Guidelines for measures to prevent money laundering and terror financing

(set by the Board of Storebrand ASA 22 September 2009)

Introduction

These guidelines apply to Storebrand ASA and its subsidiaries. Storebrand is a key player in the financial market. Trust is an important competitive factor. Measures to prevent financial crime, money laundering and terrorist financing are an integral part of the group's activities and therefore an important focus area for developing and maintaining trust in the market.

Storebrand's rules for ethics and social responsibility provide a platform for these guidelines and for Storebrand's goals being part of the prevention of money laundering and financial crime in general. The guidelines are based on the Norwegian act on measures to prevent money laundering and terrorist financing (the "Norwegian Money Laundering Act").

Objective

Storebrand shall avoid having any dealings with funds generated by criminal activities. Protection against money laundering, fraud and internal irregularities are significant measures to protect the Storebrand companies' finances and reputation and their employees. Cases related to funds generated by criminal activities must be handled in such a way that the reputation of Storebrand is not damaged.

Within each business area, Storebrand shall identify the operational risk related to money laundering and terrorist financing. Storebrand shall have knowledge of its customers and understand its customers' business from a risk sensitive basis. This risk sensitive approach implies that implemented measures shall be adapted to the business's identified risk of being exploited within the area of money laundering and terrorist financing.

In order to achieve a risk sensitive adaptation of implemented measures, Storebrand shall perform risk assessments and implement risk based routines, perform ongoing monitoring and updating of risk assessments performed and also reassess implemented routines as required.

Storebrand shall conduct itself in a manner which supports Storebrand's strategy within social responsibility and boosts Storebrand's reputation in the market in all contexts.

This involves:

• Guidelines in this area shall apply to the whole organisation. In subsidiaries the principles shall be complied with as far as is practically possible and compatible with relevant legislation.
• There shall be equal treatment of all cases in the organisation.
• Criminal activities shall generally be reported.
• When ethical guidelines, authorisations and other guidelines are breached there shall be an assessment of whether this shall have consequences for the  employment conditions.
• Employment shall generally be terminated if a legal employment assessment provides the basis for such a reaction.
• Storebrand shall comply with the authorities' requirements for measures to prevent money laundering and ensure that the companies' systems and employees are capable of, and have the necessary expertise, for such compliance.
• Preventive measures and measures to expose breaches are the shared responsibility of the whole organisation. Managers at all levels are responsible for taking the necessary initiatives to protect customers, employees and the companies.
• The companies shall have a sufficient system(resources/expertise) to process specific cases in a professional and efficient way, with clear division of responsibilities between the various units/levels of the organisation.

Compliance with legislation and rules concerning measures to prevent money laundering and terrorist financing

Storebrand shall comply with legislation and regulations in this area and contribute to preventing and reducing the social problem of financial crime. Storebrand shall have a consistent attitude to money laundering, fraud and internal irregularities. Storebrand shall demonstrate such an attitude, both within the organisation and externally.

Storebrand shall comply with the authorities' intentions and requirements regarding the reporting of suspicious transactions. In order to be able to do this Storebrand shall implement adequate procedures and routines for risk assessment and identification of customers, analysis of transactions and investigation of possible suspicious transactions.

Roles and responsibility

The Norwegian Money Laundering Act defines which companies are subject to the money laundering regulations and which are subject to an obligation to report. The companies in Storebrand being subject to obligation to report are those group companies which are covered by the definition in the Norwegian Money Laundering Act at any time.

The managing director of each company subject to an obligation to report has an overall responsibility for attending to the company's risk management regarding the security risk which the companies, their finances, reputation and employees are exposed to in relation to irregularities at any time.

The managing director is also responsible for establishing systems (instructions and guidelines) which cover the following significant action points plus appointing responsible units and/or people:

• The instructions and guidelines required for processing irregularities (events) and preventive measures shall be established and implemented.
• The required training of employees shall be implemented.
• The companies shall set responsible reporting points as required for both internal and external reporting of irregularities.
• Procedures for investigations (scrutiny) of relevant cases shall be clarified.
• Managing directors are given full authority to seek external assistance for conducting the required investigations when irregularities are detected, as required.
• A system shall be established for implementing the necessary legal assessment of the circumstances of a case before a decision is taken on the reaction. This applies in particular to the processing of internal irregularities in terms of employment legislation and assessing internal irregularities and fraud in terms of criminal law.
• The board shall make a decision on reporting criminal activities on the basis of a recommendation by the managing director. The board may give the managing director full authority to submit a report without this having been considered in advance by the board. Personnel managers and those legally responsible shall have made their statements when the recommendation is made. The board shall be continually updated on major cases.
• The managing director shall inform the board annually about the situation concerning measures to prevent money laundering and other financial crime, including presenting an overview of cases reported externally.
• The managing director shall ensure that sufficient preventive systems have been established, including implementing measures in the companies' process descriptions and systems to detect suspicious transactions as early as possible to prevent losses.
• Managing directors are responsible for establishing the required internal communication in such cases, including with those responsible for internal control, auditing, security, personnel and legal affairs.
• The required preparations must be made in relation to internal and external information (media) in such cases. In major cases the information strategy shall be clarified with the board.

Every group company subject to an obligation to report shall appoint a money laundering supervisor. The role and its responsibilities are defined in the applicable money laundering legislation and in the specific job description and shall amongst other things cover:

• Training
• Assessment of suspicious transactions
• Reporting to The Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime
• Reporting money laundering to the managing director

When drawing up the annual auditing plan internal auditing shall assess the need for revising guidelines, procedures and routines.

Foreign companies/units shall have an employee who is specifically responsible for cases related to money laundering and terror financing.

Money Laundering Forum

Storebrand has set up a money laundering forum in the group which follows up work on money laundering and financial crime, specifically focusing on possible synergies and cooperation across the group companies. The forum shall consist of those responsible for money laundering in the group companies, supplemented by support functions. The chairman of the Money Laundering Forum shall be appointed and report to the Group Director for Social Responsibility and shall be responsible for checking compliance with the group companies' internal guidelines.

The Money Laundering Forum shall have the following duties:

• Drawing up, administering and continually updating internal guidelines for combating money laundering and financial crime with regard to applicable legislation at any time, including drawing up common rules for the group associated with customer control, continuing monitoring, contracting out, storing documentation and PEPs (politically exposed people).
• Overall responsibility for the development of systems and routines common to the group companies when problems affect several companies or when a solution common to the group companies should be established.
• Overall professional legal responsibility for understanding and complying with money laundering regulations within the group companies.
• Investigating suspicious transactions which involve several companies within Storebrand.
• Encouraging and assisting the line in its responsibility for ensuring that the respective products, systems and routines are in line with the applicable money laundering regulations at any time.
• Assisting the line in its responsibility for performing customer control and reporting of suspicious transactions with regard to money laundering.
• Ensuring that all information on money laundering on the Internet is up to date at all times and that an annual report on money laundering is produced.

Training

Storebrand shall organise and provide training for the company's employees, which is to be adapted to the various companies with regard to measures to prevent money laundering and terrorist financing. Employees shall be informed at least once a year about rules and routines linked to measures to prevent money laundering and terrorist financing plus new trends, patterns and methods which may be used within money laundering and terrorist financing.

Employees shall regularly be informed about changes to legislation and regulations, internal rules and routines. The duration and intensity of training shall be varied according to needs and the employee's links with customers and transactions in which there is a greater or smaller danger of Storebrand being exploited by money laundering and terrorist financing.

Reporting and information internally and to the authorities

The companies shall have specially appointed employees who shall be the reporting point for both internal and external reporting of irregularities. If a suspicion of internal irregularities is detected the group's personnel manager shall be notified and the group's guidelines for irregularities shall be applied.