As criminals can use financial services to launder money and finance their criminal activities, it is important to have the right process to know our customers. Knowing the customer allows us to better understand the business relationship. We are obliged to detect unusual and suspicious activities and to check whether a specific customer or investment is on sanctions lists.

Money laundering, terrorism and financial sanctions violations not only harm society, but can also damage the stability and reputation of the financial sector. It is in the interest of the financial industry and society that financial institutions take measures to prevent money laundering and terrorist financing. To detect money laundering, we cooperate with a number of actors, including other banks, authorities and the police.

To ensure the effective establishment and implementation of an anti-money laundering and anti-terrorist financing culture, we:

• We have adopted anti-money laundering, counter-terrorist financing and financial sanctions compliance policies that require all parts of our business to take effective measures to comply with applicable laws.
• Customer Due Diligence (CDD) consists, among other things, of identifying and verifying the identity of the customer based on documents, data or information obtained from reliable and independent sources. We also need to understand the beneficial owner, ownership and structure of our customers.
• We perform daily reviews of the customer base against financial sanctions and PEP¹ lists. Furthermore, all holdings in our funds and portfolios are screened against sanctions lists on a daily basis.
• Initiating or continuing a business relationship with a PEP¹ or other relevant high-risk customers requires approval from an authorised decision-maker.

¹Politically Exposed Person (or PEP, from English Politically Exposed Person). A person in a politically exposed position, family members and known employees of this person, is deemed, through their position and influence, to have a position that constitutes a risk of being exploited for, among other things, bribery.

• CDP (Carbon Disclosure Project)
  An international collaboration between institutional investors to increase reporting from companies on their sustainability work. 
• Climate Action 100+
  A collaboration within PRI with several organisations to influence the world’s 165 largest emitting companies. Swedbank Robur has been a member since 2018. (link website CA100+) 
• Finance for Biodiversity
  In December 2020, Swedbank Robur was the first Swedish signatory to the new Finance for Biodiversity initiative. A total of 37 banks, asset managers, insurers and fund operators have committed to collaborating, engaging and assessing their own impact on biodiversity by 2024, as well as developing targets and reporting of data related to biodiversity. 
• The Fund Management Company Association
  In the Fund Management Company Association, we actively participate in various working groups to drive and follow up on industry commitments, such as Guidelines for Shareholder Engagement, which is an annual follow-up of the Principles for Shareholder Engagement.
• Green Bond Principles (GBP)
  Through the International Capital Market Association (ICMAS), Swedbank Robur is a member of the Principles for Investment in Green Bonds (GBP) and supports these principles. GBP also monitors Social, Sustainable and Sustainability Linked Bond policies.
  
• GISD (Global Investors for Sustainable Development
  GISD is a global collaboration between major financial institutions and companies to deliver solutions and develop new approaches to sustainable value creation with a focus on the UN’s 17 Sustainable Development Goals. Swedbank Robur has been a member since 2019 via SISD.
  
• ICGN
  A collaboration between investors to raise the standard of corporate governance globally.
• IIGCC (International Investor Group on Climate Change)
  A collaboration for international development and dialogue on climate change, for example against climate lobbying. Swedbank Robur has been a member since 2018.
• Montreal Pledge (within the framework of the cooperation in PRI - Principles for Responsible Investments)
  In the Montreal Carbon Pledge, fund management companies undertake to measure and report the climate footprint of their investments. Climate calculations are made for Scope 1 & 2 of funds with listed equity holdings in accordance with the fund management company association’s industry standard. Swedbank Robur has been a member since 2015.
• Net Zero Asset Managers
  On 11 December 2020, Swedbank Robur signed the new international Net Zero Asset Managers initiative. The aim is to commit as an asset manager to work to reduce carbon emissions in its investment portfolios, and to support the companies in which it invests in achieving net zero emissions by 2050.
• PRI (Principles for Responsible Investment)
  PRI (Principles for Responsible Investments) are collaborations between investors to drive change in companies. Swedbank Robur is involved in various working groups and has been a member since 2009.
• SISD (Swedish Investors for Sustainable Development)
  A Swedish collaboration between Swedish financial institutions and SIDA to find opportunities to work together with Agenda 2030 and the UN’s 17 global sustainability goals. Swedbank Robur has been a member since 2018.
  
• TCFD (Task Force on Climate-Related Financial Disclosure)
  Helps organisations identify climate-related financial risks and opportunities. Swedbank Robur has been a member since 2018 and is working with the Swedbank Group to build competence in the organisation. 
• United Nations Global Impact Initiative
  The UN’s Global Compact initiative advocates that companies take responsibility for environmental and social issues. Swedbank Robur has been a member since 2010 and it is part of our sustainability analysis to influence companies to ensure the Global Compact’s ten sustainable business principles on human rights, labour terms and conditions, the environment and anti-corruption. 
• UNEP FI (United Nations Finance Initiative on Principles for Responsible Banking)
  In 2019, Swedbank AB (publ) signed the commitment to implement the UN’s 17 Sustainable Development Goals and the Paris Agreement on Climate Change by 2030.