Nordnet AB publ

Lobbying Governance

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#### Allocation of responsibilities. The board of Nordnet AB adopts Nordnet's sustainability strategy every year through our environmental and sustai­ nability policy. Furthermore, the board is kept continuously informed about the work through the sustainability mana­ ger. The board's audit committee follows up on the imple­ mentation of the sustainability strategy at each committee meeting. The risk and compliance committee is kept infor­ med on sustainability-related risks in the quarterly risk re­ port. Sustainability-related risks are also discussed in the "Regulatory Forum", which is chaired by Nordnet's risk ma­ nager and where, among others, the CEO, CFO and general counsel together with the management team are represen­ ted. The sustainability manager is responsible for developing and following up on the sustainability strategy and reports back to the audit committee. The respective department heads are responsible for implementing the sustainability strategy in their part of the business. Each company within the Nordnet Group has its respective sustainability policy that regulates operations.

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Governance within sustainability. Good corporate governance is important for effective sustainability work, as it lays the foundation for how the work should be conducted. Nordnet's governance around sustainability is based on the policies and the sustainability strategy that are adopted each year by the board of directors (unless otherwise stated, the \"board\" refers to the board of directors of Nordnet AB). When policies are described, only the most important policies within each area are referred to. Regarding the sustainability strategy, each department head within Nordnet is responsible for implementing the strategy in their part of the business. The Head of Sustainability is responsible for developing and following up on the sustainability strategy and for continuously reporting to the board's audit committee how the work is progressing, together with KPIs for climate and gender equality work. The Head of Sustainability also reports to the entire board or various committees as needed. In addition to reporting to the board, the Head of Sustainability is also responsible for reporting, informing, and preparing decision-making materials on sustainability issues for group management. The audit committee is responsible for preparing sustainability issues for decisions by the board of directors. Sustainability is a continuously recurring agenda item in the audit committee. An assessment of the board's competence in the area of sustainability has been made, and the board receives continuous training in the area. The board of directors of each subsidiary within the Nordnet Group adopts its own sustainability policy that establishes how the sustainability strategy should be implemented in its operations. Sustainability is, just like for Nordnet AB, a continuously recurring topic at board meetings in the subsidiaries. Sustainability risks are regularly presented to the group management through the Regulatory Forum, a body led by Nordnet's Chief Risk Officer and where the management team is represented. To manage the identified risks, Nordnet's management team adopts sustainability related targets, with the aim of evaluating effectiveness and target achievement. The management of sustainability risks is integrated into Nordnet's general risk management, where we work with internal control in accordance with the principle of the three lines of defense. The business operations constitute the first line of defense, while the risk control and compliance functions, and where applicable the actuarial function, constitute the second line of defense. Internal audit constitutes the third line of defense, which, on behalf of the board, monitors both the first and second lines of defense. Read more about this work in the governance report. The board's risk and compliance committee monitors sustainability-related risks through internal risk reporting. The periodic reporting to the board from the company's control functions includes sustainability risks and assessment of relevant sustainability exposures. The reports for the internal capital and liquidity assessment for Nordnet's banking operations (IKLU) and the insurance operations' own risk and solvency assessment (ORSA) include analysis and assessment of relevant sustainability risks.

https://nordnetab.com/wp-content/uploads/2025/01/Annual-and-sustainability-report-Nordnet-2024.pdf