Bonum Pankki Oyj
Material Topics
Sustainability statement, in full
The complete text of Bonum Pankki Oyj’s FY2025 sustainability statement is held here – 95 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
Administrative, management and supervisory bodies
Reference: page 24.
The Board of Directors of POP Bank Centre coop approves the Group's sustainability goals and strategy and discussed and approved the updated double materiality assessment during 2025. At end-2025 the Board had six members: two women and four men (33% women), with 50% assessed independent; the six-member Executive Board had one woman and five men. "The Board has appointed a responsible person from among its members" for sustainability oversight, supported by regular reports from the Chief Legal Officer and Sustainability Specialist. An ESG Steering Group, subordinate to the Executive Board, prepares sustainability-related proposals. No Board member is an executive of POP Bank Centre coop.
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to the administrative, management and supervisory bodies
Reference: page 26.
The Board receives information on material impacts, risks and opportunities (IROs) through the Executive Board "in the context of a regular annual review," on a case-by-case basis for operating-environment changes, and through regular business reporting. During 2025 the Board and Executive Board discussed: the update of the double materiality assessment, sustainability goals, monitoring of sustainability regulation, stakeholder and employee surveys, policies and their updates, and the ESG risk assessment. Notably, the report states plainly that the IROs "identified in the double materiality assessment have not yet been taken into account by the administrative, management and supervisory bodies in their oversight of the strategy."
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: page 26.
Each POP Bank Group entity decides its own remuneration under common Group principles, which state that remuneration "must be consistent with ... goals related to environmental, social and governance risks." However, the report is explicit about the gap at governance-body level: "There is no consistent policy within the POP Bank Group on whether sustainability-related performance and incentive schemes are offered to members of the administrative, management and supervisory bodies," and "members of POP Bank Centre's administrative, management and supervisory bodies do not have incentive schemes linked to sustainability matters."
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 27.
The report maps the ESRS 1 due diligence core elements to where each is addressed: governance/strategy embedding to GOV-1 and GOV-2; stakeholder engagement to SBM-2, IRO-1 and G1-1; identifying and assessing adverse impacts to IRO-1 and SBM-3; taking action on adverse impacts to GOV-2, S1-3, S4-3, G1-1 and G1-3; and tracking effectiveness/communicating to GOV-1, GOV-2, E1-4, S1-5, S4-5 and G1-3/governance targets. This table is the Group's own statement of where its due diligence process is disclosed across the Sustainability Report rather than a standalone due-diligence narrative.
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: page 28.
"There is no separate process or system of risk management and internal control for sustainability reporting in the POP Bank Group." The main internal functions participating in reporting are Finance, HR, Risk Control, Business and Compliance, each with defined data-collection models and controls. A Sustainability Specialist coordinates preparation of the report; the ESG Steering Group discusses reporting requirements and findings before escalating the most significant topics to the Executive Board and Board. The report discloses that its "risk assessment models, prioritisation methodologies and processes of sustainability reporting are currently in the developmental stage."
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: pages 28-31.
POP Bank Group offers retail banking (loans, investment products, accounts, cards, insurance, payment and online services) to private and corporate customers in Finland through 18 member cooperative POP Banks, and employed 888 people, all in Finland, at end-2025. Upstream value chain centres on funding (deposits, bonds, investor relations) and suppliers of IT, risk-reporting and financial-management services. Downstream covers private, corporate and member customers, with the loan portfolio (mainly residential/real-estate-secured, consumer and corporate loans) as the key value-chain element, plus local influence (branches, sponsorships, partnerships) and the Group's investment book. Sustainability targets for 2025-2027 span environmental, social and governance goals, revised in 2025 after the strategy update.
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 31-32.
Key stakeholders are customers, employees, service providers/partners, investors, authorities, credit rating agencies, local communities and interest groups, engaged via channels including customer/employee surveys, the Co-operation Act dialogue, the whistleblowing channel and cooperative meetings. The double materiality assessment "created an understanding of the interests and views of stakeholders using surveys and interviews": social themes highlighted were "local influence, personal service, employee well-being and equality and customers' data protection"; environmental themes were sustainable products and climate mitigation; governance themes were "financial stability, transparency in business operations, and the prevention of the grey economy and money laundering."
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: page 33; per-topic IRO tables at pages 71 (E1), 88 (S1), 99-100 (S4), 110 (G1), 107 (Local influence), 115 (Financial stability).
The 2025 DMA update identified material topics of E1 Climate Change (climate change mitigation, energy), S1 Own workforce (working conditions, equal treatment), S4 Consumers and end-users (information-related impacts, personal safety), and G1 Business conduct (corporate culture, whistleblower protection, corruption and bribery), plus two entity-specific topics outside the ESRS DRs: local influence and financial stability. "During 2025, the POP Bank Group's material risks and opportunities have not had financial effects on its financial position." Resilience was assessed via an Executive Board questionnaire (scale 1-5); "the average resilience score was at least level 4 (good)" for all material matters. Impacts concentrate in own operations and, via customer financing, the downstream value chain.
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: pages 34-38.
The first double materiality assessment ran 2023-2024 (stakeholder questionnaire 2022, in-depth reviews 2023) and was updated in 2025 on the existing base, using a 1-3 severity/likelihood scale and short/medium/long time horizons, with an Executive Board workshop adjusting scores. "Topics that were given a low rating, which were not assessed to be material, were working conditions and rights of value chain workers, water resources and pollution" (page 35). The 2025 update found that "biodiversity and ecosystems and the community-specific topic of sustainable products did not exceed the materiality threshold," nor did "climate change adaptation, social inclusion of consumers and/or end-users and relationships with suppliers of goods and services" (page 36); "corporate culture was identified as a new material sub-topic." No material impacts were identified for pollution, water, circular economy or biodiversity in own operations, and "the Group has not conducted consultations with affected communities" (page 38).
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: page 39.
The IRO-2 content index lists the Disclosure Requirements the statement complies with, by page: ESRS 2 BP-1 through IRO-2 (pages 23-39); E1-1 through E1-7 for Climate change (pages 71-87); S1-1 through S1-6, S1-9, S1-12 and S1-14 through S1-17 for Own workforce (pages 89-98); S4-1 through S4-5 for Consumers and end-users (pages 100-105); and G1-1, G1-3 and G1-4 for Business conduct (pages 111-114). No Disclosure Requirements are listed for E2, E3, E4, E5, S2 or S3, consistent with the DMA findings recorded under IRO-1 and SBM-3. A separate table (pages 41-44) lists datapoints deriving from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law), flagging most environmental and value-chain-worker datapoints "Not material."
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: page 72.
"The POP Bank Group does not currently have a transition plan for climate change mitigation that covers its value chain." During 2025 the Group "set emission reduction targets for Scope 1 and Scope 2 emissions from its own sites, taking into account the requirements of a transition plan," with these targets described under E1-4. The Group "intends to continue setting reduction targets for Scope 3 emissions in 2026, after which the development of a transition plan could become feasible in the medium term." This is a clear, company-stated gap: no transition plan exists yet, and full value-chain coverage (the dominant Scope 3 share of emissions, via the investment and loan portfolio) is not yet in scope.
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: page 72.
Key policies are "internal guidelines related to lending and investment activities, the Code of Conduct for suppliers and partners and the responsible procurement policy." The corporate lending policy guides assessment of environmental/climate factors in lending; the private-customer lending policy covers sustainable-lending principles; investment guidelines recommend sustainability criteria for direct/indirect investments and require external asset managers to sign the UN Principles for Responsible Investment (liquidity-securing investments are governed by regulatory liquidity criteria, not sustainability criteria). The Code of Conduct for suppliers/partners requires environmental-legislation compliance and avoidance of negative environmental impacts; the responsible procurement policy gives guidance on energy efficiency and lower-emission products. All are approved by POP Bank Centre coop's Board or Executive Board.
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: page 73.
Actions run through the lending process (environmental-factor assessment guided by the lending and collateral policy; a project since 2024 to develop more detailed sustainable-financing guidelines) and through the Vihreä laina green loan, offered since 2021 with an EIF guarantee added in 2024, available to private customers, businesses and housing companies. Some sites participate in WWF's Green Office programme: "Bonum Bank Plc's both offices in Espoo and Vaasa and POP Bank Centre coop's office in Espoo have been granted Green Office certification," with POP Bank Lannevesi seeking certification. During 2025 some sites cut emissions via renewable district heating/heating oil or EV/hybrid fleet replacement. The Group "has not yet undertaken or planned any climate-related actions that would require significant amounts of CapEx or OpEx."
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: page 74.
Targets cover 2025-2027, approved by POP Bank Centre coop's Board. Climate targets: (1) grant at least EUR 10 million in green loans in 2025 and EUR 15 million in 2026 - missed, with only EUR 0.13 million granted due to slower-than-expected demand; (2) add new sustainable (Article 8/9) funds to the product range by end-2027 - none added in 2025 (fund mix: 9% Article 6, 86% Article 8, 5% Article 9, unchanged from 2024); and (3) set Scope 1+2 emission-reduction targets and an action plan for 2025 - achieved. The Scope 1+2 target, set against a 2024 base year of 1,334 tCO2e, targets a 560 tCO2e (42%) reduction to 774 tCO2e by 2030, aligned to SBTi cross-sector criteria; Scope 3 target-setting was postponed to 2026 and the targets are unverified externally.
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: page 76.
"The Pop Bank Group's total energy consumption in 2025 was 7,487 (7,040) MWh. Of energy consumption, 56% (54%) came from renewable sources, 33% (33%) from fossil sources and 11% (8%) from nuclear." The breakdown: total fossil 2,478 MWh (2024: 2,353), nuclear 793 MWh (581), renewable (purchased electricity/heat/steam/cooling) 4,166 MWh (3,819) plus 7 MWh (8) of renewable fuel and 42 MWh (0) self-generated, and 0 MWh (279, 5%) from other sources. Consumption data were "retrieved for the period 1 January - 31 October 2025," with the remaining months estimated from the prior year's monthly average.
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 77-79.
"In 2025, the POP Bank Group's market-based total GHG emissions were 119,724 (149,460) metric tonnes of CO2eq and location-based total GHG emissions were 119,255 (149,048) metric tonnes of CO2eq." Scope 1 was 132 tCO2e (114 in 2024); Scope 2 market-based 1,007 tCO2e (1,220 in 2024); Scope 3 totalled 118,585 tCO2e (148,126), dominated by category 15 Investments at 110,444 tCO2e (139,808) and category 1 Purchased goods and services at 6,694 tCO2e (7,055). GHG intensity (market-based) was 411.2 (454.0) tCO2eq per EUR million net revenue. Scope 3 investment and loan-portfolio emissions were calculated under the PCAF methodology; the 2024 comparative was restated by -2,962 tCO2eq for a calculation-methodology refinement disclosed under BP-1 of ESRS 2 General Disclosures.
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon creditsReported
GHG removals and GHG mitigation projects financed through carbon credits
Reference: page 87.
"The POP Bank Group has not yet purchased any carbon credits or undertaken any GHG removals or storage that would have been a result of the mitigation projects identified by the Group. Therefore, the total amount of GHG removal and storage and the total amount of carbon credits outside the value chain in metric tonnes of CO2eq is 0." This is a complete, explicit nil return rather than a gap in disclosure, and it is listed in the company's own IRO-2 content index at page 87.
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 34-35, 71-72). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Climate risks are classified: mitigation-related risks are "considered transition risks"; physical risk in the loan portfolio is identified as "river floods, which may affect real estate and buildings," assessed as not expected to affect capital adequacy short-term but possibly long-term; transition risk for own operations is "the achievement of the emission reduction goals under the Paris Agreement." Scenario analysis was used: "A 4.5°C climate scenario has been used to identify physical climate risks and a 1.5°C climate scenario has been used to identify transition risks," with the 1.5°C scenario also used "to assess the risks that would arise if the POP Bank Group were to fail to meet the emission reduction targets of the Paris Agreement" (page 35).
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from ESRS 2 SBM-3 and the E1 climate resilience discussion (pages 34, 71-72). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
General resilience (all material topics) was scored via an Executive Board questionnaire on a 1-5 scale, averaging "at least level 4 (good)" (page 34). The climate-specific resilience analysis "is limited to the loan portfolio ... mortgages and real estate, and construction projects," plus own-operations transition risk; physical risk was not assessed for own operations as "not assessed as material." It "was conducted during 2024," and based on the 2025 ESG risk update "no need to update the resilience analysis has been identified." The analysis did not cover macroeconomic, energy-mix or technology-deployment assumptions, and the Group "has not separately assessed its ability to adapt its strategy and business model to climate change."
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 89-90.
Key policies: the Code of Conduct (Board-approved, sets equal-treatment requirements, no discrimination "on the basis of gender, age, ethnic background, religion, sexual orientation or any other personal characteristic"), the HR policy (covers equal treatment, wellbeing/skills development, safety, communication, involvement), and early-support-practice guidelines (addressing factors impairing work, safety or wellbeing "at a sufficiently early stage"). The Group "complies with ... the collective agreement for the financial sector." It commits to ILO Fundamental Principles and the UN Universal Declaration of Human Rights, but states it "has not conducted a policy-specific comparison" against the UN Guiding Principles on Business and Human Rights, and has "not established a Group-wide workplace accident prevention policy or management system" - each entity handles health and safety independently.
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Processes for engaging with own workers and workers' representatives about impacts
Reference: page 91.
Co-operation Act entities hold regular employee dialogue; entities with over 20 employees have a health and safety committee. Internal communication runs via the intranet, internal meetings and quarterly Group-wide briefings. "Employees' views, satisfaction and wellbeing are regularly assessed through employee surveys," with results discussed at multiple organisational levels and with shop stewards, and grievances addressed unit by unit. Employee views also feed the double materiality assessment and sustainability goal-setting. The report discloses a governance gap directly: "no person has been specified on the Group level that has operational responsibility for ensuring that engagement happens and that the results inform the company's approach."
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concernsReported
Processes to remediate negative impacts and channels for own workers to raise concerns
Reference: pages 91-92.
Remedies are case-by-case and may include occupational health care, early-support practices, HR or external-coach mediation, or workplace training; entity- or Group-level development plans can follow. Concerns can be raised with the health and safety representative, shop stewards, HR, supervisors, management, or the whistleblowing channel, received by the Compliance Officer and internal audit's Audit Director, who aim to update the whistleblower on progress "within one month." Reports are treated confidentially. The Group states it "does not separately assess the awareness of its own workforce on the processes for reporting concerns," though the Compliance Officer and Audit Director track and report annually on report volumes to the Board.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 92-93.
Actions run through occupational health services, employee surveys, resourcing and early-support practices, monitored via survey results and sickness-absence data. For working conditions: early support, supervisor training, flexible/remote work and role-based training mitigate work-life-balance and turnover impacts. For equal treatment: mandatory Code of Conduct training, voluntary equality/inclusion courses, transparent recruitment, and equal-pay reviews under the collective agreement's pay-discussion model mitigate unequal-treatment and pay-gap risks. "During 2025, the management of the POP Bank Centre coop has not been made aware of any actual material impacts on its own workforce that would have required significant remedial action."
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: page 93.
The 2025-2027 target is to "promote the equality, skills and well-being at work" of employees, measured by the employee-survey NPS score, with a target of at least 20 (revised in 2025 to align with the updated strategy). The target and the double materiality assessment's stakeholder input, including the employee survey, were used to set it, via a workshop with POP Bank Centre coop's Executive Board and experts. The actual result: "The POP Bank Group's employee survey NPS score was 13 in 2025, which is below the set target," which the report attributes partly to "the ongoing system renewal project," which "introduced changes to employees' daily work" during the reporting year.
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: page 95.
Headcount at end-2025 was 888 (830 in 2024): 225 male, 663 female employees, no "other" or undisclosed-gender employees reported. FTE data (by gender, permanent/temporary, full-time/part-time and non-guaranteed-hours) is also reported for 2025 and 2024, e.g. 2025 total FTE of 788.23 against 770.73 in 2024. Employee-turnover data shows 230 new employment relationships started in 2025 (193 in 2024; 134 permanent/96 temporary) against 158 terminations (116 in 2024). Data is drawn from the Group's HR system, reported at head-count as at period end; fixed-term contracts are used "for example for project work, deputyships or to provide internships for students."
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: page 96.
Age distribution at end-2025 (head count / %, 2024 in brackets): under 30: 197/22% (178/21%); 30-50: 462/52% (432/52%); over 50: 229/26% (220/27%). Employee turnover was 18% (14% in 2024) and the new-hire rate 28% (26%). Top-management gender distribution (defined as "CEOs and Executive Board members"): female 38/51% (44/58% in 2024), male 36/49% (32/42%). Data is drawn from the Group's HR system and a survey of Group entities for senior-executive gender data, reported as head count at period end as a proportion of total Group employees.
S1-11(was S1-12)Persons with disabilitiesReported
Persons with disabilities
Reference: page 96.
The report states directly: "The percentage of persons with disabilities among the POP Bank Group's employees cannot be reported due to legal restrictions on data collection." This is a stated reason for non-disclosure rather than a silent gap - Finnish data-protection law restricts employers from collecting disability status as personal data - and S1-12 appears in the company's own IRO-2 content index at page 96, confirming the Group treats this explanation as its complete answer to the disclosure requirement rather than as an omission.
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: page 97.
"In the POP Bank Group, 100% of employees are covered by at least statutory occupational health care services. No fatalities resulting from work-related injuries or work-related ill health have occurred in the POP Bank Group during 2025." The Group "recorded 14 injuries which occurred while commuting or work-related injuries" (8 in 2024) and "the rate of work-related injuries is 9.6" (5.9 in 2024), calculated per million hours worked. BP-2 discloses that datapoints 88(d) and 88(e) and the non-employee breakdown are deferred under ESRS 1 transitional provisions (page 23), so the days-lost and non-employee figures that would complete paragraph 88 are not yet quantified.
S1-14(was S1-15)Work-life balance metricsReported
Work-life balance metrics
Reference: page 97.
"Of POP Bank Group's employees 100% are entitled to family leave." 7% of employees took family-related leave in 2025 (6% in 2024): 5% of the workforce were women who took leave (5% in 2024) and 2% were men (1% in 2024). The figures include employees whose leave began before the reporting period but continued into it, and data is drawn from the Group's HR system. No further breakdown (e.g. by country) is given, but the entitlement rate and uptake rate are both quantified and appear in the company's own IRO-2 content index at page 97.
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total compensation)
Reference: page 97.
Unadjusted gender pay gap: "Employees (%)" 0% in both 2025 and 2024; "Senior Employees (%)" 8% in 2025 (11% in 2024). The annual total-remuneration ratio of the highest-paid individual to the median employee (excluding that individual) was 7.6 in 2025 (8.5 in 2024). Methodology: hourly pay for monthly-paid staff is derived by dividing monthly pay by "the hourly pay divisor in the collective agreement"; the report notes "differences in job roles, work experience, and the number of years in employment can influence the pay gap between women and men."
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: page 98.
"POP Bank Group has received two incidents of discrimination or harassment during 2025" (1 in 2024), collected via a questionnaire to Group entities and the whistleblowing channel; "the Whistleblowing channel has not received complaints during 2025," though the number of complaints via other channels "has not been separately collected." "The POP Bank Group did not incur any fines, penalties or compensation payments related to discrimination or harassment reports of complaints in 2025," and "no severe human rights incidents related to the POP Bank Group's workforce have arisen during 2025," with zero associated fines or compensation payments.
S4 – Consumers and End-users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: page 100.
Key policies: the Code of Conduct, the information and communication policy, the product management policy, and the data protection and information security policy, all approved by POP Bank Centre coop's Board and applying to all entities. The Code of Conduct commits the Group to national law and the ILO Declaration/UN Universal Declaration of Human Rights; the report states "the POP Bank Group has not been made aware of any incidents that took place in 2025 related to consumers or end-users regarding non-compliance" with UNGPs, the ILO Declaration or OECD Guidelines. "All the POP Bank Group's consumers and end-users come under the information reported in accordance with ESRS2 General Disclosures," and the Group explicitly does not offer products "inherently harmful to people."
S4-2Processes for engaging with consumers and end-users about impactsReported
Processes for engaging with consumers and end-users about impacts
Reference: page 102.
Channels include "online and mobile banking, emails, mailing, websites and meetings with customers," with the Chief Operating Officer of POP Bank Centre coop holding operational responsibility for communication. Views are gathered through customer meetings, satisfaction surveys, product-development involvement, feedback/complaints, and the double materiality assessment. "The POP Bank Group participates annually in the EPSI Rating customer survey," and feedback surveys follow each Taloushetki financial-advice session. Results feed the Group's sustainability goal-setting and, for example, "customer views were also taken into account when defining the features of the loan guarantee product."
S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concernsReported
Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reference: page 102.
Customers can raise concerns via the website contact form, email, online-banking messages, or their own bank, and can escalate to the Finnish Financial Ombudsman Bureau or Consumer Disputes Board. Complaints receive "a response within 15 working days," with "a final response ... within 35 working days." The banks and POP Bank Centre coop track complaints "to identify and address recurring and systematic errors"; executive management and Boards of Directors monitor them. Data protection/information-security concerns go to dedicated email addresses. The report states plainly that "there is no separate policy in place regarding the protection of individuals against retaliation for using the processes for consumers and end-users to raise their concerns."
S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actionsReported
Taking action on material impacts on consumers and end-users
Reference: pages 103-104.
Negative impacts on information quality are managed through the product management procedure and staff skills development; data-protection and information-security risks through dedicated processes, guidance, staff training and a maintained information security management system, with risk events "reported and processed centrally" and root-cause analysis applied. "During 2025, the POP Bank Group was not made aware of any actual material impacts on consumers and end-users that would have required significant remedial action," and it "has not been notified of any serious human rights issues or cases of human rights incidents related to consumers and end-users in 2025." Effectiveness is tracked via the annual product-management survey and customer feedback/complaints.
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to consumers and end-users
Reference: page 105.
2025-2027 targets: (1) produce a corporate-customer sustainability guide by end-2026 - advanced via staff training and updated lending guidelines, though "monitoring the discussion of sustainability themes in corporate customer meetings is still at the planning stage, and no metric is being monitored yet"; (2) achieve a minimum NPS of 75 for the Taloushetki advice service - achieved at 82.5 in 2025, up from the 2023 baseline; and (3) achieve minimum customer-satisfaction NPS of 33 (private) and 31 (business) - both exceeded, at 48 and 49 respectively in the 2025 EPSI Rating survey, where "the POP Bank Group had the most satisfied corporate customers in the banking sector in Finland" and ranked first on service/product quality among private-customer respondents.
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 111-112.
Key policies: the Code of Conduct, anti-bribery and anti-corruption policy, whistleblowing policy, AML/financial-crime-prevention policy, sanctions-compliance policy and (new in 2025) sustainability policy, all Board-approved. "The POP Bank Group has zero tolerance to bribery, corruption and other unethical means of influence." The whistleblowing channel is "internally accessible to all employees," received by the Compliance Officer and internal audit's Audit Director; "the implementation of an external whistleblowing channel has been assessed during 2025" but not yet adopted. Whistleblowers are protected from retaliation, with identity disclosed only where legally required or necessary for the inquiry.
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: pages 113-114.
Entities maintain gift registers with written pre-approval above a euro threshold, reviewed by the Board at least annually. Risk assessments, training, and due-diligence checks on service providers are used to prevent corruption/bribery; confidential reporting runs through the whistleblowing channel, the gift-register contact, or the compliance function. Violations go to the CEO and Board, who decide remedial action. "The training programme covers 100% of the POP Bank Group's employees and managers. The training programme covers 0% of the Board Members," though "in 2025, members of the governing bodies were provided with dedicated training." For AML: new automated monitoring systems were developed in 2025, partly centralised at POP Bank Centre coop and Bonum Bank Plc.
G1-4Incidents of corruption or briberyReported
Confirmed incidents of corruption or bribery
Reference: page 114.
"No incidents of corruption or bribery were identified in the POP Bank Group in 2025. POP Bank Group was not convicted or fined in corruption or bribery incidents during 2025. No action to address violations was carried out as no incidents were detected." The accompanying table records zero convictions for violation of anti-corruption and anti-bribery laws and EUR 0 in related fines, for both 2025 and 2024. Management receives regular reporting on AML/financial-crime risk status, covering the Executive Board and the Boards of POP Bank Centre coop, POP Banks and Bonum Bank Plc.
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct (part of MDR-T/GDR-T disclosures)
Back-filled from the "Targets related to governance" section (page 114), since G1-3-Targets did not exist as a standalone DR under the 2023 ESRS the report was prepared against; business conduct targets fell under MDR-T.
The 2025-2027 governance target: "We operate in accordance with good governance and our Code of Conduct," metric "at least 95% of our employees have completed courses on good governance and the Code of Conduct." Training covers "ethical business principles, data protection, information security, anti-corruption and anti-bribery, whistleblowing, and anti-money laundering." Tracked result: "In 2025, the completion rate for the training courses monitored ranged from 69% to 87%" - below the 95% target - with the report stating "measures to achieve the target will be continued, for example through internal communications."