Code of Conduct
TF Bank’s Code of Conduct sets the foundation for ethical behaviour and responsible decision-making across the organisation. The Code ensures full compliance with laws, regulations, and internal policies, and promotes clear communication to help customers understand the products and services offered.
It upholds a zero-tolerance policy on discrimination, advocating for equal opportunities in recruitment, compensation, training, and career advancement. To prevent conflicts of interest, TF Bank provides accessible policies that separate personal interests from professional responsibilities. Confidentiality is strictly maintained.
TF Bank is firmly committed to combating all types of financial crimes, including money laundering and terrorism financing. Employees are encouraged to report irregularities through secure whistleblowing channels.
The Code also promotes diversity and inclusion, supporting parental roles, equal pay, and gender balance. The Bank maintains procedures to investigate all allegations of workplace discrimination and harassment, implement appropriate corrective actions, and raise awareness on how to recognize and respond to such conduct.
The Code also promotes equal development and training opportunities for all employees. A safe and healthy work environment is prioritised through regular evaluations, leadership accountability, and opportunities for growth.
Code of Conduct for Suppliers
TF Bank’s Supplier Code of Conduct outlines the ethical, legal, and sustainability standards expected from all suppliers, contractors, consultants, and business partners. It ensures alignment with ESG principles and regulatory frameworks relevant to the financial sector. Suppliers are expected to comply fully with all applicable laws and regulations, including GDPR, DORA, and financial industry standards. Suppliers are responsible for ensuring compliance within their supply chains and promptly addressing any violations. The Code mandates robust anti-corruption and anti-bribery programs, supported by training and secure reporting mechanisms, with zero tolerance for unethical influence. Strong anti-financial crime controls must be in place to address money laundering, fraud, tax evasion, and insider trading. Suppliers are required to disclose any conflicts of interest and take proactive steps to mitigate them with full transparency.
Cybersecurity and data privacy are critical components, with expectations for incident response plans, employee awareness programs, and GDPR compliance. Fair treatment of customers, particularly vulnerable groups, is emphasized through clear communication and responsible service delivery. Financial integrity is maintained through accurate recordkeeping, transparent transactions, and regular audits. Suppliers shall also demonstrate responsible sourcing practices, avoid unethical supply chains and promote sustainability.
Environmental responsibility is expected, including efforts to reduce emissions, manage waste, and protect biodiversity. Human rights and labor standards must be upheld, prohibiting forced and child labor while promoting fair wages and safe working conditions. Diversity, inclusion, freedom of association, and supplier diversity initiatives are also encouraged. Whistleblowing mechanisms must be in place to ensure secure and anonymous reporting of violations.
Read our Code of Conduct for Suppliers
Sustainability Policy
TF Bank’s Sustainability Policy integrates environmental, social, and governance (ESG) principles into its operations, governance, and stakeholder engagement. It aligns with CSRD, ESRS, the UN Sustainable Development Goals, and Swedish regulatory frameworks. The policy is based on a double materiality assessment and is structured around four strategic pillars.
The first pillar, Responsible Lending, promotes financial inclusion through transparent and ethical banking services. The second, Business Ethics and Governance, ensures compliance, transparency, and effective risk management. The third pillar, Attractive Employer, focuses on fostering a safe, inclusive, and growth-oriented workplace. The fourth, Climate Action, aims to reduce environmental impact through emissions tracking, resource efficiency, and sustainable procurement.
TF Bank’s sustainability strategy is designed to deliver impact over the short, medium, and long term. In the short term, the Bank aims to strengthen ESG policies and initiate low-carbon projects. In the medium term, it seeks to deepen ESG integration and shift operations to low-carbon solutions. In the long term, the goal is to achieve net-zero emissions by 2050 and expand stakeholder collaboration.
Additional commitments include the protection of human rights, fair labor practices, and community engagement. Governance and ethics are reinforced through anti-corruption measures, anti-money laundering controls, IT security, and data privacy. Supplier responsibility is also emphasized, ensuring ethical conduct across the value chain.
Read our Sustainability Policy
Summary of our Anti-Financial Crime Policy
TF Bank is committed to protecting the integrity of the financial system and ensuring its operations are not exploited for financial crime. Financial crime (FC), including money laundering, terrorist financing, sanctions evasion, and proliferation financing, poses a serious threat to global stability. The Bank has a responsibility to its customers, shareholders and regulators to prevent the Bank from being used for the purposes of FC. TF Bank Group maintains a strong focus on identifying the FC risks to which it is exposed, and to manage these risks in an efficient and proportionate manner across all jurisdictions in which it operates.
The Policy is built on a risk-based approach, supported by an enterprise-wide risk assessment (EWRA) that evaluates financial crime risks at both global and local levels. TF Bank maintains strict Know Your Customer (KYC) standards, ensuring thorough due diligence during onboarding and throughout the customer relationship. High-risk customers and industries are subject to enhanced scrutiny, and prohibited relationships – such as those involving sanctioned entities or illegal activities – are not permitted.
Transaction monitoring is a key component of the Anti-Financial Crime framework. TF Bank Group ensures timely reporting to relevant regulatory institutions; also internal reporting mechanisms and whistleblowing protections are in place to encourage vigilance and accountability among all employees and other stakeholders. The Policy is applicable for the Group. Wherever local regulations are stricter than the requirements in the Policy, the stricter standard shall apply. The Bank’s Anti-Financial Crime governance is proportionate and appropriate to the nature, scale, risk profile and complexity of the organisation, so that the objectives of the regulatory requirements and provisions are achieved efficiently.
Policy training for all relevant employees and other stakeholders is in place in order to ensure a suitable background and experience.
Summary of our Anti-Bribery and Corruption Policy
The TF Bank operates under a zero-tolerance policy towards bribery and corruption. TF Bank is committed to ethical business practices and compliance with anti-corruption laws and international standards, including the United Nations Convention against Corruption. The Policy outlines the steps we take to prevent, detect, and address incidents of bribery and corruption within the organization. Based on regular risk assessments, TF Bank establishes solid procedures to promptly, independently, and objectively mitigate the risk of corruption. TF Bank has established the measures (controls) efficient to prevent, detect, and address allegations of corruption and bribery. The measures are being regularly reviewed, to ensure that the controls are adequate and effective.
The policy’s target group is all TF Bank’s employees as well as the other stakeholders in the value chain. All employees, board members, and relevant partners receive annual training on ethical conduct and anti-corruption measures. High-risk roles receive additional onboarding and refresher sessions to ensure awareness and compliance. TF Bank provides a confidential whistleblowing mechanism for reporting suspected violations. TF Bank is committed to transparency and accountability in its efforts to combat corruption and bribery.
Summary of our Credit Policy
TF Bank is committed to responsible lending practices that align with applicable laws, regulations, and ethical standards. The Policy governs all credit related activities across TF Bank’s operations in Europe.
TF Bank’s credit decisions are based on sound lending principles, ensuring that loans are only granted when the borrower demonstrates the ability to meet their obligations. TF Bank actively manages credit risk to ensure it remains within TF Bank’s defined risk appetite. All credit operations are designed to protect the TF Bank’s financial stability and ability to meet its obligations. The Bank identifies, measures, and controls risks through robust internal processes and governance structures. Credit assessments are objective and based on the customer’s financial capacity.
Ethical standards also extend to debt collection, which is conducted in line with the same principles that guide the TF Bank’s lending practices. To prevent financial crime, TF Bank applies strict Know Your Customer (KYC) procedures before entering any business relationship.
All employees are expected to adhere to TF Bank’s Code of Conduct, ensuring consistency and integrity in credit operations. The Bank also maintains clear policies to avoid conflicts of interest and prevent errors or regulatory breaches.
TF Bank demonstrates and is committed to transparency, responsible lending, and long-term financial sustainability.
Summary of our IT and Information Security Policy
TF Bank protects the confidentiality, integrity and availability of information to safeguard our customers, our services and the financial system. Our IT and Information Security Policies are Board‑approved, with the CEO accountable for implementation, supported by the three lines of defense model.
Our framework aligns with GDPR, FFFS 2014:5, the EBA ICT Guidelines, and DORA, covering information assets and third‑party suppliers through risk assessments and contractual safeguards. It includes incident response and privacy breach procedures, as well as tested business continuity and disaster recovery plans.
People and culture are central: all employees share responsibility for protecting information and receive security awareness training and practical guidance. We measure progress, report to management and the Board, and undergo independent Internal Audit. This commitment reflects the Bank’s dedication to ethical conduct, transparency, and the responsible use of technology.
Summary of our Privacy Policy
TF Bank is committed to the lawful and secure handling of personal data, in full compliance with GDPR and other applicable regulations. A robust internal governance framework is in place, with clearly defined roles and responsibilities, including a Data Protection Officer (DPO) who oversees compliance.
Personal data is processed only for predefined purposes and must be adequate, relevant, and limited to what is necessary. Data no longer needed is deleted unless retention is legally required. Confidentiality is maintained, and data subjects’ rights are respected and facilitated.
TF Bank ensures transparency in data processing, keeping individuals informed about how their data is used. Each processing activity is justified with a lawful basis. Data sharing with third parties is governed by formal privacy arrangements and conducted in compliance with legal requirements.
Personal data is securely managed using encryption, access controls, and regular audits to prevent unauthorized access, loss, or damage. TF Bank is prepared to respond effectively to data breaches through a structured incident response plan.
Continuous monitoring and risk assessments ensure ongoing compliance and improvement. All employees receive mandatory, role-specific training and participate in awareness initiatives to reinforce data protection responsibilities.