Nordea Bank Abp

In 2023, climate-related corporate governance activities by Nordea Funds revolved around topics such as climate-related governance, strategy, risk management, targets, disclosures and lobbying practices, to drive towards alignment with the Paris Agreement. [...] Social and governance proposals covered topics such as human rights due diligence, impact assessments and transparency on lobbying, as well as specific proposals on topics such as diversity, equity and inclusion, freedom of association, child labour and AI ethics.

### Governance

The board of directors of Nordea Funds and the board of directors of the Danish Nordea Invest fund associations have decided to delegate deci­
sions regarding engagements and exclusions to the Responsible Investments Committee of Nordea Asset Management, which is chaired by the CEO
of Nordea Asset Management. The board receives regular reporting on the activities of the Responsi­ble Investments Committee, including engagements
with, and exclusions of, companies.

### Governance

The board of directors of Nordea Funds and the board of directors of the Danish Nordea Invest fund associations have decided to delegate deci­
sions regarding engagements and exclusions to the Responsible Investments Committee of Nordea Asset Management, which is chaired by the CEO
of Nordea Asset Management. The board receives regular reporting on the activities of the Responsi­ble Investments Committee, including engagements
with, and exclusions of, companies.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]The two functions within Nordea that are responsible for direct and indirect activities influencing climate-related policy are Group Public Affairs (GPA) and Group Sustainability (GS).
GPA, as defined in Nordea, is about monitoring, analysing and advocating regarding new regulatory initiatives. The goal is to ensure that relevant stakeholders - politicians, authorities, regulators - make informed decisions regarding regulations which will impact Nordea in the future. The Public Affairs' work and behaviour in Nordea should at all times be in line with Nordea's Purpose, Values and Principles as set out in our Code of Conduct as well as with the Code of Conduct of the EU transparency register.
Sustainable Finance is a prioritized advocacy area for Nordea, as decided by Nordea's Group Leadership Team (GLT). In order to drive the advocacy activities on sustainable finance and coordinate across Nordea, a Core Team has been set up, according to Nordea's working procedures for Public Affairs. The Sustainable Finance Advocacy Core team is the operational driving force where each member is selected on the mandate of a GLT member. Ultimately the CEO and GLT are responsible for any positions. Nordea's representatives on sustainable finance-related matters in external associations (listed above) are also included in the Core Team as well as a representative from GS. The GS representative in the Core Team is responsible for ensuring alignment of advocacy activities with Nordea's Group-wide sustainability strategy, including voluntary commitments.
GS is a centre of excellence function responsible for developing the Group-wide sustainability strategy and initiatives and for informing and advising senior management on new regulation or market practises within the area of sustainability. GS should ensure that defined sustainability strategies and objectives are incorporated into the business agenda of the whole Group. This should be closely coordinated and executed in collaboration with the Business Areas and relevant Group Functions.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]The two functions within Nordea that are responsible for direct and indirect activities influencing climate-related policy are Group Public Affairs (GPA) and Group Sustainability (GS). GPA, as defined in Nordea, is about monitoring, analysing and advocating regarding new regulatory initiatives. The goal is to ensure that relevant stakeholders - politicians, authorities, regulators - make informed decisions regarding regulations which will impact Nordea in the future. The Public Affairs' work and behaviour in Nordea should at all times be in line with Nordea's Purpose, Values and Principles as set out in our Code of Conduct as well as with the Code of Conduct of the EU transparency register. Nordea Group refraining from participating in lobbying or advocacy activities aimed at weakening climate policy is part of the Nordea Group wide position statement on climate change is one of our important commitments.