Code of Conduct

1. Introduction


1.1 Purpose

The Code of Conduct contains guidelines for how we behave towards each other internally in KommuneKredit as well as externally towards our business partners. The intention of the Code is to underpin a good working environment as well as a professional business conduct suitable for a modern and well-run business.


The Code sets the direction for decisions and processes. It contains a set of principles rather than a full set of rules. Employees, who are unsure of how to act in a specific situation, may seek further guidance from, for example, internal policies, guidelines and administrative procedures or their immediate superior. Reference is made to these types of documents throughout the Code.


The Code of Conduct reflects KommuneKredit’s values –  Competent, Solution-driven, Responsible and Inclusive. The values underpin the association’s mission and vision.



2. Conduct in KommuneKredit


2.1 Steady and stable

KommuneKredit must be a steady and stable link between clients and investors. It is important that the conduct of employees underpins the steadiness and stability that permeates the business and sets the tone for the day-to-day work in KommuneKredit.


2.2 Relations to external parties

KommuneKredit wants to continuously build and maintain well-functioning relations with our stakeholders, including investors, suppliers, public authorities etc., through professional conduct.


2.3 Relations to clients

KommuneKredit’s employees must be impartial and must act in accordance with sound business practice. Products and services must be offered on equal terms and delivered with the same high standard to all clients. This ensures that clients see KommuneKredit as a flexible, credible, transparent and accessible business partner.


2.4 Confidentiality

Any knowledge gained through employment at KommuneKredit concerning KommuneKredit’s business and confidential information about the association, the association’s employees, clients and other business partners, is covered by confidentiality. Confidentiality is defined in the employment contract.


2.5 Conflicts of interest

There must be no question that employees carry out their tasks for the good of KommuneKredit. Conflicts between the interest of KommuneKredit and the interest of the employee (or of their related parties) with significance for work related matters must always be avoided. If in doubt, the employee shall bring a potential conflict of interest to the attention of their immediate superior, so that the necessary precautions can be taken.


2.6 Rules for receiving and giving gifts

There must be no doubt as to an employee’s impartiality in relation to carrying out work in the best interest of KommuneKredit. All employees must follow the rules for the giving and receiving of gifts as described in the association’s rules for receiving and giving gifts. The rules can be found in the association’s employee handbook.


2.7 Rules for travelling

Travel expenses (transportation, overnight accommodation and consumption) must be kept at a level which is appropriate and fair. Detailed requirements are described in the association’s rules for travelling.


2.8 External communication

Unless other arrangements are explicitly agreed, only KommuneKredits CEO may speak to the press. The principles for KommuneKredit’s external communication are further described in the association’s communication strategy.


2.9 Substance abuse

KommuneKredit is an alcohol-free and drug-free work environment. It may be permitted to consume alcohol on special occasions (such as staff events, Christmas lunches and such like). Another example could be getting a beer together after work while paying attention to conduct and signal value with regard to colleagues still working and potential visitors at KommuneKredit’s premises.


KommuneKredit’s substance abuse policy is described in the associations employee handbook.


2.10 Smoking

Smoking in the workplace is not permitted. KommuneKredit’s policy on smoking is described in the employee handbook.


2.11 Stress

The association has formulated a policy on stress to promote employee satisfaction and a sound work environment. The policy is intended to prevent stress.

KommuneKredit’s policy on stress is described in the association’s employee handbook.


2.12 Work environment and diversity

KommuneKredit’s employees must respect each other and each other’s differences. In addition, the individual’s right to privacy must be respected and a work place free of discrimination, harassment and bullying must be maintained.


Any discrimination on grounds of for example gender, ethnic or social class, religion or faith, political or other beliefs, disability, age and sexual orientation is unacceptable.  Employees, who have knowledge of or suspect discrimination, harassment or bullying, must bring this to the attention of their immediate superior or to KommuneKredit’s HR-function.


2.13 Mediation

KommuneKredit has a mediation policy, which sets out the guidelines for how conflicts can be prevented and handled, if they occur. The mediation policy can be found in the association’s employee handbook.


2.14 Responsibility

Responsibility is an integrated part of KommuneKredit’s business model. To KommuneKredit responsibility means integrating social, environmental and ethical concerns into the business. All employees are expected to conduct themselves responsibly, for example by supporting a sustainable consumption of materials and resources in the association.


The principles for KommuneKredit’s work with responsibility is drafted in a separate responsibility policy.


2.15 Actions in the event of an inappropriate incident

There are a number of policies, systems and administrative procedures etc. meant to ensure that KommuneKredit’s employees act appropriately in every respect. However, it is important that employees have the option of safely reporting if they experience inappropriate incidents or behaviour. ‘Guidelines on actions in the event of inappropriate incidents’ describe the channels employees may use, if they experience non-compliance with existing rule sets.


3. The Code in practice


3.1 Compliance

All employees are expected to be familiar with KommuneKredit’s Code of Conduct and are aware that work-related activities are compliant herewith.

It is the responsibility of the individual leader to ensure that the Code of Conduct is known by the employees within his/her area of responsibility.

Leaders at all levels must lead by example.