Årsredovisning 2025

Nordea Annual Report 2025 153
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E4 Biodiversity and ecosystems, cont.
updates and the fact that we have limited exposure to sec-
tors in our Nordic home markets where this risk is ele-
vated. However, we recognise that risks related to nature 
degradation tend to emerge only in the long term and that 
there is high uncertainty associated with assessing ecosys-
tem risks, due in part to the complexity of quantifying 
these risks in the value chain. 
We assessed credit risk to be the risk category most 
impacted by biodiversity-related transition risk. This risk 
stems mainly from our counterparties via our financing 
activities. Credit quality deterioration and collateral deval-
uation are examples of transmission channels through 
which biodiversity-related transition risk drivers can 
impact credit risk. The risk was identified to be elevated 
for certain parts of our lending portfolio, for example our 
lending to the agriculture, forestry, materials and construc-
tion sectors, which are prone to biodiversity-related transi-
tion risk. It could materialise across all time horizons as 
society takes measures to protect nature. 
Operational risk was assessed to be another impacted 
risk category. Biodiversity-related risk drivers could impact 
operational risk through litigation and reputational risk 
linked to greenwashing; increased regulatory require-
ments; and financial disclosure risk.
We also assessed business model risk to be impacted. 
Business model risk stemming from biodiversity-related 
transition risk could arise due to the composition and 
nature of the assets we have on our balance sheet, espe-
cially over the longer term. If we were to adopt an inap-
propriate long-term strategy, this risk could materialise via 
credit losses and reduced lending opportunities.
Transition plan and consideration of biodiversity 
and ecosystems in strategy and business model
During the period 2022–25 we began to progressively 
incorporate biodiversity into our business in order to help 
reduce negative impacts on, and promote the protection 
and restoration of, biodiversity and ecosystems. Nature is a 
key theme under our 2030 strategic sustainability priori-
ties, and as part of our nature-related transition plan, we 
aim to further improve our understanding, quantification 
and management of impacts and dependencies and asso-
ciated risks and opportunities. 
Each year, we assess biodiversity- and ecosystem-re-
lated physical and transition risks as part of our bank-wide 
materiality assessment (MA) of climate and environmental 
risks and our business environment scanning (BES) of cli-
mate and environmental risks. The insights and conclusions 
from these assessments enable us to make informed stra-
tegic decisions regarding business plans and internal pro-
cesses. They also help us identify and track relevant moni-
toring indicators so we can adjust to changes in our busi-
ness environment in a timely manner. More information on 
the MA can be found on page 93 in “General information” 
and page 112 in “E1 Climate change”. The BES is described 
in more detail on page 115 in “E1 Climate change”. 
Our MAs have helped increase our understanding of 
nature and biodiversity, enabling us to form clearer posi-
tions on these topics and integrate them into internal 
information and knowledge sharing, polices, guidelines 
and internal rules. We have also continued to actively par-
ticipate in financial sector initiatives and research collabo-
rations to forward the field. 
In 2023 we set practice targets to build internal compe-
tence and capacity in relation to biodiversity and ecosys-
tems as part of our commitment to the UNEP FI Principles 
for Responsible Banking. The targets were to assess the 
biodiversity-related impacts, dependencies, risks and 
opportunities associated with our lending, internal opera-
tions and supply chain in 2024. The targets were met, with 
the assessment findings reported in our 2024 
Sustainability Statement. 
Comprehensively assessing and quantifying the indirect 
effects of nature-related risk drivers stemming from our 
financing remains challenging as the methodological 
approach and data for measuring such effects are still 
under development. In 2025 we continued to build on our 
capabilities to quantify biodiversity- and ecosystem-related 
impacts, risks and opportunities to support our evolving 
strategic response and risk management. In line with the 
results of the double materiality assessment (DMA), we 
focused on our downstream value chain. The level of matu-
rity reached enabled us to integrate biodiversity and eco-
systems into our 2030 business strategy. Going forward, a 
focus will be to use our expertise to help make the nature 
agenda financeable.
To better understand our customers’ approach to bio-
diversity and ecosystems, we will engage in dialogues 
with large customers in high-impact sectors in the period 
2026–28. This will also help us build competence inter-
nally and strengthen our customers’ ability to understand 
risks, opportunities and dependencies, thereby supporting 
the development of biodiversity transition plans. 
Policies related to biodiversity and ecosystems
The table below provides a comprehensive overview of our 
policies related to biodiversity and ecosystems. 
Unless otherwise stated, the scope of the policies and 
guidelines is global in geographical terms and includes 
our upstream value chain, own operations and down-
stream value chain. The thematic and sector guidelines 
acknowledge the link between human rights and biodiver-
sity and ecosystems. 
We have initiated work to gather all sustainability- 
related guidance under a sustainability sector and thematic 
framework. This will include thematic guidelines, positions 
(such as a forthcoming deforestation position), and sector 
guidelines. As our sector and thematic guidelines and 
responsible investment policies were developed before the 
CSRD-compliant DMA was introduced, their relationship to 
material impacts, dependencies, risks and opportunities 
identified through the DMA process is indirect. Going for-
ward, we will ensure that ESG-related policies, positions 
and sector guidelines are grounded in the outcomes of our 
DMA process and other relevant analysis, reflecting a 
robust, evidence-based approach to managing ESG risks 
and opportunities. In 2025 we revised our sector guidelines 
for the mining, real estate, defence, and fossil fuel-based 
industries, with the updated versions to be published in 
2026. Our guidelines for food production (formerly agricul-
ture and aquaculture), forestry and shipping are scheduled 
for revision in 2026. 
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 ultimately 
accountable. Although 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.

===== SIDA 155 =====

Nordea Annual Report 2025 154
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E4 Biodiversity and ecosystems, cont.
Policy (entity) Relevance to E4 biodiversity and ecosystems Related E4 impacts, risks and opportunities Further details
Thematic guideline on 
biodiversity 
(Nordea)
• Recognises: 
 – all drivers of biodiversity loss, including climate change; land, freshwater and 
sea use change; direct exploitation; invasive alien species; and pollution 
 – the global importance of biodiversity and our responsibility to contribute to 
societal targets and goals such as the Kunming-Montreal Global Biodiversity 
Framework and the EU Biodiversity Strategy for 2030.
• Contribution to biodiversity loss
• Biodiversity-related transition risks
• The guideline forms part of the policy framework overseen by the Group Accountable Executive for ESG risk – the Chief of Staff.
• The guideline outlines our commitment to:
 – assess and address biodiversity-related impacts, dependencies, risks and opportunities
 – incorporate biodiversity-related considerations into strategy, risk management, governance, stakeholder engagement and offerings 
over time.
Sector guideline  
for the agricultural 
industry 
(Nordea)
• Sets expectations for customers and portfolio companies to:
 – integrate biodiversity into their environmental management planning and 
decision-making processes 
 – undertake environmental baseline studies and assess the environmental 
impact of their operations.
• As above • The guideline states that companies throughout the supply chain are expected to refrain from engaging in operations in areas covered 
by international conventions aimed at protecting and supporting biodiversity. These include the UN Convention on Biological Diversity 
and the Ramsar Convention on Wetlands of International Importance Especially as Waterfowl Habitat. The protected areas include those 
defined by the International Union for Conservation of Nature.
• We do not monitor stakeholder compliance with these expectations.
• Read more on page 119 in “E1 Climate change”.
Sector guideline for the 
forestry industry 
(Nordea)
• As above • As above • As above 
Sector guideline for the 
real estate industry 
(Nordea)
• As above • As above • As above
Sector guideline for the 
defence industries 
(Nordea)
• As above • As above • The guideline encourages all business relationships to follow international conventions aimed at protecting and supporting biodiversity 
– including the Kunming-Montreal Global Biodiversity Framework.
• We do not monitor stakeholder compliance with these expectations.
Sector guideline for the 
fossil fuel based industries 
(Nordea)
• As above
• For both financing and investments, the guideline includes criteria related to 
drilling in the Arctic, which is assessed to pose significant risks to biodiversity 
and ecosystems. Our priority is to assess and promote sound management of 
biodiversity- and ecosystem-related risks in the wider Arctic region.
• As above • We do not monitor stakeholder compliance with these expectations.
• Read more on page 119 in “E1 Climate change”.
Sector guideline for the 
mining industry 
(Nordea)
• States that we do not provide financing to new or existing customers actively 
engaging in mountaintop removal mining, which has negative impacts on the 
extent and conditions of biodiversity and ecosystems.
• As above • The guideline states that mining customers are required to adhere to international conventions aimed at protecting and supporting 
biodiversity. These include the conventions detailed above for the agricultural industry. 
• Read more on page 119 in “E1 Climate change”.
Responsible Investment 
Policy 
(Nordea Asset 
Management)
• Concludes that biodiversity loss can pose systemic financial risks across 
investment portfolios. 
• As above • The Policy forms part of the policy framework overseen by the Nordea Asset Management Holding Board.
• As we invest across a vast array of sectors and geographies, our portfolio is associated with a wide range of biodiversity-related risks and 
opportunities.
• The Policy is complemented by Nordea Asset Management’s white paper on biodiversity and nature, which describes its investment 
approach to biodiversity and nature, and is republished annually.
• Read more on page 119 in “E1 Climate change”.
Responsible Investment 
Policy
(Nordea Life & Pension)
• Includes expectations for investee companies to: 
 – disclose material biodiversity- and nature-related impacts, dependencies and 
risks and how these are integrated into their business strategy and risk 
management
 – prevent biodiversity loss and aim to be nature positive. 
• As above • The Policy forms part of the policy framework overseen by the Nordea Life Holding Board, and the boards of directors of the local NLP 
entities.
• Read more on page 120 in “E1 Climate change”.

===== SIDA 156 =====

Nordea Annual Report 2025 155
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
E4 Biodiversity and ecosystems, cont.
Actions and resources related to 
biodiversity and ecosystems
We continuously work to mitigate the impacts of biodiver-
sity- and ecosystem-related risks on our risk types. We 
maintain a well-diversified portfolio across and within sec-
tors and industries, and manage it in line with our overall 
risk management procedures, such as our credit policies. 
We also engage with our customers to support biodiver-
sity transition efforts; respond strategically to develop-
ments in society; and set and work towards relevant 
Group-level and sector targets. Where project finance is 
concerned, we are a signatory to the Equator Principles, 
which impose requirements to assess risks to and impacts 
on biodiversity. Moreover, each year, we assess all office 
locations – new and old – to identify potential impacts on 
and risks to nature. 
As an active owner, Nordea Asset Management (NAM) 
prioritises engagement as the primary mechanism to 
address nature and biodiversity impact drivers. To this end, 
NAM is involved in numerous thematic and collaborative 
engagements. These include Nature Action 100; the 
Investor Policy Dialogue on Deforestation, which is aimed 
at addressing the drivers of climate change and land use 
change; the NAM aquaculture engagement, which is 
aimed at addressing natural resource use and direct 
exploitation; and the NAM PFAS engagement, which is 
aimed at addressing pollution.
As Nordea Life & Pension (NLP) invests globally and 
across a wide range of sectors, its portfolio is naturally 
exposed to biodiversity-related risks. Recognising the 
importance of these risks, NLP has started incorporating 
biodiversity considerations into its due diligence process by 
assessing if and how external asset managers address bio-
diversity in their strategies. In 2025 asset managers man-
aging approximately 95% of NLP’s assets in listed equities 
and corporate bonds were members of one or more of the 
existing global biodiversity initiatives, such as the Finance 
for Biodiversity Foundation and Nature Action 100. In the 
management of its real estate portfolio, NLP assesses how 
new developments and projects may affect ecosystems 
and biodiversity and takes steps to manage these impacts.
In order to address biodiversity- and ecosystem-related 
dependencies, impacts, risks and opportunities over time, 
better data is needed. We are taking a progressive and 
exploratory approach to addressing the question of data 
by assessing different metrics and data providers. Our 
focus is on developing our capacity to quantify dependen-
cies, impacts, risks and opportunities stemming from our 
financing activities, in line with the outcomes of our mate-
riality assessments. 
We do not currently include biodiversity offsets or 
nature-based solutions in our corporate biodiversity action 
plans. Nor do we draw on local and indigenous knowledge 
when planning and taking actions related to biodiversity 
and ecosystems. We are working to better understand and 
design actions needed to address our impacts and risks. In 
the future, we may find it relevant to use nature credits 
and/or consult with indigenous peoples and local commu-
nities in our work.
Actions supporting our aims related to biodiversity and 
ecosystems in 2025 included the following.
• Piloting a tool that quantifies the biodiversity footprint 
and ecosystem dependency of companies and portfolios 
to assess its usefulness for strategy development, risk 
management, reporting and disclosures. 
• Initiating a research and development collaboration with 
Jyväskylä University in Finland – focusing on assessing 
the biodiversity footprint of commercial real estate, con-
sidering the life cycle of buildings in the Nordic countries. 
Both this and the aforementioned pilot will enable us to 
enhance our knowledge regarding data availability, use 
and limitations and will thus support our evolving 
approach on this topic.
• Expanding our green funding framework to cover activi-
ties specifically addressing biodiversity.
• (NAM) Republishing NAM’s white paper on biodiversity 
and nature describing its approach to biodiversity and 
nature.
• (NAM) Working towards fulfilling NAM’s initiation tar-
gets in accordance with the commitments made under 
the Finance for Biodiversity Pledge. 
• (NLP) Conducting a review of data availability and ana-
lytical tools in order to better understand the exposure of 
NLP’s portfolio to biodiversity-related risks.
• (NLP) Completing an assessment of NLP using the 
ENCORE tool for the first time. The assessment identified 
materials, utilities, and consumer discretionary as the 
sectors with the highest impact and/or dependency on 
nature. 
Targets related to biodiversity and ecosystems
Having built internal expertise and capacity through our 
practice targets set in 2023, we continue to evolve our 
approach, aiming for refined quantified data so we can set 
future targets that are measurable, time bound, and out-
come oriented. Specifically, we are further exploring and 
developing our capacity to quantify the biodiversity- and 
ecosystem-related impacts, dependencies, risks and 
opportunities associated with our financing activities.
As part of our 2030 strategy, we have set an engage-
ment target for the period 2026–28 to learn about and 
support the biodiversity-related transitions of our large 
corporate customers in material, high-impact sectors. 
  2028 Nor dea bank target (relative) NEW
By the end of 2028, engage in dialogues on bio­
diversity with customers representing ≥80% of our 
large corporate lending exposure in relevant sectors 
with a high impact on nature
Target scope
The target covers the Large Corporates & Institutions 
(LC&I) corporate lending portfolio across our four Nordic 
markets, within relevant sectors.
Methodologies
The relevant sectors with a high impact on nature were 
selected based on our double materiality assessment, 
Business Environmental Scanning reports, external 
sources and tools (ENCORE, the WWF biodiversity risk 
 filter), and sector analysis. They were assessed to be 
 construction, paper and forest products, materials, power 
production, shipping, food processing and beverages, 
 fishing and aquaculture, mining and supporting activities, 
and real estate. As the portfolio is dynamic, the number of 
customers engaged with may be revised annually in the 
run-up to 2028.
As this is a newly established target, there is currently 
no performance monitoring status to report.

===== SIDA 157 =====

Nordea Annual Report 2025 156
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
SOCIAL INFORMATION
S1 Own workforce 
As an employer committed to fostering a sustainable workplace, 
we  e nable growth and career development for all, actively support 
employee well-being, and prioritise diversity and inclusion. 
We aspire to be the preferred employer in the financial 
industry in our operating countries and are committed to 
ensuring Nordea is a place where people want to have a 
career and can thrive. 
Enabling growth is key to realising this vision. We pro-
vide a wealth of opportunities for career development, 
and ensure our people have clear paths for growth. In 
2025 we launched the first wave of “Career Hub”, an 
AI-powered learning platform which matches employee 
skills and aspirations with development opportunities 
while tracking learning journeys. 
Our leaders are empowered to create an environment 
where teams can perform at their best, driving our busi-
ness forward while upholding our values: collaboration, 
ownership, passion and courage. 
To deliver on our strategic priorities, we identify and 
address critical competency needs, acquiring necessary 
skills and mitigating execution risks to build a future-ready 
workforce. New employee development initiatives focus 
on essential competency building in areas such as sales, AI 
tools and sustainability.
We prioritise employee well-being through a holistic 
approach that encompasses proactive, preventive and reac-
tive measures. In doing so, we support a sustainable work-
place where our employees can flourish both personally and 
professionally while maintaining a good work-life balance. 
In all areas of the organisation, we emphasise diversity 
and inclusion, as we believe varied perspectives and 
expertise enable us to deliver more innovative solutions 
and drive positive change. Fostering an environment 
where everyone feels valued and heard makes our organi-
sation stronger and means we can deliver a better service 
to our diverse customers. Support for diversity and inclu-
sion also helps us contribute to the inclusivity and safety 
of the societies in which we live. 
We continue to make progress towards fulfilling our 
commitment to close the adjusted gender pay gap by the 
end of 2026, having reduced the gap to 1.43% by the end 
of 2025. Moreover, we have met our 2025 ambition for 
employee development plan coverage and have seen a 
substantial increase in the number of senior leadership 
positions filled by internal candidates. 
Our efforts are gaining external recognition, with 
improved Universum rankings reflecting enhanced per-
ception of us as an employer among both students and 
professionals across all our markets.
Our culture is deeply rooted in our values, drives our 
performance, and has been key for our progress. Building 
a true high-performance culture is something we have 
been continuously working on over the past six years. 
Going forward, we will continue these efforts. In our 2026–
30 strategy period we will focus on developing a culture of 
high performance, proactivity and innovation, supported 
by technology, talent and transformational leadership.
2022–25 targets Status
Ensure that each gender has at least 40% representation at the top three leadership levels  
combined by the end of 2025 Target met
Achieve a minimum average index score of 90 for diversity and inclusion by the end of 2025 89
2030 targets
Ensure that each gender has at least 40% representation at the top three leadership levels combined by the end of 2030
Achieve a minimum average index score of 90 for diversity and inclusion by the end of 2030
See “Targets related to own workforce” on page 163 for more information, including our performance  
against the targets. 
~100
nationalities represented  
among our employees 
end-2025 gender split  
among our employees
51% women 49% men

===== SIDA 158 =====

Nordea Annual Report 2025 157
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Impacts, risks and opportunities overview for S1 Own workforce
Impact, risk or opportunity Title Value chain Time horizon
Working conditions
Positive impact  
(potential)
Good working environment
    
Positive impact  
(actual)
Employee well-being
    
Negative impact  
(actual)
Work overload
    
Risk Employee health and well-being     
Equal treatment and opportunities for all
Positive impact
(actual)
Diverse and inclusive workplace
   
Positive impact
(actual)
Career development
   
Negative impact  
(actual)
Gender pay gaps
    
Negative impact  
(potential)
Discrimination and  inequality
    
 Very long term Short term  Medium term  Long term Upstream  Own operations  Downstream
In this section
We focus on how we manage the impacts of our busi-
ness activities on our own workforce and how we miti-
gate associated risks. We summarise the own work-
force-related material impacts and risks identified in 
our double materiality assessment and explain why 
they are relevant for our strategy and business model. 
Then we present our policies that apply across the 
identified material impacts and risks. 
We organise the remainder of the section according 
to how we address the material impacts and risks: 
engagement processes, remediation processes and 
channels for raising concerns, and actions. We describe 
our targets – including our progress against them – 
and explain how we monitor the effectiveness of our 
policies and actions. Where relevant, we group the 
information according to the following sub-topics: 
• working conditions
• equal treatment and opportunities for all.
We conclude by presenting key metrics related to our 
own workforce, which span topics such as characteris-
tics of our employees, skills development and remuner-
ation, as well as entity-specific metrics.
Material impacts and risks and their interaction with 
strategy and business model
Matters concerning our own workforce are directly 
 relevant for our strategy and business model. 
Own workforce can be connected to inclusive and safe 
societies, one of the sustainability themes embedded in 
our business strategy. This is because workforce-related 
matters such as respect for human and labour rights, 
equality, fair employment conditions, and equal opportuni-
ties for learning and development all contribute towards 
the safety and inclusivity of the societies in which we live.
As a financial services provider, we have a business 
model based on creating value for customers, employees, 
investors, shareholders and society in general. Our capac-
ity to create value for our stakeholders and provide daily 
banking services for our customers is dependent in part on 
a healthy, competent and productive workforce with safe 
working conditions, now and in the future. 
Given the relevance of our own workforce for the suc-
cess of our strategy and business model, it is vital that we 
address related material impacts and risks.
Our entire workforce, consisting of employees and 
non-employees of the Nordea Group, was included in the 
scope of our double materiality assessment (DMA). Those 
subject to the material impacts identified through the 
assessment are primarily employees; in some cases, they 
are non-employees. Employees are people who are in an 
employment relationship with us. Non-employees are peo-
ple working for us through companies primarily engaged 
in employment activities, such as consultants. Depending 
on the impact, any employee or non-employee is or could 
be positively or negatively affected. Where career devel-
opment is concerned, employees are positively affected. 
Where gender pay gaps are concerned, both women and 
men could be negatively impacted. The risk identified 
relates to all Nordea employees and arises from our 
dependence on our workforce.
Our main operations are in countries with advanced 
legal requirements for working conditions, including regu-
lations and requirements regarding forced, compulsory 
and child labour. In addition to meeting these require-
ments, our human rights due diligence (covering all oper-
ating countries) has not identified any operations at signif-
icant risk of incidents of forced, compulsory or child labour.
Policies related to own workforce
The following table provides a comprehensive overview of 
our policies related to working conditions and/or equal 
treatment and opportunities for all. The internal rules 
listed in the table below form part of our internal rules 
framework, for which the Board of Directors is ultimately 
accountable. Unless otherwise stated, the policies are 
available to all employees on our intranet.
Our overarching policy framework for people risk 
derives from the Group Board Directive on Compliance 
Risk. The framework covers all policies and guidelines 
described below, except for the Code of Conduct, the 
Human Rights Policy and the Guidelines on Business 
Continuity. 
The policies and guidelines apply to all Nordea Group 
employees and non-employees regardless of their con-
tract type unless otherwise stated. Moreover, we comply 
with the local laws and regulations that cover members of 
our workforce in their respective countries of employment 
and respect the local collective agreements in place in our 
operating countries. 
We have processes in place for creating and updating 
internal rules, including guidelines for consultation and 
stakeholder management to ensure the interests of key 
stakeholders are considered.

===== SIDA 159 =====

Nordea Annual Report 2025 158
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Policy (entity) Relevance for S1 own workforce Related S1 impacts, risks and opportunities Further details
Code of Conduct 
(Nordea)
• Outlines the ethical principles for conducting business at Nordea.
• Requires us to: 
 – ensure good working conditions through a safe and healthy workplace
 – uphold labour rights
 – promote and value diversity and inclusion
 – maintain a qualified and competent workforce
 – support and respect human rights.
• All • Among other labour rights addressed in the Code, we respect the upper limits for regular working hours and overtime 
prescribed by the laws of the countries in which we operate.
• The Code is available to all external stakeholders at nordea.com. 
• Read more on page 169 in “S4 Consumers and end-users” and page 177 in “G1 Business conduct”.
Human Rights Policy 
(Nordea)
• Details our commitment to provide safe and fair working conditions.
• Prohibits the use of forced, bonded, involuntary or child labour in any area of our operations.
• Requires us to pay special attention to people who may be disadvantaged, marginalised or 
excluded from society and who may therefore be particu larl y vulnerable to negative human 
rights impacts.
• All • The Policy is overseen by the Board of Directors. 
• The Policy outlines our commitment to respect internationally recognised human rights standards and meet the 
corporate responsibility to respect human rights as defined in the UN Guiding Principles on Business and Human Rights. 
It does not address human trafficking.
• The Policy is aligned with the Universal Declaration of Human Rights and the International Labour Organization’s (ILO’s) 
Declaration on Fundamental Principles and Rights at Work, to which we adhere, and the UN Global Compact, to which 
we are a signatory.
• Read more on page 169 in “S4 Consumers and end-users”.
Occupational Health & 
Safety (OH&S) guideline 
(Nordea)
• Outlines how we continuously work to ensure a safe and inclusive workplace by promoting 
health and well-being, ensuring a good working environment, and managing illness and work 
ability.
• Explains the ambition, purpose and scope; concepts; roles and responsibilities; performance 
indicators; and reporting of this work and the OH&S management system.
• Good working environment
• Employee well-being
• Work overload
• The guideline forms part of the policy framework overseen by the Group Accountable Executive (GAE) for people risk 
– the Chief People Officer (CPO).
• The guideline complements and is aligned with local regulation, and is a key document related to working conditions. It 
covers the employees in our six main operating countries and is also aligned with the European directives on safety and 
health at work and International Organization for Standardization (ISO) standards 45001 and 45003 to ensure that best 
practice is adhered to.
Guidelines on Business 
Continuity 
(Nordea)
• Support us in safeguarding our operations; the interests of our customers and other 
stakeholders; our reputation; and our ability to continue activities, processes and services 
should an extraordinary event, such as a pandemic, occur.
• Employee health and well-being • The Guidelines form part of the policy framework overseen by the GAE for business continuity and crisis management 
– a member of the GLT.
• The Guidelines set out the principles and overall rules for managing business continuity in the Group. This is done 
through division/unit-specific and Group business continuity plans (BCPs) and liquidity contingency plans (CPs).
• The division/unit-specific BCPs support us in resuming essential business operations after a business disruption in 
accordance with defined recovery time objectives. The Group BCPs are for selected scenarios, for example pandemics. 
They include pre-defined escalation, coordination and communication protocols for quickly assessing the situation in 
order to support a clear, consistent and timely flow of communication within the organisation and to customers. They 
also specify mitigating actions under the different scenarios.
Guidelines regarding 
Equal Opportunities to 
Parental Leave in Nordea 
(Nordea)
• Make parental leave accessible to all parents. • Diverse and inclusive workplace
• Employee well-being
• The Guidelines form part of the policy framework overseen by the GAE for people risk – the CPO. 
• The Guidelines cover the employees in our six main operating countries.
Diversity & Inclusion 
Policy 
(Nordea)
• Sets out how we work to ensure equal treatment and opportunities for all in the workplace.
• Focuses on various aspects, such as gender equality; LGBTQ+ inclusion; ability variation; 
cultural inclusion regarding ethnicity, nationality and religion; age diversity; and equal pay for 
equal work.
• Diverse and inclusive workplace
• Discrimination and inequality
• Gender pay gaps
• The Policy forms part of the policy framework overseen by the GAE for people risk – the CPO. 
• We maintain a related internal Guideline on Diversity and Inclusion, which applies to our entire workforce.
• The Policy is aligned with the Universal Declaration of Human Rights, the ILO’s Discrimination Convention, the Charter of 
Fundamental Rights of the European Union (EU), EU directives on equal treatment, and local legislation concerning non-
discrimination and equality.
• The Policy is available to all external stakeholders at nordea.com. 
Guidelines on 
Recruitment, Onboarding 
and Offboarding 
(Nordea)
• Support inclusion and a diverse workforce.
• Require us to prevent discrimination and inequality at the recruitment stage by considering all 
applicants irrespective of gender, gender identity or expression, ethnicity, impairment, sexual 
orientation, creed or age.
• Career development
• Diverse and inclusive workplace
• Discrimination and inequality
• The Guidelines form part of the policy framework overseen by the GAE for people risk – the CPO. 
• To help ensure a diverse workforce, the Guidelines include a requirement for both women and men to be among the final 
three candidates for leadership positions. This requirement also supports the achievement of our Group-level gender 
target, which is presented in more detail on page 163. The Guidelines apply to all employees working at Nordea.

===== SIDA 160 =====

Nordea Annual Report 2025 159
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Policy (entity) Relevance for S1 own workforce Related S1 impacts, risks and opportunities Further details
Non-discrimination 
procedure 
(Nordea)
• Helps ensure that we comply with non-discrimination legislation.
• Encourages and supports a culture of equal opportunities and equal rights. 
• Addresses harassment, sexual harassment, bullying and similar violations in the workplace.
• Diverse and inclusive workplace
• Discrimination and inequality
• The procedure forms part of the policy framework overseen by the GAE for people risk – the CPO. 
• The procedure covers discrimination based on racial/ethnic origin, colour, sex, sexual orientation, gender identity, 
disability, age, religion, and national extraction. We respect additional protections, for example those concerning political 
opinion, which are included in local legislation.
Assessment policy 
(Nordea)
• Is aimed at ensuring a professional, ethical and standardised approach to the psychometric 
testing of job candidates.
• Promotes fairness and equal opportunities through a commitment to select on merit.
• Career development
• Discrimination and inequality
• The policy forms part of the policy framework overseen by the GAE for people risk – the CPO. 
• According to the policy, assessments should only include questions that are clearly relevant to the demands of the job 
and are free from the influence of bias. All assessments for selection and promotion must be monitored to ensure they do 
not unfairly exclude or disfavour any section of the population.
• The policy applies to all job candidates.
Learning Policy 
(Nordea)
• Supports employees in taking opportunities to acquire the competencies needed to realise 
business strategies and goals.
• Career development • The Policy forms part of the policy framework overseen by the GAE for people risk – the CPO. 
• The Policy is aimed at enabling career development. It states that employees are responsible for developing their 
competence and should actively strive to enhance their competencies and skills. 
• Leaders are responsible for offering employees opportunities and providing time for competence development. 
Management is responsible for ensuring that employees have the right level of competence to reach business objectives.
• The Policy applies to all employees working at Nordea.
Guideline on competence 
and capacity 
management 
(Nordea)
• Describes the processes we should have in place to ensure we have enough skilled and 
competent employees to carry out our operations effectively and professionally. 
• Sets expectations regarding the controls we have in place to manage related risks in our daily 
operations.
• Career development • The Guideline forms part of the policy framework overseen by the GAE for people risk – the CPO. 
Remuneration Policy 
(Nordea)
• Sets out the strategic principles and requirements governing remuneration. 
• Supports gender-neutral remuneration through the application of pay principles.
• Gender pay gaps • The Policy is overseen by the Board of Directors.
• The Policy is referred to internally as the Group Board Directive on Remuneration.
• All remuneration policies and practices at Nordea are based on the principle of equal pay for equal work or work of 
equal value, regardless of gender.
• The Policy applies to all employees working at Nordea and is available to all external stakeholders at nordea.com.
• Read more on page 177 in “G1 Business conduct”.
Group CEO Instructions 
on Raising Your Concern 
(Nordea) 
• Outline the rights, responsibilities and protection of individuals when they raise a concern. 
• Describe the responsibilities, rules and procedures for the Raise Your Concern (RYC) unit 
when handling such cases. 
• All • The instructions are overseen by the Group CEO. 
• The instructions cover concerns raised by individuals through our RYC channels and concerns detected through other 
internal channels that are handled by means of the RYC process. 
• The instructions apply to all employees and consultants working for Nordea, as well as non-permanent and former staff.

===== SIDA 161 =====

Nordea Annual Report 2025 160
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Engagement processes related to own workforce
Working conditions
We seek to ensure solid working conditions for everyone 
at Nordea through engagement and continuous dialogue 
with our employees and union representatives. In particu-
lar, we use:
• our People Pulse employee engagement surveys
• internal cooperation fora, councils and committees
• team and individual PLD dialogues.
Our Chief People Officer (CPO) is responsible for key 
engagement processes related to working conditions and 
equal treatment and opportunities for all, while all leaders 
are responsible for ensuring continuous engagement and 
an inclusive workplace. 
Each quarter, we conduct our employee engagement 
survey, People Pulse, where employees can give feedback 
based on their perception of Nordea as a workplace and 
bank. Depending on the quarter, the survey covers various 
aspects, such as working conditions; workload and stress; 
learning and development; diversity and inclusion; mal-
treatment; and other factors that influence employees’ 
overall engagement and well-being. The insights gained 
help us identify key areas for improvement and facilitate 
meaningful conversations and actions to enhance our 
workplace culture. In 2025 the survey response rate was 
85%, which demonstrates its effectiveness in representing 
the views of our employees. The survey is confidential, 
with responses collated and analysed by an external 
vendor.
We gather further feedback on how employees per-
ceive their workplace experience through our biannual 
Employee Experience Survey. The Survey assesses 
employee experience across all workplace interactions 
and services and is distributed to a portion of employees 
depending on their location. The results are used to iden-
tify areas for improvement in our workplace.
We strive for diverse representation among the employ-
ees and union representatives in our cooperation fora. 
These structured recurring cooperation fora are held – and 
thus enable employee representation and feedback – at 
both the Group and local levels.
Engagement also takes place at the team level, 
between employees and leaders in team meetings, and 
the individual level, in performance, learning and develop-
ment (PLD) dialogues and check-ins between employees 
and leaders. 
The PLD dialogue and check-ins are aimed at driving 
performance, enhancing career development and support-
ing employee aspirations through goal-setting and devel-
opment planning; coaching and feedback; and the review 
of performance and growth potential. We recommend that 
leaders and employees hold PLD check-ins throughout the 
year to ensure continuous dialogue and complement the 
annual PLD dialogue. 
Team and individual-level engagement occurs at multi-
ple stages throughout the year to ensure continuous dia-
logue. We set expectations for leaders and strongly 
encourage teams to engage in dialogues to help translate 
the People Pulse results into learning opportunities and 
actions at least twice a year. These dialogues support 
leaders and teams in identifying what is working well and 
what could be even better and in agreeing on the next 
steps. The frequency of check-ins is arranged between the 
employee and the leader. 
Equal treatment and opportunities for all
We engage with our employees on matters related to 
equal treatment and access to opportunities through:
• Country D&I Councils
• our People Pulse employee engagement surveys
• team and individual PLD dialogues
• Employee Resource Groups.
Our Country D&I Councils oversee the local D&I agenda, 
ensure relevant actions are taken to support D&I work 
locally, and support local Employee Resource Groups. 
Each Council consists of ten core members. In addition to 
these, employee representatives may be selected by the 
unions through dialogues between the Council chairs and 
the unions and in accordance with local legislation and 
collective agreements. To ensure mutual information and 
advice sharing, each Country D&I Council is assigned a 
sponsor from within our Group-wide D&I Committee. The 
Councils report to the Group-wide D&I Committee on 
actions, progress and findings on an annual basis.
As part of our effort to ensure non-discrimination as a 
fundamental human right, we measure the perception of 
D&I in our People Pulse survey twice a year and take 
action based on the outcome.
We also have the following voluntary employee-led 
Employee Resource Groups (ERGs), which aim to contrib-
ute to fostering an inclusive workplace by providing peer 
support and highlighting diverse perspectives: Ability 
Variation, Cross-Faith and Beliefs, Cross Cultural, Cross 
Generations, Gender Equality, and LGBTQ+ and Allies. ERG 
representatives are regularly invited to Country D&I 
Council meetings.
Consultation with workers’ representatives
We have established a process for informing and discuss-
ing with workers’ representatives the information referred 
to in the Sustainability Statement and our means of 
obtaining and verifying it in alignment with the Corporate 
Sustainability Reporting Directive (CSRD) requirement as 
implemented in the Finnish Accounting Act.
A select group of employee representatives were con-
sulted on the 2025 Sustainability Statement. Additionally, 
our Board of Directors, including its employee-elected 
members, approved the Statement according to a defined 
process.
Remediation processes and channels 
for raising concerns
We have given our own workforce a clear way to address 
grievances and have processes in place to provide for 
remediation in cases where we have caused or contributed 
to work overload or gender pay gaps or where members 
of our workforce feel their rights have been violated. We 
encourage our employees to engage in open dialogue and 
raise concerns through our whistleblowing function, Raise 
Your Concern (RYC); Group People’s Ask HR function; and 
support functions, which are in place at all levels of the 
organisation. Employees can also raise concerns through 
the channels described in “Engagement processes related 
to own workforce” above.
We encourage employees and non-employees who feel 
they have been subjected to bullying, harassment or dis-
crimination to report incidents via the RYC function and 
reach out to their leader or Group People for support. In 
2025 there were 2 substantiated incidents (3 in 2024) and 
33 complaints (26 in 2024) related to discrimination, 
including harassment. Additionally, there were 19 other 
complaints (24 in 2024) filed through the channels pro-
vided for our own workforce to raise concerns related to 
working conditions, equal treatment and opportunities for 
all, and other-work related rights. There were no severe 
human rights incidents (0 in 2024) reported. There were 
no fines or financial penalties and no compensation for 
damages (0 in 2024) as a result of the above-mentioned 
incidents and complaints during the reporting period. 
More information about how we collect data on incidents, 
complaints and severe human rights impacts can be found 
on page 166. Further details on the RYC function are pro-
vided in “G1 Business conduct” on page 178.
We take steps to ensure that our workforce is informed 
about the available grievance mechanisms. We raise 
awareness in various ways, including through our annual 
Code of Conduct training and internal awareness cam-
paigns, for example intranet content. More information on 
our Code of Conduct training and how we assess work-
force awareness regarding channels for raising concerns 
can be found in “G1 Business conduct” on page 178.
We are committed not only to providing access to these 
channels but also to giving our workforce the knowledge, 
confidence and psychological safety to use them when 
needed. To this end, we have adopted confidentiality poli-
cies that protect individuals who raise concerns, ensuring 
privacy and protection of their personal data. These poli-
cies allow for anonymous submissions and prohibit retali-
ation against those using grievance mechanisms.
In addition to these channels, the People Pulse survey 
includes specific questions on potential maltreatment, 
including harassment, once a year. Teams can use our 
“Let’s Talk” tool to help them address workplace maltreat-
ment concerns or reported maltreatment in a structured 
way. The tool also provides guidance on implementing 
appropriate remedial actions where necessary.

===== SIDA 162 =====

Nordea Annual Report 2025 161
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Actions and resources related to own workforce
We continuously act on our responsibility to address mate-
rial positive and negative impacts and risks related to our 
own workforce. We have “People Priorities”: focus areas 
that support our Group strategy and help us respond to 
developments affecting our workforce. We set these prior-
ities for periods of 3–5 years, taking into account ongoing 
dialogues with relevant stakeholders. 
The actions described below are aligned with our 
 2022–25 People Priorities.
Working conditions
We have an occupational health and safety (OH&S) man-
agement system for managing working conditions and 
taking action in response to identified material impacts 
and risks. The system provides a framework for identifying 
workplace risks at an early stage and highlighting 
strengths, helping us improve working conditions and 
employee engagement, well-being and work ability. 
Mitigating actions are identified and taken in each country, 
business area and Group function, followed up on regu-
larly during the year, and fed into a process for managing 
and reporting on people risk. The system is owned and 
governed by a designated team, spans all organisational 
areas and levels, and involves country-level OH&S com-
mittees. It covers all employees and operates on an annual 
cycle, with four phases: investigation, risk assessment, 
action and follow-up. 
To support employee work-life balance and mitigate 
work overload, we align with local collective agreements, 
for example regarding limits on overtime and weekly 
working hours. We have also introduced a hybrid working 
model with a set of guiding principles, giving employees 
the flexibility to perform focused tasks from home and 
helping them manage their work-life balance. In addition, 
our employees have the option to agree on flexible start 
and end times with their leader, depending on their role. 
We have processes in place to follow up on unused holi-
day and ensure that available paid annual leave is taken 
by employees. Unused holidays are reported to employees 
and their leaders regularly. Moreover, we provide equal 
opportunities for parental leave for all parents during 
pregnancy, the adoption process and the child’s infancy. 
After their parental leave, employees may also take unpaid 
childcare leave.
To enhance employee working conditions, we support 
various internal activities promoting sport or culture. We 
focus on activities that are accessible to as many employ-
ees as possible. We also arrange Group-level and local 
events to acknowledge and promote different aspects of 
health or working conditions. For example, we hold “Let’s 
Get Energised week”, an initiative to increase knowledge 
and engagement regarding healthy habits that support a 
sustainable work life. In addition, we observe World 
Mental Health Day, which is aligned with the World Health 
Organization’s global initiative to raise awareness about 
mental well-being. We also provide health checks and 
occupational healthcare services as required by local 
regulations.
Twice a year, our subject matter experts in Group 
People assess people risks using our common risk taxon-
omy and common risk grid. The assessment helps us iden-
tify appropriate actions to take to prevent work overload 
and mitigate the risk of failure to protect employee health 
and well-being. It provides a comprehensive and consoli-
dated picture of people risks and thus supports the Chief 
People Officer (CPO) in making decisions and prioritising 
actions to be taken. We also perform annual business con-
tinuity planning and testing to support leaders and 
employees in knowing how to act in a crisis situation, 
including adverse external events such as pandemics.
Actions supporting safe and healthy working conditions 
in 2025 included:
• continuing to stabilise and mature the OH&S system by 
closing identified gaps, further aligning it with our exist-
ing people processes, and enhancing our data capabili-
ties for better insights into employee health and safety
• encouraging team and one-on-one dialogues based on 
the People Pulse results, including those related to 
 workload and well-being
• improving the governance of and reporting on the 
 mandatory OH&S training for leaders.

===== SIDA 163 =====

Nordea Annual Report 2025 162
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
Equal treatment and opportunities for all
We have taken a number of actions focused on supporting 
diversity and inclusion and the achievement of our D&I 
target. We also welcome and enable the self-identification 
of gender identity among our employees. In compliance 
with regulatory restrictions on sensitive data, we do not 
register gender identity.
As leaders’ behaviour and actions serve as an example 
to others, we have a leadership framework and supporting 
leadership principles in place. These encourage leaders to 
foster inclusion and empower people, and enable them to 
create purpose and inspire employees to grow and con-
tribute. Our leadership core learning curriculum is availa-
ble on demand for all leaders at Nordea. All new leaders 
are required to complete a mandatory “license to lead” 
programme during their first six months on the job. This 
comprehensive training package covers people processes, 
core leadership skills and legal responsibilities. We moni-
tor gender balance in the leadership programmes to help 
ensure equal access to development opportunities.
Our leadership principles, together with our policy 
framework, are aimed at fostering an inclusive working 
environment and preventing harassment. These aims are 
supported by dedicated internal procedures and manda-
tory training for leaders and employees that includes con-
tent on preventing harassment. 
Our ambition is to close the adjusted pay gap between 
women and men in equivalent roles by the end of 2026. To 
this end, we are remediating pay gaps through pay 
reviews, focusing on negative outliers identified in our 
annual pay equity analysis. Looking ahead, we will con-
tinue to enhance transparency regarding pay guidance, 
pay levels and pay equity, both internally and for job appli-
cants. In 2026 we will further strengthen our structured 
approach to pay setting and implement the new European 
Union requirements regarding pay transparency, support-
ing our ongoing commitment to fairness, compliance and 
trust across the organisation.
To support our employees with their career develop-
ment, we have developed “Nordea Job Catalogue”, a 
resource they can use to search through all jobs at Nordea. 
In this way, we hope to inspire them to form their unique 
career journey. The Catalogue is based on our Group-wide 
job architecture, which structures jobs based on external 
benchmarks and market standards. The job architecture 
provides a clear overview of career opportunities and also 
helps support equal pay for equal work. 
The development plan is a key tool for helping employ-
ees grow in their current role and prepare for the next 
steps in their career. It enables them to record their career 
development goals and track their progress towards them 
together with their leader. In 2025 we met our ambition for 
at least 80% of employees to have a development plan in 
place. 
Recognising that significant learning and development 
happens outside formal training – and that it is best 
achieved through a combination of training and on-the-
job experience – we use a 70-20-10 learning framework to 
support continuous learning. 70% of learning happens 
through on-the-job experience, 20% through feedback, 
coaching and mentoring, and 10% through more formal 
learning, such as digital courses and classroom training 
designed for different career paths. 
At Nordea, we hire the vast majority of our senior lead-
ers from internal candidates. This presents great develop-
ment opportunities for our employees and enables us to 
draw further on the valuable experience already present 
among our workforce. 
Each year, we conduct strategic workforce planning to 
identify critical competency needs and ensure our work-
force capacity and skills align with both current require-
ments and future strategic objectives.
We have a graduate programme – the Nordea Graduate 
Programme – which is designed to help us attract, 
develop and retain high-potential talent, thereby ensuring 
a diverse and fit-for-the-future pipeline of leaders and 
specialists for Nordea. The programme is built around 
future critical skills and offers learning journeys consisting 
of rotations, on-the-job experience and targeted training 
sessions.
S1 Own workforce, cont.

===== SIDA 164 =====

Nordea Annual Report 2025 163
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Actions supporting equal treatment and opportunities 
for all in 2025 included:
• integrating a people focus scorecard, including D&I, 
engagement and well-being metrics, into variable pay 
plans
• updating our “Let’s Talk” process to strengthen our 
response to workplace harassment
• launching a new talent development platform, “Career 
Hub”, for a first wave of employees to build a company- 
wide skills taxonomy aligned with our job architecture
• taking steps to expand the scope of our succession plan-
ning in order to maintain a talented workforce and 
ensure business continuity 
• launching new employee development initiatives 
focused on essential competency building in areas such 
as sales, AI tools, and ESG matters
• implementing mandatory training programmes for all AI 
tool users, which must be completed before access to 
these tools is granted.
Targets related to own workforce
In 2022 we set gender and D&I-related targets for 2025 to 
drive our progress as a diverse and inclusive workplace, 
combat discrimination, and ensure equality among our 
workforce. The targets were aligned with and supported 
the achievement of UN Sustainable Development Goals, 
including but not limited to Goal 5 Gender Equality and 
Goal 10 Reduced Inequalities.
During the preparation of new targets related to own 
workforce, rele vant st akeholders, including leader ship and 
subject matter experts, are involved and the pro posals are 
discussed in relevant fora, including the D&I Committee.
  Gender target
Ensure that each gender has at least 40% 
 representation at the top three leadership levels 
combined by the end of 2025
Target scope and methodology
The target was aimed at driving the gender balance of 
women and men in all parts of the organisation.
It was calculated as the percentage of women and men 
holding positions at leadership levels 1, 2, and 3, with a 
leader defined as an employee to whom one or more 
employees directly report. The target had a baseline value 
of 35.9% and the base year was 2021. Read more in 
“Gender and age distribution” on page 165.
Performance against target
We have exceeded our minimum 40% representation tar-
get, achieving 43% at the end of 2025. The target level 
was reached for the first time in October 2023 and contin-
ued to stabilise in the run-up to 2025.
Performance against the target was closely tracked. 
Progress and potential areas for improvement were 
shared and discussed in relevant cooperation fora and 
committees, including the D&I Committee, and through 
events aimed at all employees. Each year, we publish a 
D&I report internally on our intranet, providing the entire 
workforce with a comprehensive update on our progress 
related to all aspects of D&I. In addition, progress was 
tracked internally and formally reported to the relevant 
committees.
Looking ahead to 2030
We will maintain the target to ensure at least 40% gender 
representation across the top three leadership levels in the 
run-up to 2030, upholding our commitment to equal rep-
resentation and enabling us to continue to improve the 
balance in certain areas of the organisation. The scope 
and methodology for this target will be unchanged from 
the 2025 target.
  D&I target
Achieve a minimum average index score of 90 for 
diversity and inclusion by the end of 2025
Target scope and methodology
The target was based on three questions in the People Pulse 
survey, on employees’ perception of fair treatment, equal 
opportunities and an inclusive environment, respectively. It 
had a baseline value of 89 and the base year was 2023. 
The diversity and inclusion index is calculated as a sim-
ple average of the question scores. The questions require 
participants to score statements on a scale of 0–10; the 
answers are transferred to a scale of 0–100.
The target outcome is reported based on the latest 
results available in the reporting period, i.e. the Q4 2025 
survey. Progress towards the target was assessed on an 
annual basis in order to establish whether there was a 
trend in the scores.
Performance against target
The index was maintained at 89 in the fourth quarter of 
2025, just below the target of 90. This is the same result as 
in 2024. At the same time, performance remained strong, 
with results exceeding benchmarks in the majority of the 
measured topics. We remain committed to maintaining the 
target and achieving it by 2030, with a sustained focus on 
initiatives aimed at further developing a diverse and inclu-
sive workplace.
Performance against the 2025 target was tracked as 
described above for the gender target.
Looking ahead to 2030
We will maintain our target to achieve a minimum average 
index score of 90 for diversity and inclusion by the end of 
2030. The scope and methodology for this target will be 
unchanged from the 2025 target.
Monitoring the effectiveness of policies and 
actions for other material sustainability matters
While we have not set formal targets related to the 
remaining identified material sustainability matters, we 
internally track the effectiveness of related policies and 
actions. For example, we follow trends in the People Pulse 
survey and report results and key data to senior leadership 
and relevant committees. This includes monitoring our 
well-being index, which comprises questions on workload, 
work distribution and employee empowerment. Analysis 
of trends ensures that impacts are known and actions can 
be taken with the firm support of the appropriate deci-
sion-makers. Read more in “Engagement processes 
related to own workforce” on page 160.
To help address the material impact related to gender 
pay gaps, we have set an ambition to close the adjusted 
pay gap between women and men by the end of 2026. To 
help address the material impact related to career devel-
opment, we had the ambition for at least 80% of our 
employees to have a development plan in place by the 
end of 2025 – an ambition we have now met. In addition, 
we have other metrics in place to measure gender pay 
gaps, gender distribution, training and skills development 
and other relevant KPIs related to the identified impacts. 
The metrics are presented on pages 164–166.
For material impacts and risks related to working environ-
ment, employee well-being and work overload, we have a 
process in place to track the effectiveness of relevant policies 
and actions. KPIs, key risk areas and additional performance 
indicators are reported with an agreed frequency to relevant 
stakeholders, who then use the information to make any nec-
essary adjustments. Progress on the indicators has been 
measured since 2024 and the ambition is to keep within an 
agreed risk appetite. We also analyse and report on data 
related to employee experience, employee turnover, sick 
leave, exit surveys and overtime hours, and carry out physical 
risk assessments of the premises. The metrics are presented 
on pages 164–166. Our biannual people risk assessment, 
described on page 161, helps us track and assess the effec-
tiveness of our actions to prevent and mitigate negative 
impacts related to working conditions. After each assess-
ment, Group People provides a status report on people risk 
to the relevant committees.

===== SIDA 165 =====

Nordea Annual Report 2025 164
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Metrics
Key employee metrics
The total number of employees (NOEs) and the break-
downs by gender, country and contract type are reported 
based on the headcount as at the end of the reporting 
period, i.e. 31 December 2025. The most representative fig-
ure for the total number of employees and corresponding 
breakdowns in the financial statements are on page 265 
and are reported based on full-time equivalents (FTEs). 
Therefore, the figures are not directly comparable. 
Depending on their contract type, employees are cate-
gorised as permanent or temporary. When applicable, they 
are further categorised as non-guaranteed hours employ-
ees. Non-guaranteed hours employees may therefore be 
included among both permanent and temporary employ-
ees. We employ around 300 summer trainees each year, 
which is the main reason behind fluctuations in the head-
count during the reporting period.
Non-employees include individuals working for Nordea 
through companies that primarily engage in employment 
activities, such as consultants. The metric is calculated as 
the total number of full-time equivalents (FTEs), with the 
FTE value based on non-employee contracted working 
time percentages as at the end of the reporting period.
The employee turnover metrics are based on FTEs, with 
the FTE value based on employee contracted working 
time percentages as at the end of the reporting period. 
The employee turnover rate is calculated as the total num-
ber of employees (FTEs) who left Nordea during the 
reporting period either voluntarily or due to dismissal, 
retirement or death in service, divided by the average 
number of employees (FTEs) during the reporting period. 
The voluntary employee turnover rate only includes 
employees who left Nordea voluntarily. Leavers do not 
include internal moves or expiring temporary contracts. 
Flexible workers, consisting mainly of non-guaranteed 
hours employees, are excluded from all employee turnover 
metrics.
Number of employees by gender, NOEs
2025 2024
Men 15,567 16,128
Women 16,277 17,051
Not reported1 3 4
Total 31,847 33,183
1) Corresponds to system registrations that are neither men nor women.
Number of employees by country 1, NOEs
2025 2024
Denmark 7,053 7,524
Estonia 1,068 1,155
Finland 6,576 6,885
Norway 3,356 3,486
Poland 5,922 6,040
Sweden 7,375 7,587
International offices 497 506
1) Includes all operating countries.
Number of non-employees, FTEs
2025 2024
Number of non-employees 4,959 6,628
Employee turnover 
2025 2024
Number of leavers (FTEs) 1,801 2,023
Employee turnover rate (%) 6.1% 6.8%
Number of voluntary leavers (FTEs)* 1,218 1,468
Voluntary employee turnover rate (%)* 4.1% 4.9%
* Entity-specific metric
Number of employees by contract type, NOEs
2025 2024
Men Women Not reported1 Total Men Women Not reported1 Total
Number of employees 15,567 16,277 3 31,847 16,128 17,051 4 33,183
Number of permanent 
employees 15,030 15,806 3 30,839 15,356 16,254 4 31,614
Number of temporary 
employees 537 471 0 1,008 772 797 0 1,569
Number of non-guaranteed 
hours employees 281 241 0 522 297 277 0 574
Number of full-time 
employees
2 14,857 14,754 3 29,614 15,267 15,369 4 30,640
Number of part-time 
employees 710 1,523 0 2,233 861 1,682 0 2,543
1) Consists of system registrations that are neither men nor women.
2) “Full-time employees” refers to the count of employees working full time. This figure does not equate to 
full-time equivalents (FTEs), which is a measure of work capacity.

===== SIDA 166 =====

Nordea Annual Report 2025 165
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Gender and age distribution
The top management level corresponds to the Group 
Leadership Team (GLT). The metric is based on headcount 
and shows the percentage of women and men at the top 
management level as at the end of the reporting period.
The top three leadership levels correspond to leader-
ship level 1, which comprises the Group CEO and the lead-
ers that report directly to him, including members of the 
GLT; leadership level 2, which comprises leaders reporting 
to leadership level 1; and leadership level 3, which com-
prises leaders reporting to leadership level 2. The metric is 
based on headcount and shows the percentage of women 
and men at the top three leadership levels combined as at 
the end of the reporting period.
The graduate programme gender split is based on 
headcount and shows the percentage of women and men 
hired for the Nordea Graduate Programme during the 
reporting period. 
The gender split for the core leadership programmes 
shows the percentage of women and men among the par-
ticipants who completed the programmes during the 
reporting period.
The age distribution of employees is reported based on 
the headcount as at the end of reporting period.
Age distribution of employees
2025 2024
# % # %
Under 30 years old 5,110 16 6,151 18
Between 30 and 50 years old 18,766 59 18,877 57
Over 50 years old 7,971 25 8,155 25
Gender distribution
Gender1
2025 2024
# % # %
Gender distribution at 
top management 
level2
Men 8 62 8 67
Women 5 38 4 33
Gender distribution at 
top three leadership 
levels combined*
Men 359 57 378 59
Women 268 43 261 41
Graduate programme 
gender split* (%)
Men – 53 – 47
Women – 47 – 53
Core leadership 
programmes gender 
split (%)*
Men – 46 – 47
Women – 54 – 53
1) Gender categories include men and women only as “not reported” is not material 
to these metrics (<1).
2) “Top management” refers to the Group Leadership Team.
* Entity-specific metric
Health and safety metrics
The information on employees covered by the operational 
health and safety (OH&S) management system derives 
from documents describing the OH&S risk assessment 
process. The sick leave rate is calculated as the total num-
ber of sick leave days divided by the total number of 
planned working days during the reporting period. The 
calculation covers our six main operating countries: 
Denmark, Finland, Norway, Sweden, Poland and Estonia. 
Flexible workers, mainly non-guaranteed hours employ-
ees, are excluded from the calculation.
Health and safety metrics
2025 2024
Employees covered by the health and
safety management system (%) 100 100
Sick leave rate (%)* 3.4 3.3
* Entity-specific metric
Training and skills development
Employees who participated in regular performance and 
career development reviews are calculated as the number 
of employees who received an assessment form for a per-
formance review (based on the latest available data in the 
reporting period) divided by the total headcount. 
Percentages for men and women are calculated by divid-
ing the number of male and female employees who 
received such a form by the headcount for male and 
female employees, respectively. Employees who are on 
long-term leave of absence or are working for Nordea for 
a short period of time, where an annual performance 
review is not possible, do not participate in the review.
The average number of training hours is calculated as 
the total number of hours of training completed during the 
reporting period by employees employed at the end of the 
reporting period divided by the total headcount. The 
calculation of training hours covers formal documented 
training and does not include time spent on informal peer 
feedback, coaching or on-the-job learning.
Employees with development plans are calculated as 
the number of employees with a development plan at the 
end of the reporting period divided by the total head-
count. Flexible workers, mainly non-guaranteed hours 
employees, are excluded from the calculation. 
 The internal hiring metric is calculated as the sum of 
positions filled via promotion or internal recruitment at 
leadership levels 1 and 2 divided by all positions filled both 
internally and externally at leadership levels 1 and 2 dur-
ing the reporting period.
The total headcounts and gender-specific headcounts 
used as the denominators are displayed in the table 
“Number of employees by gender” on page 164.
Training and skills development
Gender1 2025 2024
Employees who participated in regular performance and career 
development reviews (%)
Men 95 92
Women 92 94
Total 93 93
Average number of training hours Men 16.2 16.1
Women 16.5 16.1
Per employee 16.3 16.1
Employees with development plans (%)* 82 73
Leadership level 1 and 2 positions filled by internal candidates (%)* 87 69
1) Gender categories include men and women only as “not reported” is not  ma terial to these metrics (<1).
*Entity-specific metric

===== SIDA 167 =====

Nordea Annual Report 2025 166
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S1 Own workforce, cont.
Incidents, complaints and severe human rights impacts 
The key figures for the reporting year are presented on 
page 160. The data on incidents and complaints is calcu-
lated as the total number of cases. For 2025, we present 
the figures in a way that more closely reflects our internal 
reporting processes for raising concerns and aims to pro-
vide further clarity. We present the data according to three 
discrete categories: (1) substantiated incidents of discrimi-
nation, (2) complaints involving discrimination, and (3) 
other complaints. Substantiated incidents are not counted 
among the complaints. A substantiated incident is one 
where a case investigation results in formal consequences 
according to our people disciplinary process or Raise Your 
Concern (RYC) process.
To enable easy comparison, we have updated the clas-
sification of the 2024 figures to match these categories. 
The total number of incidents and complaints reported in 
2024 has not changed. We present the revised figures on 
page 160. 
The data is collected from a case management system 
by the RYC unit and from a dedicated dashboard by Group 
People. The data on severe human rights incidents is col-
lected from the RYC unit’s case management system and 
includes cases of non- r espect of the UN Guiding Principles 
on Business and Human Rights, the International Labour 
Organization’s Declaration on Fundamental Principles and 
Rights at Work or the OECD Guidelines for Multinational 
Enterprises. The data on fines, penalties and compensa-
tion for damages is collected from relevant Group func-
tions via email. Depending on the nature of the case, it 
may be transferred from the RYC unit to Group People or 
vice versa for handling. Therefore, reconciliation is per-
formed when sourcing the data to avoid double counting. 
No reconciliation was required during the reporting 
period, as no fines, penalties or compensation for dam-
ages needed to be paid. 
Gender pay gaps
The unadjusted gender pay gap is a comparison of the 
average gross annual pay for all female employees with 
the average gross annual pay for all male employees 
expressed as a percentage of the average pay level for 
male employees. Pay corresponds to total direct compen-
sation, including base salary, cash allowances, bonuses 
and long-term incentive rewards, as relevant.
The adjusted gender pay gap is based on a comprehen-
sive global pay equity analysis of our pay practices con-
ducted by the external vendor Mercer on an annual basis. 
This is a regression model analysis, which controls for fac-
tors that influence differences in pay in an objective way, 
including job complexity, experience, performance and 
location, and identifies pay differences between women 
and men in comparable positions that are not due to these 
factors.
Gender pay gaps
2025 2024
Adjusted gender pay gap (%)* 1.43 1.75
Unadjusted gender pay gap (%) 21.48 22.90
* Entity-specific metric
Remuneration ratio
The annual total remuneration ratio is the remuneration of 
the highest paid individual divided by the average total 
remuneration of employees (excluding the highest paid 
individual).
Remuneration ratio
2025 2024
Annual total remuneration ratio 40.7 45.7

===== SIDA 168 =====

Nordea Annual Report 2025 167
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
SOCIAL INFORMATION
S4 Consumers and end-users
As the largest financial services group in the Nordics, we have the size 
and reach to ensure that individuals and households across the region can 
take part in the financial system in a way that is safe, fair and  su pportive 
of their financial well-being. 
Financial decisions impact people’s exposure to risks and 
ability to capture opportunities, and are a crucial part of 
planning for the future. We are committed to supporting 
our customers in strengthening the positive impacts of their 
financial decisions, while addressing potential barriers that 
could limit their access to and trust in financial services.
Our work is guided by internationally recognised frame-
works and the OECD’s definition of financial well-being: 
being in control, feeling secure and having the freedom to 
make financial choices that support one’s goals. To embed 
this definition in practice, we contribute to supporting 
financial well-being through three enablers, informed by 
the United Nations Environment Programme Finance 
Initiative: financial inclusion, financial tools and insights, 
and financial skills.
Together, these guide us in designing services, making 
decisions and engaging with society.
Our approach is not only about enabling positive impacts 
but also about addressing customer vulnerabilities – which 
may be triggered by different circumstances – in a respon-
sible and proactive way. We recognise that there are risks 
and barriers that can make financial well-being harder to 
achieve. Digital accessibility challenges, exposure to fraud 
and data privacy are critical issues that require continuous 
attention. 
In 2025 we published our financial well-being and inclu-
sion commitment summary, which connects directly to our 
customer promise and our strategic sustainability priorities. 
The summary, which is available at nordea.com, includes 
examples of how we work to foster financial well-being and 
deliver on our commitment to fair and inclusive banking. 
Our next steps are to continue to develop initiatives 
related to our three key enablers and strengthen how we 
measure outcomes and follow up on results. 
Our key enablers to promote financial well-being
Financial inclusion 
Ensure products and services are 
accessible and inclusive
Financial tools and insights 
Provide insights and solutions 
that support confident 
financial decisions
Financial skills 
Build knowledge and 
awareness that strengthen 
 resilience and enable equal 
participation in society
Community engagement
Community engagement is integral to our work to sup-
port financial well-being. It enables us to extend our 
reach beyond our existing customers and, in some 
cases, connect with people not yet fully included in the 
financial system, for example children or refugees. To 
support long-term positive impacts in society, our 
 community engagement activities focus on building 
financial well-being, enabling entrepreneurship, and 
supporting social belonging. Activities are organised 
through our own initiatives as well as various partner-
ships. We currently work with approximately 60 local 
and national partners. All our employees are invited to 
volunteer 16 hours a year, in person and/or online. 
~1,500
employee volunteers  
in 2025
>1.2m
 
participants in financial learning activities  
facilitated by us and our partners since 2016

===== SIDA 169 =====

Nordea Annual Report 2025 168
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S4 Consumers and end-users, cont.
Impacts, risks and opportunities overview for S4 Consumers and end-users
Impact, risk or opportunity Title 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
    
Negative impact  
(potential)
Exclusion of customers without digital literacy or internet access
   
Information-related impacts for consumers and/or end users
Positive impact  
(potential)
Access to quality information
    
Risk Data privacy    
Personal safety of consumers and/or end-users
Positive impact
(potential)
Customer protection due to customers being made aware of fraud
   
Negative impact  
(actual)
Customer exposure to fraud on our platforms and through our 
products and services
   
 Upstream  Own operations  Downstream  Short term  Medium term  Long term  Very long term
In this section
We focus on how we manage the impacts of our prod-
ucts and services on our customers, and how we miti-
gate associated risks. We summarise the related mate-
rial impacts and risks identified in our double material-
ity assessment and explain why they are relevant for 
our strategy and business model. Then we present our 
policies that apply across the identified material 
impacts and risks. 
We organise the remainder of the section according 
to material impacts and risks, which are grouped where 
relevant to reflect the interconnected nature of certain 
topics. 
We present the disclosures under the following themes:
• financial inclusion and digital accessibility challenges
• access to quality information
• data privacy
• fraud awareness and exposure to fraud.
For each theme, we explain how we are addressing the 
material impacts or risks through customer engage-
ment, remediation processes and channels for raising 
concerns, and actions. We also describe how we moni-
tor the effectiveness of our policies and actions, citing 
key figures where helpful.
Material impacts and risks and their interaction 
with strategy and business model 
Matters concerning consumers and end-users, in particu-
lar those related to customer financial well-being, are 
directly relevant for our strategy and business model. We 
view customer financial well-being as encompassing 
financial inclusion; financial safety, including protection 
against fraud; data privacy; and knowledge and skills 
regarding financial products, services, planning and 
decision-making. 
Two of the sustainability themes embedded in our busi-
ness strategy are financial well-being and inclusive and 
safe societies. What is more, we wish to establish our-
selves as a personal, accessible and inclusive adviser by 
2030. In this respect, an inclusive product and service 
offering, tools and insights supporting financial know-
ledge and skills, and fraud prevention measures are all 
important.
As a financial services provider targeting a diverse 
range of customers, we have a business model that is reli-
ant on individuals’ ability to participate in the financial 
system and access the Nordea products and services they 
need. Moreover, the nature and scale of our business 
mean that we process vast amounts of customer data. 
Failing to protect this data could entail not only risks to 
individuals’ privacy, but also operational disruption, repu-
tational damage and financial penalties. Customer finan-
cial safety is also essential as it can determine our ability 
to attract and retain customers. 
Given the relevance of financial well-being for the suc-
cess of our strategy and business model, it is vital that we 
address related material impacts and risks.
All consumers and end-users likely to be materially 
impacted by our business activities were included in the 
scope of our double materiality assessment (DMA). Those 
subject to the material impacts identified through the 
assessment are private individuals using our products and 
services, including individuals in vulnerable situations. 
These individuals are subsequently referred to as 
customers. 
To better reflect the overarching nature of financial 
well-being, in our 2025 disclosures the positive impact 
which in 2024 was referred to as “Financial well-being” is 
now referred to as “Access to quality information”. In addi-
tion, commentary on community engagement is now 
included under different material impacts in acknowledge-
ment of its relevance to multiple aspects of financial 
well-being.
Policies related to consumers and end-users
The following table provides a comprehensive overview of 
our policies related to customer well-being. Depending on 
the policy, it may be aimed at (i) supporting financial 
inclusion and/or addressing the potential exclusion of cus-
tomers without digital literacy or internet access, (ii) sup-
porting customers’ access to quality information, (iii) sup-
porting customer data privacy, (iv) increasing awareness 
of fraud among customers, (v) helping to prevent and mit-
igate the negative impacts of fraud on customers, or (vi) a 
combination of the above. Unless otherwise stated, the 
policies are available to all employees on our intranet. 
The internal rules listed in the table below form part of 
our internal rules framework, for which the Board of 
Directors is ultimately accountable. Several of the guide-
lines presented in the table below form part of our con-
duct and customer outcomes (C&CO) risk policy frame-
work, which guides our work to ensure fair treatment of 
customers, accessibility and good customer outcomes, and 
safeguard the interests of vulnerable customers.

===== SIDA 170 =====

Nordea Annual Report 2025 169
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S4 Consumers and end-users, cont.
Policy (entity) Relevance for S4 consumers and end-users Related S4 impacts, risks and opportunities Further details
Code of Conduct 
(Nordea)
• Outlines the ethical principles for conducting business at Nordea.
Requires us to: 
• encourage feedback from our customers and identify and handle complaints in a timely, fair and 
consistent manner
• reject all forms of discrimination
• be open and transparent in our communication
• respect customers’ right to data privacy.
• All • The Code is overseen by the Board of Directors. 
• Among other things, the Code sets out the general principles included in the Customer Handling Guideline (see 
below) with respect to treating customers fairly.
• The Code is available to all external stakeholders at nordea.com. 
• Read more on page 158 in “S1 Own workforce” and on page 177 in “G1 Business conduct”.
Customer Handling 
Guideline 
(Nordea)
• Governs the provision of all financial products and services offered to Nordea customers.
Requires us to:
• act honestly, fairly, professionally and in the best interests of our customers, and communicate in a 
way that is clear, fair and not misleading 
• consider customers’ vulnerability when providing products and services so we can ensure they 
receive a level of support proportionate to their needs and circumstances
• categorise customers before providing investment services to ensure they receive an appropriate 
level of investor protection
• assess the suitability of investment products before recommending them, based on information 
collected from customers, including their sustainability preferences.
• Financial inclusion
• Digital exclusion
• Access to quality information
• Data privacy
• The Guideline forms part of the policy framework overseen by the Group Accountable Executive (GAE) for conduct 
and customer outcomes (C&CO) risk – a member of the Group Leadership Team (GLT). 
• The Guideline requires us to consider the need for alternative service channels or communication formats when 
customers are unable to access or use digital channels and tools. It also covers engagement with customers in 
payment difficulty to ensure they are treated responsibly, for example in the context of debt collection.
• The Guideline covers requirements laid down in the European Union Accessibility Act (2016/2012), and the European 
Accessibility Act (2019/882), which entered into force in June 2025.
Customer Complaints 
Handling Guideline 
(Nordea)
• Provides guidance on how to manage the risk of inadequate complaint handling.
• Explains what procedures should be in place for handling complaints, and the division of 
responsibilities within the Group.
• All • The Guideline forms part of the policy framework overseen by the GAE for C&CO risk – a member of the GLT.
Guidelines on the 
Product Approval 
Process 
(Nordea)
• Set out the requirements for approving products and services so they are fit for purpose.
• Require us to identify the target market for products and services based on their complexity and 
risk profile to ensure they are offered to the right customers through the right channels.
• Financial inclusion
• Digital accessibility challenges
• The Guidelines are applicable to all products and services developed and offered by us. 
• The Guidelines form part of the policy framework overseen by the GAE for C&CO risk – a member of the GLT.
Guidelines on Product 
Reviews 
(Nordea)
• Set out requirements for reviewing products and services throughout their life cycle to ensure they 
remain appropriate for the target market and continue to meet customer needs.
• As above • As above
Non-discrimination 
procedure 
(Nordea)
• States that we are obliged not to discriminate towards customers and defines non-discrimination 
as a basic right of every customer.
• As above • Read more on page 159 in “S1 Own workforce”.
Diversity & Inclusion 
Policy 
(Nordea)
• Sets out our commitments to uphold human rights and ensure inclusivity and non-discrimination 
with regard to customers’ gender, ability variation, LGBTQ+ identity, cultural background and age.
• Describes our aspiration regarding diversity and inclusion, which includes holding an inclusive 
dialogue with customers in an environment where everyone feels welcome and respected.
• As above • The Policy is available to all external stakeholders at nordea.com.
• Read more on page 158 in “S1 Own workforce”.
Human Rights Policy 
(Nordea)
• Outlines our commitment to respect human rights in all our business activities and relationships.
• Provides information on processes to support the rights of customers, employees and other 
stakeholders in speaking up, including about potential breaches of human rights.
• All • The Policy is overseen by the Board of Directors.
• The Policy is available to all external stakeholders at nordea.com.
• Read more on page 158 in “S1 Own workforce”.
Guidelines on 
Community Engagement 
and Sponsoring 
(Nordea)
• Outline how we help improve financial well-being, drive social inclusion and enable 
entrepreneurship through sponsorships, partnerships, donations and employee volunteering.
• Financial inclusion
• Digital accessibility challenges
• The Guidelines form part of the policy framework overseen by the GAE for reputational risk – a member of the GLT.
• To ensure we are meeting the requirements and objectives outlined in the Guidelines, we follow up on our 
community engagement activities internally at least once a year.
Responsible Investment 
Product Distribution 
Policy 
(Nordea)
• Sets out the minimum responsible investment requirements for financial products distributed by 
Nordea via advice.
• Access to quality information • Read more on page 118 in “E1 Climate change”.

===== SIDA 171 =====

Nordea Annual Report 2025 170
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S4 Consumers and end-users, cont.
Policy (entity) Relevance for S4 consumers and end-users Related S4 impacts, risks and opportunities Further details
Responsible Marketing 
Policy Summary 
(Nordea)
• Sets out our commitment to ensure we market our products and services in a responsible, 
transparent and accurate way.
• Access to quality information • The Policy Summary is compiled from internal rules which form part of the policy frameworks overseen by (i) the 
GAE for reputational risk – a member of the GLT, and (ii) the GAE for ESG risk – the Chief of Staff. 
• Our minimum requirements for responsible marketing are to comply with relevant national and international laws 
and regulations and marketing standards and ensure that sustainability-related efforts are aligned with our 
Sustainability Policy. We must also adhere to the ICC Advertising and Marketing Communications Code.
• The entire Nordea Group and all marketing and communication partners are responsible for adhering to the practices 
detailed in the Policy Summary.
• The Policy Summary is available to all external stakeholders at nordea.com.
Group Protocol on Data 
Privacy Risk 
(Nordea)
• Sets the standards and requirements for our management of personal data and data privacy risks.
• Includes guidance on how to help individuals exercise their rights in relation to their data.
• Data privacy • The Protocol forms part of the policy framework overseen by the GAE for data privacy risk – a member of the GLT.
The Protocol falls under the Group Board Directive on Compliance Risk and the Group Board Directive for Group 
Compliance. It is supplemented by additional guidelines that steer how we manage data privacy risk when 
processing individuals’ data.
Group Protocol on 
Internal and External 
Fraud Risk 
(Nordea)
• Highlights the key fraud risks we are exposed to.
• Outlines the control objectives we must meet to mitigate both internal and external fraud risks.
• Elaborates on the control capabilities that support us in detecting fraud and protecting our 
customers and society against it.
• Defines appropriate fraud management governance.
• Fraud protection
• Exposure to fraud
• The Protocol forms part of the policy frameworks overseen by the Chief Risk Officer and the GAE for fraud risk – a 
member of the GLT. 
• The Protocol sets the framework for how fraud risks are defined, and outlines overall fraud management roles and 
responsibilities. 
• While the Protocol is relevant to all employees, the target audience is employees with responsibilities related to the 
management, oversight and reporting of operational risk; members of operational risk governance fora; business risk 
managers; leaders of the above-mentioned employees; and leaders at leadership levels 2 and 3.
• The Protocol is supported by associated Group internal rules.

===== SIDA 172 =====

Nordea Annual Report 2025 171
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S4 Consumers and end-users, cont.
Financial inclusion and digital 
accessibility challenges
We aim to provide services that are inclusive, intuitive and 
aligned with our ambition to make financial well-being 
more achievable for our customers. Our support should be 
fair and suited to our customers’ individual needs and 
circumstances. 
In recent years we have expanded our digital offering to 
make banking easier and more accessible, for example for 
customers in rural areas. At the same time, we have 
strengthened our focus on helping customers adapt to 
using digital services through our contact centres, physical 
premises and community engagement. In addition, we 
provide access to needed support and solutions for cus-
tomers who are unable or do not wish to use digital 
offerings.
Engagement processes
We want to support our customers in accessing our offer-
ing and provide them with the best experience possible. 
To this end, we continuously engage with them to ensure 
our services meet their needs. 
We conduct customer interviews and surveys to gather 
information on evolving needs and expectations so we can 
improve current services and define future interactions. 
Prior to releasing new digital services, we carry out user 
testing with customers to identify the most accessible and 
optimised solutions. Once a digital service is released, we 
track anonymised user behaviour and collect feedback to 
improve interactions where required.
We also conduct surveys following interactions with 
customers and use quarterly relationship surveys to under-
stand and monitor evolving needs. The responses help us 
address changing needs through improved processes and 
internal coaching and training, with actions taken at the 
country, regional and branch levels as relevant.
In accordance with requirements in the EU Accessibility 
Act, our Danish, Finnish and Swedish websites have an 
accessibility statement, which includes information on 
how customers can provide feedback on the accessibility 
of our digital services. 
We engage with vulnerable groups such as the elderly 
population through several initiatives, for example 
in- person support meetings where customers can ask us 
questions and give feedback. In all countries, we also offer 
dedicated customer service phone lines for customers with 
specific needs. For example, in Finland, Norway and 
Sweden, the Senior Line is a way for older customers who 
do not use our digital services to receive extra guidance and 
advice from specially trained advisers. In Denmark, the 
Sunflower Line offers  tail ored support to individuals with 
hidden disabilities.
We encourage customers to contact us early if they are 
facing financial distress. When we identify that a customer 
needs support, we proactively reach out to them through 
appropriate channels. Whether the initial contact is made 
by the customer or by us, it is the starting point for explor-
ing possible ways forward together.
Remediation processes and channels 
for raising concerns
We take customer complaints seriously and are committed 
to resolving them promptly and fairly. We view complaints 
as learning opportunities and input for improving the ser-
vices we provide to our customers. Customers can make a 
complaint or provide other feedback by contacting our 
dedicated customer-facing employees or using the follow-
ing channels:
• online complaint form 
• mobile banking app
• email
• dedicated complaint mechanisms through affiliated 
branches
• customer satisfaction surveys.
Our customer-focused digital channels for making com-
plaints are embedded in operational frameworks, such as 
the Customer Complaints Handling Guideline, which 
ensures their availability. We conduct employee training to 
promote the use of these channels and perform regular 
reviews to make sure they meet accessibility requirements 
and are functioning effectively. To ensure individuals can 
express their concerns without fear of consequences, we 
have confidentiality policies and safeguards against retali-
ation, described in “S1 Own workforce” on page 160.
Our complaint handling process
Our complaint handling process is designed to ensure that 
every customer feels heard. Customer complaints are reg-
istered and handled by our customer-facing employees. In 
cases where a complaint needs further investigation, for 
example if the customer is not satisfied with the decision 
of the customer service officer or adviser, we follow a clear 
escalation process. This includes obtaining a second opin-
ion from our local customer ombudsman (in Finland, 
Norway and Sweden) or customer service manager (in 
Denmark). The local customer ombudsman or customer 
service manager investigates the case and assesses 
whether the complaint has been handled correctly and 
according to good banking practice. The customer is 
informed about the possibility to submit the complaint to 
the local financial complaint board or take it to court if 
they are dissatisfied with the outcome.
Complaints tracking and analysis 
We analyse complaints to improve customer experience. 
When negative impacts are identified, the responsible 
group discusses the feedback and considers whether pro-
cesses need to be revised. We also use complaints data to 
identify recurring issues that need addressing, which helps 
us continuously fine-tune our services. By tracking com-
plaint developments and trends in the results of external 
customer satisfaction surveys (such as the annual EPSI 
survey), we can assess customers’ awareness of and satis-
faction with our complaint handling processes. Our Group 
Leadership Team and business area management regu-
larly receive complaint development reports from our 
internal customer complaint management function.
Internal controls enable us to monitor and improve our 
complaint handling process. We perform regular audits to 
help us identify areas for improvement and ensure we are 
complying with regulatory standards. We also continu-
ously train our customer-facing employees to equip them 
with the skills and knowledge needed to handle com-
plaints in a timely, consistent and effective way. 
Human rights and grievance mechanisms
Our approach to grievance mechanisms and remediation 
is guided by the UN Guiding Principles on Business and 
Human Rights and the OECD Guidelines for Multinational 
Enterprises on Responsible Business Conduct. In 2025 
there were no reported severe human rights issues or inci-
dents connected to our customers. Additionally, our Raise 
Your Concern (RYC) process did not capture any cases of 
non-respect of the UN Guiding Principles on Business and 
Human Rights, the International Labor Organization’s 
Declaration of Fundamental Principles and Rights at Work 
or the OECD Guidelines for Multinational Enterprises on 
Responsible Business Conduct connected to consumers 
and/or end-users in the downstream value chain. 
Actions and resources
We want to be a partner our customers can depend on to 
offer credit that is appropriate for their needs and to provide 
help when financial conditions change. We are mindful of the 
responsibility that comes with lending, and aim to offer credit 
that promotes long-term financial well- being and re flects 
customers’ individual situations. To support customers who 
are vulnerable as a consequence of financial difficulties, we 
have established specialised teams in each of the Nordic 
countries. For customers facing or in financial distress, our 
solutions could include temporary payment relief, a new 
repayment plan, or other adjustments depending on the cus-
tomer’s situation. In all cases, we strive to prevent and miti-
gate potential negative impacts on the customer.
As part of our work to support accessibility, we have a 
dedicated programme spanning the Nordics to support 
our implementation of the European Accessibility 
Directive. Through this initiative, we have improved the 
accessibility of our banking services across our webpages, 
digital platforms and products. While some gaps remain, 
we are actively working to address them.
In Denmark, Finland and Sweden, we give out our 
annual Abilitypreneur award to commend an entrepreneur, 
association or company that supports people’s differences 
and abilities through their business concept. In this way, we 
seek to contribute to more inclusive workplaces and socie-
ties. In Denmark, we also participate in the Sunflower initi-
ative, which focuses on inclusion and accessibility for peo-
ple – both customers and employees – with hidden ability 
variations. By using the Sunflower lanyard, customers can 
signal a need for extra time, patience or support.

===== SIDA 173 =====

Nordea Annual Report 2025 172
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S4 Consumers and end-users, cont.
Ac
tions supporting financial inclusion in 2025 included:
• launching an awareness e-learning for customer-facing 
staff on supporting customers in financial distress to 
complement our existing training in this area
• expanding the Senior Line to Sweden, following pre-
vious launches of the service in Finland and Norway. 
  Related community engagement 
actions in 2025
• Piloting peer-guided sessions at our branches 
in Finland to support senior citizens in managing 
their personal finances and improving their 
digital skills.
• Continuing our mentoring programme in Poland 
to support women from, for example, Ukraine 
and Poland in developing financial skills and 
empower them to return to professional activity 
after a break from work. In 2025 the number of 
Nordea mentors and attending mentees doubled 
compared with 2024.
Monitoring the effectiveness of policies and actions
While we have not published formal targets related to 
financial inclusion, we internally track the effectiveness of 
related policies and actions. We are also in the process of 
investigating relevant metrics that could be used to drive 
and measure the impact and progress of our financial 
well-being work, which includes financial inclusion.
Customer satisfaction is a key measure we use to assess 
customer experience. Our internal surveys indicate contin-
uous improvements in customer satisfaction. External 
benchmark surveys confirm our high rankings among 
large corporate and private banking customers (Prospera), 
while our rankings among personal and corporate custom-
ers (EPSI) remain competitive. 
Access to quality information
We are committed to ensuring that information related to 
our products and services is clear and accessible and 
meets regulatory requirements. We also aim to provide 
customers with high-quality and relevant advice, and 
ensure fair and responsible marketing practices. 
Engagement processes
We engage with our customers to support their access to 
quality information in various ways. These include daily 
interactions in our branches and on our digital platforms, 
as well as targeted events such as live webinars on topics 
including savings and personal finances. We want every-
one to be able to understand – and benefit from – the 
information and advice we provide.
We consult customers when developing updates to 
information about our product offering so we can take 
their input into account in the revised version. Once the 
new product information has gone live, we monitor how it 
is being received by customers and, when necessary, make 
adjustments to make it clearer and more accessible.
Our advisers engage with customers through different 
channels, for example our digital platforms and online meet-
ings, to offer holistic (for example, portfolio level) and 
focused (for example, product level) advice depending on 
their needs. In addition to our human advisers, we have 
robo-adviser channels available in all the Nordic countries 
for customers who wish to receive advice online. Each chan-
nel has built-in quality controls and is programmed to sup-
port the advisory process, based on local requirements 
where relevant.
Before providing investment advice, we engage with 
customers to obtain the information we need to be able to 
recommend suitable products. We conduct suitability 
assessments in accordance with applicable regulations, for 
example the Markets in Financial Instruments Directive 
and the Insurance Distribution Directive for insurance- 
based investment products. We also seek to capture cus-
tomers’ sustainability preferences. To this end, we ask 
them how important it is for them that their investments 
(i) contribute positively to the environment and society 
and (ii) help reduce negative impacts on the environment 
and society. We then assess their preferences and assign 
them a sustainability profile so we can recommend a suit-
able investment solution. 
Remediation processes and channels 
for raising concerns
See “Remediation processes and channels for raising 
 concerns” on page 171.
Actions and resources
To ensure our advisers have the knowledge and compe-
tence necessary to be able to provide high-quality invest-
ment advice to customers, we conduct training on sustain-
ability topics in all the Nordic countries. We also focus on 
providing our customers with digital tools to help them 
visualise their financial situation and support better finan-
cial decision-making. In our digital channels, we continue 
to develop the sustainability information available for 
funds to enable self-service customers to make informed 
decisions.
For customers with a preference for sustainability, we 
offer a suite of products with enhanced sustainability cri-
teria, labelled Nordea Sustainable Selection (NSS), to 
make it easier for them to navigate sustainability-focused 
investment products. Customers can access a summary of 
the requirements for NSS at nordea.com. See “General 
information” on page 84 for more information about NSS 
products.
Actions supporting access to quality information in 2025 
included the following.
• Launching an e-learning series on sustainability in the 
investment advice context, which is available to advisers 
in all Nordic countries in all four Nordic languages and 
English.
• Launching a new Financial Health Check feature in the 
mobile banking app in all Nordic markets. By answering 
a few questions, customers can receive suggestions on 
how to improve their financial situation. Going forward, 
we plan to develop the feature further, focusing on more 
personalised omnichannel experiences. 
• Partnering with Gimi, a pocket money app designed to 
support financial literacy by teaching children and 
young people about finances through interactive learn-
ing. Our customers in Norway and Sweden can now con-
nect the app to their Nordea accounts and access addi-
tional features, such as educational material and savings 
goals. We plan to expand this partnership to Denmark 
and Finland in the coming year.
During 2025
399,000
assessments were made of customer  
sustainability preferences
41%
of these saw advised customers  
express a sustainability preference

===== SIDA 174 =====

Nordea Annual Report 2025 173
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S4 Consumers and end-users, cont.
  Related community engagement 
actions in 2025
• Participating in the Finnish government’s national 
financial literacy strategy taskforces, which aim to 
make Finland a world leader in financial literacy 
by 2030.
• Continuing our collaboration with Large Ice Cream 
Company in Norway, which provides nearly 1000 
summer jobs across the country for young people 
between the ages of 13 and 17. Nordea volunteers 
provided financial skills training for the young sum-
mer employees.
• Continuing training together with Mattecentrum and 
through our own maths challenge (Matteutmanin-
gen) programme in Sweden, addressing the strong 
link between maths and financial skills. We ran an 
after-school programme with Mattecentrum to help 
300 students between the ages of 14 and 19 sharpen 
their skills ahead of national maths tests.
• Attending the EuroSkills competitive event in Den-
mark, the biggest vocational education and skills 
excellence event in Europe. 100,000 young people 
from different parts of Europe competed, and 
Nordea volunteers had the opportunity to discuss 
dreams and entrepreneurship with attendees.
Monitoring the effectiveness of policies and actions
While we have not published formal targets related to 
access to quality information, we internally monitor the 
effectiveness of related policies and actions. For example, 
we have established a control framework to monitor the 
quality of our investment advice in each business area and 
country. We follow up on the results of this monitoring 
each quarter to identify actions and/or areas for improve-
ment. Product distribution is also followed up via target 
market monitoring and internal reviews.
Data privacy
We are committed to protecting our customers’ privacy 
and personal data and managing risks to support individu-
als’ data privacy rights. 
Engagement processes
We have a customer-centric approach to data privacy and 
enable customers to control their personal data through 
the exercise of their individual rights. These include the 
right to access the personal data we process when provid-
ing them with products and services. 
We inform our customers about their rights when we 
communicate privacy information to them as part of the 
product/service onboarding process. Our Privacy Policy is 
available on our website, and in our online bank and 
mobile app. 
Customers can manage their privacy preferences online. 
For example, they can specify the data they consent to us 
collecting for the purposes of providing them with rele-
vant offers, personal advice and services online.
Remediation processes and channels 
for raising concerns
We have implemented appropriate measures, processes 
and tools to identify personal data breaches as soon as 
they have occurred so we can inform the supervisory 
authority and the customer without undue delay, as 
required. See also “Remediation processes and channels 
for raising concerns” on page 171.
Actions and resources
We are committed to continuously improving our data pri-
vacy governance framework. Data protection officers and 
a separate Group Data Protection Office unit establish the 
compliance framework governing data privacy and advise 
on, monitor and report on data privacy. Our privacy poli-
cies are reviewed annually to ensure they provide up-to-
date information on how personal data is used. 
Actions supporting customer data privacy in 2025 
included:
• updating our Group Protocol on Data Privacy Risk and 
continuing to strengthen our policy framework through 
the creation of new guidelines
• optimising our processes to ensure customers can easily 
access their personal data and exercise their data pri-
vacy rights.
Monitoring the effectiveness of policies and actions
While we have not published formal targets related to 
data privacy, we use several metrics to monitor the effec-
tiveness of related policies and actions. These metrics 
include the percentage of our workforce that has com-
pleted mandatory training; the number of complaints 
made concerning breaches of customer privacy and losses 
of customer data; the number of internal privacy experts 
engaged in personal data protection matters; whistle-
blower cases concerning severe personal data breaches; 
and legal actions concerning personal data breaches.
Fraud awareness and exposure to fraud
We are committed to continuously working to protect our 
customers, employees and society against fraud risks. We 
recognise that our platforms could be used to defraud our 
customers, and focus on both preventive and detective 
measures to keep them safe.
Engagement processes
We proactively engage with our customers and other 
stakeholders to promote fraud awareness in wider society. 
Engagement happens on a daily basis through several dif-
ferent channels, including but not limited to:
• our own websites
• our social media channels
• Nordea Netbank and authentication solutions used by 
customers
• online advertising, including social media advertising
• podcasts
• print advertising and outdoor advertising
• physical customer letters
• online events
• in-person events
• one-to-one customer meetings
• internal awareness activities for our employees.
We tailor fraud awareness content to specific target 
groups that may be more vulnerable to fraud and choose 
appropriate channels. For example, we send physical let-
ters to customers without access to digital tools. We also 
send direct messages through digital channels and run 
larger campaigns through multiple channels.
Before implementing any new fraud prevention tech-
nologies or processes, we assess the impact on customers. 
Our various customer segments have distinct fraud pre-
vention needs. We gather feedback from relevant stake-
holders through various channels to capture the perspec-
tives and needs of our customers, and adapt our fraud 
prevention approaches accordingly. Here, key data 
includes customer claims regarding missed fraud cases 
and customer interactions during monitoring and alert 
handling.
Remediation processes and channels 
for raising concerns
Our fraud resolution process is designed to provide cus-
tomers with a fair and timely resolution of their fraud 
claims, while ensuring compliance with local legislation 
and case law. The process involves reviewing fraud claims 
according to defined procedures, assigning liability for 
fraud losses, and performing actions to reimburse custom-
ers who are entitled to a reimbursement. 
We have dedicated fraud claim handling teams in all the 
Nordic countries. Any customer who has become a victim 
of fraud is considered to be in a vulnerable situation and 
anyone who has experienced fraud must be paid particular 
care and attention. With this in mind, we focus on timely 
handling, clear communication and support for the cus-
tomer throughout the claim handling process. The inten-
tion is for customers to receive equal treatment regardless 
of age, nationality, customer segment or other factors.
All claims are handled in accordance with our 
Guidelines on reimbursement of fraud claims, as well as 
applicable local reimbursement rules. Customers are 
always informed of grievance mechanisms related to reim-
bursements in the decision. More information on grievance 
mechanisms can be found on page 171.

===== SIDA 175 =====

Nordea Annual Report 2025 174
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
S4 Consumers and end-users, cont.
Actions and resources
We are continuously developing our capabilities to miti-
gate, to the extent possible, the risk that our platforms are 
used to defraud our customers. Actions include making 
improvements to authentication solutions and introducing 
additional appropriate product limitations and transaction 
limits. We are also improving our detection capabilities. 
For example, we have introduced real-time detection of 
unauthorised and authorised fraudulent transactions and 
deviations in customer behaviour, and detection of mal-
ware on customers’ devices. 
Combating fraud requires collaboration between banks, 
authorities such as the police, and various industry sectors. 
We engage in collaborations in all our operating countries 
to gather intelligence, share insights regarding fraud 
trends, and identify specific actions to take. These collabo-
rations include the countries’ banking associations.
In 2025 we conducted around 340 different customer 
awareness activities, some of which were national cam-
paigns with a reach that extended beyond our customers. 
We also raised awareness among our employees.
Actions supporting fraud awareness and prevention in 
2025 included:
• introducing a new mandatory e-learning to increase 
employee knowledge and competence regarding 
 internal and external fraud
• organising meetings and seminars with customers in 40 
branches in Denmark during a “Fraud Week” in June.
  Related community engagement 
actions in 2025
• Running our “Hard to fool” (Svårlurad) campaign 
in Sweden for the third consecutive year (in both 
the spring and the autumn).
• Continuing with financial crime prevention educa-
tion in Estonia for different age groups to share 
knowledge about how to prevent fraud. We con-
ducted 61 lessons in 47 schools and held several 
sessions for adults. 
The actions we take to detect, prevent and address 
fraud are all part of our fraud management life cycle:
Awareness
Authentication
Product
features
Detection
Aftercare
Intelligence
Nordea
Fraud Management 
Life Cycle
Intelligence and awareness 
We gather intelligence on fraud trends and tactics, and 
use the insights gained to help design our fraud aware-
ness initiatives. These include customer letters, media 
and events, and educational campaigns run either inde-
pendently or in collaboration with external partners. 
Authentication and product features
Our authentication solutions are key to securing the 
online services we offer. We also apply and maintain 
product features, for example transaction limits, to help 
make our products safer.
Detection
We detect fraud using solutions that help us identify 
and interrupt suspected fraudulent transactions and 
activities. Accurate data is key for fraud detection as it 
helps us secure a high detection rate while minimising 
friction for our customers. 
Our fraud monitoring and investigation processes 
involve manually handling and reviewing alerts and 
cases originating from automated fraud detection and 
other sources and taking reasonable steps to recover 
funds. When investigating a fraud case, we assess the 
customer’s information and evaluate the incident to 
understand the full context, why the alert was trig-
gered, and the underlying circumstances and details of 
the incident.
Aftercare
We have a remediation process in place for when 
actual fraud cases materialise, described in more detail 
under “Remediation processes and channels for raising 
concerns” on page 173.
Monitoring the effectiveness of policies and actions
While we have not published formal targets related to 
fraud, we monitor the effectiveness of policies and actions 
internally to ensure our fraud prevention and detection 
measures are appropriate and to support the development 
of fraud awareness activities. Regular fraud risk assess-
ments help us identify the threats to which we and our 
customers are exposed, learn about our strengths and 
weaknesses, and identify potential actions for 
improvement. 
In addition, internal reporting on fraud activity levels is 
provided each month to relevant senior managers, risk 
managers and other relevant stakeholders. The reporting 
helps us track our overall fraud risk exposure and the per-
formance of our fraud management processes, and sup-
ports us in taking relevant mitigating actions when 
needed. Internal and external fraud risk is also included in 
our Group Risk Report, which is shared with the Group 
Leadership Team, the Board Risk Committee and the 
Group Board of Directors. The Report provides information 
on our overall risk picture and on mitigating actions and 
key developments regarding risks in breach of the 
approved risk appetite limit.

===== SIDA 176 =====

Nordea Annual Report 2025 175
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
GOVERNANCE INFORMATION
G1 Business conduct 
We earn our stakeholders’ trust through high ethical standards, 
strong corporate governance, regulatory compliance and effective 
risk management, means by which we also contribute to the safety, 
resilience and inclusivity of the societies in which we live. 
Our stakeholders expect us to have a sustainable business 
model, generate stable and positive financial results over 
time, and be a responsible financial services provider, man-
aging cyber threats and financial crime risks while respect-
ing human rights. Amid the geopolitical tensions and rapid 
technological development we are seeing today, meeting 
these expectations has taken on a new urgency. 
We have invested significantly in our financial crime pre-
vention and cybersecurity capabilities in recent years – and 
will continue to make targeted investments to adapt to 
emerging risks and safeguard our customers and wider 
 society. We currently have thousands of employees working 
solely on combatting money laundering, sanctions evasion, 
terrorist financing and fraud.
Safe and resilient societies also rely on a stable financial 
system. We contribute to financial stability by conducting 
business to high ethical standards, managing risks compe-
tently, and maintaining a well-diversified business model 
and solid levels of capital and liquidity.
Ethical and professional business conduct is part of our 
corporate culture and is driven by our tone from the top and 
corporate governance. Strong corporate governance 
involves having clear and systematic decision-making pro-
cesses, defining clear responsibilities, avoiding conflicts of 
interest, and ensuring satisfactory internal control, risk 
manage ment, transparency and accountability.
All employees and other members of our workforce are 
required to undertake annual training to ensure proper 
awareness and knowledge of our ethical principles – 
enshrined in our Code of Conduct. We also continuously 
train our employees to ensure they have the competencies 
necessary to follow and act in accordance with laws, regula-
tions and market standards as reflected in our internal rules. 
Going forward, we will continue to support safe and 
inclusive societies by embedding human rights due diligence 
into our culture and governance so we can proactively miti-
gate and address potential harmful activities. We will also 
maintain constructive dialogue with employees, customers 
and partners to identify opportunities for positive change.
“ We contribute to financial stability 
by conducting business to high 
ethical standards and managing 
risks competently.”
Three lines of defence
We manage risks, including those related to business 
conduct, through our three lines of defence model. The 
first line of defence is responsible for managing risks and 
complying with applicable rules in the course of day-to-
day business. The second line of defence maintains 
and monitors the implementation of our risk 
management and compliance risk management 
frameworks. The third line of defence provides 
independent assurance and advice related to 
our internal control framework.
1st
Daily risk management,  
operations and development
2nd
Monitoring  
and reporting
3rd
Internal 
audit

===== SIDA 177 =====

Nordea Annual Report 2025 176
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
G1 Business conduct, cont.
Impacts, risks and opportunities overview for G1 Business conduct
Impact, risk or opportunity Title Value chain Time horizon
Corporate culture
Positive impact
(potential)
Good corporate conduct
    
Risk Compliance risk related to remuneration    
Corruption and bribery
Risk Corruption and bribery    
Financial crime and fraud prevention (entity-specific)
Negative impact
(potential)
Criminals using products and services to facilitate  
criminal activities
    
Risk Financial crime    
Risk Fraud    
Cybersecurity (entity-specific)
Risk Cybersecurity    
 Upstream  Own oper ations  Downstream  Shor t term  Medium t erm  L ong term  V ery long term
In this section
We look at the potential impacts of our business con-
duct, and how our business conduct influences risks 
and opportunities for us. We start by explaining why 
matters concerning business conduct are relevant for 
our strategy and business model. Then we summarise 
the material impacts, risks and opportunities related to 
business conduct identified in our double materiality 
assessment, including those related to entity-specific 
topics, for example financial crime prevention and 
cybersecurity. We explain how we are addressing these 
impacts, risks and opportunities through our policies 
and actions. We also describe how we monitor the 
effectiveness of our business conduct, financial crime 
prevention practices and cybersecurity. 
Material impacts, risks and opportunities and their 
interaction with strategy and business model
Matters concerning business conduct are directly relevant 
for our strategy and business model.
Good business conduct – compliance with applicable 
regulations and standards; ethical business practices; and 
strong corporate governance – contributes to inclusive 
and safe societies, one of the sustainability themes 
embedded in our business strategy. Our ambition under 
this theme is to be well established as a responsible finan-
cial services provider supporting human rights by 2030. 
Ethical and responsible business conduct will be key to 
achieving this.
As a financial services group, we have a business model 
that is reliant on our ability to attract and retain customers, 
investors and employees, and mitigate both financial and 
non-financial risks. Preserving this ability requires us to 
pay continuous attention to ethics, corporate governance, 
regulatory compliance and risk management.
Given the relevance of good business conduct for the 
success of our strategy and business model, it is vital that 
we address business conduct-related material impacts, 
risks and opportunities.
Policies related to business conduct 
The table below provides a comprehensive overview of 
our policies related to business conduct. 
Our policies, procedures and controls designed to 
strengthen our financial crime prevention programme – 
which provides a uniform set of risk management princi-
ples and mandatory standards for our organisation – are 
continuously evaluated and updated to ensure adequate 
defences against financial crime. Relevant financial crime 
policy statements are available to external stakeholders at 
nordea.com. 
Our information security policies, which include cyber-
security, are integrated into our daily security practices and 
are aligned with our strategic goals. We regularly review 
and improve our cybersecurity policies and procedures to 
ensure strong protection across the organisation. 
Information security instructions and guidelines are inte-
grated into our change and incident management pro-
cesses, ensuring we always consider security when making 
changes to systems, processes or technologies, or when 
handling security incidents. 
The internal rules listed in the table below form part of 
our internal rules framework, for which the Board of 
Directors is ultimately accountable.
Unless otherwise stated, the policies are available to all 
employees on our intranet.

===== SIDA 178 =====

Nordea Annual Report 2025 177
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
G1 Business conduct, cont.
Policy (entity) Relevance for G1 Business conduct Related G1 impacts, risks and opportunities Further details
Code of Conduct 
(Nordea)
• Outlines the ethical principles for conducting business at Nordea.
• Addresses care for the environment; human rights; labour rights; the right to privacy; fair 
competition; and bribery and corruption, among other things.
• Sets out general principles, while our internal rules provide specific guidance and advice.
• All • The Code is overseen by the Board of Directors.
• The Code is based on relevant legal requirements and internationally agreed standards, primarily the Ten Principles 
of the UN Global Compact. 
• Compliance with different sections of the Code is regularly monitored by the respective responsible functions and 
by Group Compliance. Each year, a Code of Conduct report is prepared and provided to the Sustainability and Ethics 
Committee, the Risk Committee, the Group Leadership Team, the Board Risk Committee and the Board of Directors, 
informing them about how well we are adhering to the Code and providing them with insights into our Group risk 
culture.
• We maintain internal versions of the Code in English and in all four Nordic languages. The Code is available to all 
external stakeholders at nordea.com.
• Read more on page 158 in “S1 Own workforce” and page 169 in “S4 Consumers and end-users”.
Supplier Code of 
Conduct
(Nordea)
• Sets expectations regarding the social, ethical and environmental business practices of our 
suppliers. 
• Requires our suppliers to comply with this Code even if it sets a higher standard than required by 
national laws or regulations.
• All except compliance risk related to 
remuneration 
• 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 Code is available to all external stakeholders at nordea.com.
• Read more on page 118 in “E1 Climate change”.
Group Board Directive on 
Financial Crime Risk 
Management
(Nordea)
• Requires us to perform risk-sensitive financial crime prevention controls.
• Describes the commitment of the Group Leadership Team and the Group Board of Directors to 
prevent financial crime.
• Sets out the high-level principles which form the basis for our risk management measures aimed 
at preventing financial crime.
• Defines the financial crime prevention roles and responsibilities and the requirements for 
managing financial crime risks within our organisation.
• Criminals using products and services 
to facilitate criminal activities
• Financial crime
• The Directive is overseen by the Board of Directors.
• In designing the Directive, we considered compliance with regulatory requirements and effective prevention of 
financial crime for the benefit of wider society without unduly limiting or restricting customers’ access to banking 
services.
Group Board Directive on 
Risk
(Nordea)
• Describes the commitment of our leadership to manage risks.
• Outlines the principles, roles and processes for identifying, assessing, responding to, monitoring 
and reporting risks across the organisation.
• Forms the basis for our risk management measures, including information security measures.
• All • The Directive is overseen by the Board of Directors.
Remuneration Policy
(Nordea) 
• Describes the controls we must have in place to increase the effectiveness of the Board’s work 
related to remuneration.
• Defines the rules, governance, roles and responsibilities related to remuneration.
• Compliance risk related to 
remuneration
• The Policy is overseen by the Board of Directors and is referred to internally as the Group Board Directive on 
Remuneration.
• The Policy is based on relevant legal requirements.
• The Policy sets the framework for how remuneration risk is defined and outlines overall roles and reponsibilities.
• Read more on page 159 in “S1 Own workforce”. 
Group Protocol – 
Internal and External 
Fraud Risk 
(Nordea)
• Highlights the key fraud risks to which we are exposed and the control objectives we must meet 
to mitigate them.
• Describes the requirements related to the controls we must have in place to detect and prevent 
both internal and external fraud.
• Defines appropriate fraud management governance.
• Fraud • The Protocol forms part of the policy framework overseen by the Chief Risk Officer (CRO) and the Group 
Accountable Executive (GAE) for fraud risk – a member of the Group Leadership Team.
• Read more on page 170 in ”S4 consumer and end-users”.
Group Protocol – 
Information Security 
(Nordea)
• Outlines the implementation of our information security risk framework.
• Defines the rules, governance, roles and responsibilities for the management of information 
security risk within the Group.
• Cybersecurity • The Protocol forms part of the policy framework overseen by the CRO and the GAE for information security  
– a member of the Group Leadership Team.
• The objective of the Protocol is to preserve the confidentiality, integrity and availability of our business services and 
processes, information and information systems.
• The internal version of the Protocol is available to all internal stakeholders on our intranet.
Group CEO Instructions 
on Raising Your Concern 
(RYC) 
(Nordea) 
• Outline the rights, responsibilities and protection of individuals when they raise a concern. 
• Describe the responsibilities, rules and procedures for the RYC unit when handling such cases. 
• All • The Instructions are overseen by the Group CEO.
• Read more on page 159 in “S1 Own workforce”.

===== SIDA 179 =====

Nordea Annual Report 2025 178
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
G1 Business conduct, cont.
Corporate culture
As a financial services group, we are in the business of 
trust. We always strive to conduct business to high ethical 
and professional standards, driven by our strong tone from 
the top and corporate governance. Our culture finds 
expression in our values: collaboration, ownership, passion 
and courage. Everyone at Nordea should work together 
for the benefit of all stakeholders, take responsibility for 
their conduct, act in the best interests of our customers, 
and dare to do what is right. 
Channels for raising concerns
Our whistleblowing function, Raise Your Concern (RYC), 
ensures that all internal and external stakeholders can 
safely exercise their right to speak up if they have con-
cerns about suspected misconduct. This may include 
breaches of human rights or fraudulent, inappropriate, dis-
honest, illegal or negligent behaviour in connection with 
our operations, products or services – including violations 
of laws, regulations or internal policies, instructions or 
guidelines. Concerns can be raised verbally or in writing in 
all the countries in which we operate. 
We treat all reporting with the strictest confidentiality 
to ensure that whistleblowers are adequately protected in 
accordance with our obligations under Directive (EU) 
2019/1937. It is also possible to report anonymously via 
WhistleB, an electronic reporting channel. This platform, 
managed by an external party, is entirely separate from 
our IT systems and does not track IP addresses or other 
data that could be used to identify the message sender.
All reporting is handled by our RYC team, which is an 
independent and autonomous unit within Group 
Compliance. This ensures that our investigators are sepa-
rated from the chain of management that could be 
involved in a specific matter. Our RYC procedures also dic-
tate how investigations should be monitored and finalised 
to ensure timeliness. 
Cases reported through RYC help us monitor compli-
ance with our Code of Conduct. We report key case trends 
and statistics on a no-name basis to our Chief Compliance 
Officer, Chief People Officer and Chief Risk Officer, and 
include them in management reports and reports to the 
Board of Directors. Our RYC process and investigations are 
subject to regular quality controls, and we have defined 
escalation procedures in place should any process devia-
tions be identified. In 2025 we reviewed the effectiveness 
of our RYC procedure regarding human rights grievances 
and identified areas for improvement. 
More information on RYC can be found on page 160 in 
“S1 Own workforce”. 
Training
Our Board of Directors and senior management receive 
dedicated training in ESG topics to ensure they are suffi-
ciently competent in sustainability matters, including busi-
ness conduct matters. This includes periodic specialised 
financial crime training, which encompasses bribery and 
corruption. More information on the knowledge, skills and 
expertise of the Board of Directors and senior manage-
ment can be found in “General information” on pages 
88–89. 
All employees and other members of the workforce, 
including part-time employees and consultants, are required 
to undertake annual mandatory Code of Conduct training to 
ensure proper awareness and knowledge of our ethical prin-
ciples. The training includes information on the Code and 
real-life scenarios showing how individuals can apply the 
ethical principles in their everyday work and decision-mak-
ing. The 2025 course focused in particular on topics such as 
data privacy, social media guidelines, personal account deal-
ing, incident management, and how to raise concerns. 
In addition to the Code of Conduct training, all our 
employees must complete other mandatory risk and compli-
ance training courses as part of obtaining and renewing their 
“licence to work”. In 2025 these courses were as follows.
• Anti-fraud – Foundations, new training which focuses 
on increasing knowledge and competence regarding 
internal and external fraud, and making employees 
aware of the most common fraud threats they may face 
both inside and outside the organisation.
• Financial crime, which focuses on how to manage finan-
cial crime risks in daily work and across the Group in line 
with our risk appetite and compliance culture. The course 
covers money laundering, terrorist financing, tax evasion, 
bribery and corruption, and sanctions. Where bribery and 
corruption are concerned, the course outlines key con-
cepts, our potential exposure, our prevention programme, 
and requirements placed on all employees. It also pro-
vides references to additional information as well as 
information about whistleblowing and employees’ rights 
and responsibility to use our RYC function.
• Information security essentials, which is aimed at giv-
ing our employees an overall understanding of impor-
tant topics within the area of information security, 
including cybersecurity. 
• We are all risk managers, which enables employees to 
learn about our approach to risk management. 
While we have not published formal targets related to 
training, we monitor completion rates as a means to track 
effectiveness.
2025 course completion rates (%)
Courses for all employees 2025 2024
Code of Conduct 98.1 97.4
Anti-fraud – Foundations (New) 97.3 –
Financial crime 98.1 97.2
Information security essentials 98.4 97.3
We are all risk managers 98.4 97.5
As a supplement to the general Group-wide training, 
extensive specialised training programmes are conducted 
for all employees with financial crime prevention responsi-
bilities, according to their roles and responsibilities.

===== SIDA 180 =====

Nordea Annual Report 2025 179
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
G1 Business conduct, cont.
Moreover, identified “functions at risk” are provided 
with further in-depth anti-bribery and corruption training 
tailored to their risk profiles. Functions qualify as at risk 
based on whether they have:
• a high degree of customer, supplier or public official 
interaction
• a senior leadership role
• a supporting role in corporate events
• responsibility for talent attraction and reward
• a certain control function or a role in another niche group 
with unique exposure. 
Geography is not considered a deciding factor. Of the 
functions at risk that were provided with further in-depth 
anti-bribery and corruption training in 2025, 96.4% com-
pleted the training (97.4% in 2024). This corresponds to 
18.6% of our total workforce (4.1% in 2024).
Mitigation of remuneration risk
Remuneration risk is the risk that applicable laws, regula-
tions or internal rules relating to remuneration are 
breached. The risk primarily arises when the relevant reg-
ulatory requirements are not implemented adequately. 
Remuneration risk is considered to be subject to the risk 
appetite defined for operational risks. The regulatory 
requirements relating to remuneration cover both fixed 
and variable remuneration, with the majority relating to 
variable remuneration. Most of the requirements stem 
from European Union regulations. At Nordea, they are 
integrated in our internal rules, systems and processes. 
Actions and resources related to the 
mitigation of remuneration risk 
We assess remuneration risks on an ongoing basis within 
the framework of our Risk Committee. Our Risk and 
Remuneration Alignment Committee (RRAC) supports 
remuneration risk management by governing and over-
seeing risk-adjusted remuneration assessments of the rel-
evant employees eligible for significant variable remuner-
ation in the first line of defence. The RRAC’s work is 
intended to strengthen personal accountability and 
develop a consistent approach to risk-adjusted remunera-
tion assessments through a fair and transparent process 
based on clear criteria. 
Variable remuneration awarded under our main varia-
ble remuneration plans is based on an assessment of the 
results of the Nordea Group, the relevant Nordea entity, 
the relevant business unit and the individual employee. 
Awards may be reduced, in part or in full, if the eligible 
employee has, for example, violated internal or external 
regulations or participated in an action leading to signifi-
cant losses for Nordea. Awards may also be reduced in the 
event of a significant decrease in the financial results of 
the Nordea Group or the relevant business unit.
The ESG targets included in variable pay plans derive 
from our externally communicated Group-level sustaina-
bility targets. The Group-level targets, and regularly 
updated status information, can be viewed by all external 
stakeholders at nordea.com.
We employ an external consultancy firm specialising in 
the implementation of long-term incentive plans in listed 
companies to support us in preparing our proposed Long 
Term Incentive Plan structure. This includes the targets 
ultimately approved by the Board of Directors. An external 
provider thus reviews the proposed metrics but does not 
evaluate performance against them.
Monitoring the effectiveness of policies and actions
While we have not published formal targets related to 
remuneration risk mitigation, we have integrated it into 
our remuneration risk framework by including risk, compli-
ance and conduct goals directly in short-term variable pay 
plans as well as indirectly in the terms and conditions of 
the long-term variable pay plan.
Prevention and detection of corruption and bribery
At Nordea, we recognise the corrosive effect that bribery 
and corruption have on society, and are committed to pre-
venting and detecting them. We do so by adhering to all 
applicable laws and regulations and following our 
anti-bribery and corruption (ABC) programme, which is 
outlined below.
Actions and resources related to the prevention 
and detection of corruption and bribery
We have a Group-wide ABC programme, covering all 
employees, which outlines how we prevent, detect and 
correct matters related to bribery and corruption. Key fea-
tures of the programme include a clear tone from the top; 
a zero tolerance policy; a Group Accountable Executive for 
“anti-bribery and corruption”, who is a member of the 
Group Leadership Team; an extensive suite of internal poli-
cies and procedures, including with respect to third parties 
such as suppliers and intermediaries, and gifts and hospi-
tality; training programmes; a dedicated advisory function; 
and regular management reporting. 
Our annual Financial Crime Enterprise Risk Assessment is 
key to helping us address bribery and corruption risk. Here, 
Group Compliance assesses the financial crime risks to 
which we are exposed in a manner commensurate with our 
size, complexity, business operations and global presence. 
The results help us better understand our financial crime 
risk profile and implement adequate policies, procedures 
and controls to mitigate and manage the identified risks. 
Suspected bribery and corruption can be reported using 
our Raise Your Concern function, described above on page 
178.
Monitoring the effectiveness of policies and actions
While we have not published formal targets related to the 
prevention and detection of corruption and bribery, we 
have a dedicated testing and monitoring function in Group 
Compliance, which supports and delivers various compo-
nents of the Group Compliance risk management frame-
work. This includes assessing risks, testing and monitoring 
processes and controls, and supporting the development 
of risk indicators and active risk management in the first 
line of defence. 
Financial crime prevention
Countries across the world are facing rising economic and 
social costs due to human trafficking, terrorism, corruption, 
drug smuggling, tax evasion and other forms of illegal 
activity. At Nordea, we take our responsibility towards our 
customers and society seriously. We are committed to 
complying with all applicable regulation related to finan-
cial crime prevention and have built strong defences to 
prevent our products and services from being used for 
unlawful purposes. 
Actions and resources related to 
financial crime prevention 
We are continuously developing and maintaining tools to 
manage financial crime risk, understand and monitor our 
customer relationships and behaviour, monitor suspicious 
activity and report to relevant authorities when red lines 
are crossed. 
Our annual Financial Crime Enterprise Risk Assessment 
helps us identify and assess the financial crime risks to 
which we are exposed. To ensure effective financial crime 
risk management and controls, we have clearly defined 
roles and responsibilities. Our customer-facing employees 
and financial crime domain expert units carry out daily risk 
management activities based on our policies, instructions 
and guidelines related to financial crime prevention. They 
also develop and maintain the controls required to carry 
out effective financial crime risk management. 
We have over 3,400 employees working on combatting 
money laundering, sanctions evasion, terrorist financing 
and fraud within our financial crime expertise domains: 
know your customer, transaction monitoring, sanctions, 
and fraud prevention. 
Our know your customer (KYC) framework ensures we 
know the customers with whom we have established a 
business relationship, what types of customers they are, 
the risk of conducting business with them, the nature of 
their business, their sources of wealth and funds, and the 
purpose of their transactions. A robust KYC process is key 
to securing strong anti-money laundering and counter ter-
rorist financing capabilities. Our KYC functions enable us 
not only to know our customers but also – importantly – 
to provide them with products and services in a way that 
is safe, compliant and cost-effective, while delivering a 
good customer experience.

===== SIDA 181 =====

Nordea Annual Report 2025 180
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
G1 Business conduct, cont.
We have several million customers and, as such, handle 
billions of transactions every year. Our Transaction 
Monitoring function is tasked with detecting money laun-
dering, terrorist financing and tax evasion through ongo-
ing customer activity monitoring on behalf of our business 
units. In 2025 3.6 billion transactions were monitored. Any 
suspicious activity, transactions and/or behaviour identi-
fied will trigger internal alerts, potentially followed by 
investigations and ultimate reporting to the authorities. 
Sanctions are foreign policy tools aimed at changing 
behaviour by putting pressure on political decision-mak-
ers, increasing the cost of doing business or restricting 
business completely. They can be a response to threats to 
international peace and security; violations of human 
rights; acts of genocide; or the proliferation of weapons of 
mass destruction. They can also be a means to promote 
democratic principles. We are responsible for ensuring 
that we do not violate relevant sanctions laws and regula-
tions and that our products and services are not, know-
ingly or inadvertently, used in violation of these laws and 
regulations. As such, we adhere to the EU, UN, UK and US 
sanctions regimes, including sanctions programmes 
related to Russia, on a Group-wide basis. We have also 
adopted internal guidelines to address risks stemming 
from specific geographic areas, such as Afghanistan, 
Belarus, Crimea (including Sevastopol), the Democratic 
People’s Republic of North Korea, Donetsk, Iran, Kherson, 
Luhansk, Russia, Syria and Zaporizhzhia. 
Fraud prevention at Nordea focuses on safe and user-
friendly authentication solutions for customers, safety limita-
tions built into products and services, fraud detection tools 
development, and increasing fraud intelligence and aware-
ness. Qualitative insights from customers and colleagues 
and data analysis continuously feed into our fraud preven-
tion work, helping us to bolster our fraud detection strate-
gies and improve customer awareness campaigns. More 
information on our work to increase fraud awareness and 
protect our customers and wider society against fraud can 
be found in “S4 Consumers and end users” on pages 
173–174.
We engage with authorities across the Nordics to share 
experience and support society in combatting financial 
crime. This engagement includes collaboration with the 
police and financial intelligence units, for example through 
the Operational Danish Intelligence Network (ODIN) in 
Denmark and the Swedish Anti-Money Laundering 
Intelligence Task Force (SAMLIT) in Sweden.
Monitoring the effectiveness of policies and actions
While we have not published formal targets related to 
financial crime prevention, we internally monitor (i) 
employee and third party awareness of our policies and 
(ii) the effectiveness of our actions in mitigating financial 
crime risk. We do so through our financial crime Maturity 
Framework Reporting approach. This is aimed at providing 
management with accurate status updates – via different 
sets of measures – on our financial crime defence so they 
can make informed decisions regarding any actions 
needed. The measures are shared with and can be chal-
lenged by relevant decision-making bodies, including the 
Compliance, Conduct and Product Committee; the Group 
Leadership Team; the Board Risk Committee; and the 
Board of Directors. 
Cybersecurity
Cybersecurity is a priority for us as the financial infrastruc-
ture in the Nordics is increasingly subject to complex and 
targeted cyberattacks. These attacks are designed not 
only to disrupt digital services but also to create uncer-
tainty and erode trust. With the rapidly evolving threat 
landscape and fast pace of technological change, a strong 
cybersecurity strategy is critical – not only to protect sys-
tems and data, but also to safeguard customers and main-
tain trust, resilience and the long-term operational conti-
nuity of critical infrastructure.
Actions and resources related to cybersecurity
Our approach to cybersecurity involves developing and 
maintaining a strong information security management 
system (ISMS) to ensure the confidentiality, integrity and 
availability of proprietary information and information 
entrusted to us. Our ISMS is based on recognised industry 
best practices such as the ISO 27000 and the frameworks 
provided by the National Institute of Standards and 
Technology (NIST).
We must also comply with financial industry regulations, 
including European Banking Authority guidelines, and 
other relevant European legislation introducing specific 
information security requirements. Our ISMS is supported 
by company-wide protocols, policies and guidelines, 
including supplier instructions, which ensure we meet reg-
ulatory requirements and maintain effective risk control. 
Our security culture is built on clear accountabilities, 
ongoing awareness programmes, and well-defined proce-
dures for gathering threat intelligence and detecting and 
responding to cybersecurity incidents.
Where our cybersecurity strategy is concerned, we have 
defined three guiding principles to steer our decision-mak-
ing and inform future initiatives supporting our security 
ambitions. These guiding principles are (i) advance with 
the implementation of our Zero Trust cybersecurity frame-
work, (ii) increase cybersecurity maturity to reduce the risk 
of downtime and business disruption, and (iii) adopt AI 
and automation. The principles are interconnected and 
complement each other. 
While the guiding principles provide direction, threat 
themes help us prioritise future initiatives. We identify 
these by monitoring the existing threat landscape and 
analysing evolving threats. The landscape is constantly 
changing but the latest insights gained have enabled us to 
identify three main themes to focus on: distributed deni-
al-of-service attacks, insider threats, and third party risk 
management. 
In 2025 we invested significant resources in maintaining 
and upgrading our security controls to keep pace with the 
evolving geopolitical situation and regulatory expectations 
and ensure a safe and secure service for customers. 
Monitoring the effectiveness of policies and actions 
While we have not published formal targets relating to 
cybersecurity, our three lines of defence regularly test 
whether the cyber controls we have implemented to 
ensure policy compliance and operational security are 
working as designed. These tests include simulated cyber-
attacks. We also monitor the effectiveness of these con-
trols and arrange regular independent external assess-
ments to benchmark our control performance.
Our three guiding principles for cybersecurity
 
 Advance  
Zero Trust 
Advance with the implementation 
of our Zero Trust framework to 
further improve overall security
 
 Increase cyber 
maturity 
Mature our capabilities to be 
within our risk appetite and on a 
par with EU peers or at Tier 3 in 
the NIST Cybersecurity Framework
  
Adopt AI and 
automation 
Enhance our AI and automation 
capabilities to defend against 
growing threat actor capabilities

===== SIDA 182 =====

Nordea Annual Report 2025 181
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
Appendix (EU Taxonomy)
Table 4 – 1. Assets for the calculation of GAR (EURm) Stock Turnover 
The table provides information on the EU Taxonomy eligibility and alignment of our stock of assets within the scope of the GAR disclosures at the end of the year. Note: Cells shaded in grey represent information that is not subject to disclosure.
31 December 2025  
Non- 
assessed 
exposures
Stock  
EURm
Total [gross]
carrying 
amount1
Of which 
Taxonomy- 
eligible
Of which  
Tax onomy- 
aligned
Breakdown per environmental objective
Of which Use 
of Proceeds
Of which  
transitional
Of which  
enabling
Of which financing non-material 
activities of counterparties2 5
Of which exposures financing 
counterparties reporting in 
accordance with Article 7(9)5
Of which not assessed  
considered non-material by the 
credit institution3
Climate 
Change Miti-
gation (CCM)
Climate 
Change Adap-
tation (CCA)
Water and 
marine  
resources 
(WTR)
Circular  
economy (CE)
Pollution 
(PPC)
Biodiversity 
and Ecosys-
tems (BIO)
1 GAR – Covered assets in both  numer ator and denominator 257,042 184,320 16,001 15,943 4 0 55 0 0 13,206 420 353 0 – – 0
2 Loans and advances, debt securities and equity instruments not  
HfT eligible for GAR calculation 252,497 183,154 15,590 15,531 4 0 55 0 0 13,206 319 299 0 – – 0
3 Financial undertakings 29,586 13,509 1,307 1,302 4 0 0 0 0 0 78 18 0 – – 0
4 Loans and advances 5,847 1,637 115 114 1 0 0 0 0 0 16 4 0 – – 0
5 Debt securities, including UoP 23,677 11,858 1,190 1,187 3 0 0 0 0 0 62 14 0 – – 0
6 Equity instruments 61 15 1 1 0 0 0 0 0 0 0 0 – – 0
7 Non-financial undertakings 17,693 6,240 1,078 1,023 0 0 54 0 0 0 241 280 0 – 0
8 Loans and advances 17,458 6,160 1,051 997 0 0 54 0 0 0 241 273 0 – 0
9 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 – 0
10 Equity instruments 235 80 27 27 0 0 0 0 0 0 7 0 – 0
11 Households 197,357 163,406 13,206 13,206 0 0 13,206 0 0 0 – 0
12 of which loans collateralised by residential immovable property 174,742 159,488 13,194 13,194 0 0 13,194 0 0 0 – 0
13 of which building renovation loans 142 142 0 0 0 0 0 0 0 0 – 0
14 of which motor vehicle loans 4,048 3,653 0 0 0 0 0 0 – 0
15 Local governments financing 7,862 0 0 0 0 0 0 0 0 0 0 0 0 – 0
16 Housing financing 880 0 0 0 0 0 0 0 0 0 – 0
17 Other local government financing 6,981 0 0 0 0 0 0 0 0 0 0 0 0 – 0
18 Collateral obtained by taking possession:  
residential and commercial immovable properties 2 0 0 0 0 0 0 0 0 0 – 0
19 Exposures included on a voluntary basis4 4,543 1,165 411 411 0 0 0 0 0 0 101 55 0
20 Total GAR assets 257,042
21 Assets not covered for GAR calculation 298,875
22 Central governments and Supranational issuers 10,858
23 Central banks exposure 44,647
24 Trading book 95,902
25 Undertakings and entities not subject to CSRD 128,013
26 SMEs and undertakings (other than SMEs) not subject to  
CSRD disclosure obligations 118,590
27 Loans and advances 109,536
28 of which loans collateralised by commercial immovable property 26,238
29 of which building renovation loans 0
30 Debt securities 6,403
31 Equity instruments 2,650
32 Non-EU country counterparties not subject to CSRD disclosure obligations 9,423
33 Loans and advances 8,632
34 Debt securities 791
35 Equity instruments 0
36 Derivatives 2,280
37 On demand interbank loans 0
38 Cash and cash-related assets 222
39 Other categories of assets (e.g. Goodwill, commodities etc.) 16,952
40 Total assets 555,917
Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments
41 Financial guarantees 1,781 – – – – – – – – – – – 1,781 – – 1,781
42 Assets under management6 550 – – – – – – – – – – – 550 – – 550
43 Of which debt securities 0 – – – – – – – – – – – 0 – – 0
44 Of which equity instruments 550 – – – – – – – – – – – 550 – – 550
1) Exposur e is defined as exposure for on-balance sheet items, with an adjustment for exposures reported at fair value ( Nordea Realkreditaktieselskab).
2) In ac cordance with Article 7(8)(a) and (b) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
3) In ac cordance with Article 4(1a) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
4) In ac cordance with Article 7(3) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
5) At the time o f the 2025 disclosure, this data did not yet exist and so could not be included.
6) The se assets under management (AuM) represent mainly direct equity investments through our Private Banking Portfolio Management service (PBPM). PBPM primarily invests through funds, which are fully captured in the asset managers template. These AuM are thus deemed to be non-material.

===== SIDA 183 =====

Nordea Annual Report 2025 182
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
EU taxonomy, cont.
Table 5 – 1. Assets for the calculation of GAR (EURm) Stock Capex 
The table provides information on the EU Taxonomy eligibility and alignment of our stock of assets within the scope of the GAR disclosures at the end of the year. 
31 December 2025  
Non- 
assessed 
exposures
Stock  
EURm
Total [gross]
carrying 
amount1
Of which 
Taxonomy- 
eligible
Of which  
Tax onomy- 
aligned
Breakdown per environmental objective
Of which Use 
of Proceeds
Of which  
transitional
Of which  
enabling
Of which financing non-material 
activities of counterparties2 5
Of which exposures financing 
counterparties reporting in 
accordance with Article 7(9)5
Of which not assessed  
considered non-material by the 
credit institution3
Climate 
Change Miti-
gation (CCM)
Climate 
Change Adap-
tation (CCA)
Water and 
marine  
resources 
(WTR)
Circular  
economy (CE)
Pollution 
(PPC)
Biodiversity 
and Ecosys-
tems (BIO)
1 GAR – Covered assets in both  numer ator and denominator 257,042 185,995 16,481 16,449 3 0 29 0 0 13,206 409 410 0 – – 0
2 Loans and advances, debt securities and equity instruments not  
HfT eligible for GAR calculation 252,497 185,319 16,144 16,111 3 0 29 0 0 13,206 408 294 0 – – 0
3 Financial undertakings 29,586 13,758 1,307 1,307 0 0 0 0 0 0 76 21 0 – – 0
4 Loans and advances 5,847 2,364 115 114 0 0 0 0 0 0 15 4 0 – – 0
5 Debt securities, including UoP 23,677 11,381 1,191 1,191 0 0 0 0 0 0 60 17 0 – – 0
6 Equity instruments 61 13 1 1 0 0 0 0 0 0 0 0 – – 0
7 Non-financial undertakings 17,693 8,154 1,631 1,599 3 0 29 0 0 0 332 273 0 – 0
8 Loans and advances 17,458 8,005 1,599 1,567 3 0 29 0 0 0 329 264 0 – 0
9 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 – 0
10 Equity instruments 235 149 32 32 0 0 0 0 0 3 9 0 – 0
11 Households 197,357 163,406 13,206 13,206 0 0 13,206 0 0 0 – 0
12 of which loans collateralised by residential immovable property 174,742 159,488 13,194 13,194 0 0 13,194 0 0 0 – 0
13 of which building renovation loans 142 142 0 0 0 0 0 0 0 0 – 0
14 of which motor vehicle loans 4,048 3,653 0 0 0 0 0 0 – 0
15 Local governments financing 7,862 0 0 0 0 0 0 0 0 0 0 0 0 – 0
16 Housing financing 880 0 0 0 0 0 0 0 0 0 – 0
17 Other local government financing 6,981 0 0 0 0 0 0 0 0 0 0 0 0 – 0
18 Collateral obtained by taking possession:  
residential and commercial immovable properties 2 0 0 0 0 0 0 0 0 0 – 0
19 Exposures included on a voluntary basis4 4,543 676 337 337 0 0 0 0 0 0 2 115 0
20 Total GAR assets 257,042
21 Assets not covered for GAR calculation 298,875
22 Central governments and Supranational issuers 10,858
23 Central banks exposure 44,647
24 Trading book 95,902
25 Undertakings and entities not subject to CSRD 128,013
26 SMEs and undertakings (other than SMEs) not subject to  
CSRD disclosure obligations 118,590
27 Loans and advances 109,536
28 of which loans collateralised by commercial immovable property 26,238
29 of which building renovation loans 0
30 Debt securities 6,403
31 Equity instruments 2,650
32 Non-EU country counterparties not subject to CSRD disclosure obligations 9,423
33 Loans and advances 8,632
34 Debt securities 791
35 Equity instruments 0
36 Derivatives 2,280
37 On demand interbank loans 0
38 Cash and cash-related assets 222
39 Other categories of assets (e.g. Goodwill, commodities etc.) 16,952
40 Total assets 555,917
Off-balance sheet exposures (stock) to Undertakings subject to CSRD disclosure obligations and local governments
41 Financial guarantees 1,781 – – – – – – – – – – – 1,781 – – 1,781
42 Assets under management6 550 – – – – – – – – – – – 550 – – 550
43 Of which debt securities 0 – – – – – – – – – – – 0 – – 0
44 Of which equity instruments 550 – – – – – – – – – – – 550 – – 550
1) Exposur e is defined as exposure for on-balance sheet items, with an adjustment for exposures reported at fair value ( Nordea Realkreditaktieselskab).
2) In ac cordance with Article 7(8)(a) and (b) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
3) In ac cordance with Article 4(1a) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
4) In ac cordance with Article 7(3) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
5) At the time o f the 2025 disclosure, this data did not yet exist and so could not be included.
6) The se assets under management (AuM) represent mainly direct equity investments through our Private Banking Portfolio Management service (PBPM). PBPM primarily invests through funds, which are fully captured in the asset managers template. These AuM are thus deemed to be non-material.

===== SIDA 184 =====

Nordea Annual Report 2025 183
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
EU taxonomy, cont.
Table 6 – 1. Assets for the calculation of GAR (EURm) Flow Turnover 
The table provides information on the EU Taxonomy eligibility and alignment of our assets within the scope of the GAR disclosures based on the flow of newly incurred exposures during the year.
31 December 2025  
Non- 
assessed 
exposures
Flow  
EURm
Total [gross]
carrying 
amount1
Of which 
Taxonomy- 
eligible
Of which  
Tax onomy- 
aligned
Breakdown per environmental objective
Of which Use 
of Proceeds
Of which  
transitional
Of which  
enabling
Of which financing non-material 
activities of counterparties2 5
Of which exposures financing 
counterparties reporting in 
accordance with Article 7(9)5
Of which not assessed  
considered non-material by the 
credit institution3
Climate 
Change Miti-
gation (CCM)
Climate 
Change Adap-
tation (CCA)
Water and 
marine  
resources 
(WTR)
Circular  
economy (CE)
Pollution 
(PPC)
Biodiversity 
and Ecosys-
tems (BIO)
1 GAR – Covered assets in both  numer ator and denominator 59,649 38,455 3,059 3,016 2 0 41 0 0 1,957 169 156 0 – – 0
2 Loans and advances, debt securities and equity instruments not  
HfT eligible for GAR calculation 58,906 38,227 2,942 2,899 2 0 41 0 0 1,957 169 156 0 – – 0
3 Financial undertakings 12,217 4,546 491 488 2 0 0 0 0 0 51 8 0 – – 0
4 Loans and advances 5,087 1,351 114 113 1 0 0 0 0 0 16 4 0 – – 0
5 Debt securities, including UoP 7,130 3,195 376 375 2 0 0 0 0 0 36 5 0 – – 0
6 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 – – 0
7 Non-financial undertakings 9,283 3,043 495 455 0 0 40 0 0 0 118 148 0 – 0
8 Loans and advances 9,278 3,043 495 455 0 0 40 0 0 0 118 148 0 – 0
9 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 – 0
10 Equity instruments 4 0 0 0 0 0 0 0 0 0 0 0 – 0
11 Households 35,531 30,638 1,957 1,957 0 0 1,957 0 0 0 – 0
12 of which loans collateralised by residential immovable property 31,711 28,938 1,951 1,951 0 0 1,951 0 0 0 – 0
13 of which building renovation loans 36 36 0 0 0 0 0 0 0 0 – 0
14 of which motor vehicle loans 1,576 1,576 0 0 0 0 0 0 – 0
15 Local governments financing 1,875 0 0 0 0 0 0 0 0 0 0 0 0 – 0
16 Housing financing 821 0 0 0 0 0 0 0 0 0 – 0
17 Other local government financing 1,054 0 0 0 0 0 0 0 0 0 0 0 0 – 0
18 Collateral obtained by taking possession:  
residential and commercial immovable properties 0 0 0 0 0 0 0 0 0 0 – 0
19 Exposures included on a voluntary basis4 743 228 117 117 0 0 0 0 0 0 0 0 0
20 Total GAR assets 59,649
21 Assets not covered for GAR calculation 69,230
22 Central governments and Supranational issuers 1,109
23 Central banks exposure 6,188
24 Trading book 7,700
25 Undertakings and entities not subject to CSRD 52,943
26 SMEs and undertakings (other than SMEs) not subject to  
CSRD disclosure obligations 45,892
27 Loans and advances 44,858
28 of which loans collateralised by commercial immovable property 13,376
29 of which building renovation loans 0
30 Debt securities 747
31 Equity instruments 287
32 Non-EU country counterparties not subject to CSRD disclosure obligations 7,051
33 Loans and advances 7,020
34 Debt securities 31
35 Equity instruments 0
36 Derivatives 14
37 On demand interbank loans 0
38 Cash and cash-related assets 1
39 Other categories of assets (e.g. Goodwill, commodities etc.) 1,276
40 Total assets 128,879
Off-balance sheet exposures (flow) to Undertakings subject to CSRD disclosure obligations and local governments
41 Financial guarantees 27 – – – – – – – – – – – 27 – – 27
42 Assets under management6 0 – – – – – – – – – – – 0 – – 0
43 Of which debt securities 0 – – – – – – – – – – – 0 – – 0
44 Of which equity instruments 0 – – – – – – – – – – – 0 – – 0
1) Exposur e is defined as exposure for on-balance sheet items, with an adjustment for exposures reported at fair value ( Nordea Realkreditaktieselskab).
2) In ac cordance with Article 7(8)(a) and (b) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
3) In ac cordance with Article 4(1a) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
4) In ac cordance with Article 7(3) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
5) At the time o f the 2025 disclosure, this data did not yet exist and so could not be included.
6) The se assets under management (AuM) represent mainly direct equity investments through our Private Banking Portfolio Management service (PBPM). PBPM primarily invests through funds, which are fully captured in the asset managers template. These AuM are thus deemed to be non-material.

===== SIDA 185 =====

Nordea Annual Report 2025 184
Introduction Strategic report Our stakeholders Business areas Board of Directors’ report Financial statements Other
EU taxonomy, cont.
Table 7 – 1. Assets for the calculation of GAR (EURm) Flow Capex 
The table provides information on the EU Taxonomy eligibility and alignment of our assets within the scope of the GAR disclosures based on the flow of newly incurred exposures during the year.
31 December 2025  
Non- 
assessed 
exposures
Flow  
EURm
Total [gross]
carrying 
amount1
Of which 
Taxonomy- 
eligible
Of which  
Tax onomy- 
aligned
Breakdown per environmental objective
Of which Use 
of Proceeds
Of which  
transitional
Of which  
enabling
Of which financing non-material 
activities of counterparties2 5
Of which exposures financing 
counterparties reporting in 
accordance with Article 7(9)5
Of which not assessed  
considered non-material by the 
credit institution3
Climate 
Change Miti-
gation (CCM)
Climate 
Change Adap-
tation (CCA)
Water and 
marine  
resources 
(WTR)
Circular  
economy (CE)
Pollution 
(PPC)
Biodiversity 
and Ecosys-
tems (BIO)
1 GAR – Covered assets in both  numer ator and denominator 59,649 40,217 3,432 3,408 2 0 22 0 0 1,957 195 127 0 – – 0
2 Loans and advances, debt securities and equity instruments not  
HfT eligible for GAR calculation 58,906 39,989 3,327 3,303 2 0 22 0 0 1,957 193 127 0 – – 0
3 Financial undertakings 12,217 5,244 489 489 0 0 0 0 0 0 50 11 0 – – 0
4 Loans and advances 5,087 2,052 114 114 0 0 0 0 0 0 15 4 0 – – 0
5 Debt securities, including UoP 7,130 3,192 375 375 0 0 0 0 0 0 34 7 0 – – 0
6 Equity instruments 0 0 0 0 0 0 0 0 0 0 0 0 – – 0
7 Non-financial undertakings 9,283 4,107 881 857 2 0 22 0 0 0 144 117 0 – 0
8 Loans and advances 9,278 4,104 879 856 2 0 22 0 0 0 144 117 0 – 0
9 Debt securities, including UoP 0 0 0 0 0 0 0 0 0 0 0 0 0 – 0
10 Equity instruments 4 3 2 2 0 0 0 0 0 0 0 0 – 0
11 Households 35,531 30,638 1,957 1,957 0 0 1,957 0 0 0 – 0
12 of which loans collateralised by residential immovable property 31,711 28,938 1,951 1,951 0 0 1,951 0 0 0 – 0
13 of which building renovation loans 36 36 0 0 0 0 0 0 0 0 – 0
14 of which motor vehicle loans 1,576 1,576 0 0 0 0 0 0 – 0
15 Local governments financing 1,875 0 0 0 0 0 0 0 0 0 0 0 0 – 0
16 Housing financing 821 0 0 0 0 0 0 0 0 0 – 0
17 Other local government financing 1,054 0 0 0 0 0 0 0 0 0 0 0 0 – 0
18 Collateral obtained by taking possession:  
residential and commercial immovable properties 0 0 0 0 0 0 0 0 0 0 – 0
19 Exposures included on a voluntary basis4 743 228 106 105 0 0 0 0 0 0 2 0 0
20 Total GAR assets 59,649
21 Assets not covered for GAR calculation 69,230
22 Central governments and Supranational issuers 1,109
23 Central banks exposure 6,188
24 Trading book 7,700
25 Undertakings and entities not subject to CSRD 52,943
26 SMEs and undertakings (other than SMEs) not subject to  
CSRD disclosure obligations 45,892
27 Loans and advances 44,858
28 of which loans collateralised by commercial immovable property 13,376
29 of which building renovation loans 0
30 Debt securities 747
31 Equity instruments 287
32 Non-EU country counterparties not subject to CSRD disclosure obligations 7,051
33 Loans and advances 7,020
34 Debt securities 31
35 Equity instruments 0
36 Derivatives 14
37 On demand interbank loans 0
38 Cash and cash-related assets 1
39 Other categories of assets (e.g. Goodwill, commodities etc.) 1,276
40 Total assets 128,879
Off-balance sheet exposures (flow) to Undertakings subject to CSRD disclosure obligations and local governments
41 Financial guarantees 27 – – – – – – – – – – – 27 – – 27
42 Assets under management6 0 – – – – – – – – – – – 0 – – 0
43 Of which debt securities 0 – – – – – – – – – – – 0 – – 0
44 Of which equity instruments 0 – – – – – – – – – – – 0 – – 0
1) Exposur e is defined as exposure for on-balance sheet items, with an adjustment for exposures reported at fair value ( Nordea Realkreditaktieselskab).
2) In ac cordance with Article 7(8)(a) and (b) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
3) In ac cordance with Article 4(1a) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
4) In ac cordance with Article 7(3) of Delegated Regulation 2021/2178 as amended by Delegated Regulation 2026/73.
5) At the time o f the 2025 disclosure, this data did not yet exist and so could not be included.
6) The se assets under management (AuM) represent mainly direct equity investments through our Private Banking Portfolio Management service (PBPM). PBPM primarily invests through funds, which are fully captured in the asset managers template. These AuM are thus deemed to be non-material.

===== SIDA 186 =====