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Anti-money laundering and counter-terrorist financing policy

DLR has a regulatory obligation and a responsibility to its customers, employees, owners and society to prevent DLR from being misused for laundering the proceeds of crime, terrorist financing or violation of financial sanctions.

The purpose of DLR’s anti-money laundering and counter-terrorist financing policy is to ensure a solid framework for DLR to prevent the business from being misused for financial crime, thus ensuring compliance with applicable legislative requirements. The purpose is also to ensure that DLR applies its resources effectively and takes a risk-based approach to preventing financial crime.

An essential element in the fight against money laundering and terrorist financing is to ensure that DLR’s employees are familiar with the rules and comply with the obligation of attentiveness prescribed by the rules. With this in mind, DLR provides ongoing training to DLR employees who have customer contact or process data about customers etc. in connection with DLR’s lending activity.

Anti-bribery and anti-corruption policy

The purpose of DLR’s anti-bribery and anti-corruption policy is to describe and provide instructions on how DLR’s employees should react if, during their work at DLR, a situation occurs in which they experience bribery or corruption.

DLR defines bribery as giving another person money or goods to gain an unfair advantage and corruption as the abuse of entrusted power for private gain. CLR tolerates no form of bribery, corruption, nepotism or any other inappropriate business practice.

Whistleblower policy

DLR’s whistleblower policy describes how DLR handles reports of violations or suspected violations via DLR’s whistleblower scheme, who may file a report and which issues may be reported.

Whistleblowing reports, which may be anonymous, are made to an external portal and investigated and processed within a reasonable timeframe by an appointed impartial person. The person who made the report is guaranteed feedback on the processing of the case, and a whistleblower is protected by the provisions of the Danish Whistleblower Act and thus against reprisals, provided the report is made in accordance with the rules.

DLR aims to have an open corporate culture in which everyone is free to come forward if they know or suspect irregularities or unlawful activity committed by employees, including by the management and Board of Directors.

Tax policy

DLR aims to display transparency and accountability in tax matters and to pursue best practice principles.

DLR complies with applicable tax legislation and pays all taxes due. As such, DLR pursues a policy of being a competitive business as well as a responsible taxpayer.

DLR pursues a transparent tax policy, which means that DLR must at all times be able to explain and justify its tax arrangements.

Policy and guidelines on remuneration

The purpose of DLR’s remuneration policy is to ensure that the payment of salaries is in accordance with sound and effective risk management of DLR and does not encourage excessive risk taking.

The remuneration policy must be consistent with DLR’s business strategy, objectives, values and long-term interests and ensure that the remuneration of DLR’s employees is in accordance with the statutory provisions on protection of customers and investors and other legislative requirements.

Employees of DLR are remunerated exclusively in accordance with the collective agreement with the Danish Financial Services Union. Employees of DLR do not receive any variable salary components.

The wording and implementation of the remuneration policy comply with all relevant legislative requirements.


Code of conduct

DLR’s code of conduct sets out a set of overall guidelines for business conduct at DLR. The code of conduct applies to management and all employees and is defined within the scope of DLR’s values, which are:

– Collaboration
– Professional approach
– Integrity
– Action-oriented

Corporate governance

DLR’s governance code provides an overview of DLR’s approach to the corporate governance code of the Danish Bankers Association.

DLR responds to all the recommendations of the Committee on Corporate Governance.

Human rights

DLR’s human rights policy builds on the Danish labour market model and the protection of internationally proclaimed human rights as described in the UN’s Universal Declaration of Human Rights and in the ILO’s conventions and recommendations. The Danish labour market model and the internationally proclaimed human rights form together the basis of a safe, just and fair society in which equality, inclusion, labour rights, security and health are deeply rooted values.

IT and data

Processing of personal data

DLR is a financial business, and as part of our business we register and use personal data about our customers. We take all relevant measures to protect personal data we record in accordance with applicable legislation. Information on processing of personal data describes how DLR collects, processes and discloses personal data.

Data ethics policy

DLR’s data ethics policy sets the framework for DLR’s data ethical conduct. The policy describes DLR’s approach to data ethics and use of data. Furthermore, the policy describes the principles that apply to DLR’s approach to processing data in an ethical, responsible and transparent manner.

DLR’s data ethics policy concerns DLR’s customers, DLR’s in-house initiatives and its local communities. The policy thus covers the customer data we collect and process, but also all other data that DLR may process, including data on employees and business partners. As such, the policy applies to all employees. Data includes structured as well as unstructured data and data that DLR generates itself by using and developing technology.

IT security and IT risk management policy

DLR’s IT security and IT risk management policy contains the overall description of and goals for IT security initiatives at DLR.

DLR wishes to maintain a high level of IT security for all employees, business partners and customers. The IT security and IT risk management policy and underlying business procedures, work descriptions and security measures help ensure that systems, information and data are processed in accordance with the requirements applicable to businesses in the financial sector, including SIFI institutions.

DLR’s IT security and IT risk management policy builds on best practice, international standards and legislation. The international ISO27001 standard is used as a starting point for our work to manage and control IT security.

DLR’s IT security and IT risk management policy is accessible within the organisation.

Other policies

Credit policy

At DLR, we are committed to pursuing a responsible credit policy through all stages of the business cycle, during periods of economic expansion as well as contraction. We see a responsible credit policy as the basis for a healthy loan portfolio. The credit policy defines the limits for DLR’s credit granting, including for areas such as lending, property types, risk tolerance and customer ESG matters. Within these set limits, internal business procedures and instructions further delegate lending authorities to various sections in DLR’s organisation.

DLR’s credit policy is accessible within the organisation.

Sustainability policy

The sustainability policy sets the framework for our sustainability initiatives and demonstrates how we are taking
social, environmental and governance responsibility in the day-to-day operation of DLR.

The policy builds on DLR’s principal stakeholders and focus on tranparent corporate governance:

1. Borrowers

2. Stakeholder banks

3. Bond investors

4. Employees

5. Corporate governance

Our approach to our principal stakeholders and corporate governance is described in greater detail in the reminder of this policy. Several of our focus areas are also decribed in separate policies which elaborate on the implementation of specific initiatives, and some of the areas are reported on annually in various documents available on our website.

Diversity policy

DLR’s diversity policy sets the framework for how DLR’s Board of Directors work to promote relevant and necessary diversity on the Board of Directors.

The composition of the Board should be based on diversity of skills and backgrounds. The need for diversity is given particular importance in relation to differences in professional backgrounds, experience, gender and age.

DLR’s diversity policy is accessible within the organisation.

Policy and target figures for the underrepresented gender – supreme governing body and other management levels

In its policy and target figures for the underrepresented gender at DLR’s supreme governing body and other management levels, DLR has defined both target figures and specific initiatives to ensure an equal gender distribution.

DLR’s policy and target figures for the underrepresented gender at DLR’s supreme governing body and other management levels is accessible within the organisation.


Remuneration of the Executive Board

From 2021, disclosures of the remuneration of Executive Board members are provided in the annual overviews listed below. For previous years, the information is available in DLR’s annual reports.

Remuneration of the Board of Directors

From 2021, disclosures of the remuneration of members of the Board of Directors are provided in the annual overviews listed below. For previous years, the information is available in DLR’s annual reports.