Measuring emissions: We joined Partnership for Carbon Accounting Financials (PCAF) in July 2021 and have implemented the accounting standard for GHG accounting of our financed projects´ and investments´ emissions. We disclosed our emissions on Scope 1 (direct fuel use and waste generation), Scope 2 (electricity and heating use) and Scope 3 (influenced emissions such as supply chain emissions, business travel, employee commuting and our corporate lending portfolio emissions) in the scope of our annual reporting for 2021.

EU taxonomy: We are implementing EU taxonomy reporting and have disclosed our EU taxonomy eligible portfolio in line with the regulatory expectations in the scope of our annual reporting.

Sustainable finance: We are determined to build a green product portfolio to support the transition to low carbon economy. Currently, we offer:

• loans for energy efficiency to motivate home owners to invest into sustainable future;
• credit for all electric and hybrid vehicles that meet the low emissions thresholds in local countries (in Estonia, Latvia) and Lithuania;
• sustainable pillar 2 and 3 pension funds:
  - In Estonia II and III pillar funds Sustainable Pension Index Funds
  - In Latvia II and III pillar funds Luminor Index Pension Fund Sustainable Future
  - In Lithuania Pension fund Luminor Sustainable Future Index  and sustainable exchange traded funds (ETFs) with morning star sustainability rating through our  Luminor Investor platform.
  
  We are building sustainable investment services and products that support sustainable development of businesses and motivate homeowners. Luminor's statement on the negative impacts of sustainability on investment decisions can be found here.

Environmental risk assessment: We perform an environmental and social impact assessment on the total consequences of large scale high environmental impact projects and customers.

Sector strategies: In June 2022, we approved industry ESG risk management guidelines for sectors where we deem the climate impact to be high – agriculture, construction, retail trade, manufacturing, energy. These guidelines outline the key risks per sector and the mitigation actions that we would expect our customers to undertake. Furthermore, we have launched a series of seminars to build climate risk and transition related knowledge among our customers. Read more under our Climate seminars.

• Our ESG Credit Risk Assessment procedure covers human rights due diligence questions for our large corporate customers and lending projects. We have established ESG Due Diligence Guidelines and are updating all onboarding and transactional due diligence processes to ensure environmental and human rights due diligence of all our corporate customers as well as vendors and suppliers.
• We require our Third Parties to confirm that they comply with our code of responsible business conduct (Third Party Code of Conduct). We take responsibility for the impact inflicted on society and the environment as a result of our business activities, and we expect our Third Parties to do the same. Our Third Party Code of Conduct outlines Luminor principles on responsible business conduct. The Code follows guidance provided by international standard-setters such as the OECD Guidelines for multinational enterprises, the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights and the ILO (International Labor Organization) Tripartite Declaration of Principles concerning Multinational Enterprises on Social Policy.

We ensure gender-sensitive zero tolerance policy commitment towards all forms of gender-based discrimination in employment and occupation, including psychological harm and verbal, physical and sexual harassment. Read our policy principles here.

• This is supported by our Remuneration Policy and Base Salary Management Standard and internal processes, our recruitment and development practices and processes.
• All our policies and processes are gender neutral.
• We do our best to ensure health and safety for employees, clients and visitors. All internal and local regulations are ensured, including as described in the ILO conventions and the MNE Declaration. 
• We require our third parties to ensure fair employment practices:
  
  Discrimination: The Third Party shall ensure fair treatment of employees.
  
  Freedom of Association: The Third Party shall respect the right of the Third Party’s employees to establish, join trade unions, and any other association of their choice.
  
  Prohibited Labour: The Third Party shall ensure that no forced labor or child labor is used.
  
  Working Conditions: The Third Party shall ensure that working conditions, hours and voluntary overtime are in accordance with the local regulation and industry practice, and that remuneration and benefits meet legally mandated minimums without unauthorized deductions.
  
  Health and Safety: The Third Party shall ensure a safe and healthy workplace for all employees, which is appropriately documented and implemented considering the  size, nature, and risks of the Third Party’s operations.

We are determined to fight financial crime, such as tax evasion or money laundering and to prevent financing of terrorism, breach or evasion of international sanctions and proliferation of weapons of mass destruction through any of our products, services or channels. To that end, we carefully follow area-specific legislation of our operating countries – Estonia, Latvia and Lithuania, as well as international best practices and have adopted relevant policies. Read more:

• Anti‑bribery and anti‑corruption principles in Luminor Code of Conduct
• Luminor Bank anti‑money laundering and sanctions compliance policy principles

Whistleblowing: Raise Your Concern channel.

Further information on combating money laundering and terrorism financing can be found here.

• Customer privacy and data security
• Complaints and feedback handling
• We take data protection and the storage and processing of customer data and information in the course of business very seriously. It is important to us that the customer feels safe. The information we provide on our website is designed to help the customer to exercise their individual rights and to provide a quick and satisfactory resolution, as well as explaining how to make a complaint if this is unsuccessful. Information Security Policy Principles are applicable for all Luminor Bank AS and its subsidiaries.