Dnb Bank Asa
Material Topics
Sustainability statement, in full
The complete text of Dnb Bank Asa’s FY2025 sustainability statement is held here – 159 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
The role of the administrative, management and supervisory bodies
Reference: page 67.
"DNB's Board of Directors and Group Management team are the Group's administrative, management and supervisory bodies" (page 67). The Board has three sub-committees: the Risk Management Committee, the Audit Committee and the Compensation and Organisation Committee. Under their instructions, "the Audit Committee prepares the Board's follow-up of the sustainability reporting process, including associated internal control, and the Risk Management Committee prepares the Board's follow-up of risk management in the Group." The Board signs the sustainability statement, and in 2025 "the Board considered the updated double materiality analysis for 2025" (page 67).
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies
Reference: page 67.
In 2025 the Board "received, among other things, information about the progress for metrics set within the topics of climate, diversity and equality, as well as quarterly reports about the Group's risk picture, which includes sustainability risk" (page 67). The Board follows up work on climate and the environment, social conditions and corporate governance "through periodic reporting," and is "also informed about DNB's statements on due diligence relating to sustainability through the Group's risk reporting and by signing the annual Report under the Norwegian Transparency Act" (page 67).
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: page 69.
The CEO's variable remuneration "has one financial performance criterion which is weighted at 60 per cent and five performance criteria relating to strategy and sustainability, that combined have a weighting of 40 per cent" (page 69), including "Engagement and diversity" (8 per cent, assessed qualitatively "based on employee surveys, gender balance at management level and the Group's position in society relating to diversity and equality") and "Compliance" (8 per cent). For other Group Management team members, "the Group's scorecard... weighting... at a minimum of 50 per cent," with a "Sustainable transition" line item shown on the scorecard table (page 69).
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 70.
DNB presents "an overview of where information has been given about the Group's process for due diligence in this sustainability statement" as a cross-reference table against the five core elements of due diligence (page 70): embedding due diligence into governance, strategy and the business model (GOV-2 p.67, GOV-3 p.69, SBM-3 pp.106, 148, 152, 159, 165, 169, 174, 178, 181, 185, 188); stakeholder engagement (GOV-2 p.67, SBM-2 p.76, IRO-1 p.80); identifying and assessing adverse impacts (IRO-1 p.80, SBM-3, SBM-1 p.74); taking action (MDR-A across topics); and tracking effectiveness (MDR-T/MDR-M across topics).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: pages 70-71.
"The Group is strengthening internal control over sustainability reporting, and worked in 2025 to implement a framework based on the same main principles as those used for financial reporting... The work was based on the COSO framework" (page 70). "A new complete risk assessment has not been made in the reporting year. Instead, based on previous assessments and experiences from the reporting in 2024, DNB has decided to strengthen the internal control relating to important key figures in areas where there is a need for improvements," including risks from "the use of estimates" and "an unclear distribution of roles and responsibilities in the reporting process" (page 71).
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: page 74.
"DNB is Norway's largest financial institution," with "about 2.4 million personal customers and 240 000 corporate customers" and "a total of 11 649 employees (11 515 in 2024)" across 19 countries at end-2025 (page 74). The value chain has three components: upstream (capital raising, IT and office procurement), own operations, and downstream (loans, investments, facilitation). "It is through the downstream activities loans and investments, that DNB has the greatest indirect impact on people and the environment... At the same time, as a large employer and a systemically important financial institution, DNB also has direct impacts" on employees and business ethics (page 74).
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 76-77.
DNB's stakeholder groups are customers, owners/investors, employees, authorities, industry organisations, special interest organisations, and business partners/suppliers (page 77). "The stakeholders' perspectives play a key role particularly in the work with the updated double materiality analysis... at present there are no plans for changes to the Group's strategy or business model as a result of the stakeholder dialogue" (page 76). Engagement ranges from "quarterly customer satisfaction surveys" and "annual employee surveys" to ongoing contact with "Finanstilsynet... Norges Bank... and politicians regarding relevant public affairs matters" (page 77).
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 78; materiality matrix page 79.
"DNB has identified IROs relating to topics in five of the topical ESRS standards" - E1, E3, S1, S4 and G1 - plus four company-specific topics (cyber security, financial crime, financial infrastructure, financial stability) (page 78). "IROs have also been identified in connection with topics within the other topical ESRS standards, but these topics have not been assessed as being above DNB's threshold value for materiality," including financial inclusion, which is "indirectly taken into consideration through identified IROs relating to the ESRS topic access to quality information under ESRS S4" (page 78). The matrix on page 79 plots E1 Climate change as Critical; E3 Water and marine resources and S1 Own workforce as Significant; S4 Consumers and end-users and E4 Biodiversity as Strong; S2 Workers in the value chain, E2 Pollution and E5 Resource use/circular economy as Noticeable; G1 Business conduct as Noticeable/Minimal; and S3 Affected communities as Minimal.
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 80-84.
DNB performed its double materiality analysis in 2024 "in line with the CSRD and the requirements in ESRS 1 and ESRS 2," following "EFRAG's Implementation Guidance from May 2024" and AR16 (page 80). In 2025 DNB "performed an update of the 2024 double materiality analysis and quality assured the identified IROs," using internal and external stakeholder dialogue, peer review, and a UNEP FI Portfolio Impact Analysis Tool assessment of the loan book (pages 81-82). A threshold value of "4 (significant) or more" was set in 2024 and "was not changed in 2025" (page 81). The downstream value chain is delimited to "loans (for both corporate and personal customers), investments... and facilitation activities," with financed greenhouse gas emissions and human rights assessed beyond direct business relationships (page 81).
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 85.
"The tables below show all of the ESRS disclosure requirements in ESRS 2 and the applicable disclosure requirements in the topical standards... The assessment of whether a disclosure requirement is applicable is based on the double materiality analysis, in addition to the phasing-in rules for certain disclosure requirements," drawing also on EFRAG's "memo ID 177 - Links between AR16 and Disclosure requirements" (page 85). "DNB has used the phasing-in provisions for disclosure requirements in accordance with" the 2025 "Quick Fix" regulation, and "provides an explanation when it does not report on a requirement," including where a requirement "is not considered material" (page 64).
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: page 105.
DNB's transition plan, launched in 2023, "is a continuation of the ambition to achieve net-zero emissions by 2050 that was set in 2021" and "contains concrete interim targets for selected sectors leading up to 2030" (page 105). DNB states plainly: "In the plan's current form, DNB is unable to make disclosures in accordance with the ESRS E1-1 reporting format... it is not relevant for DNB to report emissions targets in absolute values, as the targets are expressed as emissions intensity targets or loan-to-value ratio" (page 105). The decarbonisation targets "covered about 75 per cent of the Group's drawn exposure in 2025." The plan "has been approved by DNB's Group Management team and Board," with the Group CFO "responsible for monitoring implementation" (page 105).
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, where this content is disclosed in the FY2025 report (pages 82-84). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Physical risk was assessed using "NGFS' 'hot house world' scenario, which assumes that the climate targets that have been set will not limit global warming adequately, and that global warming will increase by more than 2°C by 2100," alongside "the 1.5°C scenario Net Zero 2050 (orderly) from NGFS" (page 83). Transition risk and opportunities drew on "NGFS' Net Zero (orderly) scenario, CRREM's Global Decarbonation Pathways scenarios and Business Ambition for the 1.5 Campaign scenario from the Science Based Targets initiative (SBTi)," with scenario likelihood informed by the "UNEP Emission Gap Report 2023" (pages 83-84). Scope covers the loan and investment portfolios; DNB notes "both transition and physical risk can represent financial risk, but physical climate risk is considered material in the long term" (page 83).
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/IRO-1 and the E1 climate-risk section, where this content is disclosed in the FY2025 report (pages 80, 106-110). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
DNB does not present a dedicated ESRS-format resilience analysis, but describes related stress testing: "DNB assesses the financial effects on the portfolios as a result of climate risk through stress tests, scenario analyses and risk assessments of the loan portfolio," with "annual scenario analyses relating to the climate... performed for the investment portfolios in DNB Asset Management (DAM) and DNB Livsforsikring" (page 106). A sector-level analysis "showed limited effects on DNB's loan portfolio for these sectors, which turned out to be resilient against transition risk" (page 107), though it "assumed that the bank's credit portfolio will remain unchanged (static balance), which is an assumption that becomes less and less realistic the longer the time horizon" (page 107). DNB Næringseiendom separately applies a TCFD-aligned framework using "MSCI's CVaR model" for physical risk and CRREM/BREEAM for transition risk, concluding its "strategy ensures that the portfolio is resilient against both physical damage and regulatory requirements" (page 110).
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: page 110.
DNB's Group policy for sustainability, "approved by the Group Chief Executive Officer (CEO), and the Group Chief Financial Officer (CFO)," states "that DNB supports the UN Sustainable Development Goals (SDGs), and follows leading norms and principles, such as the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the ten principles of the UN Global Compact" (page 110). "The Group instructions for responsible investments are intended... to ensure that assessments of risks relating to sustainability factors are integrated into investment decisions," applying to "all financial investments and asset classes," and DAM "has developed expectations documents for the companies it invests in, relating to a number of different sustainability topics, including climate and the environment" (page 110).
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 111-114.
Actions are organised by sector. For mortgages: green mortgages and fixed-rate loans "with price incentives for homes with an EPC label of A or B" (page 111). For commercial real estate: sustainability-linked loans and, in 2025, DNB "further strengthened and systematised the assessment of energy efficiency and transition risk as part of the credit risk assessments" (page 112). For shipping: customers "assessed by means of an integrated assessment of ESG and transition risk, which includes an AER indicator" (page 112). DNB states plainly that "the actions that DNB carries out cannot be measured as a direct reduction of greenhouse gases, and DNB therefore cannot calculate expected or achieved reduction," because emissions "arise indirectly in the Group's value chain" (page 114).
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: pages 115-134.
The transition plan sets "concrete interim targets associated with the emissions the Group finances (Scope 3 emissions), as well as decarbonisation targets for own operations" by 2030, plus a target "to mobilise NOK 1 500 billion to the sustainable transition by 2030" (page 115). Targets use emissions intensity or loan-to-value, baselined to 2019 (2023 for shipping) and 2022 for investment portfolios. In 2025 the targets "were validated by DNV," which "concluded that most of DNB's 2030 targets are consistent with assessment criteria associated with the Paris Agreement and the 1.5°C target" (page 116). Mortgage-portfolio emissions intensity fell from a 3.69 kg CO2e/m2/year baseline to 2.39 in 2025 against a -47 per cent 2030 target; housing cooperatives fell to 2.20 kg CO2e/m2/year against a -50 per cent target (pages 117-118).
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scope 1, 2, 3 and Total GHG emissions
Reference: page 134.
"In 2025, DNB's total greenhouse gas emissions were 58 536 355 tonnes CO2e (t CO2e), which is a 64 per cent increase from 2024," driven mainly by "DNB's acquisition in 2025 of the investment bank and asset management company Carnegie Holding AB" and updated PCAF factors (page 134). Gross Scope 1 emissions were 58 t CO2e (down 13 per cent); gross market-based Scope 2 was 391 t CO2e (up 2 per cent); Scope 3 category 15 Investments (financed emissions) was 58 535 081 t CO2e, up 64 per cent, split into loans Scope 1 and 2 of 8 716 739 t CO2e (down 13 per cent) and loans Scope 3 of 49 818 342 t CO2e (up 95 per cent) (page 134). "Financed emissions fall under Scope 3, category 15 Investments... The remaining Scope 3 categories have therefore been omitted" (page 134).
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 145.
"Since 2014, DNB has bought voluntary carbon credits for all present, measured direct and indirect emissions... associated with the Group's upstream value chain and own operations (Scope 1 and 3)" (page 145). In 2025 "DNB bought climate credits worth a total of 5 652 t CO2e for 2025 (7 088 t CO2e in 2024)," certified under "Plan Vivo (81 per cent), Gold Standard (11 per cent), the EBC's C-sink (2 per cent) and Verra VCS (7 per cent)," via projects including reforestation in Nicaragua and Ethiopia and a blue-carbon project in Pakistan. "98 per cent of the projects purchased are outside Europe," and "the plan is for the carbon credits to be cancelled in 2026" (page 145).
E3 – Water
E3-1Policies related to water and marine resourcesReported
Policies related to water and marine resources
Reference: page 149.
"Several governing documents have been prepared that provide guidelines for how DNB is to contribute to sustainable management of marine resources" (page 149). Under DNB's Group policy for sustainability, "DNB must also promote sustainable management of marine resources and biodiversity, and reduce natural risk," principles "integrated into DNB's credit process, risk assessments and DNB Asset Management's (DAM's) expectations documents" (page 149). The Group instructions for sustainability in credit activities prohibit financing "companies that conduct unregulated fishing... fishing with equipment that permanently damages the seabed... or fish farming that does not have the necessary permits from the authorities" (page 149).
E3-2Actions and resources related to water and marine resourcesReported
Actions and resources related to water and marine resources
Reference: page 149.
"An action plan with concrete metrics was not drawn up in 2025, but insight from stakeholders was obtained... as well as data for relevant sectors in the loan portfolio, in order to be able to set meaningful and measurable indicators at a later time." The 2025 focus was aquaculture: "a dashboard with measurable indicators was drawn up during the year for customers in salmon farming," covering "sea lice, escapes, impacts on the seabed and survival" (page 149). DNB also partnered with HUB Ocean "to explore options for better mapping and understanding of the impact of shipping on the oceans," a project continuing into 2026 (page 149).
E3-3Targets related to water and marine resourcesReported
Targets related to water and marine resources
Reference: page 150.
"DNB has not set targets for this topic, but has worked to develop its understanding of impacts and dependencies, as well as risks and opportunities relating to marine resources. It is important for the Group to ensure that any targets that are set reflect the actual conditions and challenges in the sectors that are most relevant" (page 150). In the absence of targets, effectiveness is tracked through process: "DNB does not directly measure the efficiency of compliance with policies and instructions, but follows up the topic through integrated processes in its credit and investment activities, including risk assessments and the development of indicators for relevant sectors" (page 150).
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies relating to own workforce
Reference: page 153.
"DNB's Code of Conduct, Group policy for sustainability and employee handbook provide the framework for how" the Group manages its workforce (page 153). The Code of Conduct "applies to the entire workforce, including members of the Board of Directors and employee representatives," is "approved by the Board of DNB Bank ASA," and is available to employees "in DNB's internal quality system, in addition to being published on dnb.no" (page 154). Each business area and Group unit "must carry out ongoing internal control of compliance with the working environment legislation and rules relating to health, safety and the environment," including annual confirmation that employees have read and understood the Code of Conduct (page 153).
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Processes for engaging with own workforce and workers' representatives about impacts
Reference: page 154.
"The Group's social dialogue in Norway is based on collective agreements that have been entered into with six trade unions that represent more than half of the employees" (page 154). Cooperation with trade unions "takes place at regular quarterly meetings," alongside "information and consultation meetings... regularly carried out with the employee representatives." Employee surveys also "provide the employees with an opportunity to give feedback," feeding the diversity and inclusion work, supplemented by networks including "active networks for equality and multicultural diversity, gender and sexual diversity (LGBT+)" and an internal ODA network for women in technology (page 154).
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 workforce to raise concerns
Reference: pages 154-155.
"If an employee or hired consultant feels that they are being subjected to differential treatment or discrimination, or they experience other negative incidents, they can report this through different channels," including management, the HR unit, direct contact with the safety representative, or "the Group's notification channel" (page 155). DNB uses "the external company NAVEX/GCS Compliance Services Europe Unlimited Company... and its software EthicsPoint" to manage the whistleblowing channel, which "secures full confidentiality" and "does not track IP addresses or other data from the unit, nor does the program store phone numbers or record conversations" (page 154).
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions
Reference: page 155.
DNB has "an express ambition of a 40/60 gender balance at every management level (1-4) at any given time," tracked quarterly; at end-2025 "the average proportion of women at management levels 1-4 in DNB was 37.5 per cent, compared with 36.5 per cent in 2024" (page 156). Actions include collaboration "with the VI Foundation" to promote equal opportunities for people with disabilities, and effectiveness is measured through the employee survey's inclusion score: "in the fourth quarter of 2025, the result was 5.4" against a goal of "at least 5 on a scale of 1 to 6," based on an 81 per cent response rate (page 155).
S1-4(was S1-5)Targets related to own workforceReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (own workforce)
Reference: page 156.
"DNB has an express ambition of a 40/60 gender balance at every management level (1-4) at any given time. The ambition is not time-specific... and it therefore does not meet the CSRD disclosure requirements" (page 156). Gender balance at levels 1-4 is measured quarterly: at Levels 1-2, 42.9 per cent women (6 of 14); Level 3, 39.0 per cent (39 of 100); Level 4, 37.0 per cent (156 of 422) in 2025 (page 156). The proportion of women on the Board was 60.0 per cent and on the Group Management team 42.0 per cent, versus 50.0 per cent and 41.7 per cent in 2024 (page 156).
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: pages 156-157.
DNB had 11,649 employees at end-2025 versus 11,515 in 2024: "5 162 / 5 332" women and "6 487 / 6 183" men (2025/2024). Of the 2025 total, 11,182 were permanent and 467 temporary; 11,182 full-time-equivalent roles split into 8,863 full-time and 417 part-time in Norway alone (page 157). By region: Norway 9,280 (9,861 in 2024); Europe excluding Norway 2,162 (1,446); Asia and Oceania 36 (36); North and South America 171 (172) (page 157). In 2025, "1 224" employees left (10.5 per cent of the workforce), versus "877" (7.8 per cent) in 2024 (page 157).
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: page 158 (cross-referencing page 67 for senior management gender data).
Age distribution of the workforce in 2025 versus 2024: under 30 years, 1,889 (2,096); 30-50 years, 6,368 (6,084); over 50 years, 3,392 (3,335) (page 158). "The gender distribution in the senior management in number of people and per cent is presented on page 67," where GOV-1 reports Board and Group Management team composition (page 158). This complements the management-level (1-4) gender-balance tracking reported under Targets and tracking (ESRS S1-5, page 156).
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Remuneration metrics (pay gap and total remuneration)
Reference: page 158.
"The gender pay gap is calculated based on total pay for men minus total pay for women, divided by total pay for men," including both fixed and variable components, covering Norway, Sweden and Latvia; the 2025 figure was "32" per cent (page 158). The 2024 calculation method differed (DNB had used women's fixed salary as a proportion of men's, excluding non-Norway staff and variable pay), so "the figure reported for 2024 is not presented in the table, as the figure is not comparable with the figure for 2025" (page 158). The ratio of CEO to median employee total compensation is also reported in a table on page 157.
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: page 158.
"In 2025, a total of 18 cases relating to discrimination or harassment were registered and handled (against 16 cases in 2024). Of these, 15 were reported using DNB's electronic notification channel (12 in 2024). No fines or sanctions were imposed on the Group as a consequence of this in 2025" (page 158).
S4 – Consumers and End-users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: pages 160, 165.
Data protection: "In DNB, all processing of personal data must be secure, transparent and understandable," governed by the Code of Conduct and "DNB's overriding governance principles document" (page 160); employees complete mandatory e-learning, with 88 per cent completion in 2025 (92 per cent in 2024) (page 160). Access to quality information: "How DNB will work to offer good advisory services and quality information to personal customers is set out in the governing document containing DNB's ethical guidelines (Code of Conduct) and the Group's sustainability policy" (page 165).
S4-2Processes for engaging with consumers and end-users about impactsReported
Processes for engaging with consumers and end-users about impacts
Reference: page 166.
"DNB obtains or receives views from personal customers on several levels... Customer views are obtained proactively in the form of customer contact, surveys and insight work, and reactively when complaints are made via DNB's notification channels or cases are reported to external complaints bodies" (page 166). External complaints bodies include "the Norwegian Financial Services Complaints Board (FinKN) and the Norwegian Anti-Discrimination Tribunal." In 2025 "DNB did not receive any complaints relating to serious matters involving human rights issues" (page 166).
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: pages 161, 166.
"DNB is under an obligation to report certain incidents to the Norwegian Data Protection Authority, and in 2025, the Group reported 75 personal data breaches to the Authority (115 in 2024)" (page 161). For service complaints generally, "if a customer has not received an answer within 15 business days of DNB receiving their complaint, DNB will send a preliminary reply... In extraordinary cases, it can take up to 35 days before the customer receives a preliminary answer" (page 166).
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, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reference: pages 162, 167.
Data protection: "A few new and updated governing documents relating to data protection were launched in 2025," including work to "clarify roles and responsibilities in DNB's framework for operational privacy" (page 162). Access to quality information: DNB ran "27 #huninvesterer events around the country" in 2025, attended by "4 700 people," and a survey found "41 per cent of the Norwegian population is familiar with the #huninvesterer (#girlsinvest) campaign," of whom "45 per cent... have taken action to improve their financial situation" (page 168).
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (consumers and end-users)
Reference: pages 163, 168.
"For data protection, no concrete goals have been set in accordance with the CSRD reporting requirements, because... compliance risk must be managed and decided in accordance with Group-wide criteria" (page 163); tracked instead via "fines issued by the Norwegian Data Protection Authority" (none in 2025) and "percentage of employees who have completed the four basic courses" of mandatory training. For access to quality information, "DNB has not set a specific target for this topic because it is part of the Group's core business activities," tracked instead via complaints volumes and customer satisfaction surveys (page 168).
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Policies for business conduct and corporate culture (including ESRS 2 MDR-P)
Reference: pages 174, 178.
"DNB has several governing documents that support a corporate culture that contributes to achieving the Group's goals and ambitions," anchored in "DNB's Code of Conduct," which "describes expectations, obligations and requirements for how employees in the Group should act" and covers "sustainability... human rights and rights at work, combatting financial crime, the duty of confidentiality... conflicts of interest, inside information and anti-corruption" (page 174). On corruption specifically: "The Group instructions for anti-corruption establish DNB's zero tolerance of corruption, and state that DNB must have a Group-wide anti-corruption programme" (page 178).
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: page 179.
"The Code of Conduct, the Group instructions for anti-corruption and the Group's anti-corruption framework describe what corruption is and provide guidance for employees on how to prevent and detect corruption" (page 179). High-risk functions include "areas with direct customer contact, functions in purchasing, contract awarding and hiring," all of which are "covered by the training programme," which also reaches "the Group's administrative, management and control bodies" - the Board and the Group Management team (page 179). Anti-corruption training uses three risk-based competence levels with case studies and dilemma training (pages 178-179).
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS. Reference: pages 179-180.
"No overarching goal has been set in line with the disclosure requirements in the EU's Corporate Sustainability Reporting Directive (CSRD) relating to corruption and bribery, because the work on this is largely about avoiding incidents through ongoing actions and processes" (page 179). Consistent with MDR-T's effectiveness-tracking limb, metrics are used instead: "the percentage of employees who completed the annual course KNOW:RISK Anti-Corruption" was 84 per cent in 2025 (93 per cent in 2024), and "the percentage of Board members who completed the course" was 100 per cent in both years (page 180).
G1-4Incidents of corruption or briberyReported
Confirmed incidents of corruption or bribery
Reference: page 180.
"The Group was not convicted of breaches of the anti-corruption or anti-bribery legislation in 2025, and has consequently not been fined" (page 180).