Materiality analysis

DNB is dependent on trust and a good reputation. Trust is built when the Group’s stakeholders have confidence that DNB, over time, will create value for both the Group itself and for society.

The Group´s key stakeholders: customers, public authorities, shareholders, employees and society at large, have expectations regarding how DNB exercises its role in society through, among other things, its product and service offering, infrastructure and role as an employer. DNB will build trust by being open about how it works to meet stakeholder expectations.

Integrated reporting

DNB established an integrated report for the first time for the 2015 reporting year, whereby the stand-alone corporate social responsibility report was integrated in the annual report. The goal was to give a holistic picture of DNB’s value creation. For the reporting year 2016, DNB has taken a step further by establishing a comprehensive materiality analysis that includes more than traditional social responsibility topics. It shows a prioritisation of the long-term challenges facing DNB and is intended to give an overall picture of the challenges that have the greatest impact on DNB’s future value creation. The materiality analysis replaces the materiality analysis from 2014 and is the basis for DNB’s responsible operations and input to DNB’s future strategy work.

The work on the materiality analysis in 2016 is based on the framework for integrated reporting established by the International Integrated Reporting Council, IIRC. The framework has helped to clarify which input factors and associated challenges are important to ensure long-term value creation for DNB and for DNB’s stakeholders.

DNB’s challenges have been defined based on the following input factors (types of capital):

  • Financial assets and values
  • Systems and processes which enable effective management
  • Employees and their skills and motivation
  • Customers’ loyalty and perception of DNB
  • The status of the society in which DNB operates, and relations to key players

Based on the input factors, an analysis was prepared of the challenges the Group must resolve to ensure long-term value creation. The following topics were the basis for the analysis:

  • Regulatory requirements
  • DNB’s strategic platform
  • Feedback from external and internal stakeholders
  • Global and national challenges
  • DNB’s support to global initiatives
  • Specialist literature and best practice analyses

The analysis was first presented to a number of external and internal stakeholders in a structured dialogue where they were given the opportunity to speak freely about the challenges. The challenges were thereafter ranked in order of priority based on their relative importance to long-term value creation for DNB and for society. Contributions from the stakeholders were weighted differently. Customers and shareholders were given the highest weight, then the authorities, employees and society at large. The stakeholders were particularly concerned about how DNB safeguards its role in society. As Norway’s largest bank, DNB plays a key role in filling the social role of the financial services industry. Few industries have so many contact points with the Norwegian population as the financial services industry. In addition, the Group’s largest shareholder, the Norwegian government, represented by the Ministry of Trade, Industry and Fisheries, expects DNB, as a Norwegian bank, to take a particular responsibility towards the Norwegian population.

The complete analysis and the most important challenges have been considered and approved by the group management team and the Board of Directors and provide the basis for the work on and reporting of the Group’s responsible operations. The updated materiality analysis has been prepared in accordance with the GRI 4 guidelines. The key findings in the analysis can be grouped into three main challenges related to customers, employees and society, and are the basis for the further division of this chapter:

  • Master the art of serving the customer: is about customers being given what DNB promises, and preferably more. This entails that the Group must deliver future-oriented and responsible products and services.
  • Have the right competencies: is about having committed employees who know that they are helping to fulfill DNB’s role in society. This means that the Group must attract and develop people with the abilities and the knowledge needed to contribute to the changes facing the financial services industry.
  • Contribute to a healthy economy: is about how DNB can use its competencies and resources to help solve long-term social challenges. As Norway’s largest bank, DNB has a particular responsibility for promoting a financially sustainable Norwegian society.

Ensuring profitability and financial strength is deliberately not included in the materiality analysis because the targets in these areas are well established and communicated, and are a prerequisite for success in the other areas.

Prioritised challenges

DNB’s strategy

DNB’s strategic platform consists of the Group’s vision, values and a shared customer value proposition. The strategy emphasises capital efficiency, customer experience and corporate culture. Read more about this in DNB in brief.

DNB’s stakeholders

The financial services industry is changing and facing new requirements from a variety of stakeholders. Feedback from stakeholders will therefore be an increasingly important part of the work to ensure long-term value creation in the years to come.

Having a dialogue with stakeholders and integrating their input in the decision-making processes that affect them is an ongoing part of the Group’s operations. See an overview of DNB’s stakeholder dialogue in 2016 in DNB’s sustainability library.

Regulatory requirements

Section 3-3 c of the Norwegian Accounting Act sets requirements for reporting related to human rights, labour rights and social conditions, the external environment and the fight against corruption in business strategies, daily operations and in relation to stakeholders. Section 3-3 a of the Norwegian Accounting Act also sets requirements for the reporting of non-financial and key performance indicators, including environmental requirements, equal opportunities and discrimination. DNB meets regulatory requirements for reporting through its integrated annual reporting and through reporting according to the Global Reporting Initiative (GRI).

UN Sustainable Development Goals

Support to global initiatives

DNB has chosen, in addition to following Norwegian standards, to support and participate in a number of global initiatives and international guidelines to ensure responsible operations. Such initiatives are important for learning, knowledge sharing and influencing. They also provide input to DNB’s long-term value creation.

Read more about all the initiatives DNB supports and participates in at

One of the new initiatives joined by DNB in 2016 is the United Nations’ 17 sustainable development goals. When identifying the most important challenges for long-term value creation (the materiality analysis), development goals and their impact on DNB’s value chain were evaluated. Three of the development goals are particularly relevant to the Group’s challenges relating to long-term value creation and to how DNB can make a difference:

Goal 4. Ensure inclusive and equitable quality education and promote lifelong learning opportunities for all. DNB will contribute through the learning program “A Valuable Lesson”, which aims to give children and young people a basic economic understanding regardless of social background. Read more about DNB’s various training programmes.

Goal 8. Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all. DNB will contribute to increasing economic productivity by arranging capital for innovation and restructuring in Norway, among other things by supporting entrepreneurs. Read more about how DNB connects ideas with capital.

Goal 13. Take urgent action to combat climate change and its impacts. DNB will counteract, adapt to and reduce the impacts of climate change, as well as strengthen knowledge and awareness of this, which includes arranging green bonds, green mutual funds and investments in renewable energy. Read more about DNB’s renewable commitment.

Global and local development trends

Both global and local development trends influence the DNB Group’s strategy, value creation and business model today and in the period ahead. The changes represent both risks and opportunities for the Group and require that DNB adapts its operations. The most important changes include:

Changes in customer behaviour
  • The new banking reality is digital, and the mobile phone is the technological winner. Today, very few customers visit the physical branch offices.
  • Customers are the driving forces behind digitalisation, and their key requirements are simplicity, availability, quality and user-friendliness.
  • Technological developments have made the journey from idea to product launch very short.
  • Digital information is personalised and adapted to each individual customer.
  • New solutions are offered to everyone, also to non-customers.
  • Competition is increasing as new players are challenging the most profitable product areas, and the toughest competition is now coming from companies outside the traditional banking sector.
Regulatory framework
  • Stricter capital adequacy requirements mean that DNB must have more capital behind every krone lent to its customers.
  • The supervisory authorities (national and others) require more complex and frequent reporting.
  • DNB operates in a sector with strict regulatory requirements, but new players that are not comprised by the same type of regulations, may enter this market.
  • The EU’s payment services directive, PSD2, requires that banks give third party providers access to customers’ account information and the opportunity to initiate payments directly from the third party’s own systems. 
  • In periods of recession, corporate earnings are volatile, there is higher unemployment, more bankruptcies and a rise in impairment losses for the banks. 
  • Effective communication, mobility and information sharing are making the world smaller, while the division of economic power is changing.
  • Greater political agreement on measures to limit the emission of greenhouse gases increases the risk of regulatory, commercial or technological shifts which may influence DNB customers’ business operations.
  • Urbanisation and demographic and social developments change the lifestyle of private individuals and result in a new competitive situation for companies. Higher life expectancy and longer education increase the dependency burden on the productive part of the population, which leads to greater interest in saving for retirement and elderly care.
  • The global increase in wealth creates a larger middle class with special requirements and expectations.

Responsible investment

How investment helps to make the world a better place

Ruth Astrid L. Sæter
Stig B. Fiksdal

Every minute around the clock, shares are bought and sold worldwide. Like a bounding pulse, graphs rise, peak and fall as the value of commodities, companies and industries is defined with red or black numbers in a complex interconnected market where everything from politics to nature affects the direction of the graphs.

Almost anything can be bought and sold on the world’s stock exchanges. But is this right?

This is one of the questions Janicke Scheele, head of responsible investment in Wealth Management in DNB considers every single day.

“DNB has its own guidelines for ethical investments. These follow, on the whole, best practice in the market, as defined by the Government Pension Fund Global,” says Scheele.

Climate trend

DNB’s guidelines are to ensure that the Group does not invest in companies which contribute to serious violation of human and labour rights, grave harm to the environment, unacceptable greenhouse gas emissions and serious corruption. Mining companies or power producers which largely base their operations or income on thermal coal, may also be excluded. DNB also steers clear of companies which manufacture controversial weapons, tobacco and pornography.

“As an asset manager, we have three policy instruments we can use to be a responsible investor: exclusion, positive screening and active ownership,” says Scheele

At year-end 2016, 129 companies were on DNB’s exclusion list.  21 of them had breached DNB’s environmental criteria.

“The interest in climatic problems has grown over the past year, and in the wake of the Paris Agreement and the UN’s Sustainable Development Goals, customers expect that sustainability is part of a company’s profile. We have long had two environmental mutual funds: DNB Grønt Norden and DNB Miljøinvest. The first fund actively excludes companies with direct exposure to fossil energy and actively includes companies with an environmental profile.  DNB Miljøinvest invests globally in renewable energy and energy efficiency,” explains Scheele. As a step in reducing climate risk and carbon footprint, and according to best practice, DNB chose, in January 2016, to introduce climate and coal criteria in its guidelines for responsible investment.

Sustainability integrated in corporate governance

Martin Skancke, chairman of the board of the UN-supported Principles for Responsible Investment, PRI, confirms the climate trend:

“Climate is currently one of the most central topics for the financial services industry.  It is not just about getting rid of fossil energy sources, but about developing renewable energy. “There are tremendous opportunities for investors, but also risks, as some companies profit from restructuring, while others succumb to the changes. Investors have to ask themselves what their responsibility is. What can they do that serves the interests of both their customers and society? PRI’s aim is to get sustainable reporting integrated in financial reporting. Only then can potential investors assess how robust the companies actually are,” explains Skancke.

In the autumn of 2016, he participated in a dialogue the bank had with external stakeholders, together with some of Norway’s most prominent journalists and business leaders. DNB’s goal was to gather input on how the bank should develop further, and Skancke contributed with his extensive experience from the field of responsible investment. He points out:

“Those who have power must also take responsibility. And we can ask ourselves how responsible the financial community is for creating a better world.”

How responsible is DNB?

“DNB is a large institution, and we can probably say that it has a greater responsibility than many others. DNB’s success depends on a generally healthy Norwegian economy. The bank reflects the Norwegian society. DNB should, therefore, always think holistically as an investor,” says Skancke.

“We believe that we do this,” says Janicke Scheele and elaborates: “For example, it is not always best to exclude companies. As active owners, we can invest in and influence companies that are in the process of becoming sustainable. In this way, we contribute towards greater accountability and good returns. We are often in dialogue with a company’s management throughout the year, and we use our voting rights actively in general meetings.”

Read more about DNB’s work within responsible investments.



Customers are some of DNB’s most important stakeholders. To deliver good customer experiences every single day is necessary in order to gain trust, high customer satisfaction and loyalty, and is critical to DNB’s existence. Customers increasingly expect good experiences, driven by the pace of change and innovation in other industries and by new market entrants in the financial services industry.

Positive customer experiences make DNB more attractive to both existing and new customers and are therefore important for loyalty and new sales. DNB’s aim is that customers shall have such good experiences that they talk positively about and recommend the bank to others. This is how DNB will give its customers extra value among market participants offering the same prices and terms and conditions. It should be easy to become and remain a customer of DNB, and customers should experience that the bank is there for each one of them, and is trustworthy and helpful. The individual business areas are responsible for ensuring good customer experiences in their own sphere of responsibility. The brand management division in Corporate Communications is responsible for brand experience at group level and supports the business areas’ work.


To find out whether DNB takes the right choices for its customers, it is important to involve the customers themselves. Measuring how satisfied customers are gives a picture of whether or not DNB is succeeding in the market. However, this does not necessarily provide the answers to what the Group has to do differently to better succeed. Therefore, it is becoming increasingly common to involve customers in product development and to make adjustments based on their feedback. Based on this, DNB has, among other things, employed service designers who work with product development in all of the bank’s customer segments. The designers are hired for their ability to design simple, easy-to-use solutions that meet customer needs. More service designers will be employed in the period ahead.

DNB measures preference towards the Group and perceived customer experiences based on a number of target indicators among own customers and non-customers. The two key target indicators in 2016 were the customer satisfaction index, CSI, which measures how satisfied DNB’s own customers are, and the reputation score, which measures how the population perceives DNB as a company and as a brand. These are seen in the context of other overarching preference and loyalty targets. Insight from customer satisfaction and reputation surveys is key to the further development of DNB and for the priorities that must be made. Based on the results of the surveys, concrete action recommendations are developed, which are considered quarterly at group level and in the various customer segments. The results of the customer satisfaction index and the reputation survey are published in the Group’s quarterly reports.

In addition, customer satisfaction is measured by following up customers straight after they have been in contact with the bank. Customers who have taken out a home mortgages, purchased savings or insurance products, called the customer centre, visited a branch office, been through a claims process or used DNB’s online chat service, answer questions to give feedback on the specific experience or service. In addition, advertising campaigns, events and other specific customer initiatives are evaluated. A variety of systems and methods are used, which are adapted to each channel, service or customer segment.

The solution that gives the highest number of responses from customers is a text message service which DNB has developed in cooperation with Telenor, and is sent to customers who have contacted DNB by phone. Negative feedback in this survey is followed up manually by the managers working in the customer centre.

If customers have complaints, the aim is to always address these at the first point of contact. Nevertheless, there are cases where the complaint must be dealt with by DNB’s complaints departments. The people who work in these departments aim to turn negative customer experiences into something positive.

In order to understand customers’ evaluations and gain more insight in customer needs, the Group conducts a number of different surveys. Overarching surveys of underlying drivers and in-depth analyses of customer segments and product areas are carried out to understand customer needs related to, for example, a service or channel/interface. A range of methods, both qualitative and quantitative, are used to understand the underlying needs that are essential to meet to ensure good customer experiences.


The target for the reputation score in 2016 was 70 points, while it was 80 points for the customer satisfaction index. The reputation surveys showed a negative trend in 2016. Customer satisfaction among personal customers was 73 points at year-end 2015, whereas it was 67 points in the fourth quarter of 2016. The reputation score was 70.1 points at year-end 2015 and 64.0 points in the fourth quarter of 2016. The main reason for the decline in both the customer satisfaction index and the reputation score was single major issues and measures which had a direct impact on perceived customer value for the individual customer. Panama Papers and the Dakota Access Pipeline must be mentioned among these issues, while price changes, such as fees for ATM withdrawals, negatively affected perceived customer value. The Greenwich Quality Index showed that customer satisfaction increased in 2016 among the bank’s large corporate customers, and DNB received the best score among the banks in Norway in this survey. The Personal Banking business area also reported positive feedback due to good customer experiences at contact points such as the Group’s customer centre and customer advisers, general availability and digital contact points, such as Vipps and chat.


In 2017, the evaluation of total customer experiences will be extended to include many of the new contact points. The target for 2017 is a customer satisfaction index of 78 points and a reputation score of 70 points. In order to further improve customer satisfaction and reputation, it will be important to deliver good customer experiences that prove that customers can have confidence in DNB, that the Group delivers relevant products and services, and that it is simple to be a DNB customer. The bank must prove to its customers that it acts in their best interests through its actions and product and service offerings.

Read more about customer experiences in the section “Provide ethical products and services” below. Information on customer satisfaction for large corporates and international customers can be found in the business review section.



DNB, like the financial services industry in general, is experiencing rapid changes in its surroundings. There is a steady stream of new technological solutions and new market entrants from other sectors, customer expectations are changing, and DNB is facing new requirements due to changes in regulations. The changes entail challenges, but also offer new opportunities. The digital shift in society is affecting all of DNB’s business areas and support units, and it is necessary to deliver swiftly and meet new customer needs in order to survive as a bank in the long term. DNB must effectively identify and realise new business opportunities, while continually improving and automating existing operations.


The pace of innovation and the ability to deliver on new customer needs is about developing future-oriented solutions that keep up with customer habits and needs, changes in the market and the regulatory framework and new offerings from new and traditional competitors. DNB must capitalise on existing and new customer data to increase sales, profitability and customer satisfaction through increased relevance and personalisation.

The Board of Directors defines, together with the group management team, the most important strategic initiatives to reach ambitions and goals in light of the digital shift. These are operationalised in the business areas and support units, and development needs are defined to realise goals and plans. IT presents the proposals to the group management team on a quarterly basis for approval of related IT investments. Important strategic clarifications in connection with goals and plans are also elevated to group management on an ongoing basis. Based on guidance from the Board of Directors about what will be important for the bank in the future, group management has approved and initiated seven group projects. The projects comprise, among other things, better use of customer insight, a faster pace of innovation and preparation for compliance with the Payment Services Directive, PSD2. Each of the projects is directly owned by a group executive vice president, and since many of the consequences of the projects will affect the entire Group, the entire group management team represents the Steering Committee.

During 2016, DNB worked to increase its capacity within digitalisation and innovation. One of the measures was to establish the Digital Floor. This floor is used for time-limited digitisation activities such as design sprints, scoping and solution workshops in projects, as well as high-priority digitisation projects. In addition, dedicated employees (service designers, sprint facilitators and innovation specialists) are hired and trained to facilitate and drive these activities forward.

Another initiative is to implement new working methods such as agile, devops1) and design-driven product and service development. All development of new customer functionality is now based on one or more of these methods, and the result is better customer experiences and faster time-to-market.

DNB has started an internal academy to train account officers in the corporate customer units to become better strategic advisers within total financing solutions. DNB is also planning to put together more integrated customer teams with representatives from various relevant parts of the Group. The management of working capital is also increasingly important for many customers, and a separate unit has therefore been established with a stronger focus on this.

1) Development methodology with ongoing releases up until production, based on close collaboration between development and operational resources and a high degree of automation.


In 2016, Vipps and home mortgage digitisation were the largest projects that were delivered in this way. The result is that the areas of application for Vipps have expanded rapidly, such as “split a bill”, e-commerce payments to companies, in-app purchases and invoice payments. In 2016, DNB achieved an even stronger position in the Norwegian market, entailing a four-fold increase in usage, with 1.1 million new Vipps customers in 2016. Vipps Invoice was launched in 2016.

Within home mortgage digitisation, DNB has so far, probably as the first bank in the world, managed to achieve a fully digitised process for extending existing mortgages, from application to payment on account. The new refinancing solution is far simpler and faster for customers. In addition, the proportion of digital refinancing applications has increased, while the processing time has been reduced due to the new solution. DNB Markets is experiencing an increase in the use of digital self-service solutions within securities and foreign exchange trading.

Innovation and development affects everyone in the Group, which is why this is reported on in the quarterly employee surveys. Employees’ perception of the innovation status in the organisation gives an indication of how well this is rooted in all parts of the Group. In the latest survey, in the fourth quarter of 2016, the score was 82 points. No target was set for this score in 2016.

Cooperation with start-up companies was also an important factor within innovation in 2016. DNB started NXT Accelerator and will eventually launch the DNB Fintech platform to identify possible cooperation opportunities with promising Norwegian fintech and technology companies. As the bank becomes even more of a technology company, it will be natural to use the same methods as the world’s leading technology companies to drive innovation. These companies constantly identify and acquire promising companies with technology which fits well into their strategy, with the intention to improve, further develop or innovate the company’s business model. DNB sees it as an opportunity to partner with technology companies to swiftly create the best customer experiences. Read more about DNB NXT Accelerator.

To retain existing customers and attract new customers in both the personal and corporate markets, it is important that DNB continues to invest in better customer experiences. The companies that win customer loyalty in the long run, are those who manage to solve customers’ problems in the best manner. This means putting customer needs first and seeing the profitability of a product/service in a longer perspective. An example is person-to-person payments, where the launch of Vipps has helped to make everyday life easier for customers. Even though the bank does not make money through this Vipps service, it has created a user base which DNB can capitalise on through other solutions, such as Vipps Invoice.


In the personal customer market, the main ambition for 2017 is to be able to offer all of the bank’s services wherever the customer is. This means on mobile phones, via the 24/7 chat service with immediate response, personalised advice and services, and swift responses to applications and requests. The main channels will be Vipps, the mobile bank and chat. The aim is that Vipps Invoice will be adopted by an increasing number of personal and corporate customers.

In the corporate market, the focus is on neutralising the lead the Group’s main competitors have in the field of cash management, offering digital versions of existing manual advisory services, contributing to the full digitisation of customer processes (such as digital signing of all documents), as well as offering better credit services (for example, proactive overdraft facility when the bank sees that a company is heading into a short-term liquidity squeeze, and invoice purchases). In addition, real-time payments will be implemented for all customer segments and key currencies, and customers will be offered better and more automated accounting and ERP2) functions through cooperation and competition with accounting and ERP suppliers.



DNB has a responsibility to help ensure that the banking industry delivers ethical products and services and has to make conscious choices related to what should be offered, how this is delivered and to whom. The choices DNB makes affect individuals, society, companies, industries and financial stability in Norway, and will in turn affect the confidence the surrounding world has in DNB. DNB’s existence is dependent on trust from all of its stakeholders. Trust is earned or damaged when DNB delivers products and services that surpass, or deviate from, what is expected.


DNB’s group policy for corporate social responsibility is normative for all product and service development. Under the policy, DNB is committed to take into account sustainability and ethics in all its activities, including the development of products and services, advisory services and sales. The group guidelines for product development are part of the risk management framework. In addition, Norwegian laws and regulations and expectations from stakeholders must be observed. The group guidelines for ethics (the code of ethics) are intended to contribute to increasing the awareness of and compliance with the high ethical standards which are required to be observed by DNB employees. A fundamental principle is open, clear and truthful communication which safeguards customer interests in connection with sales and advisory services. Both the group policy for corporate social responsibility and the code of ethics are approved by DNB’s Board of Directors of DNB. Read more about this in the corporate governance section.

DNB requires that its employees comply with high ethical standards. This is of value both for the Group as a whole and for the individual employee, and is regarded as part of the responsibilities DNB has as a player in Norwegian society. Ethical topics are emphasised in all parts of the organisation, something which is regarded as a considerable contribution to maintaining the necessary trust from the outside world. DNB is working together with other players in the financial industry to promote a marketing standard for the industry with respect to credit cards and consumer loans to clarify the significance of responsible credit card use.

An important task is to implement ongoing measures aimed at all employees in Norway and in the organisation’s international operations to ensure the right attitudes. Based on a risk-based approach, targeted initiatives are implemented in those parts of the organisation which are deemed to be most exposed to ethical challenges and potential breaches of the law. This applies particularly to those parts of the large corporate and SME business areas that have considerable exposures in countries with a higher level of corruption or lower protection of the environment or labour rights etc., as well as to the units in DNB which buy products and services from such countries.

Training and other activities are tailored so that employees know what is expected of them. The implementation of such training is mandatory for all employees, both in and outside Norway, and managers have a particular responsibility for following up their employees in this respect. In addition, ethics is a key topic in the introduction programmes for new employees and new managers.

In the personal banking market, it is important that DNB offers products and services which are tailored to the individual customer, and that the customers get the information they need to make the best possible choices. In cooperation with the rest of the financial services industry, DNB has supported three measures which will have effect in the short term: a common Norwegian debt register, an industry standard for the marketing of credit cards and consumer loans, plus better invoicing practices in the industry. The debt register is expected to be in place in 2018, while the marketing standard and invoicing practices will be introduced in 2017.

DNB works to increase awareness among consumers through the A Valuable Lesson project, which is aimed at children in fifth to seventh grade (10-12-year olds). See more under “Promote financial literacy” in the chapter Contribute to a healthy economy . A new DNB strategy for credit cards and consumer loans is also currently being drafted.

Conduct risk can be described as non-compliance with ethical principles and generally reprehensible conduct. DNB is strongly aware of the risk that may arise due to the Group’s conduct in sales processes and business practice to help ensure that legal disputes such as the so-called Røeggen and Eiendomsinvest cases do not occur in the future. An updated framework for risk management is currently being drafted. This will clearly define the importance of the topic of conduct risk. Ethical dilemmas and assessments related to conduct risk will be integrated in various parts of the Group’s compliance training.

DNB has an internal notification procedure whereby employees can report their concerns about unethical or unlawful behaviour, or other reprehensible matters that are at odds with organisational integrity. There is a link to the internal notification web page on the Group’s intranet. The web page is in several different languages and internal notifications are sent by email to DNB’s group chief audit executive. All employees are informed about the notification mechanism through the Group’s ethics training. DNB’s employees are protected from reprisals or the like resulting from notifications. This is described in the code of ethics. In 2016, the group chief audit executive received fewer than 20 notifications. This was at approximately the same level as the year before.


As a consequence of the review of DNB’s internal notification procedure after the so-called Panama Papers case, the Board of Directors has initiated a process to establish a solution for anonymous, electronic notification to an external party, in addition to the internal notification procedure. Notification is being expanded to include external employees. Read more about the Panama Papers case in the Group chief executive’s statement and “The Board of Directors actively followed up the Panama Papers case” and in the stakeholder dialogue table in the sustainability library.

In the second half of 2016, new group guidelines and procedures for the approval of products and services were drafted. This measure was implemented as compliance with the existing guidelines and policies in this field have not been good enough.

DNB did not receive any fines related to marketing or product and services branding during 2016. The Norwegian Consumer Council notified in January 2016 that they would bring a civil action against DNB related to the management of the DNB Norge funds, and DNB received the writ of summons in June. DNB is of the opinion that the DNB Norge funds have been actively managed and created significant value for the unit holders. DNB’s calculations show that over the past ten years, two of three customers have received higher returns than if they had invested in an index fund. The court hearing is expected to take place in the course of 2017. See note 52 to the annual accounts.


The new group guidelines for the approval of products and services will be implemented in 2017 and will:

  • include a wide range of assessment and decision points for the approval, but also for the ongoing monitoring of products and services (including social responsibility, ethics and reputation, etc.)
  • ensure that the assessments of products and services always take into account the customer segment to which they are offered
  • support development processes with swift time-to-market and rapid changes in products and services after the launch
  • clearly place the responsibility for products and services offered to the various customer segments

In order to succeed in the future, it is important to monitor the implementation of the new routines for the approval and follow-up of products and services. In addition, competence enhancement must continuously be on the agenda. It is important to have knowledge about what it takes to be a responsible provider of financial products and services in the markets where DNB operates, where changes occur rapidly and where stakeholders set clear requirements. Ever-new combinations of technology and financial services are challenging the established norms related to responsible products and services, for example privacy protection, information security and availability. In order for DNB to act ethically and sustainably in a long-term perspective, it is necessary to challenge the organisation with respect to potential changes.



DNB handles large amounts of customer data of both a personal and business nature. The quantity of information increases in step with the offering of digital products and services. New technological solutions and an increasingly complex threat scenario require that employees understand relevant risks and how customer information should be managed in a secure manner. This is crucial in preventing information from going astray and in maintaining customer confidence. In 2016, the digital threat scenario and incidents aimed at DNB were characterised by various forms of fraud, the development of Internet bank viruses and attempts at digital espionage. The challenges facing DNB are the same that are hitting the entire financial services industry, in Norway and internationally.


Privacy protection comprises the fundamental rights of individuals, such as the right to privacy, and the right to be able to decide over one’s own personal data. The processing of personal data affects customers’ confidence in DNB. DNB is working actively to ensure that personal data is processed in accordance with the requirements laid down in the EU’s new General Data Protection Regulation (GDPR). This privacy protection regulation is expected to come into force in the form of a new Norwegian Privacy Protection Act in May 2018. DNB has a privacy protection ombudsman who is responsible for processes related to the right of inspection, the right of protection, privacy protection inquiries, as well as notifications to the Norwegian Data Protection Authority in the event of any unauthorised disclosure of personal data. DNB reports and follows up deviations in accordance with prevailing regulations. The existing process for deviation management will be revised as part of the action plan for privacy protection for the period 2017-2018.

In addition, DNB has a separate security policy governing the Group’s work within this area. To support the security policy, the Group has guidelines and rules on information security and the handling of personal data which shall be taken into consideration in all system solutions, products, processes and services.

After the Group’s requirements related to information security and management thereof were revised in 2015, DNB implemented the changes in 2016. Risk related to information security is reported each quarter to the group management team and the Board of Directors. An annual review of DNB’s threat scenario is submitted to the group management team.


DNB is heading towards more automation and digitalisation, and the field of information security is no exception. In 2016, an action plan was established for information security, and progress is reported to the group management team. Great emphasis has been placed on technical safeguards to prevent fraud in a better and more effective way, and this will continue in 2017. Following up IT suppliers is also an important part of the security work.

DNB wishes to help customers to become better protected against cybercrime. In 2016, DNB held customer seminars where advice was given on information security. Customers have access to information and advice on the safe use of the Internet bank, bank cards, the mobile bank and other services on Customers are notified if they have an Internet banking virus on their computers.

DNB cooperates with private and public institutions, both in Norway and internationally, to prevent crime. DNB has been an initiator of and contributor to FinansCERT, an organisation which contributes to the handling of security incidents across the industry. Furthermore, DNB cooperates closely with, among others, the National Criminal Investigation Service and reported several incidents to the police in 2016. On account of its security measures, DNB is a safe and secure financial services institution for its customers and business partners.


Having the required expertise and sufficient awareness among the Group’s employees is a key factor in risk mitigation. In 2016, an interactive training program was developed and distributed to all employees. As in previous years, National Security Month events were held in October. This is a comprehensive campaign across the entire Group covering various topics within the field of information security. The activities are measured and evaluated, and DNB will continue to work strategically with security communication and training in 2017.

At the end of 2016, DNB established a group-wide privacy protection plan of action for the period 2017-2018. The action plan comprises improvements in governing documents and rules and regulations, and will contribute to quality improvements in the processing of personal data in the Group’s processes and the related IT infrastructure. In addition, DNB will increase awareness and knowledge of privacy protection among its employees.

Read more about targets and measures under the topic “The art of serving the customer” in the sustainability library.


Ensure engaged employees

Why this is material

The financial services industry is in a period of rapid change when innovation, technology, competitiveness and customer insight are becoming increasingly important. Employees must therefore meet new requirements, and this affects, not least, how DNB puts together the Group’s collective expertise. In order to meet the needs of tomorrow, DNB has to both attract new competencies and develop what the Group already has. Tomorrow’s employees will also have different requirements which their employers will have to meet. These factors must be taken into account when organising various tasks and to ensure that the Group will continue to be an attractive employer.

Policy and approach

To achieve its business goals and succeed with the vision “the art of serving the customer”, DNB is dependent on having engaged and motivated employees. HR has the main responsibility for this. The direction of the DNB organisation’s cultural and competence development is determined by the group strategy and is also affected by the increasing pace of digitalisation. The group policy for people and organisation is guiding for the work to promote adaptability and change capacity. The policy is elaborated on in the guidelines for attracting and appointing new employees and the guidelines for leadership and competence development.

The group policy for people and organisation states that competence development is based on the Group’s strategic and business targets and should enable the individual employee to capitalise on his or her talents. Managers must ensure that employees have clearly defined goals for their work and that each individual sees the connection between his or her work and the Group’s value creation. DNB facilitates professional and personal development so that employees are stimulated and given the opportunity to develop their competencies.

DNB’s variable remuneration scheme is in compliance with the Group’s guidelines and supports strategy, it´s financial targets and values. The total remuneration should be competitive and cost-effective and not expose the Group to unwanted risk. The Group’s total limit for variable remuneration is determined annually by the Board of Directors’ Compensation Committee. Individual remunerations are awarded within defined limits in each unit based on a total evaluation of the individual employee’s pre-agreed financial and non-financial goals.

Evaluation of results in 2016

One of the measures which particularly contributed to a high level of engagement and a sound understanding of the Group’s strategic direction in 2016 was the introduction of the interaction platform @work (Facebook for companies), a vital tool in ensuring increased information sharing, transparency and engagement in the organisation. Another important initiative was the Brand Ambassador programme, which highlights employees who can be used as role models in the way they are present for customers and colleagues, and creates engagement and positivity about and in DNB.

In the future, the employees’ expertise will become an even greater competitive advantage. Each employee is expected to take responsibility for making him/herself relevant when competency needs change. In DNB, employees can improve their skills through internal and external training activities and, not least, through knowledge sharing at work. Opportunities for competency development are crucial for both employee engagement and long-term value creation.

In 2016, learning and development activities for the Group’s managers placed particular emphasis on change management and innovation through mass communication, manager seminars and management development programmes. The Group’s prerequisites for change, innovation and employee engagement are measured three times a year through the PULSE employee survey.

DNB has initiated a programme for managers called Performance Management, which is specifically aimed at enhancing performance among employees who work in the personal banking market. The programme has three focus areas: clear targets, close follow-up of employees and constructive feedback. It is confirmed through the employee satisfaction surveys that the involvement of individual employees increases motivation and engagement.

However, the most important arena for learning and ensuring that the Group has the right competencies is each employee’s daily work tasks. To ensure that all employees can deliver to the best of their ability, a system is in place to ensure a regular dialogue between managers and employees. It is expected that everyone in the organisation has a minimum of two annual meetings related to their targets and development. 94 per cent of employees reported that the performance dialogue was carried out in 2016.

In order to attract and retain individuals with critical expertise, the business areas may have remuneration schemes adapted to market practices which deviate from the Group’s other schemes. It is a guiding principle in DNB is that all remuneration should be based on an overall assessment of the individual employee’s contribution to the attainment of the Group’s, the unit’s and individual goals. The remuneration schemes of DNB’s international offices and subsidiaries are adapted to local labour markets and regulations.

Throughout 2016, periodic PULSE surveys were conducted which comprised all of the Group’s employees. The results showed that there is a high level of employee engagement and that managers communicate well. The PULSE surveys for 2016 paint a picture of a robust organisation that has fared well through significant restructuring. The low sickness absence rate is also an indication that the employees are engaged in their work. In 2016, sickness absence was 4.5 per cent, compared with 4.4 per cent in 2015. In 2017, efforts to maintain a stable, low sickness absence rate will continue.


As of 2017, change and innovation constitute a target that both the Group and each business area and support unit will be measured and followed up on. The target in the period up until 2019 is still to ensure motivated employees. This means improving the engagement index in the annual employee survey, strengthening the corporate culture through new initiatives and following up managers’ quarterly management communication results.

PROMOTE adaptability and change capacity

Why this is material

In the past, DNB has proven to have a great ability to adapt to change, be it in the markets, the competitive situation or the regulatory framework. The Group has succeeded in changing its competencies and capitalising on past experience. The speed and complexity of the changes are now challenging DNB’s ability to be fundamentally innovative.

Due to digitalisation within most areas in the Group, there is a need for new competencies and fewer resources in the future. Automation will displace work tasks, and changes in customer behaviour make it vital to have expertise in new technology and other working methods, products and services.

Policy and approach

The group policy for people and organisation is guiding for the work to promote adaptability and change capacity. The policy is elaborated on in the guidelines for the restructuring and placement process, leadership and competence development and international assignments. All employees in units which are affected by restructuring processes involving redundancies are invited to mapping/guidance interviews.

Learning takes place primarily through the employees’ daily tasks, i.e. by performing challenging tasks and projects, as well as through feedback on performance. Structured and targeted training programmes are also offered as a supplement. Managers are responsible for facilitating learning and ensuring that competence acquired is used in the best interests of the individual and the DNB Group.

DNB’s Job Centre has been established to, among other things, help and support the employees in the resulting change processes. The purpose of a stay in the DNB Job Centre is to help employees become aware of their own skills and enable them to search for relevant vacant positions internally or externally. They can receive guidance and coaching in connection with the choices they need to make, and internal and external periods of secondment are facilitated so that they can acquire new skills. Employees who, for various reasons, are unable to continue in their positions are also offered alternative tasks or necessary adjustments. By cooperating with humanitarian organisations, the Job Centre has been able to offer meaningful tasks in several areas.

Evaluation of results in 2016

Through 2016, a total of 212 employees visited the Job Centre to receive help and support. 28 employees left the Group, while 78 employees were offered a new job in DNB. The Job Centre assisted 188 employees with health-related challenges. The turnover for the DNB Group was 5.4 per cent. There were no significant differences between women and men. 816 new employees were recruited. See the key figures table below for more information.

Competence and talents must also be nurtured well in the business areas, and the Group has a range of training measures.

In 2016, new group principles for competency development were developed. They emphasise the responsibility of each person to stay updated and the importance of everyone acquiring digital skills. Through the year, further emphasis was placed on making training measures as effective and accessible as possible through the use of digital training programs.


It will be challenging to implement adequate internal organisational adjustments in the future. The Group’s competency needs cannot be covered solely through internal competence development, and external recruitment will be necessary. As other companies and industries are experiencing the same challenges, the job market will be demanding in the period ahead.

Attract and develop talents

Why this is material

In an industry with a high pace of change, the Group is also being challenged with respect to its total competence profile. While the greatest emphasis used to be placed on traditional financial expertise, it is now necessary to further develop the organisation’s digital skills. This will affect those who are already working in DNB and also require that the candidates the Group wishes to attract, have a different competence profile. DNB must become a more attractive employer for people with special skills who do not necessarily have banking as their preferred sector.

Policy and approach

The group policy for people and organisation is guiding for the work to promote adaptability and change capacity. The policy is elaborated on in the guidelines for attracting and appointing new employees and the guidelines for leadership and competence development.

In order to establish a clearer profile towards digital professionals, DNB has gone new ways to attract employees in the fields of technology and innovation. Two competitions, DNB Digital Challenge and Vippsathon, were held in 2016 and have resulted in the appointment of new graduates, part-time employees and summer interns.

Evaluation of results in 2016

DNB is one of the most attractive employers in Norway and in 2016 was ranked number one by business students in Universum’s survey for the second year in a row. Furthermore, DNB was for the first time voted the country’s most attractive employer in the category “Business” by “Professionals”, i.e. persons who have a few years of work experience.

DNB has also increased its attractiveness among IT students and was ranked as the fifth most attractive workplace. This shows that DNB benefits from a very attractive position when it seeks new employees outside the Group. 67 students were on a summer internship in DNB in 2016.

In 2016, DNB recruited seven new candidates with different backgrounds and experience to its group trainee programme. During the two-year programme, the trainees work in five different units, including three months at one of DNB’s offices outside Norway. The candidates follow an individually tailored programme and are assigned a mentor at management level.

DNB is also committed to retaining competent employees and search for potential in each individual manager and employee. Talent reviews are conducted on an ongoing basis where performance and potential are considered in order to develop managers and employees to make them able to meet new challenges and tasks.

DNB’s managers play a vital role in employee development and in ensuring that DNB achieves its goals. Leadership in DNB is based on three principles: create results, develop individuals and teams, as well as set direction and drive change. The principles are described in DNB’s governance principles.

DNB offers business-critical training through four professional academies in the fields of credit, savings, insurance and cash management to the entire Group. Among other things, the academies offer training in accordance with industry requirements determined by Finance Norway governing the sale of non-life insurance and savings products. 2 468 employees participated in training through DNB’s academies in 2016. 9 471 employees completed group-wide training measures through @work, which is close to a doubling from 2015. NOK 2 339 was spent on competence development measures per employee, which is on a level with 2015. DNB attaches great importance to strengthening employee knowledge and awareness of ethics, anti-money laundering, counter financing of terrorism and information security. DNB is dependent on having good access to both specialist professionals and good managers who succeed in creating change and developing their own units. DNB has facilitated development programmes aimed at both management talents and top executive talents, and the participants have taken on greater responsibilities both during and after the programmes.


In 2017, DNB will appoint approximately 100 employees with IT expertise. DNB will continue to be the most attractive employer for students.

ensure equality and diversity
Why this is material

The DNB Group is committed to being a fair and professional employer which sets a good example in areas such as diversity and women in management. The reason why DNB has put this high on the agenda is that gender balance and diversity in ethnic and formal backgrounds in senior executive positions will help ensure that DNB delivers better results. Since DNB is Norway’s largest bank, what happens in the Group will also be significant for equal opportunity initiatives in the financial services industry.

Policy and approach

DNB is committed to equal pay, regardless of gender, for the same work and performance. The Group will continue to differentiate pay based on performance, but the ambition is to correct historical imbalances. In 2016, the bank set aside an ‘equal pay pool’ of NOK 17 million to equalise imbalances that cannot be explained by factors other than gender. A plan of action for equal pay has been drafted in cooperation with the trade unions, summarising various initiatives in the Norwegian part of the Group. The action plan addresses, among other things, equal participation, a balanced gender ratio as one of the job assignment criteria in restructuring and employment processes, internal mentor and network schemes for women, mapping and analysis of pay levels and pay differences in units, equal pay guidance and quality assurance in salary and bonus settlements.

The Group’s recruitment guidelines help ensure quality, diversity and non-discrimination in selection processes. Local regulatory requirements are complied with and DNB has a zero-tolerance approach to discrimination in recruitment processes.

There is great ethnic and national diversity in the Group’s international operations, and concrete measures have been initiated to increase diversity in the Group’s Norwegian operations. In recruitment initiatives targeting students, gender and ethnic background are emphasised. DNB is also working actively to attract employees from a broad selection of educational institutions and disciplines.

DNB has set several targets to ensure sufficient access to talented women managers: minimum 50 per cent female representation in internal management development and talent programmes, and minimum 40 per cent women candidates on lists for succession planning. Managers are required to identify potential talented women managers and use performance dialogues to motivate these to seek management challenges. Internal mentor and network schemes for talented women managers have also been established. In recruitment processes for management positions, the best qualified male and female candidates must be identified before the final choice is made. When recruiting managers, procedures must be in place to ensure that female candidates are identified, and these should be actively encouraged to apply for the positions. A balanced gender ratio should be one of the job assignment criteria in restructuring processes. When changing the composition of management teams, particular emphasis should be placed on achieving a better gender balance.

Evaluation of results in 2016

DNB has set a female representation target at the top four management levels of minimum 40 per cent. The Group has implemented various measures to achieve this target. At the end of 2016, the percentage of women in senior management positions was 33.5 per cent, a rise from 31.3 per cent in 2015. The targets in this important work have not yet been reached, but DNB is making good progress. The Group focused on the measures to improve the gender balance at the various management levels in 2016, and they are well established in the business areas. The organisation is positive to the implementation of these measures, which has become reinforced by the positive attention received both in the media and from other businesses and research institutions. DNB received the annual equal opportunity award from the Norwegian Confederation of Vocational Unions (YS) for its work to improve equal pay and equal opportunities in its operations.


DNB will increase its initiatives to promote individual development of leadership skills among selected women managers and management talents, and ensure a gender balance among managers and profiled key persons who speak on behalf of the company internally and externally. Important future targets will be to develop strategies and measures to ensure equal opportunities for men and women, and to increase diversity among employees and managers. This will apply in particular to the Norwegian part of the Group’s operations since there is already great ethnic and national diversity in the Group’s international units. In all parts of the Group’s operations, there is a zero-tolerance approach to discrimination on the basis of, for example, ethnic background, functional ability or gender, and DNB shall ensure good working standards in all countries where the Group has operations.

DNB will adjust its operations in line with changes in pensions and the retirement age in Norway, among other things, through a review of the Group’s senior policy.

safe working conditions and a positive working environment

Why this is material

Measures to improve the working environment aim to prevent and reduce health-related problems arising from the work situation. Safety measures aim to prevent and reduce the harmful effects of occupational injuries. Health, safety and environment (HS&E) are therefore important elements in the group policy for people and organisation. DNB is committed to preventive working environment measures that promote employees’ safety, health, well-being and job satisfaction.

Policy and approach

The governing document is the group policy for people and organisation. The policy is elaborated on in the group guidelines for health, environment and safety. Cooperation between management and employees should ensure that efforts to improve the working environment are future-oriented and an integral part of daily operations.

All DNB managers must be updated on HS&E issues and new managers must complete HS&E training which complies with the Norwegian Working Environment Act and DNB’s internal HS&E requirements. Safety representatives receive HS&E training in accordance with the guidelines for the financial industry. A total of 27 managers and 37 safety representatives completed HS&E training in 2016. The training is aimed at the Group’s Norwegian operations. In addition, managers are trained in how to handle sickness absence. First aid expertise is continually assured among the employees through courses and films.

DNB places importance on having an inclusive working environment. DNB’s targets specified in the inclusive workplace agreement are: sickness absence reductions, special adaptation for employees with reduced capacity for work and an increase in the average retirement age. The targets are regularly discussed with the Norwegian Labour and Welfare Administration (NAV). The agreement applies until the end of 2017.

In DNB’s operations in Norway, the physical and ergonomic working environment is surveyed annually, together with knowledge related to the Group’s environmental goals and physical security. Through the HS&E survey, the employees have the possibility to influence their own working environment so that measures can be implemented.

To counteract the consequences of sedentary work, there is good access to adjustable height desks and the possibility for ergonomic advice via the company health service. In Oslo, Bergen and Trondheim, facilitating physical activity by having DNB training and exercise classes is an important preventive measure.

Special adaptations are made for employees with reduced capacity for work. The number of disabled parking spaces has been adapted to the actual requirements in each building. The Group has guidelines on harassment, bullying and other improper conduct. The guidelines shall ensure that a reported event is assessed swiftly, predictably and consistently.

The risk of robbery has been practically eliminated due to the transition to cashless branch offices. Consequently, courses on how to deal with robberies are no longer held in the Norwegian part of the organisation. 569 employees participated in courses on threat management, security and fire protection during the year. 37 employees in the Norwegian part of the Group were exposed to threats. In 2016, witness support was given to two employees who testified in a court case.

Evaluation of results in 2016

In 2016, 26 evacuation drills were carried out in DNB’s operations in Norway. Four accidents and injuries were registered during working hours or in connection with travel to or from work, but none were of a serious nature. Workplace accidents are registered in the Group’s event database and reported as occupational injuries to the Norwegian Labour and Welfare Administration (NAV). The incidents are reported to the group working environment committee, and serious incidents are reported to the Norwegian Labour Inspection Authority. In addition, criminal acts involving violence or force are reported to the Group’s security department for further action.


DNB will continue its work to develop and implement preventive working environment initiatives which contribute to employee health, safety, job satisfaction and well-being. @work (Facebook for companies) and nano-learning (short and intensive courses) will be increasingly used to develop corporate culture, in ergonomics training and to give general training within HS&E.

Read more about targets and measures within the topic “Have the right competencies” in the sustainability library.

UN Sustainable Development Goals

Key figures




As Norway’s largest bank, DNB has an ambition to promote the development of an active and well-functioning business sector in Norway. DNB’s most important contribution to promoting innovation and restructuring and contributing to long-term value creation in Norway is to act as a competent partner which provides good advice, helps companies gain access to equity and debt capital and ensures efficient settlement solutions.

Today, there are approximately 500 000 small and medium-sized enterprises (SMEs) in Norway. They are the bedrock of the Norwegian business community, representing 99 per cent of all companies in the country and accounting for half of all value creation. In order to be a good bank for Norwegian customers with operations outside Norway, it is also vital that DNB has a broad international presence within the industries where Norway is a key player.

SMEs are very important growth engines and a major driving force behind restructuring and innovation in the Norwegian business sector. Although most of them remain small, a few grow to be strong, and these create many jobs. Each year, several thousand companies disappear and are replaced by at least as many new ones. The new companies grow faster and have higher productivity than the companies they replace. This leads to change, growth and higher productivity.


The pace of change in society is escalating, and the average life span of companies has been reduced considerably over the past few years. At the same time, new and innovative companies create growth and new jobs. This is why entrepreneurs play an increasing role in maintaining today’s welfare society. 50 000 new companies are established in Norway each year, and about three of ten of these survive past the first five years. For DNB, it is important to be there from the start and ensure that as many start-up companies as possible succeed. DNB aims to help more people dare to take the plunge and succeed in creating jobs for themselves and others. DNB has helped entrepreneurs and start-up companies over many years. The focus has mainly been on making things easier for them and on being a good sparring partner and adviser. The commitment to promoting innovation and restructuring in the Norwegian economy must be shared by the entire Group. For example, the DNB NXT and DNB NXT Accelerator initiatives involve several business areas and support units across DNB, and will be important for the entire DNB Group in the years ahead.

Most important measures:

  • The Start-up Book: a free guide for entrepreneurs containing useful information, tips and tricks on how to start your own business. About 100 000 books have been distributed since May 2014.
  • The start-up pilots: a specialist team that is organised under the corporate market segment in DNB. The pilots give guidance to those who wish to start for themselves and help upcoming business owners with everything they have to make up their minds about during the idea, start-up and growth phases. The service is free and nationwide. In 2016, 2 763 potential entrepreneurs received help from the specialist team, and since the start of the service in 2014, the start-up pilots have helped more than 8 000 start-up and entrepreneurial companies. The start-up pilots make webinars, hold courses and are present at entrepreneurial events nationwide. The users are very satisfied with this service.
  • Special web pages under target start-up companies and emphasise knowledge sharing.
  • Close collaboration with entrepreneur and start-up communities nationwide.

As Norway’s largest bank, DNB has an important role to play in helping the Norwegian business community gain access to capital. Business loans are an important source of growth and profitability for companies. DNB increased its loans to SMEs by 5.3 per cent from 2015 to 2016 (3.7 per cent in 2014-2015). DNB’s lending growth is higher than the market in general, where the 12-month growth in gross debt to non-financial enterprises in Norway was 2 per cent in December 2016.

The restructuring in Norway also requires that private capital is put to work to promote future growth and value creation. DNB has Norway’s largest network of entrepreneurs and start-up companies. At the same time, the Group has the largest network of investors. DNB wishes to facilitate venues where these parties can meet. It is when ideas and capital meet that future value and jobs are created. This is why DNB launched, in 2016, DNB NXT, a long-term strategy to help ensure that more private capital is invested in exciting growth companies.

Towards the end of 2016, the Group launched DNB NXT Accelerator. DNB and StartupLab invited promising startups to DNB NXT Accelerator, a three-month programme for technology companies. The purpose of the accelerator programme is to help the selected companies launch their products in the market. The programme provides financing, expertise, networks, advisory services and support.

Read more about DNB NXT.

DNB develops solutions to make everyday life easier for customers and companies. Simplifications and more cost-effective solutions strengthen the companies’ profitability. Payments is one of the areas within banking and finance that is experiencing the most rapid development. DNB’s payments app, Vipps, has more than two million users, and in the course of 2016, more than 30 000 small companies, clubs and associations became registered “Vippsers”. DNB will now make Vipps available in far more payment situations, including e-commerce, invoices and physical stores.

Vipps Invoice is an example of a more effective solution launched by DNB. In 2016, 164 million paper invoices were issued in in Norway with an estimated cost to society of NOK 21 billion. This is time-consuming and costly for companies and customers. At the end of October 2016, invoice payments were launched through the Vipps app. In less than three months, 500 000 users accepted Vipps Invoice. Vipps Invoice helps ensure that many more customers pay on time and saves companies significant costs. Another example is simpler payment solutions for e-commerce. A high percentage of customers do not complete a shopping process online due to complicated payment solutions. The development of simple solutions is important to increase online sales, and Vipps’ ambition in this area is to become the preferred solution. In the course of 2017, it will be possible to pay without the use of bank cards or cash in many thousands of stores in Norway.

Read more about Vipps.


DNB’s ambition is to assist everyone who starts their own business and facilitate that more people will do the same. DNB plays an important role as an intermediary between ideas and capital. DNB can highlight promising entrepreneurial companies and help ensure that they get the best growth conditions. Some of these will be customers for years to come, others will become business partners, and some may perhaps become future competitors, but all will make a positive contribution to society. However, DNB also acknowledges that the Group does not have all the solutions itself, and it is therefore important that new forms of alliances and cooperation are formed.

The Board of Directors and DNB’s group management team follow the start-up initiatives and participate in the social debate about what are the correct and important measures to promote innovation and restructuring. Reports are regularly sent to the group management team and the Board of Directors on the measures initiated. The group management team actively participates in arenas and events which are relevant for entrepreneurs and for companies that are in a restructuring or growth phase.


With two million personal customers in Norway, DNB has a special responsibility to ensure that as many people as possible have the possibility to make good financial decisions. Research shows that poor financial habits are passed down from one generation to the next, and DNB regards it as its social responsibility to teach, particularly children, good financial habits at an early age. Customers who are financially literate are also able to make good financial choices. This is beneficial for society, customers and DNB.


The responsibility for promoting financial literacy is embodied in the group policy for corporate social responsibility, which states that the bank shall support useful objectives and secure important social values in those areas and industry sectors where the Group operates. The bank’s main initiative to promote financial literacy in 2016 was the learning program A Valuable Lesson, developed in partnership with the Norwegian Red Cross. A Valuable Lesson is a digital learning tool consisting of five modules within personal finance. The program complements the learning targets for the fifth to seventh grade (10 to 12-year-olds). DNB believes it is important that children learn about personal finance at an early age so that they can make sound financial choices, irrespective of background. The Red Cross also meets many who are not taught about personal finance at home and therefore meets a need. The division for Corporate Social Responsibility and Political Affairs is responsible for A Valuable Lesson.

In a society that is becoming increasingly digitalised, and where manual services are gradually being removed and/or becoming fee-based, it is important for the bank’s customers to have a minimum level of knowledge about digital banking services in order to be able to manage their own financial affairs. DNB has therefore developed a course in digital banking services to give non-digital customers sufficient knowledge to be able to carry out basic banking services in the Internet and mobile bank. Customers learn to check account balances, pay invoices, create direct debits/e-invoices, transfer money between own accounts and more.

The courses started as an initiative for customers living near a branch office that was about to be closed. The purpose of the course was to make customers able to perform the services they would otherwise have received help to do from the bank. Employees at the branch offices who have held the courses have received positive feedback from the participants. It was later decided to offer these courses nationwide, whether branch offices were to close or not.

To simplify the learning process for customers and enable them to be able to use the knowledge at home, a “Guide to digital banking services” was launched, both for the Internet bank on PCs and tablets and for the mobile bank. Course participants have been given this guide, and it has also been made available to all customers in all branch offices across Norway and distributed in the post if requested by calling DNB’s customer centre. No plan has been made for further courses in 2017, but the “Guide to digital banking services” is being further developed. DNB is also in dialogue with various stakeholder groups to consider opportunities to enter into partnership to offer such courses.

In addition to these specific measures, DNB regularly holds seminars for customers to help them make better financial choices. This may be seminars on pensions, shares, savings or macroeconomic trends.

Read more about courses offered by DNB.


Parallel to the development and launch of A Valuable Lesson, DNB has worked politically to get the topic of personal finance into the school curriculum. In 2016, DNB continued the dialogue with politicians, educational institutions and teachers to make the topic of personal finance a more prominent part of the curriculum of primary schools. In report to the Storting 28 (2015-2016), “Fag – Fordypning – Forståelse – En Fornyelse av Kunnskapsløftet” (Disciplines – Deeper understanding – A renewal of the knowledge promotion”), personal finance was given more attention than has been the case in the past. It was proposed that personal finance should be included in the curriculum under the multidisciplinary theme “public health and life control”.

When the Norwegian parliament (Stortinget) discussed the report in the autumn of 2016, it became clear that the parties had heeded the signals to focus on personal finance, and the importance of having knowledge about personal finance and private consumption was emphasised.

During 2016, people outside the target group of A Valuable Lesson expressed that they wanted to use the concept. This shows that the content is of interest for a wider group than just 10 to 12-year-olds and that there is further potential in making small adjustments that can make it relevant for other target groups.

In 2016, 260 courses in digital banking services were held where customers received a personal invitation in the post. It has been up to each branch office whether or not to hold courses based on demand. A total of 355 courses were arranged throughout Norway.


DNB ensures that sustainability considerations are safeguarded in the Group’s investment, credit and insurance operations through, among other things, the development and management of policies, guidelines and principles, and the operationalisation of these. In a social perspective, DNB aspires to contribute towards the viability of the Norwegian economy by providing capital for sustainable development.

In addition to specific measures within the Group’s investment, credit and insurance operations, products and services are developed to provide environmental benefits to society. Green car financing (car loans and leasing) in Norway totalled NOK 2.3 billion in 2016 and represented 26 per cent of DNB’s total car financing. Within renewables, direct loans to wind, water and solar energy totalled NOK 45.6 billion, which is 24 per cent of total loans to the energy/offshore sector. Read more about DNB’s results and targets within renewable energy in the key figures table in the sustainability library.


In 2017, it will be important for DNB to measure the effect of A Valuable Lesson. A large group of teachers have used A Valuable Lesson, and to be able to say that it is a success, DNB wishes to examine in 2017 to what extent A Valuable Lesson helps children to actually improve their knowledge of personal finance. It is also interesting to expand the concept to include tools which parents and children can use at home, to raise the general awareness of personal finance among families. A total of 1 390 teachers registered on læ To ensure that A Valuable Lesson delivers the best possible tools for teachers, an evaluation will also be made of the content.

2017 has been established as a “Savings Year” in DNB, where particular importance is placed on giving customers access to products and services which make it easier to save. It is therefore natural that A Valuable Lesson in 2017 includes tasks about saving in particular and how children can learn more about how to save smart.



Responsible investment implies taking environmental and social conditions into account and ensuring sound corporate governance in investment management. The main purpose is to achieve long-term returns with an acceptable level of risk, contribute to sustainable development and avoid contributing to the violation of fundamental rights. Customers on behalf of whom DNB makes investments, expect the Group’s investment activities to be responsible. Responsible investment is important for DNB’s life insurance company and for the Group’s equity investments, management of mutual funds and the active management of investors’ portfolios of financial instruments.


There are special guidelines for DNB’s investment operations to ensure that the Group does not contribute to the infringement of human and labour rights, corruption, serious environmental harm or other acts which can be perceived to be unethical. The guidelines for ethical investments cover all asset classes and financial investments through DNB Livsforsikring, the Group’s equity investments and DNB Asset Management.

Responsible investment in DNB is based on internationally recognised principles. The measures used are mainly positive screening, active ownership through dialogue and voting, negative screening and exclusion. DNB does not invest in companies if they themselves or through the entities they control produce tobacco or pornography. Nor does DNB invest in companies involved in anti-personnel mines or cluster weapons, as described in the Anti-Personnel Mine Ban Convention and the Convention on Cluster Munitions, or in companies which develop and produce central components for use in weapons of mass destruction1).

DNB has an Ethical Investment Committee that monitors compliance with the guidelines. If a company is involved in controversial weapons, tobacco or pornography, or violates the coal criterion, all securities will be sold, and the company will be excluded from the investment universe. When a company is suspected of violating other criteria in the guidelines, DNB will principally try to influence the company through active ownership and dialogue. In cases where companies in which DNB has holdings on behalf of customers are suspected of acting contrary to DNB’s guidelines and internationally recognised standards and conventions, DNB will encourage them to correct their actions. Companies that act contrary to DNB’s guidelines or over time show no willingness to rectify the situation may be excluded from the Group’s investment portfolio.

DNB’s ambition is to offer its customers equity funds investing in companies which excel within environmental and social performance and corporate governance. DNB puts considerable resources into ensuring that the Group’s responsible investments are of high quality. The work is undertaken by a team consisting of a manager and two analysts who work closely with both investment management and the companies. Their assessments are supported by two external consulting firms that monitor companies in the portfolio, prepare sustainability analyses and engage in dialogue with companies in cooperation with and on behalf of DNB and the Group’s customers. The purpose of the dialogue is to influence the companies in a positive direction. The contact with the companies is often triggered by special issues relating to environmental and social aspects and ownership administration, but may also reflect a wish to improve the companies’ general sustainability performance. Event-based dialogue is based on the severity of the suspected violation of the guidelines, the size of the Group’s holding in the company and the probability that the dialogue will influence the situation. DNB also takes an active stance on selected topics. These topics are under continual review, and in 2016, corruption was one of several important topics in the dialogue with companies.

1) Weapons of mass destruction are defined as NBC weapons (nuclear or atomic, biological and chemical weapons).



As a step in reducing environmental and climate risks and carbon footprint in the portfolios, climate and coal criteria were included in DNB’s guidelines for ethical investments in 2016. According to the coal criterion, mining companies and power producers which themselves or consolidated with entities they control derive 30 per cent or more of their income from thermal coal, or base 30 per cent or more of their operations on thermal coal, may be excluded from the investment universe. The use of “may” implies that the company’s strategy and future allocation between coal and renewable operations will be taken into consideration. In 2016, 44 companies were excluded based on this criterion. An additional 15 companies were excluded in January 2017.

DNB exercises active ownership primarily through dialogue with individual companies and by using its voting rights. During 2015, DNB’s responsible investment analysts had 72 meetings with 53 companies to discuss various environmental and social issues and sound corporate governance. In many of the meetings, various topics relating to environmental and social issues and corporate governance were also discussed. Through GES Investment Services, DNB conducted 113 dialogues with 86 companies concerning seemingly reprehensible incidents or suspected breaches of international standards or conventions. The dialogues are structured processes with clear targets for the desired outcome. In addition, milestone attainment is measured.

In 2015, DNB voted at 122 general meetings in Norway. At 26 of these meetings, voting was contrary to recommendations made by the board of directors. DNB is in continuous dialogue with the companies to be able to influence them so that cases presented at general meetings are in line with what the Group considers to be good corporate governance.


DNB will continue to refine processes to include environmental and social aspects, as well as topics related to corporate governance in investment operations. The Group will focus on further integrating environmental and social aspects and ownership administration in investment decisions, focusing on dialogue, in the period up to 2018. Equity funds which invest in companies which distinguish themselves in this respect will be developed.

See a complete overview of excluded companies and read more about ethical investment and company dialogue in the sustainability library.

Measuring the greenhouse gas emissions of mutual funds relative to reference indices

As part of efforts to reduce exposure to companies with high climate risk, in 2016 DNB started to measure the carbon footprint of all equity funds. Carbon footprint, also called carbon intensity, is the measure of a company’s greenhouse gas emissions relative to the company’s turnover and is one of several factors that says something about the company’s climate impact. After identifying the carbon risk in the portfolios, there are different approaches to reducing the risk.

DNB uses information from MSCI ESG Research about companies’ greenhouse gas emissions. The companies’ carbon footprint is weighted by the respective holding in the portfolios. The same is done for the index. In the calculation, any cash in the portfolios is distributed proportionately between the other companies. For companies without emission data, the average figure for companies in the portfolio with emission data has been used in the calculation. DNB reports CO2 equivalents that include scope 1 and scope 2 emissions, as defined by the Greenhouse Gas Protocol. Scope 1 includes direct emissions from sources that are owned or controlled by the organisation, scope 2 includes indirect emissions associated with purchased energy, while indirect emissions associated with purchased goods and services that fall in under scope 3, are not included. The method for reporting greenhouse gas emissions is under development and could be subject to change.

The graph shows 19 equity funds and their respective indices where data on greenhouse gas emissions for more than 90 per cent of the funds’ investments are specified. These funds represent about 83 per cent of the total market value of all of DNB’s equity funds. Some funds are not included due to the lack of emission data. The graph is a snapshot of the portfolio as at 31 December 2016 and shows that compared with the respective indices, the majority of the funds had a lower or equal carbon footprint.

There is great uncertainty surrounding data on greenhouse gas emissions. Firstly, practices for the reporting of such emissions vary considerably, while some companies do not report their emissions, and estimated figures are used where data is missing. Despite the uncertainty, DNB is of the opinion that greenhouse gas emissions are an important factor to use in analyses of companies’ climate risk and impact.

Greenhouse gas emissions from DNB’s mutual funds relative to reference indices


DNB wishes to contribute to sustainable development in society. Responsible business operations that emphasise environmental and social aspects, corporate social responsibility and business ethics are essential to DNB. The Group’s resources shall be used to meet customer needs without violating the law, international conventions, rules or prohibitions. This is done because it is morally and ethically correct, but also because it represents sound risk management. The financing of activities in legal or ethical grey areas represents unacceptable risk.


DNB’s credit policy states that environmental risk factors shall be analysed on a par with other possible risk drivers and be of decisive importance with respect to whether or not applications for credit should be approved.

DNB has separate guidelines for corporate social responsibility within credit activities for corporate customers. The guidelines describe how DNB’s business areas should assess corporate customers’ CSR performance and risk associated with environment, social and governance factors (ESG risk). The guidelines shall ensure that DNB considers CSR/ESG risk for all customers and contributes to promoting responsible and sustainable business operations.

In 2016, several changes were made to the guidelines. Among other things, DNB’s expectations to all corporate customers were made more clear. Customers must comply with relevant laws and regulations in the countries where they operate, but also act in accordance with international conventions and guidelines. DNB requires that human and labour rights are respected and that customers take into account the environment through responsible management of their environmental footprint. Customers are also expected to take into account relevant challenges for their operations as a result of actual and expected climate changes. In addition, it was clarified which activities DNB will refrain from financing and examples were given within industries/subjects such as protected/vulnerable natural habitats, defence/controversial weapons, energy, logistics/transportation, seafood and fisheries, forestry as well as metals and mining.

DNB has adopted the Equator Principles. According to the Group’s credit guidelines, all advice in connection with project financing, project-related corporate loans and bridge loans laid down in the criteria principles shall be assessed based on the Equator Principles. The principles are a common set of guidelines used by the majority of large international financial institutions for managing environmental and social issues in project finance. Financial institutions which have adopted the principles, have undertaken not to provide project-related financing to customers who do not wish to or are unable to comply with the principles. By adopting and following up the Equator Principles, DNB ensures that projects financed by the Group develop and are operated in an environmentally friendly and socially responsible manner.

In DNB, each customer team first evaluates whether a project complies with the Equator Principles. DNB’s internal equator team reviews the summary, follows up and clarifies any outstanding issues and unidentified risks and determines the final risk category. A memo and minutes from the equator team’s meeting are attached to the credit case when it is due to be considered by the relevant credit committee. As part of the annual loan review, compliance with the Equator Principles should be evaluated and reported to the relevant credit-approval body for each credit commitment.


DNB acknowledges that some industries may have a greater negative impact on the environment, people, health and nature than others. This could lead to financial risk, legal risk and in some cases to conflicts of interest. DNB has therefore developed special sector guidance notes for CSR/ESG to ensure that decisions are well-founded and in accordance with DNB’s corporate social responsibility policy and commitment to deliver responsible financial services. In 2016, such sector guidance notes were introduced for the following industries/sectors: energy, weapons and defence, seafood, metals and mining, as well as forestry. In 2017, DNB will consider establishing a further one or two sector guidance notes.

DNB has previously had two different processes for considering CSR/ESG risk in credit activities – one for large corporates and one for SME customers. In 2016, a common risk-based assessment process was developed for all corporate customers. A risk-based approach implies that customers and cases with serious potential consequences and a high probability of negative impacts on the environment and people require an extended review and documentation. The guidelines for corporate social responsibility in credit activities are available in the sustainability library.

A special CSR/ESG risk assessment tool has been developed, including discussion points, to be used in cases where such risk is considered to be medium or high. Discussion points have been prepared on the following topics: environmental issues, climate change, human and labour rights, corruption and ethics, as well as corporate governance and transparency. In addition, industry specialists in the relevant corporate customer sections in the business area Large Corporates and International must be consulted.

CSR/ESG risk must be assessed, where this is relevant, for all corporate customers and incorporated in the decision-making basis in the credit approval tool for customers. The CSR/ESG risk assessment of the individual customer must be documented and included as part of the decision-making basis for considering whether or not to approve credit applications.

In 2016, a total of seven projects were processed in accordance with the Equator Principles. A list of these can be found in the sustainability library.


DNB will continue to develop the processes to integrate ESG risk in credit assessments. Among other things, the method and structure for assessing the consequences and probability of CSR/ESG risk will be adapted to the group-wide risk process adopted in 2016. The framework will be adjusted and updated based on feedback from users and other stakeholders. Efforts to make it easier to report and monitor environmental and social risks in the credit process will continue. Processes and systems will be adapted whereby the estimated consequences and the probability that CSR/ESG risk will occur can be recorded, stored and used for reporting.

The development of e-based training in the new guidelines was started in 2016 and will be completed during the first quarter of 2017. Thereafter, basic e-based training will be available to relevant employees and managers who work with credit applications for DNB’s corporate customers. Specialised and topic-based training will also be developed and implemented as needed.

Initiatives will also be taken to acquire one or more common sources for neutral and independent information about the CSR/ESG risk relating to companies, projects, sectors, countries and regions. This will increase the competence and awareness of such risks among relevant parties. Supplementing own assessments with assessments made by external experts will increase the quality of internal analyses of customers’ CSR/ESG risk.

In 2017, an e-based training program for Equator Principle assessments prepared by the Equator Principles Association will be made available to relevant employees and managers in DNB.


Sustainability considerations in the field of insurance are mainly related to environmental aspects. Climate change is resulting in more single, large claims of greater scope. DNB aims to offer products and services which are relevant and transparent for customers. DNB Forsikring offers both property insurance and personal insurance to customers in the personal banking market in Norway. Non-life and personal insurance products cover important needs in people’s lives by protecting their material values in the event of damage and unforeseen circumstances, such as illness or accidents. Insurance operations in DNB are organised in DNB Forsikring AS, a separate limited liability company.


The operations are governed by DNB’s group policy for corporate social responsibility and underlying guidelines, and the company aims not to contribute to the infringement of human and labour rights, corruption, serious environmental harm or other acts which could be regarded as grossly unethical. DNB’s guidelines on combating corruption state that DNB has zero tolerance for corruption and is to have a robust defence against corruption based on openness and verifiability. DNB Forsikring is committed to preventing corruption and fraud, and this is a continual process.

The sale of insurance products in Norway primarily takes place through personal contact with customers at physical offices, on the telephone, or in connection with sales processes for the insured objects. DNB has adopted the approval scheme for sellers/advisers in the non-life insurance industry. This is a national scheme to promote and ensure that sellers and advisers have the necessary knowledge and skills and the right attitudes. It is important for DNB Forsikring to ensure the quality of its sales and advisory services so that customers can make the right choices.

DNB Forsikring has a number of agreements with suppliers of insurance services which are offered to customers. It is important for the company that it is as certain as possible that the suppliers with whom it enters into agreements act in an ethical and sustainable manner. When entering into supplier agreements with DNB Forsikring, suppliers must sign DNB’s code of responsible business conduct for suppliers. This document contains requirements for environmental management, ethical business practices, human rights and labour standards on a par with other contracts entered into in the Group. Read more about responsible procurement in the sustainability library.

The managing director of DNB Forsikring is a member of BRS (the Risk and Non-life Insurance Industry Board), while the responsible actuary is head of FUAS (the Specialist Actuary Committee for Non-life Insurance) in Finance Norway. Through its roles in BRS and FUAS, DNB Forsikring has participated in in Finance Norway’s environmental work since 2009, by, among other things, participating in a pilot project where the company contributed with detailed data on insurance claims. The aim was to achieve a better understanding of risk and to identify the need for more preventive work.


As at 31 December 2016, DNB Asset Management managed a capital portfolio of NOK 2.4 billion on behalf of DNB Forsikring. The company has its own asset management strategy with separate risk limits for insurance, but otherwise complies with the Group’s guidelines for ethical investments. Read more about the operationalisation of the guidelines in the responsible investments section.

Customers increasingly expect simple, smart and digital solutions. The digitalisation of the value chain in insurance is expected to accelerate over the coming years. New digital solutions will provide better and more streamlined customer experiences, and lower costs will result in lower prices to customers. Vipps Invoice for young adults is an example of a simple payment solution that was introduced to DNB Forsikring’s customers in 2016. Together with the company’s insurance package for young adults, these are examples of measures to simplify the purchase and payment of insurance products for young adults who need to insure their personal possessions in a simple way and at a predictable price.


DNB will continue to provide ever-better data to be used in environmental work, both within the company and generally in BRS. Related claims data will be used to enable the insurance industry, the public authorities and society to make the right decisions. This work will also clarify the roles and responsibilities of the municipalities and the government.

DNB Forsikring will develop KPIs related to sustainability and environmental aspects in the course of 2017. DNB also supports the objectives of the BRS’ climate committee for 2017:

  • make climate-related claims data available and use it to enable the insurance industry, the public authorities and society to make the right and robust decisions
  • make increasing use of the data to achieve industrial-policy and strategic goals
  • communicate to the public authorities and society the social role of the insurance industry as an investor and in loss prevention
  • clarify the roles and responsibilities of the municipalities and the government
  • draft a joint communication plan and action platform



Global and national development trends emphasise how important it is for DNB to view risks and opportunities in a long-term perspective. DNB’s owners are also concerned that long-term challenges are reflected in the Group’s corporate governance, something which is also specified in the State Ownership Report. The Group’s long-term strategy will contribute to stability and profitability over time.


DNB’s governance system should help to ensure a long-term perspective while contributing to a balanced monitoring of the company’s performance. This is done by, among other things, establishing financial, operational and strategic KPIs, in addition to health and risk indicators. In this way, targets are set which do not solely rate the financial performance of the Group, but also non-financial values.

To ensure that risk management is integrated in the Group’s governance processes, the Risk Appetite framework is included as part of DNB’s governance system. The framework represents an operationalisation of the Group’s policy and guidelines for risk management, whose purpose is to contribute to a strong and long-term risk culture.

In order to operationalise the risk targets, appurtenant boundary indicators are set, and in the aforementioned governance system, separate KPIs are established which define acceptable risk. The framework distinguishes between several risk categories, which are earnings and capital adequacy, market risk, credit risk, liquidity risk, operational risk, anti-money laundering and reputational risk. Over the last few years, greater emphasis has been placed on the non-financial risk categories, and a balanced approach will help to safeguard the long-term risk scenario.

The indicators are first set at group level before they are distributed to the rest of the organisation. Monitoring takes place through a dashboard system to help ensure that the risks which have been identified as most significant at group level are also subject to monitoring and discussion in operative units in the organisation. Follow-up via the dashboard also helps to highlight developments and trends.

Risk Appetite is reported monthly to the group management team, and is also a significant part of the quarterly risk report which is presented to the Board of Directors. Other measures to develop the risk culture in the Group include training programmes for employees.

DNB’s incentive structure should help to manage the DNB Group’s risks and opportunities. The variable remuneration scheme is performance-based without exposing the Group to unwanted risk, and it also aims to counter excessive risk-taking, as well as promote healthy and effective risk management in DNB. This is secured through a strong link between individual target setting and the Group’s governance model.

In DNB’s variable remuneration model, the total amount is based on profits achieved over the past two years. In addition, the payment of minimum 50 per cent of the variable remuneration is deferred and conditional in the form of DNB shares. The remuneration paid in the form of shares is divided into three, subject to minimum holding periods (deferred and conditional) with one-third payable each year over a period of three years. Release of the shares is subject to an annual ex-post risk assessment in line with the regulations. Variable remuneration cannot exceed 50 per cent of fixed salary for members of the group management team.

DNB does not offer other long-term incentive schemes for its employees. Read more about risk management and the remuneration scheme in Corporate governance.


In 2016, DNB implemented a comprehensive review of the Group’s products and services delivered to customers in Norway to identify reputational risk. The result of the review was presented to DNB’s group management team in April 2016.

Based on experiences from the review, DNB has adopted new group guidelines for the approval of products and services. The purpose of the group guidelines is to ensure high quality in DNB’s portfolio of products and services, and thereby increase its competitiveness, improve its reputation and safeguard its corporate social responsibility. The guidelines and procedures for compliance shall support effective product development and approval, and contribute to innovation and change capacity.

The elements in the delivery of a product or service often span business areas and support units, legal entities and external parties. The group guidelines use different roles to allocate responsibility and are therefore independent of the organisational structure. All roles have an independent responsibility for making sure that sound assessments and decisions are made in the best interests of customers and DNB.


One of the ambitions for 2017 is that the new guidelines for the development of products and services are adopted and help to reduce risk in connection with individual commitments and services, as well as at group level.



DNB aims to ensure confidence in the bank’s intentions and future prospects through openness about the Group’s opinions and activities, as this contributes towards building trust. The information DNB communicates to its stakeholders, particularly through reporting, must be reliable, complete and relevant. See also the sustainability library for an overview of the stakeholder dialogue for 2016.


DNB’s group guidelines for ethics (the code of ethics) state that employees should communicate in an open, truthful and unambiguous manner, and give all stakeholders correct and timely information.

DNB supports initiatives in the financial services industry which promote openness and transparency. Through integrated reporting, the bank will provide good and complete information about the company’s ability to achieve long-term value creation, including how macroeconomic, social and environmental factors affect the company. DNB bases this work on the regulatory framework International Integrated Reporting Council, IIRC, and uses an “input-output” model to describe its business model and value creation. The model clarifies which input factors are used and shows dependencies and connections in the business model and the values created.

Beyond a general openness about the condition of the company, it is important for DNB to be open about tax reporting. In Norway, country-by-country reporting to the tax authorities was introduced from 2016. The reporting requirement is based on the OECD’s proposal and is part of a larger tax project, Base Erosion and Profit Shifting, BEPS. BEPS has proposed various measures to prevent erosion of the tax basis and profit shifting in multinational companies. The country-by-country report will be part of DNB’s transfer pricing documentation. The purpose of the country-by-country reporting is to give the tax authorities in all countries greater insight into companies’ global operations and thus gain a better basis for assessing the risk of incorrect pricing and the allocation of profits. Country-by-country reporting should include an overview of turnover, profits, taxes paid, invested capital, number of employees and assets per country, as well as an overview of legal entities and their main operations.


Throughout 2016, DNB had an ongoing project to establish consistent definitions and assess changes to routines and systems in order to be able to carry out country-by-country reporting.


Country-by-country reporting is a way to be open about DNB’s operations outside Norway. When this type of reporting to the tax authorities is in place, DNB will also consider being open about other aspects, in addition to reporting to the tax authorities.

Read more about the targets and measures within the topic “Contribute to a healthy economy” in the sustainability library.