Business ethics and governance

Good business ethics and sound corporate governance are basic prerequisites for TF Bank’s values and trust from customers, employees and the market, and also contribute to public trust in the financial sector.

Anti-corruption, AML and prevention of terror financing

Corruption primarily refers to the giving or accepting of a bribe or undue benefit, as well as inappropriate conduct in conflicts of interest. Running operations in a manner that prevents corrupt practices from taking root is essential for maintaining the trust of our customers, employees, and the market. The Bank’s anti-corruption efforts are based on the Bank’s code of conduct, which encompasses all employees. The code of conduct is reviewed and updated every year, and the updated code is shared with the Bank’s employees. Furthermore, anti-corruption training is carried out regularly to give employees guidance on how to act in the best way if they experience uncertainty in a relationship or business relationship. All in all, this contributes to an awareness among all employees that the work with anti-corruption is an ongoing process.

We work proactively to prevent TF Bank from being used for money laundering or terrorist financing both to counteract this societal problem and to protect our customers. The work takes place within the framework of the risk assessment and know your customer (KYC) process carried out on each new customer in the Bank. Thereafter, transactions and activities are continuously monitored. Suspected cases of money laundering or terrorist financing are investigated and reported to the relevant authorities in each market. In addition, the Bank continually updates its monitoring systems to enhance detection capabilities and stay ahead of evolving risks.

To ensure that all employees are equipped with the knowledge and tools to identify and address risks related to corruption, money laundering, and terrorist financing, TF Bank provides comprehensive training programs. These training sessions are mandatory for all employees and are regularly updated to reflect the latest regulatory changes, emerging risks, and best practices. Employees are educated on how to recognise and report suspicious activity and ensure compliance with internal and external regulations.

To maintain a high level of business ethics, TF Bank has a whistleblower function where suspected cases of deviations from the Code of Conduct, violations of internal or external regulations, as well as money laundering and terrorist financing can be reported anonymously. The whistleblower function is available on the Bank’s website and is accessible for all stakeholders. TF Bank ensures that reports made through this function are treated with the utmost confidentiality and in accordance with the high standards of integrity.

TF Bank has also adopted the Code of Conduct for Suppliers. The Bank’s suppliers are evaluated on the basis of different premises, including their own anti-corruption and AML practices. The Code of Conduct for Suppliers is distributed to suppliers who then will approve our code of conduct for suppliers or demonstrate that they have an internal equivalent code of conduct. The Bank’s compliance function ensures that annual follow-ups of suppliers in relation to the code of conduct are conducted.

Information security and GDPR

TF Bank works preventively with systematic information security. We continuously adapt the security measures based on the organisation’s needs and risks in accordance with regulatory requirements, good practice and ethical standards.

We also require that persons who process personal data undertake confidentiality through written agreements and strict information security measures. This also applies to our suppliers, which is established in our Code of Conduct for Suppliers.

Personal data is handled by TF Bank in a correct and appropriate way. We work to ensure that the personal data we process is correct, complete and up to date. Personal data is protected by bank secrecy, which means that TF Bank may not disclose personal data to unauthorised persons. The Bank also has extensive routines for processing personal data in accordance with GDPR and related local regulations.

To support these efforts, TF Bank provides ongoing training to employees on information security and data protection. This ensures that all personnel are equipped with the knowledge and awareness necessary to handle personal data securely and responsibly, in line with the Bank’s policies and legal obligations.

Sound corporate governance and efficient risk management

TF Bank follows the Swedish Code of Corporate Governance and uses a well-proven model for corporate governance with clear responsibilities, guidelines and policies in all significant areas.

The Company’s risk management is based on three lines of defence that start in the ongoing operations, which include all employees. The second line comprises the independent control functions and risk control, which review, evaluate and report to management and the Board of Directors regarding risks and compliance. The third line consists of internal audit, which is an independent audit function directly subordinate to the Board. The internal audit is mainly responsible for providing the Board with reliable and objective evaluation of risk management, financial reporting and control and governance processes in order to reduce the presence of risks and improve the control structure.

TF Bank is committed to maintaining a robust governance framework that supports both short-term objectives and long-term sustainable growth. TF Bank continually reviews and refines its governance practices to adapt to changing regulatory requirements and market conditions. Moreover, the Bank ensures transparency and regular communication with stakeholders to foster trust and accountability across all levels of operation.

More information about TF Bank’s corporate governance can be found in the corporate governance report on page 118-128.