 
related to our own operations, such as own workforce. Here, 
we considered factors such as funding and operational 
expenses when assessing the scope of impacts. The latter 
approach was also applied to impacts relating to our 
upstream activities, such as funding and treasury. 
Our offices were not assessed to be located in or near 
biodiversity-sensitive areas, and the impacts and depend-
encies of our own site locations on biodiversity and eco-
systems were assessed to be immaterial. Therefore, we did 
not assess mitigation measures to be necessary. We con-
sult affected communities in the development of our own 
site locations through close collaboration with municipali-
ties and nearby communities.
The ENCORE tool fed into the assessment of impacts 
and dependencies of our corporate lending and invest-
ment portfolios on biodiversity and ecosystems. We 
assessed the biodiversity- and ecosystem-related impacts 
and dependencies of own site locations using the WWF 
Biodiversity Risk Filter tool. 
Regarding impacts on climate change, further details 
on our assessment of our greenhouse gas (GHG) emis-
sions are provided in “E1 Climate change” on pages 110–
150, with the related methodology explained in “Gross 
scopes 1, 2, 3 and total GHG emissions” on pages 136–138. 
In order to determine impact materiality at the Group 
level, the outcome of each standardised assessment was 
subject to thresholds. These included scores across criteria 
for each assessed impact. Impacts related to our lending 
and investment portfolios were also subject to thresholds 
based on sectoral exposures. Sensitivity analyses of the 
thresholds applied ensured the level of sustainability report-
ing was suitable considering our organisational context.

===== SIDA 94 =====

Nordea Annual Report 2025 93
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
Determining financial materiality
In line with the impact materiality assessment, we con-
ducted extensive desk research and used expert judge-
ment to identify opportunities. We assessed materiality 
using qualitative and quantitative assessment criteria, 
expert evaluation, and materiality thresholds.
We set appropriate thresholds to determine opportuni-
ties by placing high importance on actual or potential rev-
enue income. In identifying and assessing material oppor-
tunities, we considered the factors of likelihood and mag-
nitude as described by the ESRS. 
For the DMA, we used the output of our annual risk 
materiality assessment (MA), which is aligned with super-
visory and regulatory ESG-related risk management guid-
ance such as the ECB Guide on climate-related and envi-
ronmental risks. In the MA, we assess the impact of CSRD 
topics, sub-topics and sub-sub-topics on our risk types, 
including credit, market, liquidity and operational risks. We 
view the ECB Guidelines and the ESRS as complementary, 
and since the ESRS are not sector specific, we consider the 
output of the MA to be direct input for the DMA. 
To support the identification of ESG risk relevant to us, 
we perform a thorough risk identification process to iden-
tify transmission channels, i.e. causal chains that explain 
how ESG risks are transmitted to us through our sectoral 
value chain, encompassing counterparties, invested assets, 
third parties and own operations. The relevance of ESG 
risks is assessed by way of heatmaps, relevant research 
findings and consultation with subject matter experts. The 
risk identification process considers country and sector 
views across corporate and retail portfolios. 
The materiality assessment process includes performing 
concentration, sensitivity and scenario analyses across dif-
ferent risk categories. If it is not possible to quantify a risk, 
we use expert judgement within the qualitative assessment 
parameters. The risk materiality thresholds relate to our 
Common Equity Tier 1 capital, liquidity indicators, and pre-
determined qualitative criteria. We assess the impact of ESG 
risks on our risk types over short-, medium-, long- and very 
long-term horizons. The time horizons are aligned with the 
horizons provided in the ESRS and have also been adopted 
for reporting purposes. They are defined as follows:
• short term: less than or equal to one year (≤1 year)
• medium term: one to five years (>1–5 years)
• long term: five to ten years (>5–10 years)
• very long term: longer than ten years (>10 years), 
extending to 30 years. 
In the 2025 MA we considered various climate-related 
physical and transition risk factors, including extreme 
weather; variability in temperature; regulatory trends; and 
societal, customer and demographic trends, and incorpo-
rated these into specific climate-related physical and tran-
sition risk stress testing at different levels of granularity.
Our climate-related transition risks are mainly driven by 
a need to reduce counterparty GHG emissions. These risks 
may manifest themselves in our business by affecting the 
value of collateral pledged to us and may also relate to 
legal and reputational risk stemming from changed mar-
ket sentiment and litigation linked to greenwashing. In 
general, transition effects are more likely to materialise in 
the short-to-medium term, but may also materialise in the 
very long term if there is a delayed transition or no transi-
tion ahead of 2050. 
Climate-related physical risks were assessed to mainly 
stem from the devaluation of collateral (e.g. real estate, 
ships and vehicles). We identified and assessed cli-
mate-related hazards by comparing exposures to cli-
mate-related physical risks over different time horizons in 
three Representative Concentration Pathway (RCP) sce-
narios, including the most severe climate scenario.
In our assessment of risks related to biodiversity and 
ecosystems, we considered various risk factors in our cli-
mate and environmental risk factor taxonomy, including 
climate change; changes in land use, freshwater use and 
sea use; direct exploitation of species; and impacts and 
dependencies on ecosystem services. The process involved 
identifying risk transmission channels, developing and 
using heatmaps, and applying different time horizons, all 
of which was then used to determine the risk relevance for 
different sectors and geographies. 
In the 2025 MA we identified that we are exposed 
to sectors and counterparties with potential high 
biodiversity- r elated transition risks, which could impact 
us via regulatory-driven efforts to protect biodiversity and 
ecosystems. The need for companies to adapt their busi-
ness models to reduce their impact on nature could affect 
their profitability and create credit risk for us. In general, 
transition risks are more likely to impact us in the short-to-
medium term, but may also materialise in the long-to-
very-long term time horizons. 
On the operational risk side, we considered reputational 
risk and legal risk from greenwashing or failure to comply 
with ESG regulation to be material. Business model risk, 
meanwhile, could arise across all time horizons via 
nature-related effects impacting credit quality or the value 
of collateral securing our lending.
We identified a low risk related to dependency on eco-
system services in the Nordic countries, which was accord-
ingly not deemed to be material for us. However, the 
longer-term risk outlook is uncertain due to challenges in 
quantifying risks via the sectoral value chain. 
The assessment was performed internally, without the 
involvement of external stakeholders, and did not include 
an assessment of systemic risk related to biodiversity and 
ecosystems.
Material impacts, risks and opportunities 
In the 2025 DMA we identified our material sustainability 
matters and thus defined the scope of our 2025 sustaina-
bility reporting under the CSRD. Material topics were 
those found to be material from an impact materiality per-
spective, a financial materiality perspective, or both. 
The current financial effects of the material risks identi-
fied during the reporting period relate to our internal capi-
tal requirement (ICR). The ICR specifies the type and dis-
tribution of internal capital we consider adequate to cover 
the nature and level of all risks to which the Group, or any 
of its subsidiaries, are or might become exposed in the 
foreseeable future, including during periods of stress. 
The material impacts, risks and opportunities identified 
in the assessment were mapped to the ESRS on a sub-
topic and/or sub-sub-topic level as relevant, and informed 
our prioritised sustainability themes presented on page 82 
above. The table below provides a full overview. 
General information, cont.

===== SIDA 95 =====

Nordea Annual Report 2025 94
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Overview of sustainability matters for disclosure under ESRS
ESRS Impact materiality Financial materiality Related Nordea sustainability theme
E1 Climate change Material Material Climate and energy
E2 Pollution Not material Not material Nature
E3 Water and marine resources Not material Not material Nature
E4 Biodiversity and ecosystems Material Material Nature
E5 Resource use and circular economy Not material Not material Climate and energy
S1 Own workforce Material Material Inclusive and safe societies
S2 Workers in the value chain Not material Not material Inclusive and safe societies
S3 Affected communities Not material Not material Inclusive and safe societies
S4 Consumers and end-users Material Material Financial well-being
G1 Business conduct Material Material Inclusive and safe societies
The tables on the following pages provide an overview of 
the material impacts, risks and opportunities identified in 
the 2025 DMA. In addition to a brief description, the tables 
indicate where the impacts, risks and opportunities were 
identified (in our own operations or in our value chain), and 
which time horizons are relevant. The impacts, risks and 
opportunities are specified in accordance with the ESRS. 
We assessed the materiality of information for specific 
disclosure requirements relating to material ESRS topics, 
and corresponding metrics, before including them. If the 
information was determined to help provide a more com-
prehensive view to meet users’ decision-making needs, it 
was included. Information not considered to be material 
enough to meet the objective of the relevant disclosure 
requirement was excluded. The need for entity-specific dis-
closures was also assessed in cases where the standards 
were not detailed enough to enable an understanding of 
our business model and strategy. The analysis identified 
relevant entity-specific topics in G1 Business conduct, relat-
ing to the prevention of financial crime and fraud in society.
The topical sections on pages 110–180 further specify 
the material impacts, risks and opportunities and how they 
are addressed in our strategy and business model. 
The 2025 DMA results are largely unchanged from 2024. 
The few changes reflect the increased robustness of the 
analyses, which enabled us to further mature the 
disclosures. 
In 2025, ESRS E4 Biodiversity and ecosystems was iden-
tified as material also from an impact perspective, high-
lighting our responsibility to prevent and reduce negative 
impacts on biodiversity. Under the sub-topic “Direct impact 
drivers of biodiversity loss”, new material impacts and risks 
were identified. At the same time, the sub-topics “Impacts 
and dependencies on ecosystem services” and “Impacts on 
the extent and condition of ecosystems” were this year not 
assessed to be material from a risk perspective. 
In ESRS S4 Consumers and end-users, under the subtop-
ics “Social inclusion of consumers and/or end users” and 
“Personal safety of consumers and/or end-users”, new 
material negative impacts were identified. These findings 
highlight our role in society to provide consumers with 
access to the financial system and strive to improve finan-
cial well-being, while protecting customers’ rights and miti-
gating the risk of fraud.
In ESRS G1 Business conduct, a new risk was identified 
under the sub-topic “Corporate culture”. Moreover, “Cyber 
security” was identified as an entity-specific matter, having 
been assessed as material from a risk perspective due to 
the threat to our operations. The entity-specific matter 
“Financial crime” was reassessed, resulting in a new mate-
rial negative impact, which highlights attempts to misuse 
our platforms to  enable t errorist financing, money launder-
ing and other criminal activities.

===== SIDA 96 =====

Nordea Annual Report 2025
95
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
E1 Climate change
Impact, risk or 
opportunity Title Description Value chain Time horizon
Climate change mitigation
Positive impact
(actual)
Financing and supporting 
the transition of 
customers, investee 
companies and sectors
We contribute to reducing greenhouse gas (GHG) emission 
levels and fulfilling the objectives of the Paris Agreement by 
providing financing and supporting customers’ transitions 
(including through capital markets solutions), accelerating 
our own transition through active engagement and business 
selection, investing, and actively engaging with investees.
Negative impact
(actual)
GHG emissions from our 
lending and investment 
portfolios and capital 
market activities
GHG emissions generated by customer activities linked to 
financing and capital markets solutions provided by us or 
investments made by us and contributing to increased GHG 
emissions not in line with the Paris Agreement, and GHG 
emissions linked to our financing of or investment in 
customers in carbon-intensive sectors without transition 
plans.
Risk Climate-related transition 
risks
Through our offering, in particular our lending to households 
and corporates, we are exposed to sectors and 
counterparties with potential high climate-related transition 
risks. These climate-related transition risks can impact us 
across our different risk categories, for example through 
credit risk due to collateral devaluation or liquidity risk due 
to additional cash outflows. 
Through our operations, we are also exposed to non-
financial risks stemming from climate-related transitional 
effects, mainly via reputational and litigation risks. These 
risks could materialise if, for example, we are subject to 
accusations of greenwashing or do not comply with rapidly 
changing or increased regulatory requirements.
Opportunity Financing and investing in 
activities to mitigate 
climate change and 
enhance adaptation
Potential revenue generation through financing and 
investments linked to climate change mitigation, climate 
change adaptation and energy efficiency activities. 
 V ery long term Shor t term  Medium t erm  L ong term Upstream  Own oper ations  Downstream
Impact, risk or 
opportunity Title Description Value chain Time horizon
Climate change adaptation
Risk Climate-related physical 
risks
Through our offering, in particular our lending to households 
and corporates, we are exposed to sectors and counter-
parties with potential high climate-related physical risks. 
These climate-related risks can impact us across our 
different risk categories, for example through credit risk due 
to collateral devaluation in the case of an acute climate 
event.
    
Energy
Positive impact
(actual)
Financing energy 
efficiency activities and 
engaging with investees 
regarding energy 
efficiency activities
We contribute to reducing energy consumption on the part 
of our customers and investees and fulfilling the objectives 
of the Paris Agreement by financing energy efficiency 
activities, engaging with investees regarding energy 
efficiency activities, and voting on energy efficiency-related 
matters.
    
Negative impact  
(actual)
Final energy consumption 
in our lending and 
investment portfolios
Increased energy consumption, not in line with the energy 
transition needed to fulfil the objectives of the Paris 
Agreement, due to investing in companies/financing 
customers with high energy consumption and without a 
transition plan.
    
Risk Climate-related transition 
risks
Through our offering, in particular our lending to households 
and corporates, we are exposed to sectors and 
counterparties with potential high climate-related transition 
risks relating to energy. These climate-related transition risks 
can impact us across our different risk categories, for 
example through the credit risk of customers in industries 
that are vulnerable to transition risks and have high energy 
consumption rates.

===== SIDA 97 =====

Nordea Annual Report 2025 96
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
E4 Biodiversity and ecosystems
Impact, risk or 
opportunity Title Description Value chain Time horizon
Direct impact drivers of biodiversity loss
Negative impact
(actual)
Contribution to 
biodiversity loss resulting 
from pollution and land, 
freshwater and sea use 
change
Contribution to biodiversity loss through pollution and land, 
freshwater and sea use change, all caused by customer 
activities linked to financing provided by us. We provide 
significant financing to the agriculture, forestry, and fishing 
and aquaculture sectors, which in the Nordic countries put 
great pressure on species and generate pollution linked to 
biodiversity loss. The financing we provide to the real estate 
and construction sectors contributes to land, freshwater and 
sea use change. 
         
Risk Biodiversity-related 
transition risks
Through our offering, in particular our lending to households 
and corporates, we are exposed to sectors and 
counterparties with potential high biodiversity-related 
transition risks. These biodiversity-related transition risks 
can impact us across our different risk categories, for 
example through credit risk as companies adapt their 
business models to reduce their impact on nature, which can 
affect their profitability and impact our counterparty credit 
risk. Operational risk and capital risk can also be materially 
impacted over time. 
    
Impacts on the state of species
Negative impact
(actual)
Contribution to 
biodiversity loss resulting 
from impacts on the state 
of species
Contribution to biodiversity loss through impacts on the 
state of species caused by customer activities linked to 
financing provided by us. We provide significant financing to 
the agriculture, forestry, and fishing and aquaculture sectors, 
which in the Nordic countries put great pressure on species 
and generate pollution linked to biodiversity loss. The 
financing we provide to the real estate and construction 
sectors contributes to land, freshwater and sea use change. 
         
S1 Own workforce
Impact, risk or 
opportunity Title Description Value chain Time horizon
Working conditions
Positive impact
(potential)
Good working 
environment
We are committed to ensuring employee health and well-
being through a holistic approach encompassing proactive, 
preventive and reactive measures in order to support 
employee engagement and performance.
    
Positive impact
(actual)
Employee well-being We provide employees with the opportunity to find a 
harmonious balance between the conflicting demands of 
work and personal life. This can help employees stay 
engaged, reduce stress and improve overall job satisfaction.
    
Negative impact
(actual)
Work overload Excessive workloads and time pressure experienced by some 
employees impact stress levels and can lead to health 
problems. We believe managing these pressures is important 
to prevent burnout and ensure sustainable productivity.
    
Risk Employee health and 
well-being
We are committed to ensuring a safe workplace by 
promoting health and well-being and managing illness and 
work capacity. Failure to do so, especially during adverse 
external events such as pandemics or other crises, could 
have an impact on our capacity to deliver on our business 
strategy. Unwanted attrition and a lack of resources to 
provide our daily banking services could lead to poor 
customer experience, and financial loss and reputational 
damage.
    
Equal treatment and opportunities for all
Positive impact
(actual)
Diverse and inclusive 
workplace 
We support a diverse and inclusive workplace by promoting 
equal opportunities where all aspects of employment are 
concerned. We aim to create a workplace where employees 
feel valued and empowered to contribute.
   
Positive impact
(actual)
Career development We provide structured learning, clear career paths and access 
to new opportunities for employees in order to help them stay 
competent and maintain relevant skills, unlock their potential 
and find fulfilment in coming to work each day.
   
Negative impact
(actual)
Gender pay gaps To the extent that gender-based pay differences exist, this 
can undermine equal and fair treatment and regulatory 
requirements. Pay equity is key for us and we have a plan in 
place to eliminate the overall adjusted pay gap by 2026.
    
Negative impact 
(potential)
Discrimination and 
inequality 
Societal inequalities and biases can manifest in the 
workplace, leading to unequal treatment of employees. This 
can result in reduced employee well-being and a sense of 
unfairness. We have measures and procedures to identify 
and prevent all types of discriminatory behaviour and foster 
an inclusive environment.
    
 V ery long term Shor t term  Medium t erm  L ong term Upstream  Own oper ations  Downstream

===== SIDA 98 =====

Nordea Annual Report 2025 97
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
S4 Consumers and end-users 
Impact, risk or 
opportunity Title Description Value chain Time horizon
Social inclusion of consumers and/or end-users
Positive impact
(potential)
Financial inclusion based 
on (non-discriminatory) 
access to financial 
products and services
We aim to promote financial inclusion and give everyone 
equal access to basic banking services. We provide non-
discriminatory access to financial services, ensuring our 
customers receive equitable treatment through an 
omnichannel approach. In this way, we enable customers 
who may have different needs and preferences to easily 
manage their finances.
    
Negative impact 
(potential)
Exclusion of customers 
without digital literacy or 
internet access
As banking services become more digital, barriers for 
customers with limited digital skills are created, thereby 
increasing financial vulnerability. 
  
Information-related impacts for consumers and/or end users
Positive impact
(potential)
Access to quality 
information
We can contribute to the financial well-being and long-term 
financial security of our customers by providing them with 
complete and understandable product information. High-
quality service and personalised advice across all channels 
can further contribute to our customers’ financial well-being.
    
Risk Data privacy We consider data privacy to be key for responsible banking 
and are fully committed to protecting individual rights and 
keeping personal data safe. Breaches to personal data 
security and privacy could create operational disruption, 
expose us to legal claims and proceedings and reputational 
damage, and carry financial penalties.
   
Personal safety of consumers and/or end-users
Positive impact
(potential)
Customer protection due 
to customers being made 
aware of fraud
Our continuous work to increase fraud awareness among 
our customers and in wider society is key to helping us 
prevent fraud. We contribute to fraud awareness in society 
through education and awareness campaigns. These can 
help customers identify and prevent fraud attempts and 
thereby reduce the risk of fraud.
  
Negative impact
(actual)
Customer exposure to 
fraud on our platforms 
and through our products 
and services
Our platforms may be misused as a means to defraud our 
customers, leading to negative impacts for people using our 
products and services. To address this situation to the extent 
possible, an active fraud management approach is essential.
  
G1 Business conduct
Impact, risk or 
opportunity Title Description Value chain Time horizon
Corporate culture
Positive impact
(potential)
Good corporate conduct We contribute to a robust and stable financial system by 
conducting business to high ethical and professional 
standards, with sound governance and a strong risk culture.
    
Risk Compliance risk related to 
remuneration
Failure to comply with applicable remuneration-related laws 
and regulations could expose us to non-financial risks 
leading, for example, to regulatory sanctions, financial 
penalties and reputational damage.
  
Corruption and bribery
Risk Corruption and bribery Failure to comply with applicable anti-bribery and 
corruption legislation could expose us to non-financial risks 
leading, for example, to fines, reputational damage and 
criminal prosecution.
  
Financial crime and fraud prevention (entity-specific)
Negative impact 
(potential)
Criminals using products 
and services to facilitate 
criminal activities
Our products and services could be abused by criminals 
seeking to exploit the financial system. This could result in 
money laundering, terrorist financing, and sanctions evasion 
and circumvention.
    
Risk Financial crime Failure to comply with applicable laws and regulations 
addressing money laundering, terrorist financing, tax 
evasion and sanctions could expose us to non-financial risk 
leading, for example, to fines, reputational damage and 
criminal prosecution.
  
Risk Fraud Failure to prevent internal or external fraud could result in 
financial losses for both us and our customers and non-
financial risks leading, for example, to regulatory criticism  
and reputational damage.
  
Cybersecurity (entity-specific)
Risk Cybersecurity Cyberattacks designed to disrupt online services are 
becoming increasingly frequent and sophisticated. Failure to 
protect ourselves and others against such events could lead, 
for example, to loss of customer data or service 
unavailability.
  
 V ery long term Shor t term  Medium t erm  L ong term Upstream  Own oper ations  Downstream

===== SIDA 99 =====

Nordea Annual Report 2025 98
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Basis for preparation
This Sustainability Statement (“Group sustainability 
report” as per the Finnish Accounting Act) has been pre-
pared in accordance with the European Sustainability 
Reporting Standards (ESRS) and the Finnish Accounting 
Act, Chapter 7, implementing the EU’s Corporate 
Sustainability Reporting Directive (CSRD). It has been pre-
pared on the same consolidated basis as our financial 
statements, covering the parent company, Nordea Bank 
Abp, and its subsidiaries, i.e. the Nordea Group, and refers 
to our financial year, which was from 1 January 2025 to 31 
December 2025. The reported data covers the Nordea 
Group as a whole unless otherwise stated. 
The disclosed sustainability matters and associated key 
figures are based on a double materiality assessment 
(DMA), as required by the CSRD. In the DMA, we assess (i) 
the material ESG-related impacts of our business activities 
on society and stakeholders and (ii) the material impacts 
of ESG factors on us. The scope includes direct business 
relationships in both the upstream and downstream value 
chains. For more information on the DMA and its results, 
see pages 91–97.
Our financial statements and Sustainability Statement 
include all mandatory disclosures for sustainability topics 
identified as material based on the DMA. In the 
Sustainability Statement, we have not chosen to omit spe-
cific information corresponding to intellectual property, 
nor have we applied the exemption for the disclosure of 
impending developments or matters in the course of 
negotiation. Disclosures derived from other EU legislation 
have been included, as noted on pages 101–104. 
Additional reporting on our voluntary commitments can 
be found at nordea.com. 
When available, we use customer-reported data in our 
calculations and reporting. When such data is not availa-
ble, we use proxy-based estimates and management 
judgements. This primarily relates to environmental infor-
mation and metrics within the value chain, where indirect 
sources are used to complement the customer-specific 
data available. Estimates have also been applied with 
respect to our own operations due to the immaturity and 
limited availability of certain data points. Dependency on 
estimates means our disclosures and impact assessments 
are associated with a degree of outcome uncertainty. 
However, the calculations are deemed to provide a reliable 
description of our exposures.
Estimates can also impact forward-looking information, 
such as our forecasting of progress towards environmental 
targets. They are, however, essential for preparing such 
information, and provide useful insights into how we 
respond to ESG-related opportunities. 
We regularly review the use of estimates and judge-
ments to assess their accuracy and identify ways to 
improve them, for example by developing hybrid proxies 
or adopting the latest guidance from the Partnership for 
Carbon Accounting Financials (PCAF). Such updates were 
applied during 2025, with data quality improvements driv-
ing a baseline recalculation and restatements of 2019 base 
year results – which our total GHG emissions are moni-
tored against. These restatements demonstrate how we 
ensure that disclosures based on estimates remain rele-
vant over time, and are anchored within our robust meas-
urement methodologies. See “E1 Climate change” on page 
147 for more detailed information on metrics subject to 
measurement uncertainty and the data sources and meth-
odologies applied. 
We acknowledge that the regulatory landscape is 
evolving and have accordingly opted for a pragmatic 
approach to reporting, applying the current ESRS require-
ments while preparing for potential simplification in the 
future. In the light of this, we continue to apply transitional 
provisions regarding value chain information (in “E4 
Biodiversity and ecosystems”) as well as the phase-in pro-
visions specified on pages 99–101. 
This Sustainability Statement has been subject to assur-
ance by PricewaterhouseCoopers Oy. The scope of the 
assured information is indicated in the independent practi-
tioner’s limited assurance report on page 374. No external 
body other than the assurance provider has validated the 
metrics disclosed. 
Risk management and internal controls
Our sustainability reporting is subject to a robust risk man-
agement and internal control framework. Group Risk plays 
a key role in defining our taxonomy for ESG risk factors 
and provides guidance on how to consistently and compa-
rably embed ESG-related impacts, risks and opportunities 
in strategy and risk management, including by defining 
relevant roles and responsibilities. This work supports the 
identification of the prioritised ESG-related risks which 
form the basis for the double materiality assessment and 
our approach to sustainability reporting. 
The internal control process is based on five main com-
ponents: control environment, risk assessment, control 
activities, information and communication, and monitor-
ing. Within the internal control framework, all business 
areas and Group functions are responsible for managing 
the risks they incur when conducting their activities and 
for having controls in place to ensure compliance with 
internal and external requirements. The evolving regula-
tory environment and implementations of the CSRD and 
the ESRS are key drivers of risk related to sustainability 
reporting and compliance. To help mitigate this risk, a cen-
tralised function coordinates the production of the 
Sustainability Statement, while our governing bodies, 
management, risk management functions and other staff 
carry out the control processes with a particular focus on 
financial reporting and greenwashing risks.
We have established Group control functions with 
appropriate and sufficient authority, independence and 
access to the CEO, the Group Leadership Team and the 
Group Board of Directors to fulfil their mission in line with 
our risk management framework. The sustainability 
reporting process is monitored by various committees, 
with reporting ultimately to the Board Operations and 
Sustainability Committee and the Board Audit Committee.

===== SIDA 100 =====

Nordea Annual Report 2025 99
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Disclosure requirements and incorporation by reference
Section Page(s) Additional information
ESRS 2 General information
BP-1 General basis for preparation of the sustainability statements 98
BP-2 Disclosures in relation to specific circumstances 98
GOV-1 The role of the administrative, management and supervisory bodies 88–90
GOV-2 Information provided to and sustainability matters addressed by the undertaking’s administrative, management and 
supervisory bodies
90
GOV-3 Integration of sustainability-related performance in incentive schemes 90
GOV-4 Statement on sustainability due diligence 91
GOV-5 Risk management and internal controls over sustainability reporting 98
SBM-1 Strategy, business model and value chain 82–85
SBM-2 Interests and views of stakeholders 86–87
SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model(s) 93–97
IRO-1 Description of the process to identify and assess material impacts, risks and opportunities 91–93
IRO-2 Disclosure requirements in ESRS covered by the undertaking’s sustainability statement 99–104
ESRS E1 – Climate change
ESRS 2 GOV-3 Integration of sustainability-related performance in incentive schemes General information 90
E1-1 Transition plan for climate change mitigation 114–117
ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model(s) 111
ESRS 2 IRO-1 Description of the processes to identify and assess material climate-related impacts, risks and opportunities General information 91–93
E1-2 Policies related to climate change mitigation and adaptation 118–121
E1-3 Actions and resources in relation to climate change policies 122–123
E1-4 Targets related to climate change mitigation and adaptation 124–130
E1-5 Energy consumption and mix 136
E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions 137
E1-7 GHG removals and GHG mitigation projects financed through carbon credits 150
E1-9 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities – ESRS phase-in provision applied
ESRS E4 – Biodiversity and ecosystems
E4-1 Transition plan and consideration of biodiversity and ecosystems in strategy and business model 153
ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model(s) 152–153
ESRS 2 IRO-1 Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks and opportunities General information 91–93
E4-2 Policies related to biodiversity and ecosystems 153–154
E4-3 Actions and resources related to biodiversity and ecosystems 155
E4-4 Targets related to biodiversity and ecosystems 155
E4-6 Anticipated financial effects from biodiversity and ecosystem-related risks and opportunities – ESRS phase-in provision applied

===== SIDA 101 =====

Nordea Annual Report 2025 100
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Section Page(s) Additional information
ESRS S1 – Own workforce
ESRS 2 SBM-2 Interests and views of stakeholders General information 86–87
ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model(s) 157
S1-1 Policies related to own workforce 157–159
S1-2 Processes for engaging with own workers and workers’ representatives about impacts 160
S1-3 Processes to remediate negative impacts and channels for own workforce to raise concerns 160
S1-4 Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material 
opportunities related to own workforce, and effectiveness of those actions
161–163
S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and 
opportunities
163
S1-6 Characteristics of the undertaking’s employees 164
S1-7 Characteristics of non-employees in the undertaking’s own workforce 164 ESRS phase-in provision  
partially applied
S1-9 Diversity metrics 165
S1-13 Training and skills development metrics 165
S1-14 Health and safety metrics 165 ESRS phase-in provision  
partially applied
S1-15 Work-life balance metrics – ESRS phase-in provision applied
S1-16 Remuneration metrics (pay gap and total remuneration) 166
S1-17 Incidents, complaints and severe human rights impacts 160
ESRS S4 – Consumers and end-users
ESRS 2 SBM-2 Interests and views of stakeholders General information 86–87
ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model(s) 168
S4-1 Policies related to consumers and end-users 168–170
S4-2 Processes for engaging with consumers and end-users about impacts 171–173
S4-3 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns 171, 173
S4-4 Taking action on material impacts on consumers and end-users, and approaches to mitigating material risks and pursuing 
material opportunities related to consumers and end-users, and effectiveness of those actions
171–174
S4-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and 
opportunities
172–174

===== SIDA 102 =====

Nordea Annual Report 2025 101
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Section Page(s) Additional information
ESRS G1 – Business conduct
ESRS 2 GOV-1 The role of the administrative, supervisory and management bodies General information 88–90
ESRS 2 IRO-1 Description of the processes to identify and assess material impacts, risks and opportunities General information 91–93
G1-1 Business conduct policies and corporate culture 176–178
G1-3 Prevention and detection of corruption and bribery 179
Entity-specific Financial crime and fraud prevention 179–180
Entity-specific Cyber security 180
Datapoints that derive from other EU legislation
Disclosure 
Requirement Related datapoint SFDR reference Pillar 3 reference Benchmark Regulation reference EU Climate Law reference Page reference
ESRS 2 GOV-1 Board’s gender diversity paragraph 21 (d) Indicator number 13 of Table #1 of Annex 1 Commission Delegated Regulation (EU) 2020/1816, Annex II 89
Percentage of board members who are independent 
paragraph 21 (e)
Delegated Regulation (EU) 2020/1816, Annex II 88
ESRS 2 GOV-4 Statement on due diligence paragraph 30 Indicator number 10 Table #3 of Annex 1 91
ESRS 2 SBM-1 Involvement in activities related to fossil fuel activities 
paragraph 40 (d) i
Indicators number 4 Table #1 of Annex 1 Article 449a Regulation (EU) No 575/2013;
Commission Implementing Regulation (EU) 
2022/2453 Table 1: Qualitative information on 
Environmental risk and Table 2: Qualitative 
information on Social risk
Delegated Regulation (EU) 2020/1816, Annex II Not material
Involvement in activities related to chemical 
production paragraph 40 (d) ii
Indicator number 9 Table #2 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Not material
Involvement in activities related to controversial 
weapons paragraph 40 (d) iii
Indicator number 14 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1818, Article 12(1) Delegated 
Regulation (EU) 2020/1816, Annex II
Not material
Involvement in activities related to cultivation and 
production of tobacco paragraph 40 (d) iv
Not material
ESRS E1-1 Transition plan to reach climate neutrality by 2050 
paragraph 14
Regulation (EU) 2021/1119, 
Article 2(1)
114–117
Undertakings excluded from Paris-aligned 
Benchmarks paragraph 16 (g)
Article 449a
Regulation (EU) No 575/2013; Commission 
Implementing Regulation (EU) 2022/2453 
Template 3: Banking book – Climate change 
transition risk: alignment metrics
Delegated Regulation (EU) 2020/1818, Article12.1 (d) to (g), and 
Article 12.2
117
ESRS E1-4 GHG emission reduction targets paragraph 34 Indicator number 4 Table #2 of Annex 1 Article 449a
Regulation (EU) No 575/2013; Commission 
Implementing Regulation (EU) 2022/2453 
Template 3: Banking book – Climate change 
transition risk: alignment metrics
Delegated Regulation (EU) 2020/1818, Article 6 124–130

===== SIDA 103 =====

Nordea Annual Report 2025 102
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Disclosure 
Requirement Related datapoint SFDR reference Pillar 3 reference Benchmark Regulation reference EU Climate Law reference Page reference
ESRS E1-5 Energy consumption from fossil sources 
disaggregated by sources (only high climate impact 
sectors) paragraph 38
Indicator number 5 Table #1 and Indicator 
n. 5 Table #2 of Annex 1
Not material
Energy consumption and mix paragraph 37 Indicator number 5 Table #1 of Annex 1 136
Energy intensity associated with activities in high 
climate impact sectors paragraphs 40 to 43
Indicator number 6 Table #1 of Annex 1 Not material
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions 
paragraph 44
Indicators number 1 and 2 Table #1 of 
Annex 1
Article 449a; Regulation (EU) No 575/2013; 
Commission Implementing Regulation (EU) 
2022/2453 Template 1: Banking book – Climate 
change transition risk: Credit quality of exposures 
by sector, emissions and residual maturity
Delegated Regulation (EU) 2020/1818, Article 5(1), 6 and 8(1) 137
Gross GHG emissions intensity paragraphs 53 to 55 Indicators number 3 Table #1 of Annex 1 Article 449a Regulation (EU) No 575/2013; 
Commission Implementing Regulation (EU) 
2022/2453 Template 3: Banking book – Climate 
change transition risk: alignment metrics
Delegated Regulation (EU) 2020/1818, Article 8(1) 137
ESRS E1-7 GHG removals and carbon credits paragraph 56 Regulation (EU) 2021/1119, 
Article 2(1)
150
ESRS E1-9 Exposure of the benchmark portfolio to climate-
related physical risks paragraph 66
Delegated Regulation (EU) 2020/1818, Annex II Delegated 
Regulation (EU) 2020/1816, Annex II
Not material
Disaggregation of monetary amounts by acute and 
chronic physical risk paragraph 66 (a)
Article 449a Regulation (EU) No 575/2013; 
Commission Implementing Regulation (EU) 
2022/2453 paragraphs 46 and 47; Template 5: 
Banking book – Climate change physical risk: 
Exposures subject to physical risk.
Not material
Location of significant assets at material physical risk 
paragraph 66 (c).
Not material
Breakdown of the carrying value of its real estate 
assets by energy-efficiency classes paragraph 67 (c).
Article 449a Regulation (EU) No 575/2013; 
Commission Implementing Regulation (EU) 
2022/2453 paragraph 34; Template 2: Banking 
book -Climate change transition risk: Loans 
collateralised by immovable property – Energy 
efficiency of the collateral
Not material
Degree of exposure of the portfolio to climate- 
related opportunities paragraph 69
Delegated Regulation (EU) 2020/1818, Annex II Not material
ESRS E2-4 Amount of each pollutant listed in Annex II of the 
E-PRTR Regulation (European Pollutant Release and 
Transfer Register) emitted to air, water and soil, 
paragraph 28
Indicator number 8 Table #1 of Annex 1 
Indicator number 2 Table #2 of Annex 1 
Indicator number 1 Table #2 of Annex 1 
Indicator number 3 Table #2 of Annex 1
Not material
ESRS E3-1 Water and marine resources paragraph 9 Indicator number 7 Table #2 of Annex 1 Not material
Dedicated policy paragraph 13 Indicator number 8 Table 2 of Annex 1 Not material
Sustainable oceans and seas paragraph 14 Indicator number 12 Table #2 of Annex 1 Not material

===== SIDA 104 =====

Nordea Annual Report 2025 103
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Disclosure 
Requirement Related datapoint SFDR reference Pillar 3 reference Benchmark Regulation reference EU Climate Law reference Page reference
ESRS E3-4 Total water recycled and reused paragraph 28 (c) Indicator number 6.2 Table #2 of Annex 1 Not material
Total water consumption in m 3 per net revenue on 
own operations paragraph 29
Indicator number 6.1 Table #2 of Annex 1 Not material
ESRS 2 - SBM 3 - E4 paragraph 16 (a) i Indicator number 7 Table #1 of Annex 1 Not material
paragraph 16 (b) Indicator number 10 Table #2 of Annex 1 152–153
paragraph 16 (c) Indicator number 14 Table #2 of Annex 1 152–153
ESRS E4-2 Sustainable land / agriculture practices or policies 
paragraph 24 (b)
Indicator number 11 Table #2 of Annex 1 153–154
Sustainable oceans / seas practices or policies 
paragraph 24 (c)
Indicator number 12 Table #2 of Annex 1 153–154
Policies to address deforestation paragraph 24 (d) Indicator number 15 Table #2 of Annex 1 153–154
ESRS E5-5 Non-recycled waste paragraph 37 (d) Indicator number 13 Table #2 of Annex 1 Not material
Hazardous waste and radioactive waste paragraph 
39
Indicator number 9 Table #1 of Annex 1 Not material
ESRS 2 - SBM3 - S1 Risk of incidents of forced labour paragraph 14 (f) Indicator number 13 Table #3 of Annex I Not material
Risk of incidents of child labour paragraph 14 (g) Indicator number 12 Table #3 of Annex I Not material
ESRS S1-1 Human rights policy commitments paragraph 20 Indicator number 9 Table #3 and Indicator 
number 11 Table #1 of Annex I
158
ESRS S1-1 Due diligence policies on issues addressed 
by the fundamental International Labour 
Organisation Conventions 1 to 8, paragraph 21
Delegated Regulation (EU) 2020/1816, Annex II 158
ESRS S1-1 processes and measures for preventing 
trafficking in human beings paragraph 22
Indicator number 11 Table #3 of Annex I Not material
ESRS S1-1 workplace accident prevention policy or 
management system paragraph 23
Indicator number 1 Table #3 of Annex I 158
ESRS S1-3 Grievance/complaints handling mechanisms 
paragraph 32 (c)
Indicator number 5 Table #3 of Annex I 160
ESRS S1-14 Number of fatalities and number and rate of work-
related accidents paragraph 88 (b) and (c)
Indicator number 2 Table #3 of Annex I Delegated Regulation (EU) 2020/1816, Annex II Not material
Number of days lost to injuries, accidents, fatalities or 
illness paragraph 88 (e)
Indicator number 3 Table #3 of Annex I Not material
ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a) Indicator number 12 Table #1 of Annex I Delegated Regulation (EU) 2020/1816, Annex II 166
Excessive CEO pay ratio paragraph 97 (b) Indicator number 8 Table #3 of Annex I 166
ESRS S1-17 Incidents of discrimination paragraph 103 (a) Indicator number 7 Table #3 of Annex I 160
Non-respect of UNGPs on Business and Human 
Rights and OECD Guidelines paragraph 104 (a)
Indicator number 10 Table #1 and Indicator 
n. 14 Table #3 of Annex I
Delegated Regulation (EU) 2020/1816, Annex II Delegated 
Regulation (EU) 2020/1818 Art 12 (1)
160
ESRS 2 - SBM3 - S2 Significant risk of child labour or forced labour in the 
value chain paragraph 11 (b)
Indicators number 12 and n. 13 Table #3 of 
Annex I
Not material

===== SIDA 105 =====

Nordea Annual Report 2025 104
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
General information, cont.
Disclosure 
Requirement Related datapoint SFDR reference Pillar 3 reference Benchmark Regulation reference EU Climate Law reference Page reference
ESRS S2-1 Human rights policy commitments paragraph 17 Indicator number 9 Table #3 and Indicator 
n. 11 Table #1 of Annex 1
Not material
Policies related to value chain workers paragraph 18 Indicator number 11 and n. 4 Table #3 of 
Annex 1
Not material
ESRS S2-1 Non-respect of UNGPs on Business and 
Human Rights principles and OECD guidelines 
paragraph 19
Indicator number 10 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Delegated 
Regulation (EU) 2020/1818, Art 12 (1)
Not material
ESRS S2-1 Due diligence policies on issues addressed 
by the fundamental International Labour 
Organisation Conventions 1 to 8, paragraph 19
Delegated Regulation (EU) 2020/1816, Annex II Not material
ESRS S2-4 Human rights issues and incidents connected to its 
upstream and downstream value chain paragraph 36
Indicator number 14 Table #3 of Annex 1 Not material
ESRS S3-1 Human rights policy commitments paragraph 16 Indicator number 9 Table #3 of Annex 1 and 
Indicator number 11 Table #1 of Annex 1
Not material
Non-respect of UNGPs on Business and Human 
Rights, ILO principles or OECD guidelines paragraph 
17
Indicator number 10 Table #1 Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Delegated 
Regulation (EU) 2020/1818, Art 12 (1)
Not material
ESRS S3-4 Human rights issues and incidents paragraph 36 Indicator number 14 Table #3 of Annex 1 Not material
ESRS S4-1 Policies related to consumers and end-users 
paragraph 16
Indicator number 9 Table #3 and Indicator 
number 11 Table #1 of Annex 1
168–170
Non-respect of UNGPs on Business and Human 
Rights and OECD guidelines paragraph 17
Indicator number 10 Table #1 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II Delegated 
Regulation (EU) 2020/1818, Art 12 (1)
171
ESRS S4-4 Human rights issues and incidents paragraph 35 Indicator number 14 Table #3 of Annex 1 171
ESRS G1-1 United Nations Convention against Corruption 
paragraph 10 (b)
Indicator number 15 Table #3 of Annex 1 Not material
Protection of whistle-blowers paragraph 10 (d) Indicator number 6 Table #3 of Annex 1 171
ESRS G1-4 Fines for violation of anti-corruption and anti-bribery 
laws paragraph 24 (a)
Indicator number 17 Table #3 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II) Not material
ESRS G1-4 Standards of anti-corruption and anti- 
bribery paragraph 24 (b)
Indicator number 16 Table #3 of Annex 1 Not material

===== SIDA 106 =====

Nordea Annual Report 2025 105
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
ENVIRONMENTAL INFORMATION
EU Taxonomy disclosures
EU Taxonomy supporting the transition
The EU Taxonomy Regulation (hereafter “the Taxonomy”) 
and its delegated acts define environmentally sustainable 
or “Taxonomy-aligned” economic activities based on tech-
nical screening criteria. In order for an activity to be 
Taxonomy aligned, it must contribute substantially to one 
of the EU’s climate and environmental objectives while not 
significantly harming any of the other objectives. In addi-
tion, minimum safeguard requirements must be met. 
In 2025 we continued to work on assessing the implica-
tions of the EU Taxonomy requirements and further devel-
oped our disclosure methodology, including by imple-
menting the delegated regulation amending the 
Taxonomy Disclosures, Climate and Environmental dele-
gated acts. The amending delegated regulation, 
Regulation (EU) 2026/73, applicable since 1 January 2026, 
simplifies the Taxonomy reporting templates and intro-
duces methodological changes that affect the disclosures. 
There are not yet any common standards for or 
approaches to making these disclosures. The approach we 
have adopted reflects our understanding and interpreta-
tion of the EU Taxonomy requirements and the guidance 
from the EU Commission. We explain how the amending 
delegated regulation has affected our disclosures below.
Sustainability is an integral part of our Group strategy, 
as reflected in our strategic sustainability priorities. 
Through our customer offering, engagement and risk 
management activities, we aim to support customers and 
investees in aligning their activities with a net zero by 
2050 trajectory. The Taxonomy can facilitate strategy 
implementation, for example by guiding our approach to 
sustainable financing facilitation and informing our dia-
logues with customers. We facilitate sustainable financing 
through our green funding framework, which draws on 
the Taxonomy’s “substantial contribution” criteria in estab-
lishing how we identify, select, verify and report sustaina-
ble financing. Going forward, we will continue to review 
options for further aligning our green funding framework 
with the Taxonomy.
We have adjusted our product process to fulfil our obli-
gations under the Taxonomy regarding Sustainable 
Finance Disclosure Regulation (SFDR) products. At the 
product level, we disclose whether the EU criteria for envi-
ronmentally sustainable economic activities are taken into 
account in the design of the product and if so, whether the 
product has a built-in commitment to making Taxonomy-
aligned investments. At present, our selection of SFDR 
products with such a commitment is small. This is because 
we do not have sufficient data to support a meaningful 
commitment to a minimum proportion of Taxonomy-
aligned investments. For each SFDR Article 8 or 9 product, 
we calculate and disclose the Taxonomy-alignment of the 
actual investment, subject to data availability and quality.
When providing investment advice, we explain the main 
elements of the EU Taxonomy to our customers before 
assessing their sustainability preferences. This includes 
assessing whether they consider it important to invest in 
line with the EU’s environmental objectives as defined in 
the Taxonomy, as this is a regulatory requirement under 
the Markets in Financial Instruments Directive (MiFID II). 
We currently have a small selection of investment funds 
with a commitment to Taxonomy-aligned investments. 
Data related to Taxonomy-aligned investments is still 
developing for the industry as a whole.
Group disclosures 
In accordance with the third EU Commission notice con-
cerning disclosures on sustainability, we disclose consoli-
dated key performance indicators (KPIs) for each of our 
business segments. We make these disclosures in the tem-
plates for credit institutions and asset managers and also 
disclose weighted KPIs for the Group based on the business 
segment KPIs. Nordea Investment Funds S.A. and Nordea 
Funds Ltd are covered by the KPI for asset managers. 
The above-mentioned amending delegated regulation 
introduces materiality thresholds allowing financial 
institutions to omit full KPIs or assets included in KPIs 
where the use of proceeds is known if they represent less 
than 10% of the institution’s total assets or total net turno-
ver. We have chosen to implement these materiality thresh-
olds for our Group-level disclosures and have omitted the 
investment firm template. Since the revenue related to the 
investment firm template is less than 10% of that of the 
Group
1, the activities in the template have been deemed to 
be non-material and have not been assessed for Taxonomy 
eligibility or alignment. The templates for credit institutions 
and asset managers can be found in “Appendix (EU 
Taxonomy)” on page 181. The weighted KPIs for financial 
conglomerates and the summary of KPIs to be disclosed by 
credit institutions can be found below. 
Our disclosures include subsidiaries on a prudential con-
solidated basis as per Annex V of the Disclosures Delegated 
Regulation. Exposures to Nordea Life & Pension are there-
fore treated under the equity method, meaning that they 
are treated in the same way as any other equity holdings. 
Since Nordea Life & Pension did not fall under the 
Corporate Sustainability Reporting Directive (CSRD) in 
2025, the exposures were not assessed for alignment within 
the Group Taxonomy disclosures. Due to the fact that 
Nordea Life & Pension is treated under the equity method 
and does not have to comply with the CSRD, the consoli-
dated Group table does not include insurance activities. 
The financial conglomerate weighted KPIs and a sum-
mary of the credit institution KPIs are displayed on page 
109. The remaining disclosures can be found in “Appendix 
(EU Taxonomy)” on pages 181–190.
Changes to our EU Taxonomy disclosures in 2025  
in line with the amending delegated regulation 
• Exposures to companies not subject to Corporate 
Sustainability Reporting Directive (CSRD) reporting 
obligations (except for those with voluntary disclo-
sures or with a parent company falling under the 
CSRD), derivatives, cash and cash equivalents, 
on-demand interbank loans, and other assets, such 
as goodwill and commodities, are now excluded 
from the denominator of the green asset ratio (GAR). 
• All tables have been simplified.
• The tables including activities related to the nuclear 
and fossil gas sectors have been omitted and instead 
the information has been included in Tables 8-9 
(GAR  s ector information) and Table 14 – Template 
for the KPI of Asset Managers.
• Comparative data for the previous year has been 
omitted.
• Tables 6 and 7 (assets for the calculation of GAR 
flow) have been introduced.
• Materiality thresholds have been implemented in the 
investment firm template and for the assets under 
management and financial guarantees KPIs.
1) The revenue related to the investment firm template accounts for 5.8% of that of the Group. This can be seen in Tables 2 and 3 (weighted KPIs of financial conglomerate). 
The majority of our revenue is from internal Nordea Group customers.

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Nordea Annual Report 2025 106
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
EU Taxonomy disclosures, cont.
EU Taxonomy tables Page
Table 1 – 0. Summary of KPIs to be disclosed by 
credit institutions under Article 8 Taxonomy 
Regulation 109
Table 2 – Weighted KPIs of financial conglomerate 
(turnover) 109
Table 3 – Weighted KPIs of financial conglomerate 
(capex) 109
Table 4 – Template 1: Assets for the calculation of 
GAR (EURm) Stock Turnover 181
Table 5 – Template 1: Assets for the calculation of 
GAR (EURm) Stock Capex 182
Table 6 – Template 1: Assets for the calculation of 
GAR (EURm) Flow Turnover 183
Table 7 – Template 1: Assets for the calculation of 
GAR (EURm) Flow Capex 184
Table 8 – Template 2: GAR sector information 
(EURm) Turnover 185
Table 9 – Template 2: GAR sector information 
(EURm) Capex 185
Table 10 – Template 3: GAR KPI Stock (%) Turnover 186
Table 11 – Template 3: GAR KPI Stock (%) Capex 187
Table 12 – Template 4: Flow KPI (%) Turnover 188
Table 13 – Template 4: Flow KPI (%) Capex 189
Table 14 – Template for the KPI of Asset Managers 190
Data and methodology for the KPIs to 
be disclosed by credit institutions 
The green asset ratio (GAR) key performance indicator 
(KPI) shows our exposures related to Taxonomy-aligned 
activities as a proportion of our total covered assets1 and is 
our main KPI, reported in Tables 4–7 on pages 181–184. 
In line with the amending delegated regulation, the 
methodology for calculating the GAR changed during 
2025. Therefore, this KPI should not be compared with 
that of the previous year. The methodological change 
included a reduction in the denominator of the GAR, as 
exposures to companies not subject to the Corporate 
Sustainability Reporting Directive (CSRD) (except for 
those with voluntary disclosures or with a parent company 
falling under the CSRD), derivatives, cash and cash equiv-
alents, on-demand interbank loans, and other categories 
of assets, such as goodwill and commodities, are now 
excluded. Additionally, exposures to non-CSRD companies 
that have voluntary disclosed Taxonomy KPIs are now 
included in the numerator. 
In 2025 there was an increase in total Taxonomy-
aligned assets that was not due to the amending dele-
gated act. The increase was due to the following. 
• An increase in the total amount of Taxonomy-aligned 
exposures to activities contributing to the environmental 
objectives sustainable use and protection of water and 
marine resources, transition to a circular economy, pollu-
tion prevention and control, and protection and restora-
tion of biodiversity and ecosystems.
• An update to our methodology for calculating the top 
15% of national or regional building stock in primary 
energy demand (PED) terms in Finland. This was partly 
based on a study conducted by Granlund for Rakli Ry in 
2024 and partly based on updated internal calculations 
of PED thresholds for single-family houses. 
• An improvement in Energy Performance Certificate 
(EPC) data coverage in Finland.
In 2025 there was also an increase in the total amount of 
Taxonomy-eligible exposures to activities contributing to 
the four aforementioned environmental objectives.
The assets in scope for credit institutions are exposures to 
companies falling under the CSRD (financial and non-fi-
nancial companies), exposures to non-CSRD companies 
that voluntarily disclose Taxonomy KPIs or have a parent 
company falling under the CSRD, retail exposures (motor 
vehicle loans, renovation loans and mortgages), local gov-
ernment financing, collateral obtained by taking posses-
sion of residential and commercial immovable properties, 
and off-balance sheet exposures. An overview of how we 
assess these assets is provided below. 
Assets Assessment
Exposures to CSRD 
companies
For non-financial CSRD companies, we weight the exposure to the company’s reported share of Taxonomy-eligible 
and Taxonomy-aligned turnover and capital expenditure (CapEx). For financial CSRD companies, we weight the 
exposure to the company’s share of eligible and aligned economic assets among its total covered assets. This means 
that all loans are treated as general purpose loans.
Exposures to non-CSRD 
companies
If a non-CSRD company has voluntarily disclosed Taxonomy KPIs, we include the exposure and assess it following 
the same approach as for exposures to CSRD companies.
Local government 
financing
We do not assess local government financing for Taxonomy alignment since we do not have a business model based 
to a great extent on financing public housing, and data on specialised lending to local governments is unavailable.
Collateral obtained by 
taking possession of 
residential and 
commercial immovable 
properties
Data on collateral obtained by taking possession of residential and commercial immovable properties is not 
available and is therefore not assessed for Taxonomy alignment.
Household exposures Motor vehicle loans Motor vehicle loans granted after 1 January 2022 are in scope. However, due to the 
comprehensive level of detail required for the Taxonomy assessment and limited data 
availability, we do not assess motor vehicle loans for Taxonomy alignment.
Renovation loans Due to limited data availability, we do not assess renovation loans for Taxonomy alignment.
Mortgages We assess whether mortgages contribute to the environmental objective climate change 
mitigation according to activity 7.7 Acquisition and ownership of buildings. A description of 
how the assessment is made can be found below.
1) Total covered assets refer to all on-balance sheet exposures except for exposures to non-CSRD companies (except for those that have made voluntary disclosures or have a 
parent company falling under the CSRD), central governments, central banks, supranational issuers, the trading portfolio, derivatives, cash and cash equivalents, on-demand 
interbank loans, and other categories of assets, such as goodwill and commodities. The terms “GAR stock” and “total GAR assets” used in the predefined tables should be 
understood with reference to the GAR definitions provided.

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Nordea Annual Report 2025 107
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
EU Taxonomy disclosures, cont.
The image to the right provides an overview of how we 
assess whether mortgages contribute to the environmen-
tal objective climate change mitigation according to activ-
ity 7.7 Acquisition and ownership of buildings. 
In 2025, for residential real estate lending in the 
Norwegian and Swedish markets, we assessed the full 
gross carrying amount of mortgages for Taxonomy align-
ment. For residential real estate lending in the Danish and 
Finnish markets, we assessed the gross carrying amount 
excluding second mortgages (top-up loans). 
For buildings built before 31 December 2020, the 
threshold for substantial contribution is EPC class A or the 
building being within the top 15% of the national or 
regional building stock. For the Danish and Norwegian 
market, the top 15% building stock threshold was deter-
mined based on the buildings having an EPC class A or B 
label. In Sweden, the top 15% was identified based on pri-
mary energy demand (PED) thresholds established in a 
study by the Swedish Property Federation. For the Finnish 
market, the calculation of top 15% PED thresholds was 
based on a study by Granlund in 2024, using energy per-
formance certificate data from the Centre for State-
Subsidised Housing Construction (Varke). The thresholds 
for the Finnish market had previously been based on a 
Granlund study from 2022. In addition to this, the method-
ology for calculating the top 15% of single-family houses 
was updated based on an internal study. Single-family 
house energy consumption data is protected under the 
General Data Protection Regulation in Finland and is 
therefore not part of the Granlund report, which is based 
on public data. These updates led to an increase in the 
amount of Taxonomy-aligned mortgages across the Nordic 
markets. However, in cases where loans had multiple col-
lateralised assets with conflicting Taxonomy alignment, 
the full loan amount was considered to be non-aligned. 
This methodological change, implemented in 2025, 
adversely affected the amount of Taxonomy-aligned 
mortgages.
For buildings built after 31 December 2020, the building 
is considered to significantly contribute to climate change 
mitigation if it has a PED which is at least 10% lower than 
the threshold for the nearly zero energy building (NZEB) 
requirements in the respective country. Due to a lack of 
PED data in Norway and Denmark, small residential build-
ings with an EPC class A label in Norway and all buildings 
with an EPC class A2020 label in Denmark were consid-
ered to have a PED 10% lower than the national threshold 
set for nearly zero energy buildings. In Sweden and 
Finland, the assessment was based on PED thresholds.
The assessment of whether a building has been built 
before or after 31 December 2020 should be based on the 
date of the application for a construction permit. Due to data 
limitations, our assessment was made based on when the 
building had been completed. This is a conservative 
approach due to the stricter assessment criteria for newer 
buildings. 
Physical climate risk assessments for residential real 
estate lending were carried out to determine whether the 
exposures fulfilled “do no significant harm” criteria. 
Exposures identified as being subject to medium or high 
physical climate risk were not assessed as Taxonomy 
aligned. The assessments applied a Representative 
Concentration Pathway scenario of 4.5 for the time period 
2011–40. As retail exposures only include mortgages and 
not renovation loans or motor vehicle loans, minimum 
safeguards were not considered.
Tables 8 and 9, on GAR sector information, provide a 
breakdown of Taxonomy-eligible and Taxonomy-aligned 
exposures to CSRD companies by sector. The first 10 rows 
are based on the principal activity of the counterparty 
(using NACE codes) and only cover activities identified in 
the Taxonomy delegated acts. The 10 largest sectors based 
on total exposure are displayed. The table also includes 
information on the total exposure to companies’ nuclear 
and gas activities. 
The off-balance sheet KPIs covering financial guaran-
tees and assets under management (AuM) have been 
omitted in the 2025 disclosures. The assets covered by the 
AuM KPI are assets delegated to Nordea Investment 
Management by Nordea Bank Abp. As the net turnover 
generated by the activities covered by the KPIs accounted 
for only 0.1% of the Nordea Group’s total net turnover in 
2025, the KPI was considered to be non-material. Table 18 
– Template for the KPI of Asset Managers provides a 
clearer overview of the Taxonomy alignment of our AuM. 
The KPI covering financial guarantees was also consid-
ered to be non-material since the net turnover generated 
by the activities covered by the KPI accounted for only 
0.1% of the Nordea Group’s total net turnover in 2025. 
The reporting in the credit institution tables (Tables 1–3, 
below) is based on data originating from our internal core 
banking systems and external data on (i) CSRD companies’ 
disclosed Taxonomy eligibility and alignment KPIs, includ-
ing fossil gas and nuclear exposures, (ii) EPCs for buildings, 
(iii) PEDs for buildings and (iv) physical climate risk assess-
ments in relation to residential real estate lending. 
CLIMATE CHANGE MITIGATION
Activity 7.7:
Acquisition and ownership of buildings
Buildings built before 31 Dec 2020 31 December 2020 Buildings built after 31 Dec 2020
Substantial contribution:
At least EPC class A or within the top 15% of the national or 
regional building stock in PED terms
A PED at least 10% lower than the national threshold set for nearly 
zero energy buildings
Do no significant harm:
Climate change adaptation: any exposures subject to medium or high physical climate risk are not assessed to be Taxonomy aligned.
Minimum safeguards:
Retail exposures: no MS assessment for activity 7.7

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Nordea Annual Report 2025 108
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
EU Taxonomy disclosures, cont.
Data and methodology for the KPIs to 
be disclosed by asset managers
The subsidiaries covered by the asset manager KPI (Table 
14, on page 190) are Nordea Investment Funds S.A. and 
Nordea Funds Ltd. The KPI of the template for asset man-
agers is a weighted average of the value of (i) investments 
in the Taxonomy-aligned economic activities of investee 
companies, (ii) debt securities with the purpose of financ-
ing specifically identified activities or projects, and (iii) 
environmentally sustainable bonds issued by investee 
companies. The equity and debt securities are assessed for 
Taxonomy eligibility and alignment based on the 
Taxonomy-eligible and Taxonomy-aligned activities 
financed by their proceeds. 
In line with the amending delegated regulation, the 
methodology for calculating the KPIs for asset managers 
changed during 2025. As with the green asset ratio (GAR) 
for credit institutions, the methodological change included 
a reduction in the denominator of the GAR for asset man-
agers due to the exclusion of exposures to non-CSRD com-
panies (except for those with voluntary disclosures or with 
a parent company falling under the CSRD), derivatives, 
cash and cash equivalents, on-demand interbank loans, 
and other categories of assets, such as goodwill and com-
modities. The numerator also changed to include expo-
sures to non-CSRD companies that had voluntarily 
disclosed Taxonomy KPIs. In addition to the methodologi-
cal changes, the tables were simplified and the tables 
including activities related to the nuclear and fossil gas 
sectors were omitted, with the information instead 
included in the template for the KPI of asset managers. 
The data on CSRD undertakings was acquired from a 
third-party service provider. 
There has been an increase in total Taxonomy-aligned 
assets which was not due to the amending delegated reg-
ulation. The increase was due to an increase in the total 
amount of Taxonomy-aligned exposures to activities con-
tributing to the environmental objectives sustainable use 
and protection of water and marine resources, transition 
to a circular economy, pollution prevention and control, 
and protection and restoration of biodiversity and ecosys-
tems, as non-financial undertakings have been obliged to 
disclose alignment since the financial year 2024. 
There has also been an increase in the total amount of 
Taxonomy-eligible exposures to activities contributing to 
the four aforementioned environmental objectives as 
financial undertakings have been obliged to disclose eligi-
bility since the financial year 2024.
The assets in scope for asset managers are exposures 
to investee companies falling under the CSRD (financial 
and non-financial undertakings), non-CSRD investee com-
panies that voluntarily disclose Taxonomy KPIs or have a 
parent company falling under the CSRD, local government 
and municipal financing, and use-of-proceeds debt instru-
ments. An overview of how we assess exposures to inves-
tee companies is provided below.
Exposures Assessment
Exposures to 
CSRD investee 
companies
For both financial and non-financial CSRD 
companies, we weight the exposure to the 
company’s share of eligible and aligned turnover 
and capital expenditures (CapEx) as provided by 
our data provider. 
Exposures to 
non-CSRD 
investee 
companies
If a non-CSRD company has voluntarily disclosed 
Taxonomy KPIs, we include this exposure and 
assess it following the same approach as for 
exposures to CSRD companies.
Exposures to 
local government 
and municipal 
financing
We include these exposures and assess them 
following the same approach as for exposures to 
CSRD companies so long as they have been 
assessed for Taxonomy eligibility and alignment 
in the information provided by our data provider.
Exposures to 
use-of-proceeds 
debt instruments
We include these exposures and assess them 
following the same approach as for exposures to 
CSRD companies so long as they fulfil our 
internal sustainable labelled bond criteria.

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Nordea Annual Report 2025 109
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
EU Taxonomy disclosures, cont.
Table 1 – 0. Summary of KPIs to be disclosed by credit institutions under Article 8 Taxonomy Regulation
31 December 2025
Total exposure to Taxonomy-  
aligned activities (EURm) KPI KPI
% coverage (over 
total assets)2 (%)
non assessed exposures  
(% of covered assets)3 (%)
non assessed exposures  
(% of covered assets)3 (%)
Turnover-based CapEx-based Turnover-based CapEx-based Turnover-based CapEx-based
Main KPI Green asset ratio (GAR) stock 16,001 16,481 6.2% 6.4% 46.2% 0.0% 0.0%
31 December 2025
Total exposure to Taxonomy-  
aligned activities (EURm) KPI KPI
% coverage (over 
total assets)2 (%)
non assessed exposures  
(% of covered assets)3 (%)
non assessed exposures  
(% of covered assets)3 (%)
Turnover-based CapEx-based Turnover-based CapEx-based Turnover-based CapEx-based
Additional KPIs GAR (flow) 3,059 3,432 5.1% 5.8% 46.3% 0.0% 0.0%
Trading book1
Financial guarantees4 - - - - 0.3% 100% 100%
Assets under management4 - - - - 0.1% 100% 100%
Fees and commissions income1
1) Fees and commission income and Trading book KPIs will only apply from 2028. 
2) The percentage of assets covered by the KPI over the institution’s total assets.
3) In accordance with Article 7(8) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73. 
4) Omitted in line with Article 4(1)(f) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73. 
Notes: Cells shaded in grey represent KPIs that are not subject to disclosure. In line with the Regulation (EU) 2026/73, the methodology to calculate the GAR changed during 2025. Therefore, this KPI should not be compared with that of the previous year. For information, the 2024 reported KPIs were as follows: 
Turnover 4.0% and CapEx 4.1%.
Table 2 – Weighted KPIs of financial conglomerate (turnover)
The table provides a weighted average of KPIs based on our Taxonomy-eligible and Taxonomy-aligned activities as a 
financial conglomerate. The KPIs are collected in the respective tables from the business areas and weighted based on 
the business areas’  share of Group revenue.
Revenue 
(EURm)
Propor-
tion of 
Group 
revenue 
Tax-
onomy- 
eligible
Tax-
onomy- 
aligned
 
“Non- 
assessed  
exposures5”
Breakdown per environmental objective 
Of which 
Use of 
Proceeds
Of which 
tran-
sitional
Of which 
enabling
Climate 
Change 
Mitigation 
(CCM)
Climate 
Change 
Adapta-
tion (CCA)
Water and 
marine 
resources 
(WTR)
Circular 
economy 
(CE)
Pollution 
(PPC)
Biodiver-
sity and 
Ecosys-
tems 
(BIO)
Banking1, 2 10,557,652 89.9% 64.5% 5.6% 5.6% 0.0% 0.0% 0.0% 0.0% 0.0% 4.6% 0.1% 0.1% 0.0%
Asset management3 505,818 4.3% 2.0% 0.3% 0.2% 0.0% 0.0% 0.0% 0.0% 0.0% - 0.0% 0.1% 0.0%
Investment firms4 679,905 5.8% - - - - - - - - - - - -
Total operating income 11,743,375 100.0%
Group average KPI 66.5% 5.9% 5.8% 0.0% 0.0% 0.0% 0.0% 0.0% 4.6% 0.2% 0.2% 0.0%
1) “Banking” includes all subsidiaries which are consolidated based on the equity method.
2) The green asset ratio stock is our main KPI and is therefore used as the KPI for our banking business segment.
3) “Asset management” covers the subsidiaries Nordea Investment Funds S.A . and Nordea Funds Ltd.
4) “Investment firms” covers Nordea Investment Management AB. This KPI is considered non-material and is not disclosed as the 
revenue related to the KPI is less than 10% of our total revenue and is mainly from internal Nordea Group customers.
5) In accordance with Article 7(8) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73. 
Note: Cells shaded in grey represent KPIs that are not subject to disclosure.
Table 3 – Weighted KPIs of financial conglomerate (CapEx)
The table provides a weighted average of KPIs based on our Taxonomy-eligible and Taxonomy-aligned activities as a 
financial conglomerate. The KPIs are collected in the respective tables from the business areas and weighted based on 
the business areas’ share of Group revenue.
Revenue 
(EURm)
Propor-
tion of 
Group 
revenue 
Tax-
onomy- 
eligible
Tax-
onomy- 
aligned
 
“Non- 
assessed  
exposures5”
Breakdown per environmental objective 
Of which 
Use of 
Proceeds
Of which 
tran-
sitional
Of which 
enabling
Climate 
Change 
Mitigation 
(CCM)
Climate 
Change 
Adapta-
tion (CCA)
Water and 
marine 
resources 
(WTR)
Circular 
economy 
(CE)
Pollution 
(PPC)
Biodiver-
sity and 
Ecosys-
tems 
(BIO)
Banking1, 2 10,557,652 89.9% 65.1% 5.8% 5.8% 0.0% 0.0% 0.0% 0.0% 0.0% 4.6% 0.1% 0.1% 0.0%
Asset management3 505,818 4.3% 0.9% 0.3% 0.2% 0.0% 0.0% 0.0% 0.0% 0.0% - 0.0% 0.1% 0.0%
Investment firms4 679,905 5.8% - - - - - - - - - - - -
Total operating income 11,743,375 100.0%
Group average KPI 66.0% 6.0% 6.0% 0.0% 0.0% 0.0% 0.0% 0.0% 4.6% 0.2% 0.2% 0.0%
1) “Banking” includes all subsidiaries which are consolidated based on the equity method.
2) The green asset ratio stock is our main KPI and is therefore used as the KPI for our banking business segment.
3) “Asset management” covers the subsidiaries Nordea Investment Funds S.A . and Nordea Funds Ltd.
4) “Investment firms” covers Nordea Investment Management AB. This KPI is considered non-material and is not disclosed as the 
revenue related to the KPI is less than 10% of our total revenue and is mainly from internal Nordea Group customers.
5) In accordance with Article 7(8) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73. 
Note: Cells shaded in grey represent KPIs that are not subject to disclosure.

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Nordea Annual Report 2025 110
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
ENVIRONMENT INFORMATION
E1 Climate change
With our firm commitment to be net zero by 2050, we are working 
closely with our customers to support their transitions to net zero 
and have  integrated climate change into our strategy and risk man-
agement to capture opportunities and strengthen our resilience. 
The Paris Agreement had its 10th anniversary in 2025. 
Progress in reducing emissions has been made, but not 
fast enough to meet the Paris targets. At the current pace, 
global warming is likely to exceed 1.5°C within the next 
decade, contributing to more severe extreme weather 
events, including floods, heatwaves and wildfires.
2025 was characterised by growing geopolitical tensions 
and regional divergence in climate policy. Amid the turbu-
lence and climate deregulation, we saw the European 
Union maintain a strong regulatory framework for climate 
neutrality by 2050 and agree on a 2040 climate target. In 
our home markets, the Nordic countries showed progress 
towards their net zero goals. The polarised landscape 
underlines the importance of a supportive policy environ-
ment for the real economy transition, which directly affects 
our ability to fulfil our climate commitments. 
As a leading Nordic financial services group, we are 
focused on supporting our customers’ transitions to net 
zero and contributing to the climate objectives of the 
Nordic countries in an inclusive manner. We work closely 
with our customers to understand their decarbonisation 
priorities and support them in financing their transition 
plans. Recognising that customers are at different stages 
in their transition journeys, we adapt our offerings to meet 
their needs and focus on developing capabilities and 
solutions that respond to the increasing need to finance 
the transition. 
Climate change considerations are also integrated into 
our investment strategies as a responsible asset manager. 
We are committed to supporting the transition through 
active ownership and engagement with investees and 
asset managers as well as a strong sustainable investment 
offering.
Besides working together with customers and invest-
ees, we draw on our expertise and partner with the 
broader community to support system-wide change. 
Through engagement with societal stakeholders and par-
ticipation in policy dialogues, we strive to support market 
conditions that can incentivise and further increase the 
supply of and demand for transition financing. We also 
play an active role in international climate finance net-
works, helping to further develop and standardise prac-
tices for transition planning, target setting and risk man-
agement across the industry.
We have made strong progress in executing our climate 
transition plan and supporting our customers with theirs. 
Our lending portfolio emissions have fallen by 44% since 
2019 and we have facilitated EUR 235bn in sustainable 
financing since 2022. In the run-up to 2030, we will con-
tinue to build resilience and work closely with our custom-
ers to support their individual transition journeys. 
Our new climate targets for 2030
Nordea Bank: Engage annually with corporate customers (collectively representing at least 70% of financed emissions in 
the large corporate lending portfolio) on the topic of net zero transition during the period 2026–30
Nordea Asset Management: By 2030, ensure that 100% of transition-critical investee companies are either aligned with 
the Paris Agreement or are subject to active stewardship to improve alignment
Operations and supply chain: By 2030, ensure that all identified transition-critical suppliers are either aligned with the 
Paris Agreement or are subject to active engagement to improve alignment
“ We will continue to build 
resilience and work closely 
with our customers.”
44%
reduction in greenhouse gas 
emissions across our lending  
 portfolio since 2019

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Nordea Annual Report 2025 111
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
Impacts, risks and opportunities overview for E1 Climate change
Impact, risk or opportunity Title Value chain Time horizon
Climate change mitigation
Positive impact
(actual)
Financing and supporting the transition of customers, investee 
companies and sectors     
Negative impact
(actual)
GHG emissions from our lending and investment portfolios and 
capital market activities     
Risk Climate-related transition risk      
Opportunity Financing and investing in activities to mitigate climate change 
and enhance adaptation     
Climate change adaptation
Risk Climate-related physical risk     
Energy
Positive impact
(actual)
Financing energy efficiency activities and engaging with investees 
regarding energy efficiency activities     
Negative impact  
(actual)
Final energy consumption in our lending and investment portfolios
    
Risk Climate-related transition risk      
 Very long term Short term  Medium term  Long term Upstream  Own operations  Downstream
In this section
We focus on how we manage the climate change-re-
lated impacts of our business activities, and how we 
mitigate associated risks. We examine the material 
impacts, risks and opportunities identified in our DMA 
and describe the policies, actions, resources and targets 
we have in place to address them. This section also 
contains relevant financed emissions disclosures and 
information on our energy consumption.
Material impacts, risks and opportunities and their 
interaction with strategy and business model 
Matters concerning climate change are directly relevant 
for our strategy and business model. 
Part of our strategy as a financial services group 
involves supporting the transition to a low-carbon, cli-
mate-resilient economy – in line with the goals of the Paris 
Agreement – by financing and supporting investment in 
more sustainable technologies and businesses. At the 
same time, we seek to strengthen our business to make it 
more resilient and future proof. 
The greenhouse gas (GHG) emissions associated with 
our lending and investment portfolios and generated by 
our own operations amounted to 19.8 MtCO2e in 2025 
(details are provided in the table “Gross Scopes 1, 2, 3 and 
total GHG emissions” on page 137). There are also GHG 
emissions associated with our sovereign debt financing 
(details are provided in separate tables on page 145). Our 
scope 1, 2 and 3 emissions are partially caused by high 
energy consumption across the value chain and contribute 
to our negative climate-related impacts on people and the 
environment. It is not possible to estimate the direct or 
indirect effects of these emissions on people or the envi-
ronment, or a time horizon for these effects, due to the 
complex nature of climate change. These impacts are con-
nected to our business relationships as a financial services 
company (providing financing to corporates and house-
holds and investing in companies). Our own operations 
equate to around 0.15% of our total emissions. 
Financing and investment to support the transition of 
customers and sectors has a positive climate impact when 
counterparties transition in line with the goals of the Paris 
Agreement. For example, it can support the scaling of 
solutions to address climate change or help achieve very 
rapid GHG reductions in high-emitting sectors. We view 
such transition financing as an opportunity that we can 
explore further. Where sustainable funding is concerned, 
we report on positive impacts such as water saved, energy 
saved through energy efficiency, clean energy produced, 
and emissions avoided in our green bond asset portfolio. 
We strive to increase our positive impact by pursuing 
opportunities to finance and invest in adaptation solutions 
and opportunities to scale funding connected to activities 
that mitigate climate change. Additional details on how 
we help manage the impacts of climate change are pro-
vided in “Transition plan” on page 114. 
Changes in the climate will affect society and pose mul-
tiple risks to the economy, creating opportunities and 
introducing new risks for banks. In particular, physical and 
transition risks associated with climate-related changes 
can impact the balance sheets and profitability of financial 
institutions. Understanding and managing these risks and 
their impacts over time is important for us and is a key 
consideration where our strategy and business model are 
concerned. Further details on the risk management of our 
lending and investment portfolios related to climate 
change are provided below.

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Nordea Annual Report 2025 112
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
Transitional risk vulnerability
321
1
2
3
Physical risk vulnerability
Air transportation
Real estate
Crops, plantation 
& hunting
Power production
Fishing & 
aquaculture Animal 
husbandry
Paper & forest products
Accommodation & leisure
Shipping
Construction
Mining & 
supporting activities
Utilities, distribution 
& waste management
Wholesale trade
IT services
Healthcare
Banks
Funds
Insurance
Industry names have been selectively identified to illustrate the population and 
 distribution across vulnerability bands.
Lending portfolio
Our risk management framework includes a process to 
perform a bank-wide materiality assessment (MA) to con-
sider how climate change risks can be drivers of our risk 
types (for example, credit, market, liquidity and opera-
tional risks). Our MA considers various levels of granularity 
(for example, individual asset classes, sectors, customers 
and geographies) to ensure relevant risk coverage of our 
exposures. The assessment includes both quantitative and 
qualitative components and is built on insights from other 
internal processes such as heatmapping, scenario analysis 
and stress testing. The matrix below outlines our view of 
climate change vulnerability by sector. 
Climate-related transition risk is mainly driven by 
changes in regulation aimed at advancing the transition to 
a low-carbon economy. To meet the Nordic countries’ GHG 
emissions reduction targets, companies will need to invest 
in technology and pay higher prices for polluting. They 
could lose revenue due to higher costs and changes in con-
sumer behaviour. Company transitions also rely significantly 
on public and private capital investment, which may have 
implications for economic growth, productivity and infla-
tion. We see this as an opportunity for our business, as we 
can be involved in steering capital towards adaptation solu-
tions and funding activities that mitigate climate change.
Climate-related transition risks can also directly mani-
fest themselves in our business by affecting the value of 
collateral pledged to us. For example, poor energy effi-
ciency can impact the market resale value of real estate, 
ships and vehicles. 
Climate-related transition risk drivers can also relate to 
legal and reputational risk, stemming from changed mar-
ket sentiment and litigation linked to greenwashing. 
In general, transition effects may materialise at any point 
in the short-to-long term, but could also materialise over 
longer time horizons if there is a delayed transition or no 
transition ahead of 2050.
Climate-related physical risk impacts in the Nordics are 
mainly driven by water-based hazards, predominantly flood-
ing events. These are reinforced by chronic effects such as 
variability in temperature and precipitation, reduction in 
snow/ice and sea level rise, and increases in soil moisture 
and ground frost. Some of these impacts are already seen 
in the short term, but they are considered chronic and 
more likely to materialise over longer time horizons. The 
main direct impact of climate-related physical risks on us 
is within real estate, through collateral devaluation. The 
main indirect impact is through potential credit quality 
deterioration due to disruptions to customers’ business 
operations, for example, through their global value chains.
We use stress testing and scenario analysis to assess 
the resilience of our business model and sustainability 
strategy. Stress testing is part of our internal capital ade-
quacy assessment process (ICAAP), which includes a 
short-term transition risk scenario. Additionally, our pru-
dential transition planning process includes medium-term 
and long-term scenario analysis. These exercises explore 
theoretical scenarios with different climate policy assump-
tions to address the uncertainty related to the pace and 
stringency of policy changes and market shifts. 
The short-term scenario assumes a sharp increase in 
the carbon tax, aligned with a delayed and then acceler-
ated transition, which increases energy prices and triggers 
changes in energy demand. This affects sectors’ output 
and costs depending on their emissions and energy inten-
sity. Furthermore, it leads to real estate devaluation, in 
particular for less energy-efficient buildings, which will be 
subject to increased operational costs.  
The medium-term scenarios compare different transition 
scenarios from both ends of the carbon pricing spectrum. 
These focus on different climate policies and dynamic factors 
that cannot be captured in the short term, such as emissions 
reduction efforts in line with customers’ transition plans.
The long-term analysis is aimed at identifying the impacts 
and risks associated with potential portfolio reallocations 
between sectors supporting our long-term climate targets.
Our assessment of climate-related physical risks covers 
the following:
• acute physical hazards (short to very long term)
 – coastal flooding and storm surges
 – extreme precipitation and inland flooding
• chronic physical hazards (medium to very long term)
 – variability in temperature
 – variability in precipitation
 – reduction in snow/ice and sea level rise
 – increases in soil moisture and ground frost.
Our current approach focuses on assessing how changes in 
physical hazards could impact valuations of immovable 
properties over time up to the year 2100. We use vulnerabil-
ity mapping to identify assets sensitive to impacts from 
chronic and acute climate change events. The mapping 
combines physical hazard vulnerability and asset distribu-
tions, and enables us to identify areas where physical hazard 
risks could be considered to be potentially material. Physical 
hazard sensitivity is calculated at the postal code level. 
Industries identified as exposed to climate-related risks

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Nordea Annual Report 2025 113
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
In 2025 we assessed our exposures to climate-related 
physical risks in three of the Representative Concentration 
Pathway (RCP) scenarios developed by the scientific com-
munity and adopted by the Intergovernmental Panel on 
Climate Change (RCPs 2.6, 4.5 and 8.5), covering the short, 
medium and long terms up to the year 2100 (2011–40, 
2041–70 and 2071–2100). RCP 2.6 is aligned with the Paris 
Agreement, while RCP 8.5 is the most severe climate sce-
nario. The table to the right shows our exposures subject to 
climate-related physical risks in RCP 4.5 for the time period 
2011–40. To support the assessment, we used physical haz-
ard data from the Swedish Meteorological and Hydrological 
Institute (SMHI). The data used consists of information on 
12 different climate hazard indices, which can be divided 
into climate indices, hydrological indices, and fire risk indi-
ces. Each hazard index indicates the change in the respec-
tive physical hazard due to climate change. 
Our exposures with collateral were allocated to postal 
codes with a physical location. We also conducted a review 
of scientific studies to determine the actual possible impact 
on the value of properties that were identified as being at 
risk due to physical hazards. The availability of reliable 
research meeting all criteria applicable to our portfolio was 
limited, especially where geographical scope, time frame 
and climate risk type were concerned. Actual impacts 
could therefore differ from internal findings. Nevertheless, 
we attempted to adopt more conservative assumptions in 
order to not underestimate the exposures at risk. The final 
assessment varied depending on the type of risk (chronic, 
acute, or associated with sea level rise). 
The findings of the 2025 MA – in particular the results 
of the climate change stress testing under the ICAAP – led 
us to conclude that ESG-related credit risk, specifically cli-
mate change-related credit risk, was material. Additional 
capital was therefore reserved to cover credit risk linked to 
climate-related risk. Climate-related transition and physi-
cal risks led to a marginal increase in loan losses under 
different ICAAP scenarios. 
The table below shows the share of our end-2025 expo-
sure in each asset class that was exposed to climate-re-
lated physical risk in RCP 4.5 during the period 2011–40.
Climate-related physical risks
RCP 4.5 scenario 
Residential  
real estate
Commercial 
real estate
Residential and 
Commercial  
real estate
Chronic 1.3% 1.0% 1.2%
Acute 0.9% 0.9% 0.9%
Chronic and acute 0.8% 0.8% 0.8%
Investment portfolio
We conducted the resilience analysis of the investment 
portfolios of Nordea Asset Management (NAM) and 
Nordea Life & Pension (NLP) by assessing their climate 
value at risk. We applied the MSCI Climate Value-at-Risk 
(Climate VaR) tool for listed equities and corporate bonds, 
which covers assessments of both climate-related risks and 
climate-related opportunities across a range of plausible 
climate change scenarios. The following three scenarios 
produced by the Network for Greening the Financial 
System (NGFS) were selected: 
1. The “Net Zero 2050” scenario, which limits global warm-
ing to 1.5°C through the immediate introduction of strin-
gent climate policies and innovation, reaching net-zero 
emissions by 2050. Climate-related physical risks are rel-
atively low but climate-related transition risks are high. 
2. The “Delayed Transition” scenario, which assumes that 
new climate policies are not introduced until 2030. After 
2030, there is a 67% chance of limiting global warming to 
below 2°C. This leads to higher climate-related physical 
risks compared with the Net Zero 2050 scenario.
3. The “Nationally Determined Contributions (NDCs)” sce-
nario, which includes all pledged policies reflected in the 
NDCs, even if they are not yet implemented. Emissions 
decline but nonetheless lead to 2.6°C of warming, which is 
associated with moderate-to-severe climate-related 
physical risks. 
For each of these scenarios, climate risk was assessed using 
three distinct climate metrics: policy risk, technology oppor-
tunities and physical risk. Policy risk refers to the investment 
value at risk due to future climate policy. Technology oppor-
tunities represent the investment upside due to low-carbon 
technology revenues. Combined with policy risk, these 
result in net climate-related transition risk. Physical risk 
refers to the investment value at risk materialising as a 
result of climate-related acute weather events and chronic 
changes in weather patterns. For both NAM and NLP, cli-
mate-related costs for companies were calculated for both 
transition and physical risks, with transition risk-related 
costs calculated up to 2050 and physical risk-related costs 
calculated up to 2100. These costs were discounted to the 
net present value to determine the climate value at risk for 
current portfolios under a range of possible climate scenar-
ios and temperature outcomes. The table below depicts the 
value at risk as at the end of 2025. 
We view scenario analysis as an important tool for illus-
trating how different climate pathways may affect our 
portfolio through both physical and transition risks. At the 
same time, we recognise that current models for physical 
risk focus primarily on direct impacts on real assets. These 
models do not fully capture all dimensions of climate-re-
lated risk and uncertainty for corporates or investment 
portfolios, such as complex value chain impacts, adapta-
tion responses, systemic and macroeconomic impacts, or 
the compounding effects of multiple events occurring at 
once. For this reason, our scenario analysis should be 
viewed as indicative rather than predictive.
Methodologies and models in the physical risk area con-
tinue to develop, and data on, for example, macroeconomic 
effects linked to physical climate risk is becoming increas-
ingly available. Preliminary analysis of such data suggests 
that chronic, long-term climate impacts identified through 
a top-down macroeconomic approach can be higher than 
the direct impacts identified through bottom-up asset-level 
models. We are refining our approach by expanding our 
core climate risk framework, assessing new data and mod-
elling capabilities as they become available. 
The latest resilience analysis, using the methods and 
tools described above, was conducted in January 2026 
using data as at the end of 2025.
Climate value at risk (Climate VaR)
Net zero 2050 Delayed transition NDCs
Climate VaR as at the end of 20251
Policy risk 
(%)
Technology 
opportunities 
(%) 
Physical 
risk (%)
Policy risk 
(%) 
Technology 
opportunities 
(%)
Physical 
risk (%) 
Policy risk 
(%) 
Technology 
opportunities 
(%) 
Physical 
risk (%) 
Nordea Asset Management
Listed equities -10.2 1.6 -0.6 -3.6 0.3 -1.0 -2.5 0.4 -1.5
Corporate bonds -3.2 0.0 0.0 -0.4 0.0 0.0 -0.3 0.0 0.0
Nordea Life & Pension
Listed equities -8.9 1.5 -0.5 -3.0 0.3 -0.9 -2.0 0.3 -1.3
Corporate bonds -4.8 0.1 0.0 -0.6 0.0 0.0 -0.4 0.0 -0.1
1)  Policy risk and technology opportunities are calculated at the instrument level, meaning they take into account the remaining maturity of individual bonds. The data cover-
age is 81% and 88% for policy risk and 71% and 78% for technology opportunities for NAM and NLP, respectively. Physical risk values are based on company levels (listed 
equities or corporate bonds) and are not adjusted for maturity and instrument type. The data coverage for physical risk is 81% for NAM and 88% for NLP.

===== SIDA 115 =====

Nordea Annual Report 2025 114
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
Transition plan
We have fully integrated climate change into our business 
strategy and risk management as it is material for us in 
terms of impacts, risks and opportunities. Our transition 
plan for climate change mitigation is the strategy we have 
in place to achieve net-zero GHG emissions across our 
value chain by the end of 2050 at the latest and build 
long-term resilience. The plan is embedded within and 
aligned with our financial planning and overall business 
strategy, which incorporates strategic sustainability priori-
ties approved by the Board of Directors. 
As a financial services group, our greatest climate 
change-related impacts, risks and opportunities are asso-
ciated with the financed emissions originating from our 
lending and investment portfolios, which represented 
99.9% of our total GHG emissions in 2025. As a responsible 
bank, we also want to lead the way by decarbonising our 
own operations. To support our long-term net zero objec-
tive, we have set short- and medium-term climate targets 
for our lending and investments and for our own opera-
tions. Our targets were set using normative scenarios and 
modelled net zero pathways, and are described in more 
detail on pages 124–130.
The key components for the implementation of our 
transition plan build on our identified decarbonisation 
levers. They include the policies and sector guidelines we 
apply, the products and services we offer to customers 
and investees, and our engagement with customers, port-
folio companies, suppliers, the financial industry and 
broader society. Our guidelines include sector and the-
matic guidelines, which apply to all business areas and 
own operations and provide guidance on different ESG 
themes. They also specify our requirements for our lending 
and investments to mitigate our exposure to climate-re-
lated transition and physical risks. Moreover, they include 
expectations for our customers and portfolio companies to 
encourage them to adopt best practices and actions to 
improve their performance. More information on our poli-
cies and guidelines can be found on pages 118–120.
We monitor progress on our transition plan through 
quarterly ESG reporting and forecast our development in 
relation to our long-term objective and business strategy. 
This helps us ensure our business develops in line with the 
plan, supporting our customers’ and society’s transition to 
net zero. To accelerate the plan’s implementation, we have 
established sustainability-related key performance indica-
tors, which have been integrated into our variable pay 
plans (see “General information“ on page 90 for more 
information). We continuously strive to strengthen our 
transition planning by reviewing our targets annually and 
improving our systems and data quality. A particular focus 
is the implementation of the new ESG-related require-
ments deriving from the amended Capital Requirements 
Directive and the associated EBA Guidelines on the man-
agement of ESG risks – relating to the identification, 
measurement and management of ESG risks. These 
requirements also include an obligation to develop spe-
cific plans to monitor and address the financial risks aris-
ing in the short, medium and long terms from ESG factors 
(“prudential transition plan”), which will help us further 
enhance our ESG risk management. We also seek to drive 
ambition and standardisation in transition planning across 
the industry through active involvement in financial indus-
try networks.

===== SIDA 116 =====

Nordea Annual Report 2025 115
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
Lending portfolio
We have set lending-related climate targets based on 
in-depth analysis of our portfolio emissions and climate 
risks; science-based net-zero-aligned pathways; and the 
Guidance for Climate Target Setting for Banks provided by 
the United Nations Environment Programme Finance 
Initiative (UNEP FI). To steer our lending portfolio towards 
our long-term net zero objective and reduce our transition 
risk, we have adopted a portfolio-wide target to reduce 
our financed emissions by 40–50% by the end of 2030 
compared with 2019. To support progress towards our 
portfolio target, we have also set sector-specific targets, 
based on climate-related risk deep dives on material sec-
tors within our lending portfolio and aligned with our sec-
tor roadmaps.
In recent years we have taken action to ensure our large 
corporate customers in climate-vulnerable sectors have 
transition plans in place, and have factored these into our 
business planning. Engaging with our customers, particu-
larly those in high-emitting sectors, and providing them 
with advice and financing for their transition plans is key for 
supporting the decarbonisation of the real economy and 
reducing our financed emissions. 
Recognising that different sectors and customers are at 
different stages in their transition journeys, we are widening 
our sustainable product offering beyond sustainabili-
ty-linked loans to meet different needs. At the same time, 
we are enhancing our lending and green loan offerings to 
support the development of technologies and infrastructure 
needed for a resilient low-carbon economy.
While our focus is on engagement and financing the 
transition, specific economic activities, such as the extrac-
tion and combustion of fossil fuels, are ultimately incompat-
ible with the transition to a net-zero economy. The 
financing of such activities poses elevated lock-in risks 
associ ated with stranded asset risk. Limiting exposure to 
these activities thus serves as risk mitigation. To reduce our 
transition risk, we fully phased out lending to companies in 
coal mining and coke oven product manufacturing in 2021 
and to companies in thermal peat mining in 2025, with an 
exception for customers impacted by energy security meas-
ures in Finland. We continue to have a restrictive approach 
to the oil and gas sector. By the end of 2025, our lending to 
the oil and gas exploration and production sector amounted 
to EUR 3m (0.001% of total lending). This represents a 
decrease of 99.7% between 2019 and 2025 (EUR 884m at 
the end of 2019).
The main decarbonisation levers that have contributed to 
the emissions reductions in our lending portfolio include 
changes to the composition of our lending book, including 
lower lending volumes in the Shipping and Oil & Gas port-
folios, and emissions reductions achieved by our customers. 
See page 125 for further details.
To inform our strategy-setting process and risk manage-
ment, we perform a business environment scanning (BES) 
each year. The BES gives us insights into how climate and 
environmental factors may impact our business environ-
ment. These insights and conclusions support our business 
areas in making informed strategic decisions, managing 
their business strategies and capturing opportunities. They 
also inform the identification of risks in the materiality 
assessment and support us in further developing our 
frameworks for climate and environmental risk manage-
ment, stress testing and capital planning. Moreover, the 
insights gained from BES support us in complying with rele-
vant supervisory and regulatory requirements regarding the 
alignment of business models with the external business 
environment.

===== SIDA 117 =====

Nordea Annual Report 2025 116
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
Investment portfolio
We have set short- and medium-term climate targets for 
the investment portfolios of Nordea Asset Management 
(NAM) and Nordea Life & Pension (NLP). The targets are 
based on comprehensive analysis of our portfolio carbon 
intensities and transition-critical sectors; science-based 
net-zero-aligned pathways; and the Institutional Investors 
Group on Climate Change Net Zero Investment 
Framework. Our target is to reduce the carbon intensities 
of NLP’s and NAM’s portfolios by 40–50% by the end of 
2029 and 50% by the end of 2030, respectively.
Engaging with investee companies in high-emitting, 
transition-critical sectors is key to supporting the decar-
bonisation of the real economy and reducing the carbon 
intensity of our investment portfolios. We actively engage 
with these companies, both unilaterally and collabora-
tively, to help drive them to decarbonise and align with net 
zero pathways. To steer our work, we have formulated 
engagement targets addressing portfolio companies 
within the high-emitting, transition-critical sectors in the 
portfolios. We also engage with asset managers to 
encourage net zero alignment.
We offer investment advice and a wide range of sus-
tainability-focused investment products to our customers 
based on their sustainability preferences. Our Nordea 
Sustainable Selection and Sustainable Selection Improve 
fund offerings are characterised by enhanced sustainabil-
ity and engagement criteria, respectively. We have a target 
to increase the share of investments in NLP´s portfolio 
supporting nature and the climate transition by 20% by 
the end of 2030 compared with 2023, and will therefore 
strive increasingly to invest in companies that provide 
solutions needed for the transition. We will also continue 
to develop and grow our sustainability-focused offerings 
to cater for investor demand. All our climate targets for 
investments are integrated into NAM’s and NLP’s invest-
ment strategies and portfolio management, with responsi-
ble investment policies guiding the investment processes.
Between 2019 and 2025, the weighted average carbon 
intensity (WACI) of NAM’s listed equity and corporate bond 
portfolios decreased significantly, by 52%. While changes in 
portfolio composition and other factors, such as inflation, 
contributed to the decrease, the main driver was investee 
company emission intensity reductions, especially in 
high-emitting sectors such as utilities and industrials. These 
intensity reductions were attributable in approximately 
equal part to absolute emissions reductions and non-infla-
tionary increases in investee company revenues without an 
associated increase in emissions.
2025 figures for NLP show a carbon footprint decrease of 
40% between 2019 and the end of 2025 for listed equities, 
corporate bonds and directly held real estate. The target 
performance and the decarbonisation levers are discussed 
in more detail on page 128.
Our policies regarding the thermal and metallurgical coal 
mining sectors and the oil and gas extraction and produc-
tion sectors are very restrictive. By the end of 2025, our 
investments in organisations classified as coal mining com-
panies amounted to EUR 1.5m for NAM, while NLP did not 
have any such investments, and our investments in oil and 
gas extraction companies and/or companies supporting oil 
and gas extraction amounted to EUR 1,484m (EUR 1,461m 
for NAM and EUR 23m for NLP). To identify our exposure, 
we use the NACE industry classifications, which in 2025 we 
complemented with the Bloomberg Industry Classification 
Standard (BICS) industry categories Oil & Gas and Oil & Gas 
Services to better capture our exposure.
We have restrictive policies for investing in companies in 
the upstream oil and gas sector. As a consequence, there are 
currently no investments in oil and gas exploration and pro-
duction companies among NLP’s products and such compa-
nies are excluded from 76% of NAM’s funds. In the remain-
ing NAM funds, a limited exposure to these companies 
caters to customers with investment strategies that cannot 
deviate from indexes or who want to invest in certain geog-
raphies. We take responsibility for these exposures by voting 
at annual general meetings and ensuring an active and con-
structive dialogue with the companies to push them to 
improve their climate and environmental standards.
E1 Climate change, cont.

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Nordea Annual Report 2025 117
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
Own operations
To support progress towards our long-term net zero 
objective and to lead the way as a responsible bank, we 
have set a target to reduce greenhouse gas emissions 
from our own operations and supply chain by at least 50% 
by 2030. To achieve this target, we have defined eight 
actions. In 2025 the emissions reduction achieved through 
four of the eight actions was quantified to assess the 
impact of these actions as decarbonisation levers. The four 
actions were decrease in air travel, electric company cars 
only policy, paperless banking, and efficient energy con-
sumption in buildings. Together, these have led to a 52% 
reduction in the carbon emissions from our own opera-
tions between 2019 and 2025. The actions are further 
described in “Own operations” on page 123.
In addition to our eight actions, engagement with our 
suppliers on their transitions and net zero alignment is key 
to supporting the decarbonisation of our supply chain. Our 
2025 target was to ensure that 80% of our related spend-
ing was on suppliers either aligned with the Paris 
Agreement or subject to active engagement to become 
aligned. We achieved this target before the end of the 
year. Our new engagement target focuses on transition- 
critical suppliers.
On our long-term path to net zero, we are also commit-
ted to making a net positive carbon contribution in our 
own operations (through offsetting) by 2030. To offset our 
residual emissions within the current target scope, we 
have purchased carbon credits. Up until 2023 we sup-
ported the generation of renewable energy through the 
purchase of avoided emissions credits. In 2024 we revised 
our strategy and shifted to neutralising emissions through 
the purchase of carbon removal credits. We are imple-
menting the revised strategy by building a portfolio of 
offtake agreements with carbon dioxide removal suppli-
ers, and signed our first agreement in 2025 (see page 150 
for details).
We are currently reviewing our operational carbon 
strategy and our medium-term target for 2030.
Investments for implementation
Due to the nature of our business model as a financial ser-
vices group, our greatest impact on climate change occurs 
via our lending and investment portfolios. We report coun-
terparties’ EU Taxonomy eligibility and alignment according 
to their capital expenditure (CapEx) KPIs. Our own CapEx 
and operational expenditure (OpEx) related to mitigating 
climate change via portfolio management are focused on 
building capacity among our workforce, acquiring emis-
sions data and developing our operating systems. The 
majority of costs associated with the reduction of our own 
operations emissions relate to investments to improve 
energy efficiency and emissions monitoring activities. In 
general, the expenditures for mitigating climate change 
through portfolio management are higher than those for 
reducing our own emissions.
With reference to the exclusion criteria for the Paris 
-aligned benchmarks stated in Articles 12(1), points (d) to 
(g) and Article 12(2) of Commission Delegated Regulation 
(EU) 2020/1818 (the Climate Benchmark Standards 
Regulation), we are not excluded from the EU Paris-
aligned benchmarks.
E1 Climate change, cont.

===== SIDA 119 =====

Nordea Annual Report 2025 118
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
Policies related to climate change 
mitigation and adaptation
The table below provides a comprehensive overview of 
our policies related to (i) addressing climate-related risks 
and negative impacts and (ii) increasing climate-related 
positive impacts and opportunities.
The policies guide on best practices and alignment with 
international conventions and standards that we encour-
age and expect customers, portfolio companies and other 
stakeholders to follow. Overall, we have 15 climate change 
policies/guidelines, covering our Group operations and 
value chain in terms of investments, advice, lending 
and procurement. 
Our policies primarily address climate change mitiga-
tion. Climate change adaptation is a prioritised area in 
terms of managing physical risks and is expected to be 
covered in depth across our policies in the future. 
Our climate change policies are based on international 
treaties, standards and initiatives such as the United Nations 
Framework Convention on Climate Change (UNFCCC), the 
Paris Agreement, the UN Global Compact, the Principles for 
Responsible Investment (PRI), the Principles for Responsible 
Banking (PRB) and the Equator Principles. They are further 
informed by the guidance developed by the Glasgow 
Financial Alliance for Net Zero, the Net-Zero Banking 
Alliance, the Net-Zero Asset Owner Alliance and the Net 
Zero Asset Managers Initiative (For more information, see 
“Actions and resources in relation to climate change” on 
page 122). In addition, we seek to make our policies compli-
ant with the European Union’s environmental policy objec-
tive of a climate-neutral  ec onomy by 2050 and the EU action 
plan for financing sustainable growth. Our sector guidelines 
are also aligned with sectoral initiatives.
With the exception of the sector guidelines, the internal 
rules listed in the table below form part of our internal 
rules framework, for which the Board of Directors is ulti-
mately accountable. Although the sector guidelines are 
not included within the ESG Policy Framework, their 
development and implementation are mandated by the 
Board of Directors. 
The policies/guidelines are all available to external 
stakeholders at nordea.com
Policy (entity) Relevance to E1 Climate change Related E1 impacts, risks and opportunities Further details
Sustainability Policy
(Nordea)
• Defines the principles we follow to ensure the long-term sustainability of our 
operations and thus strengthen our long-term customer relationships and 
contribution to a greater good.
• Describes how sustainability is managed at Nordea, including material climate 
change mitigation- and adaptation-related impacts, risks and opportunities.
• Describes the roles and responsibilities for the governance of sustainability and 
broad commitments across our financing, investments and advice.
• All • The Policy forms part of the policy framework overseen by the Board of Directors.
• The Policy is a replica of our Group Board Directive on Sustainability.
• The Group CEO is responsible for the Policy´s implementation and for having the business area and Group 
function heads ensure it is, where relevant, known and adhered to within their respective areas of 
responsibility.
Position Statement on 
Climate Change
(Nordea)
• Defines the scope and principles of our climate change agenda.
• Takes into account the nature of our business, where investments, credit 
operations and purchases can have both local and global impacts.
• Lists our overall Group positions and commitments.
• All • The Statement forms part of the policy framework overseen by the Group CEO.
• Our Group positions and commitments include commitments to:
 – enable our customers to finance sustainable and renewable sources of energy and energy efficiency 
projects 
 – refrain from participating in lobbying or advocacy activities aimed at weakening climate policy.
Supplier Code of Conduct
(Nordea)
• Obliges our suppliers to share our standards and continuously collaborate with 
us on improvements that can have a positive impact and mitigate risk.
• Includes expectations for large suppliers to commit to being net zero by 2050 at 
the latest and to have climate science-based transition plans in place by 2028.
• Climate-related transition risks (both climate change mitigation and 
energy)
• Climate-related physical risks
• Final energy consumption in our lending and investment portfolios 
and own operations
• The Code is overseen by the Board of Directors.
• The internal rules in our Outsourcing and Third Parties Risk Policy Framework require suppliers to comply 
with the Supplier Code of Conduct.
• The Supplier Code of Conduct is aligned with the UN Guiding Principles for Business & Human Rights, the Ten 
Principles of the UN Global Compact, and the OECD Guidelines for Multinational Enterprises on Responsible 
Business Conduct.
• Read more on page 177 in “G1 Business conduct”.
Responsible Investment 
Product Distribution 
Policy 
(Nordea)
• Sets out the minimum responsible investment requirements for financial 
products distributed by us via advice.
• Explains our ESG positions, including our climate commitment and product-
specific climate change positions.
• All • The Policy forms part of the policy framework overseen by the Head of Asset & Wealth Management.
• The Policy reflects our thematic guidelines, Position Statement on Climate Change, and sector guidelines for 
products in the advisory universe.
• We have an investment product offering with enhanced sustainability criteria for customers that express a 
preference for sustainability.
• Strategic partners in the advisory product universe must to commit to have net zero investment portfolios by 
2050 (at the latest) and to set up a transition plan with clear targets.

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Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
Policy (entity) Relevance to E1 Climate change Related E1 impacts, risks and opportunities Further details
Sector guideline for the 
fossil fuel based industries
(Nordea)
• Summarises our positions on these industries.
• Details investment and financing criteria for companies in the sub-sectors oil 
and gas exploration and production, thermal coal, thermal peat, unconventional 
oil and gas, and Arctic drilling.
• Financing and supporting the transition of customers, investee 
companies and sectors
• GHG emissions from our lending and investment portfolios and 
capital market activities
• Climate-related transition risks (both climate change mitigation and 
energy)
• Climate-related physical risks
• Final energy consumption in our lending and investment portfolios 
and own operations
• The guideline handles some of the sectors with the most material climate impacts and risks for us. It applies 
to our lending, investments, facilitation and procurement, and is applicable to companies where our credit 
exposure exceeds EUR 1m.
• The guideline covers oil, gas and offshore companies and mining companies engaged in the exploration, 
extraction or production of coal, peat, oil and gas. Also included are oil and gas pipeline and thermal coal 
heating and power production companies.
Sector guideline for the 
agricultural industry
(Nordea)
• Summarises our position on this industry.
• Details financing criteria for companies in the sub-sectors crop and livestock 
production, fishing and aquaculture, and food production.
• As above • We expect agriculture customers and portfolio companies to acknowledge the Intergovernmental Panel on 
Climate Change (IPCC) scientific consensus on the influence of human activities on climate change and 
commit to align their business activities with the goals of the Paris Agreement.
• Read more on page 154 in “E4 Biodiversity and ecosystems”.
Sector guideline for the 
shipping industry
(Nordea) 
• Summarises our position on this industry.
• Details financing criteria for companies in the sub-sectors shipbuilding and 
maritime transportation.
• Financing and supporting the transition of customers, investee 
companies and sectors
• GHG emissions from our lending and investment portfolios and 
capital market activities
• Climate-related transition risks (climate change mitigation)
• Climate-related physical risks
• Final energy consumption in our lending and investment portfolios 
and own operations
• The guideline is applicable to all companies within the shipping sector, which is one of the sectors with the 
most material climate impacts, risks and opportunities for us. It applies to companies where our credit 
exposure exceeds EUR 1m.
• The guideline is aligned with the Poseidon Principles (PP) and Responsible Ship Recycling Standards (RSRS).
• We expect shipping customers and portfolio companies to acknowledge the IPCC scientific consensus on the 
influence of human activities on climate change and commit to align their business activities with the goals of 
the Paris Agreement.
Sector guideline for the 
forestry industry
(Nordea)
• Summarises our position on this industry.
• Includes expectations for companies in the forestry industry to invest in and 
work towards sustainable forestry management and for companies in all 
industries to work towards preventing deforestation.
• As above • We expect forestry customers and portfolio companies to meet high standards with regard to the sustainable 
management of forestry assets, and to consider and reduce the environmental impact of produced products 
and services throughout their life cycle. 
• Read more on page 154 in “E4 Biodiversity and ecosystems”.
Sector guideline for the 
real estate industry
(Nordea)
• Summarises our position on this industry.
• Guides on best practice and international conventions and standards that we 
encourage and expect real estate companies to follow.
• All • We expect real estate companies to invest in and work towards developing sustainable buildings.
• Read more on page 154 in “E4 Biodiversity and ecosystems”.
Sector guideline for the 
mining industry
(Nordea)
• Summarises our position on this industry.
• Details procurement, investment and financing criteria for companies in the 
mining sector.
• GHG emissions from our lending and investment portfolios and 
capital market activities
• Climate-related transition risks (both climate change mitigation and 
energy)
• Final energy consumption in our lending and investment portfolios 
and own operations
• The guideline applies to mining companies where our credit exposure exceeds EUR 1m.
• We expect mining companies to live up to internationally recognised and frequently applied norms and 
standards applicable to the areas and jurisdictions of their operations.
• Read more on page 154 in “E4 Biodiversity and ecosystems”.
Responsible Investment 
Policy  
(Nordea Asset 
Management)
• Describes the framework governing the approach of Nordea Asset 
Management (NAM) to responsible investments.
• Sets out NAM’s commitment to align its investment strategies with the goals of 
the Paris Agreement.
• Describes NAM’s active ownership approach, with climate change included as a 
prioritised thematic engagement area, as well as the processes for escalation.
• Sets out NAM’s expectations of investee companies regarding climate change 
mitigation, which go beyond international norms and conventions.
• All • The Policy forms part of the policy framework overseen by the NAM Holding Board.
• Companies exposed to climate risk are also expected to disclose how their long-term business strategy and 
profitability will be impacted by a different physical environment due to climate change.
• NAM has two ESG-focused committees, with specific areas of responsibility: 
 – the Responsible Investment Committee, which decides on and monitors exclusions and engagements at 
the investment level
 – the ESG Committee, which secures the governance of NAM’s ESG-related methods and principles. 
• Read more on page 154 in “E4 Biodiversity and ecosystems”.

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Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E1 Climate change, cont.
Policy (entity) Relevance to E1 Climate change Related E1 impacts, risks and opportunities Further details
Fossil Fuel Policy  
(Nordea Asset 
Management)
• Sets out the guidelines for excluding fossil fuel companies that are not 
demonstrating a transition in line with the goals of the Paris Agreement.
• All • The Policy forms part of the policy framework overseen by the NAM Holding Board.
• The Policy is applicable to all Article 9 funds, and to Article 8 funds with a few exceptions.
Responsible Investment 
Policy  
(Nordea Life & Pension)
• Governs how sustainability is integrated into the insurance- and pension-based 
investment products of Nordea Life & Pension (NLP).
• All • The Policy forms part of the policy framework overseen by the Nordea Life Holding (NLH) Board and the 
boards of directors for the local NLP entities.
• NLP decides which internally or externally managed instruments to invest in.
• The Policy is complemented by NLP’s Climate Change Policy and Engagement Policy.
• Read more on page 154 in “E4 Biodiversity and ecosystems”.
Climate Change Policy 
(Nordea Life & Pension)
• Describes NLP’s climate commitments, the logic behind its targets, and its 
processes to integrate climate-related risks and opportunities into monitoring 
and investment decisions.
• All • The Policy forms part of the policy framework overseen by the NLH Board and the boards of directors for the 
local NLP entities.
Engagement Policy 
(Nordea Life & Pension)
• Describes NLP’s approach to active ownership as a long-term investor. • All • As above

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