The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How Nordea respects and promotes human rights

Nordea is the largest financial services group in the Nordic region and one of the biggest banks in Europe, with three main tasks: to convert savings into financing, to manage credit and other financial risks, and to enable payments and other financial transactions efficiently and securely. Nordea believes that human rights are fundamental to sustainable finance  Tweet This! and provide the core values on which a sustainable financial system should be built.

This case study is based on the 2018 Sustainability Report by Nordea published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Nordea works systematically to embed human rights across its operations, and to strengthen its due diligence processes. In order to respect and promote human rights Nordea took action to:

  • assess human rights-related risks
  • integrate human rights into guidelines
  • work in partnerships
  • address children’s rights

What are the material issues the company has identified?

In its 2018 Sustainability Report Nordea identified a range of material issues, such as climate action, diversity and inclusion, business ethics, community engagement. Among these, respecting and promoting human rights stands out as a key material issue for Nordea.

Stakeholder engagement in accordance with the GRI Standards                        

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Nordea engages with:

Stakeholder Group                Method of engagement
Employees ·      Coffee corners

·      People Pulse




·      GEM

·      BA Heads

·      BEVC

·      Sustainability Committee

Board of Directors ·      Meetings



·      Customer satisfaction surveys

·      Individual customer meetings

·      Customer contact centre



·      Annual General Meeting

·      Individual investor meetings

·      Investor questionnaires




·      Qualifying questionnaire

·      Supplier audits

·      Individual meetings

Regulators ·      EU Commission

·      FSA



·      Fair Finance Guide

·      Amnesty

Media ·      Interviews

·      Press releases

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Nordea conducted workshops and interviews with both internal and external stakeholders.

What actions were taken by Nordea to respect and promote human rights?

In its 2018 Sustainability Report Nordea reports that it took the following actions for respecting and promoting human rights:

  • Assessing human rights-related risks
  • As part of risk evaluations in the credit decision-making process for a customer Nordea analyses and assesses companies’ risk exposure, risk management and performance regarding human and labour rights. Nordea investigates whether companies have been involved in controversies, and the actions they have taken to mitigate and rectify the potential impacts of such controversies. All Nordea funds are also subject to annual norm-based screening, used to identify listed companies allegedly involved in breaches of international law and norms, including human rights. If a company is identified in this screening process, Nordea will initiate an internal assessment process of the company and the incident.
  • Integrating human rights into guidelines
  • Nordea supports the UN Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights and has included human rights in its Code of Conduct, Sustainability Policy, Responsible Investment Policy, Supplier Code of Conduct and its Sector Guideline for the Defence Industry. Human rights also form part of Nordea’s Code of Conduct training, which is mandatory for all employees as part of their Licence to Work training.
  • Working in partnerships
  • Nordea is a funding member and a member of the Advisory Council of the Corporate Human Rights Benchmark (CHRB). The benchmark aims to measure, on an annual basis, the human rights performance of the world’s 500 largest publicly listed companies, looking at the policies, processes and practices the companies have in place to address their human rights efforts, and how they respond to serious allegations of human rights violations. The 2018 benchmark assessed 101 companies from the Agricultural Products, Apparel, and Extractives industries that were chosen on the basis of their size (market capitalisation) and revenues. Nordea believes that the CHRB will raise the level of awareness of the materiality of human rights and help companies meet investor expectations on human rights. It will also enable financial institutions such as Nordea to assess and help clients make sure they are not linked to human rights abuses.
  • Addressing children’s rights
  • Nordea is a board member of the Financial Coalition against Commercial Sexual Exploitation of Children, a collaboration between Swedish banks, other financial companies in Sweden, the Swedish Bankers’ Association, ECPAT Sweden and other relevant participants. The coalition aims to prevent crime in cooperation with the Swedish Police and to eliminate the means of making payments for child pornography. In 2018, several working groups were established to advance these efforts.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standard addressed in this case is: Disclosure 412-1 Operations that have been subject to human rights reviews or impact assessments

Disclosure 412-1 Operations that have been subject to human rights reviews or impact assessments does not correspond to any SDG.


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  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP



1) This case study is based on published information by Nordea, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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