GRI index

GRI indicator	Description	Location in report	Reporting 2023
Organisational profile
2-1	Name of the organisation, ownership and legal form, location of headquarters, and location of operations	About KBN	Haakon VIIs gate 5b, 0161 Oslo. KBN operates in Norway.
2-2	Entities included in the organisation’s sustainability reporting		Kommunalbanken AS
2-3	Reprting period, frequency, dato of publishing, and contact person		01.01.2023 to 31.12.2023, annually, 14.03.24. Harald Jacobsen Head of Communication and Sustainability Mobile: +47 995 38 005 haj@kbn.com
2-4	Restatements of information		None
2-5	External assurance		The annual report as a whole is not externally verified. Greenhouse gas accounting in the annual report is externally assured.
Activities and employees
2-6	Activities, value chain, and other business relationships	About KBN Performance in 2023 Objectives for 2024	KBN borrows from around the world and offers low-cost loans to Norwegian municipalities and country authorities. The core of KBN's supply chain is its use of issue managers in connection with our funding activities. KBN also has agreements with and carries out financial transactions with a number of financial undertakings. Our financial agreements and transactions are subject to internal financial guidelines, which require, inter alia, that issue managers must be subject to anti-money laundering rules. KBN also purchases consulting services to a normal extent and goods and equipment for normal operations to a limited extent.
2-7	Employees	Statement on equality	84 employees, 36% women, 64% men, Oslo. Data gathered by head counting at the end of the reporting period. No large variations in total number of employees.
2-8	Workers who are not employees		Throughout 2023, KBN have hired 25 temporary workers, mainly consultants in IT, HR, Compliance og administrative services. Data gathered by head counting at the end of the reporting period. No large variations in number of workers.
Governance
2-9	Governance structure and composition	The Board of Directors of KBN The management team Organisational structure and governing bodies Sustainability	Minority backgrounds have not been mapped among the board members, but it is assumed that minority backgrounds are less represented on the board than the general population. The board is composed according to expertise in finance, risk management, legal, and municipalities and counties.
2-10	Nominating and selecting the highest governance body	Organisational structure and governing bodies Corporate governance	Meld.St.6 (2022-2023) Report to the Storting, Chapter 12.5
			https://www.regjeringen.no/contentassets/b45b4a63e301435293bd1b10d1ede45b/en-gb/pdfs/stm202220230006000engpdfs.pdf
2-11	Chair of the highest governance body	The Board of Directors	The Board of Directors and management team are independent.
2-12	Role of the highest governance body in overseeing the management of impacts	Organisational structure and governing bodies Sustainability	General guidelines are approved by the Board of Directors, and is reported quarterly.
			https://www.kbn.com/en/sustainability/our-sustainability-work/overall-guidelines-for-corporate-social-responsibility/
			https://www.kbn.com/en/sustainability/our-sustainability-work/requirements-for-suppliers/
			https://www.kbn.com/en/about-us/ethics/code-of-conduct/
2-13	Delegation of responsibility for managing impacts	Sustainability	The report is presented at each board meeting which occurs monthly.
2-14	Role of the highest governance body in sustainability reporting		The CEO is responsible for the implementation of sustainability. The audit committee is the preparatory committee for sustainability reporting to the board. The board reviews and approves reported information.
2-15	Conflicts of interest		https://www.kbn.com/en/about-us/ethics/code-of-conduct/
2-16	Communicating critical concerns	Objectives for 2024	It is reported to the CEO monthly and quarterly to the Board of Directors. No critical concerns reported in 2023.
2-17	Collective knowledge of highest governance body	The Board of Directors' main priorities in 2023 NUEs recommendation	A program is conducted for skills development among the directors with various topics, as well as a requirement for annual training in money laundring.
2-18	Evaluating the highest governance body’s performance	Organisational structure and governing bodies	An annual self-evaluation is carried out. It will be considered to implement measures if necessary. Examples are measures to increase competence, which has been done in the past in the fields of finance and IT. The administration helps to arrange this. Another measure is to change the area of responsibility for the individual on the board, and in more serious cases to replace board members. There has not been a need for this in the past. KBN is also subject to the EBA's guidelines for the suitability of members of the board and other key functions. In addition, a separate assessment form has been created for the sustainability work/ESG at the board.
2-19	Remuneration policies	Statement of financial positions, Note 4 Statement on equality	Guidelines for remuneration are meausred by compliance with the bank's value.
2-20	Process for determining remuneration	Organisational structure and governing bodies NUEs recommendation Statement of financial positions, Note 4
2-21	Annual total compensation ratio		The change in the CEOs total compensation is 2.96 times the average annual change in compensation for other employees, with the same percentage increase as the median percentage increase for other employees. Students are not included in the selection.
Strategy, policies and practices
2-22	Statement on sustainable development strategy	Forward The Board of Directors' Report 2023
2-23	Policy commitments		The guidelines are adopted by the board. KBN carries out regular risk-based vigilance assesments and maps and assesses actual and potential negative consequences. Annual review of the ethical guidelines are assessed internally. For suppliers, surveys are carried out as further follow-up on a quarterly, half-yearly or annual basis, depending on the supplier's size.
			https://www.kbn.com/en/about-us/ethics/code-of-conduct/
			https://www.kbn.com/en/sustainability/our-sustainability-work/overall-guidelines-for-corporate-social-responsibility/
			https://www.kbn.com/en/about-us/ethics/code-of-conduct/
2-24	Embedding policy commitments		https://www.kbn.com/en/about-us/ethics/code-of-conduct/
2-25	Processes to remediate negative impacts		A complaint channel has been created for customers to identify and process complaints: https://www.kbn.com/en/customer/complaints/ As of today, there is no concrete process for handling the complaints. The emergency plan includes 8 different scenarios with a description of how the crisis managment is carries out. The recovery plan is covered by ICAAP, where the CEO presents to the board at least annually an overview of the capital requirement together with a long-term capital plan. The communication plan must ensure that KBN's reputation is secured in the event of critical incidents that could damage the bank's reputaiton.
2-26	Mechanisms for seeking advice and raising concerns	Objectives for 2024 Statement on equality
2-27	Compliance with laws and regulations		KBN was not sanctioned or fined in 2023. What is defined as a significant case is included in the assessment system internally for operational risk management.
2-28	Membership associations		https://www.kbn.com/en/sustainability/our-sustainability-work/
Stakeholder engagement
2-29	Approach to stakeholder engagement	Sustainability
2-30	Collective bargaining agreements		39% of KBN's employees are covered by collective agreements. Employees are covered by the bank's own collective agreements even if they are not organised.
Energy
308	Management approach	Objectives for 2024
308-1	New suppliers that were screened using environmental criteria	Performance in 2023 Objectives for 2024	52% of new suppliers are assessed against environmental criteria.
Employment
401	Management approach	Objectives in 2024
401-2	Benefits provided to full-time employees that are not provided to temporary or part-time employees		All employees (expect students) have life insurance, health insurance, disability and invalidity cover through KBN. All employees are covered by KBN's leave and pension scheme. Figures include KBN's headquarters in Oslo. All employees have access to parental leave through KBN.
Training and education
404	Management approach	Objectives for 2024
404-1	Average hours of training per year per employee		85% of employees completed the "Kompetanseløftet" program in 2021, with a requirement of at least 15 hours duration. In addition, training was carried out in ethics, cyber security and various lectures for all employees.
404-3	Percentage of employees receiving regular performance and career development reviews	Objectives for 2024
Supplier social assessment
414	Management approach	Objectives for 2024
414-1	New suppliers that were screened using social criteria	Performance in 2023 Objectives for 2024	52% of new suppliers are assessed against social criteria.
Socioeconomic compliance
419	Management approach
419-1	Non-complaince with laws and regulations in the social and economic area		KBN was not sactioned or fined in 2023.

GRI indicator	Description	Location in report (page number)	Reporting 2022
Organisational profile
2-1	Name of the organisation, ownership and legal form, location of headquarters, and location of operations	About KBN (6)	Haakon VIIs gate 5b, 0161 Oslo. KBN operates in Norway.
2-2	Entities included in the organisation’s sustainability reporting		Kommunalbanken AS
2-3	Reprting period, frequency, dato of publishing, and contact person		01.01.2022 to 31.12.2022, annually, 27.02.23. Harald Jacobsen Head of Communication and Sustainability Mobile: +47 995 38 005 haj@kbn.com
2-4	Restatements of information		None
2-5	External assurance		The annual report as a whole is not externally verified. Greenhouse gas accounting in the annual report is externally assured.
Activities and employees
2-6	Activities, value chain, and other business relationships	About KBN (6), Objectives for 2023 (and 2025) (57), Performance in 2022 (55)	KBN borrows from around the world and offers low-cost loans to Norwegian municipalities and country authorities. The core of KBN's supply chain is its use of issue managers in connection with our funding activities. KBN also has agreements with and carries out financial transactions with a number of financial undertakings. Our financial agreements and transactions are subject to internal financial guidelines, which require, inter alia, that issue managers must be subject to anti-money laundering rules. KBN also purchases consulting services to a normal extent and goods and equipment for normal operations to a limited extent.
2-7	Employees	Statement of equality (64)	86 employees, 43% women, 57% men, Oslo. Data gathered by head counting at the end of the reporting period. No large variations in total number of employees.
2-8	Workers who are not employees		Throughout 2022, KBN have hired 25 temporary workers, mainly consultants in IT, HR, Compliance og administrative services. Data gathered by head counting at the end of the reporting period. No large variations in number of workers.
Governance
2-9	Governance structure and composition	The Board of Directors (30), Organisational structure and governing bodies (35), Performance in 2022 (55), The management team (32)	Minority backgrounds have not been mapped among the board members, but it is assumed that minority backgrounds are less represented on the board than the general population. The board is composed according to expertise in finance, risk management, legal, sustainability and municipalities and counties.
2-10	Nominating and selecting the highest governance body	Organisational structure and governing bodies (35), Corporate governance (39)	Meld.St.6 (2022-2023) Report to the Storting, Chapter 12.5: https://www.regjeringen.no/contentassets/b45b4a63e301435293bd1b10d1ede45b/en-gb/pdfs/stm202220230006000engpdfs.pdf
2-11	Chair of the highest governance body	The Board of Directors (30)	The Board of Directors and management team are independent.
2-12	Role of the highest governance body in overseeing the management of impacts	Performance in 2022 (55), Organisational structure and governing bodies (35)	General guidelines are approved by the Board of Directors, and is reported quarterly. https://www.kbn.com/en/sustainability/our-sustainability-work/requirements-for-suppliers/
2-13	Delegation of responsibility for managing impacts	Performance in 2022 (55)	The report is presented at each board meeting which occurs monthly.
2-14	Role of the highest governance body in sustainability reporting		The CEO is responsible for the implementation of sustainability. The audit committee is the preparatory committee for sustainability reporting to the board. The board reviews and approves reported information.
2-15	Conflicts of interest		https://www.kbn.com/en/about-us/ethics/code-of-conduct/
2-16	Communicating critical concerns	Objectives for 2023 (and 2025) (57)	It is reported to the CEO monthly and quarterly to the Board of Directors. No critical concerns reported in 2022.
2-17	Collective knowledge of highest governance body	The Board of Directors' main priorities (40), The Norwegian Code of Practice for Corporate Governance (43)	A program is conducted for skills development among the directors with various topics, as well as a requirement for annual training in money laundring.
2-18	Evaluating the highest governance body’s performance	Organisational structure and governing bodies (35)	An annual self-evaluation is carried out. It will be considered to implement measures if necessary. Examples are measures to increase competence, which has been done in the past in the fields of finance and IT. The administration helps to arrange this. Another measure is to change the area of responsibility for the individual on the board, and in more serious cases to replace board members. There has not been a need for this in the past. KBN is also subject to the EBA's guidelines for the suitability of members of the board and other key functions. in addition, a separate assessment form has been created for the sustainability work/ESG at the board.
2-19	Remuneration policies	Statement of financial positions (103), Statement of equality (64)	Guidelines for remuneration are meausred by compliance with the bank's value.
2-20	Process for determining remuneration	Organisational structure and governing bodies (35), The Norwegian Code of Practice for Corporate Governance (43) Statement of financial positions (103)
2-21	Annual total compensation ratio		The CEO is compensated 3.52 times as much as the average annual compensation for all employees, with a 1% higher increase than the median percentage increase for all employees. Students are not included in the selection.
Strategy, policies and practices
2-22	Statement on sustainable development strategy	Foreword (4), The Board's of Director’s Report 2022 (79)
2-23	Policy commitments		The guidelines are adopted by the board. KBN carries out regular risk-based vigilance assesments and maps and assesses acutal and potential negative consequences. Annual review of the ethical guidelines are assessed internally. For suppliers, surveys are carried out as further follow-up on a quarterly, half-yearly or annual basis, depending on the supplier's size. Ethical guidelines: https://www.kbn.com/en/about-us/ethics/code-of-conduct/ Our sustainability work: https://www.kbn.com/en/sustainability/our-sustainability-work/overall-guidelines-for-corporate-social-responsibility/ Code of conduct: https://www.kbn.com/en/about-us/ethics/code-of-conduct/
2-24	Embedding policy commitments		https://www.kbn.com/en/about-us/ethics/code-of-conduct/
2-25	Processes to remediate negative impacts		A complaint channel has been created for customers to identify and process complaints: https://www.kbn.com/en/customer/complaints/ As of today, there is no concrete process for handling the complaints. The emergy plan includes 8 different scenarios with a description of how the ciris managment is carries out. The recovery plan is covered by ICAAP, where the CEO presents to the board at least annually an overview of the capital requirement together with a long-term capital plan. The communication plan must ensure that KBN's reputation is secured in the event of critical incidents that could damage the bank's reputaiton.
2-26	Mechanisms for seeking advice and raising concerns	Objectives for 2023 (and 2025) (57), Statement of equality (64)
2-27	Compliance with laws and regulations		KBN was not sanctioned or fined in 2022. What is defined as a significant case is included in the assessment system internally for operational risk management.
2-28	Membership associations		https://www.kbn.com/en/sustainability/our-sustainability-work/
Stakeholder engagement
2-29	Approach to stakeholder engagement	Performance in 2022 (55)
2-30	Collective bargaining agreements		35% of KBN's employees are covered by collective agreements. Employees are covered by the bank's own collective agreements even if they are not organised.
Energy
308	Management approach	Objectives for 2023 (and 2025) (57)
308-1	New suppliers that were screened using environmental criteria	Performance in 2022 (55), Objectives for 2023 (and 2025) (57)	79% of new suppliers are assessed against environmental criteria.
Employment
401	Management approach	Objectives for 2023 (and 2025) (57)
401-2	Benefits provided to full-time employees that are not provided to temporary or part-time employees		All employees (expect students) have life insurance, health insurance, disability and invalidity cover through KBN. All employees are covered by KBN's leave and pension scheme. Figures include KBN's headquarters in Oslo. All employees have access to parental leave through KBN.
Training and education
404	Management approach	Objectives for 2023 (and 2025) (57)
404-1	Average hours of training per year per employee		87% of employees completed the "Kompetanceløftet" program in 2021, with a requirement of at least 15 hours duration. In addition, training was carried out in self-management, ethics, cyber security and various lectures for all employees.
404-3	Percentage of employees receiving regular performance and career development reviews	Objectives for 2023 (and 2025) (57)
Supplier social assessment
414	Management approach	Objectives for 2023 (and 2025) (57)
414-1	New suppliers that were screened using social criteria	Performance in 2022 (55), Objectives for 2023 (and 2025) (57)	79% of new suppliers are assessed against social criteria.
Socioeconomic compliance
419	Management approach
419-1	Non-complaince with laws and regulations in the social and economic area		KBN was not sactioned or fined in 2022.