What we’ve done so far
In this section we present some of our achievements with a sustainable perspective, that SEB has accomplished so far. They range from very broad initiatives to small steps in our daily work.
Prioritised fraud prevention
Fraud prevention has been a priority for SEB in recent years, including the launch of a new fraud prevention strategy and training of 9,300 SEB employees in 2009 – 2011. We are strengthening our focus on proactive measures, by reviewing fraud issues earlier in the business processes. Our core fraud combating units are Security, Compliance, Internal Audit, Information Security, Human Resources and Risk Control. They work together to strengthen fraud prevention management. This includes assisting business and support functions in building and maintaining “fraud proof” banking processes.
Fraud prevention health check
During 2011, a review of the governance of fraud risks and management within the Group’s main business areas in ten sites was undertaken by our Internal Audit team. The review included an evaluation of the overall adequacy of the fraud prevention measures within SEB. We wanted to evaluate the Group’s overall governance and management of fraud risk as compared with best practice, legal requirements and external auditor benchmarks.
As the audit report showed, strong measures for fraud prevention are in place at SEB. The focus of future work includes strengthened governance in terms of policies and procedures as well as enhancement of pre-employment screening processes.
Employee awareness training
Enhancing employee awareness about fraud trends and combating techniques is key to successful financial crime prevention. We provide all our employees with general and tailored training depending on position. All employees must pass our general anti-money laundering (AML) e-learning programme.
Know Your Customer (KYC)
In order to prevent and combat financial crime, international agreements as well as common measures and rules are necessary. We abide by European Union legislation on AML and KYC. We apply enhanced due diligence for customers, products and countries, where there is a perceived risk that the Bank is used for money laundering and financing of terrorism.
Financial Coalition Against Child Pornography
Work in the Swedish Financial Coalition against Child Pornography is beginning to yield results. According to the Swedish police, thenumber of commercial Internet sites has been reduced significantly and there are indications that the area is becoming commercially less interesting for criminals.
The purpose of the Coalition, which had 20 members at year-end 2011, is to join forces to prevent and obstruct payments for documented sexual abuse of children through the Swedish financial system.
During 2011, we continued our efforts to increase awareness about the issues. SEB also monitored transactions and served as the main contact for the Swedish police. In November, we hosted the semiannual meeting, with some 50 guests and employees receiving in-depth information from the Swedish police, Interpol, the Coalition steering group and End Child Prostitution and Trafficking, ECPAT. Effective from January 2012, we are represented in the Coalition steering group through our Head of Group Corporate Sustainability.
Preventing bribery and corruption
Bribery and corruption are unwelcome but still exist in international business practices, more prevalent in certain countries and industries than in others. Corruption threatens good governance, sustainable development, democratic processes and fair business practices. Working to prevent bribery and corruption touches upon both our procedures against money laundering and our Code of Business Conduct.
In our monitoring of potentially suspicious financial activity, we are required to identify politically exposed people (PEP’s), persons that hold or have held important political functions in a country and are therefore considered to have a higher risk of being involved in corruption. We are also required to apply enhanced due diligence procedures to their account. We may ourselves also be directly affected, in that our employees engage in bribery or corrupt activity.