Swedbank

Risk Management and Capital Adequacy Report

Pillar 3 Annual Report 2025

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Introduction

This Risk Management and Capital Adequacy Report Q4 2025 provides information on Swedbank's risk management and capital adequacy. The report is based on regulatory disclosure requirements set out in the Regulation (EU) 575/2013 "Capital Requirements Regulation" (CRR) and the Swedish Financial Supervisory Authority (SFSA) regulation FFFS 2014:12.

Information in this report pertains to the conditions for Swedbank Consolidated Situation as of 31 December 2025, unless otherwise specified.

Swedbank Consolidated Situation is referred to as Swedbank, unless otherwise stated.

This report is submitted by Swedbank AB, incorporated in Sweden, a public limited liability company with registration number 502017-7753, LEI code M312WZV08Y7LYUC71685. This document has not been audited and does not form part of Swedbank AB's audited financial statements.

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Regulatory Scope

Section 1 - Disclosure of overview of risk management, key prudential metrics and RWA. 6

Template EU OV1 - Overview of total risk exposure amounts, CRR Article 438 (d) 6

Template EU KM1 - Key metrics template, CRR Article 447(a-g), 438(b) 7

Template EU INS1 - Insurance participations, CRR Article 438(f) 8

Template EU INS2 - Financial conglomerates information on own funds and capital adequacy ratio, CRR Article 438(g) 8

Table EU OVC – ICAAP information, CRR Article 438 (a,c) 8

Template EU CMS1 – Comparison of modelled and standardised risk weighted exposure amounts at risk level, CRR Article 438(da) 9

Template EU CMS2 – Comparison of modelled and standardised risk weighted exposure amounts for credit risk at asset class level, CRR Article 438(da) 10

Section 2 - Disclosure of risk management objectives and policies 11

Table EU OVA – Institutions risk management approach, CRR Article 435(1) 11

Table EU OVB – Disclosures on governance arrangements, CRR Article 435(2) 15

Section 3 - Disclosure of the scope of application 18

Template EU LI1 - Differences between the accounting scope and the scope of prudential consolidation and mapping of financial statement categories with regulatory risk categories, CRR Article 436(c) 18

Template EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statements, CRR Article 436(d) 19

Template EU LI3 - Outline of the differences in the scopes of consolidation (entity by entity), CRR Article 436(b) 19

Table EU LIA – Explanations of differences between accounting and regulatory exposure amounts, CRR 436(b) 20

Table EU LIB – Other qualitative information on the scope of application, CRR Article 436(f,g,h) 20

Template EU PV1 - Prudent valuation adjustments (PVA), CRR Article 436(e) 21

Section 4 - Disclosure of own funds 22

Template EU CC1 - Composition of regulatory own funds, CRR Article 437 (a,d,e,f) and Article 444(e) 22

Template EU CC2 - Reconciliation of regulatory own funds to balance sheet in the audited financial statements. CRR Article 437(a) 25

Template EU CCA - Main features of regulatory own funds instruments and eligible liabilities instruments, CRR Article 437(b,c) 26

Section 5 - Disclosure of countercyclical capital buffers 30

Template EU CCyB1 - Geographical distribution of credit exposures relevant for the calculation of the countercyclical buffer, CRR Article 440(a) 30

Template EU CCyB2 - Amount of institution-specific countercyclical capital buffer, CRR Article 440(b) 30

Section 6 - Disclosure of leverage ratio 31

Template EU LR1 - LRSum: Summary reconciliation of accounting assets and leverage ratio exposures, CRR Article 451 (1)(b) 31

Template EU LR2 - LRCom: Leverage ratio common disclosure, CRR Article 451 (1)(a,b,c), 451(2), 451(3) 31

Template EU LR3 - LRSpl: Split-up of on balance sheet exposures (excluding derivatives, SFTs and exempted exposures, CRR Article 451 (1)(b) 32

Table EU LRA: Disclosure of LR qualitative information, CRR Article 451(1)(d,e) 33

Section 7 - Disclosure of liquidity requirements 34

Table EU LIQA – Liquidity risk management, CRR Article 435(1), 451a (4) 34

Template EU LIQ1 - Quantitative information of LCR, CRR Article 451a(2) 36

Table EU LIQB on qualitative information on LCR, which complements template EU LIQ1, CRR article 451a(2) 37

Template EU LIQ2 – Net Stable Funding Ratio, CRR Article 451a(3) 38

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Section 8 - Disclosure of credit risk quality...42
Table EU CRA: General qualitative information about credit risk, CRR Article 435(1)(a,b,d,f)...42
Table EU CR8: Additional disclosure related to the credit quality of assets, CRR Article 442(a,b)...44
Template EU CR1 - Performing and non-performing exposures and related provisions, CRR Article 442(c,f)...45
Template EU CR1-A - Maturity of exposures, CRR Article 442(g)...46
Template EU CR2 - Changes in the stock of non-performing loans and advances, CRR Article 442(f)...46
Template EU CR2a - Changes in the stock of non-performing loans and advances and related net accumulated recoveries, CRR Article 442(c,f)...46
Template EU CQ1 - Credit quality of forborne exposures, CRR Article 442(c)...47
Template EU CQ2 - Quality of forbearance, CRR Article 442(c)...47
Template EU CQ3: Credit quality of performing and non-performing exposures by past due days, CRR Article 442(d)...48
Template EU CQ4 - Quality of non-performing exposures by geography, CRR Article 442(c,e)...49
Template EU CQ5 - Credit quality of loans and advances to non-financial corporations by industry, CRR Article 442(c,e)...50
Template EU CQ6 - Collateral valuation - loans and advances, CRR Article 442(c)...50
Template EU CQ7 - Collateral obtained by taking possession and execution processes, CRR Article 442(c)...50
Template EU CQ8 - Collateral obtained by taking possession and execution processes – vintage breakdown, CRR Article 442(c)...51

Section 9 - Disclosure of credit risk mitigation techniques...52
Table EU CRC – Qualitative disclosure requirements related to CRM techniques, CRR Article 453(a-e)...52
Template EU CR3 - CRM techniques overview: Disclosure of the use of credit risk mitigation techniques, CRR Article 453(f)...53

Section 10 - Disclosure of credit risk SA...54
Table EU CRD – Qualitative disclosure requirements related to standardised model, CRR Article 444(a-d)...54
Template EU CR4 - Standardised approach - Credit risk exposure and CRM effects, CRR Article 453(g,h,i) Article 444(e)...55
Template EU CR5 - Standardised approach, CRR Article 444(e)...56

Section 11 - Disclosure of credit risk IRB...57
Table EU CRE – Qualitative disclosure requirements related to IRB approach, CRR Article 452(1)(a-f)...57
Template EU CR6 - IRB approach - Credit risk exposures by exposure class and PD range, CRR Article 452(g)...59
Template EU CR6-A – Scope of the use of IRB and SA approaches, CRR Article 452(b)...62
Template EU CR7 - IRB approach - Effect on the RWEAs of credit derivatives used as CRM techniques, CRR Article 453(j)...63
Template EU CR7-A - IRB approach - Disclosure of the extent of the use of CRM techniques, CRR Article 453(g)...64
Template EU CR8 - RWEA flow statements of credit risk exposures under the IRB approach, CRR Article 438(h)...65
Template EU CR9 – IRB approach – Back-testing of PD per exposure class (fixed PD scale), CRR Article 452(h)...65
Template EU CR9.1 – IRB approach – Back-testing of PD per exposure class (only for PD estimates according to point (f) of Article 180(1) CRR), CRR Article 452(h)...67

Section 12 - Disclosure of specialised lending and equity exposures...68
Template EU CR10.1 - Specialised lending: Project finance (Slotting approach), CRR 438(e)...68
Template EU CR10.2 - Specialised lending: Income-producing real estate and high volatility commercial real estate (Slotting approach), CRR 438(e)...68
Template EU CR10.3 - Specialised lending: Object finance (Slotting approach), CRR 438(e)...68
Template EU CR10.4 - Specialised lending: Commodities finance (Slotting approach), CRR 438(e)...68
Template EU CR10.5 - Equity exposures, CRR 438(e)...69

Section 13 - Disclosure of counterparty credit risk...70
Table EU CCRA – Qualitative disclosure related to CCR, CRR Article 439(a-d)...70
Template EU CCR1 - Analysis of CCR exposure by approach, CRR Article 439(f,g,k,m)...71

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Template EU CCR3 - Standardised approach - CCR exposures by regulatory exposure class and risk weights, CRR Article 439(l) ...71
Template EU CCR4 - IRB approach - CCR exposures by exposure class and PD scale, CRR Article 439(l) ...71
Template EU CCR5 - Composition of collateral for CCR exposures, CRR Article 439(e) ...72
Template EU CCR6 - Credit derivatives exposures, CRR Article 439(j) ...73
Template EU CCR7 - RWEA flow statements of CCR exposures under the IMM, CRR Article 438(h) ...73
Template EU CCR8 - Exposures to CCPs, CRR Article 439(i) ...73

Section 14 - Disclosure of exposures to securitisation positions ...74
Table EU-SECA - Qualitative disclosure requirements related to securitisation exposures, CRR Article 449(a-i) ...74
Template EU SEC1 - Securitisation exposures in the non-trading book, CRR Article 449(j) ...75
Template EU SEC2 - Securitisation exposures in the trading book, CRR Article 449(j) ...75
Template EU SEC3 - Securitisation exposures in the non-trading book and associated regulatory capital requirements - institution acting as originator or as sponsor, CRR Article 449(k,i) ...75
Template EU SEC4 - Securitisation exposures in the non-trading book and associated regulatory capital requirements - institution acting as investor, CRR Article 449(k,ii) ...76
Template EU SEC5 - Exposures securitised by the institution - Exposures in default and specific credit risk adjustments, CRR Article 449(l) ...76

Section 15 - Disclosure of market risk ...77
Table EU MRA: Qualitative disclosure requirements related to market risk, CRR Article 435(1) (a-d) ...77
Template EU MR1 - Market risk under the alternative standardised approach, CRR Article 445 ...78
Table EU MRB: Qualitative disclosure requirements for institutions using the internal market risk models, CRR Article 455(a-c,f) ...79
Template EU MR2-A - Market risk under the internal Model Approach (IMA), CRR Article 455(e) ...82
Template EU MR2-B - RWA flow statements of market risk exposures under the IMA, CRR Article 438(h) ...82
Template EU MR3 - IMA values for trading portfolios, CRR Article 455(d) ...83
Template EU MR4 - Comparison of VaR estimates with gains/losses, CRR Article 455(g) ...83

Section 16 - Disclosure of credit valuation adjustment ...84
Table EU CVAA - Qualitative disclosure requirements to credit valuation adjustment risk, CRR Article 445a (1) (a,b) ...84
Template EU CVA1 - Credit valuation adjustment risk under the Reduced Basic Approach, CRR Article 445a (3)(a) ...84
Table EU CVAB - Qualitative disclosure requirements related to CVA risk for institutions using the Standardised Approach, CRR Article 445a(2) (a) ...84
Template EU CVA2 - Credit valuation adjustment risk under the Full Basic Approach, CRR Article 455a(3)(a-b) ...85
Template EU CVA3 - Credit valuation adjustment risk under the Standardised Approach, CRR Article 445a(1)(c), 445a(2)(b-c) ...85
Template EU CVA4 - RWEA flow statements of credit valuation adjustment risk under the Standardised Approach, CRR Article 438(d,h) ...85

Section 17 - Disclosure of operational risk ...86
Table EU ORA - Qualitative information on operational risk, CRR Article 446(1)(a), 435(1) ...86
Template EU OR1 - Operational risk losses, CRR Article 446(2) (a-b) ...88
Template EU OR2 - Business Indicator, components and subcomponents, CRR Article 446(1) (c-d) ...89
Template EU OR3 - Operational risk own funds requirements and risk exposure amounts, CRR Article 446(1) (b) ...89

Section 18 - Disclosure of interest rate risk of non-trading book activities ...90
Table EU IRRBBA - Qualitative information on interest rate risks of non-trading book activities, CRR Article 448(1) (c-g) ...90
Template EU IRRBB1 - Interest rate risks of non-trading book activities, CRR Article 448(1) (a-b) ...91

Section 19 - Disclosure of remuneration policy ...92
Section 20 - Disclosure of encumbered and unencumbered assets ...93

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Template EU AE1 - Encumbered and unencumbered assets, CRR Article 443 ...93
Template EU AE2 - Collateral received and own debt securities issued, CRR Article 443 ...93
Template EU AE3 - Sources of encumbrance, CRR Article 443 ...93
Table EU AE4 – Accompanying narrative information, CRR Article 443 ...94

Section 21 - Disclosure of prudential disclosures on ESG risks ...95
Table 1 – Qualitative information on Environmental risk, CRR Article 449a ...95
Table 2 – Qualitative information on Social risk, CRR Article 449a ...98
Table 3 – Qualitative information on Governance risk, CRR Article 449a ...101
Template 1: Banking book- Indicators of potential climate change transition risk: Credit quality of exposures by sector, emissions and residual maturity, CRR Article 449 ...102
Template 2: Banking book - Indicators of potential climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral, CRR Article 449a ...106
Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics, CRR Article 449a ...107
Template 4: Banking book - Indicators of potential climate change transition risk: Exposures to top 20 carbon-intensive firms, CRR Article 449a ...109
Template 5: Banking book - Indicators of potential climate change physical risk: Exposures subject to physical risk - Sweden, CRR Article 449a ...109
Template 5: Banking book - Indicators of potential climate change physical risk: Exposures subject to physical risk - Estonia, CRR Article 449a ...110
Template 5: Banking book - Indicators of potential climate change physical risk: Exposures subject to physical risk - Latvia, CRR Article 449a ...111
Template 5: Banking book - Indicators of potential climate change physical risk: Exposures subject to physical risk - Lithuania, CRR Article 449a ...112

Section 22 - Disclosure of exposures to crypto assets ...114
Template EU CAE1 – Exposures to crypto-assets, CRR Article 501d(2) ...114

Disclosure of MREL TLAC ...115
Template EU KM2 - Key metrics, MREL, CRR Article 447(h) and BRRD Article 45i(3) (a,c) ...115
Template EU TLAC1 – Composition, MREL, BRRD Article 45i.3(b) ...116
Template EU TLAC3a – Creditor ranking – Resolution entity, MREL, BRRD Article 45i(3) (b) ...117

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Risk Management and Capital Adequacy Report – Pillar 3 – Q4 2025

Section 1 - Disclosure of overview of risk management, key prudential metrics and RWA

Template EU OV1 - Overview of total risk exposure amounts, CRR Article 438 (d)

Total REA increased by SEK 31.3bn in Q4 2025 compared to Q3 2025 with the largest drivers being increased credit risk REA (SEK 22.1bn) and operational risk REA (SEK 14.3bn), which have been partially offset by decreases in counterparty credit risk (SEK 2.9bn) and market risk REA (SEK 2.0bn).

Credit risk (excluding counterparty credit risk - CCR), also includes the RWA for the mortgage floor add-on, the add-on for corporate real estate exposures in Norway, CRE & RRE floors (Article 458 CRR) and Article 3 add-on.

Operational risk REA increased REA by SEK 14.3bn, due to the rolling three-year average of total net income being higher this year compared to last year.

Counterparty credit risk REA decreased by SEK 2.9bn, mainly due to REA decrease in securities financing transactions netting sets due to implementation of new exposure calculations with netting based on CRR3 rules, and REA decrease in derivatives due to decrease in potential future exposure (SEK 0.6bn) and replacement costs (SEK 0.3bn).

Total market risk REA decreased by SEK 2.0bn, mainly due to specific interest rate risk (SEK 1.4bn), which was driven by decreased positions in Swedish institutions covered bonds (SEK 0.5bn), Swedish and Finnish corporate debt instruments (SEK 0.4bn and SEK 0.4bn respectively).

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Risk Management and Capital Adequacy Report - Pillar 3 - Q4 2025

Template EU KM1 - Key metrics template, CRR Article 447(a-g), 438(b)

Common Equity Tier 1 (CET1) ratio decreased by 183 bps to 17.82 per cent as compared to Q3 2025. CET1 capital decreased by SEK 11.0bn, which decreased CET1 ratio by 117 bps, mainly due to special dividend, which decreased profit after anticipated dividends by SEK 8.1bn and increased deductions for intangible assets, which decreased CET1 capital by SEK 2.0bn. REA increased in total by SEK 31.3bn, which decreased the ratio by 66 bps. As detailed in OV1 and CR8 templates, REA increase was mainly driven by changes in credit risk and operational risk.

Tier 1 ratio decreased by 191 bps and Total capital ratio decreased by 204 bps mainly due to special dividend which decreased profit after dividends.

Leverage ratio decreased by 8bps to 6.56 per cent due to decreased Tier 1 capital by SEK 11.4bn compared to Q3 2025.

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Template EU INS1 - Insurance participations, CRR Article 438(f)

Swedbank does not deduct investments in insurance undertakings as the sum of such investments is less than 10 per cent of the Common Equity Tier 1. This is in accordance with CRR Article 48 (1)(b) and not from a permission in accordance with Article 49 (1) of the CRR.

Template EU INS2 - Financial conglomerates information on own funds and capital adequacy ratio, CRR Article 438(g)

| SEKm | a
31 Dec 2025 |
| --- | --- |
| 1 Supplementary own fund requirements of the financial conglomerate (amount) | 215 869 |
| 2 Capital adequacy ratio of the financial conglomerate (%) | 114.3% |

Table EU OVC - ICAAP information, CRR Article 438 (a,c)

Economic Capital
EC models are used in conjunction with stress tests to provide an objective internal view of the capital needed to manage potential risks affecting Swedbank. In contrast to the capital assessment within Pillar 1, Swedbank's EC cover all risks at a chosen confidence level. Consequently, the EC generates a more accurate and commensurate assessment of the risk to which Swedbank is exposed. Within the EC framework, credit risk, market risk, operational risk, business risk and pension risk are considered. Generally, Value-at-Risk (VaR) based models with a confidence level of 99.9 per cent are used to calculate the EC for the different risk types in the ICAAP. The confidence level, which corresponds to the confidence level used in the Basel IRB framework calibration, uses a one-year horizon. The insurance companies within Swedbank Group separately perform an annual Own Risk and Solvency Assessment (ORSA). The ORSA process assesses the risks and solvency positions by projecting the risk metrics under the base and adverse scenarios. |

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Risk Management and Capital Adequacy Report – Pillar 3 – Q4 2025

Template EU CMS1 – Comparison of modelled and standardised risk weighted exposure amounts at risk level, CRR Article 438(da)

CMS1 template excludes the other risk exposure amounts, that is the RWA for the mortgage floor add-on, the add-on for corporate real estate exposures in Norway, CRE & RRE floors (Article 458 CRR) and Article 3 add-on (without market risk). Other risk exposure amounts comprised SEK 205.5bn of which SEK 198.9bn is for risk weight floors REA article 458 and SEK 6.6bn is for Article 3 add-on.

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Risk Management and Capital Adequacy Report – Pillar 3 – Q4 2025

Template EU CMS2 – Comparison of modelled and standardised risk weighted exposure amounts for credit risk at asset class level, CRR Article 438(da)

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Risk Management and Capital Adequacy Report – Pillar 3 – Q4 2025

Section 2 - Disclosure of risk management objectives and policies

Table EU OVA - Institutions risk management approach, CRR Article 435(1)

Sustainable and profitable operations are necessary for Swedbank to be able to fulfil its strategy to empower the many people and businesses to create a better future by offering financial advise, services and products. Hence, implementing the low risk appetite as described in the following will enable Swedbank to deliver on its customer promise.

To ensure that Swedbank is well capitalised, has a strong liquidity position in relation to its risk position and regulatory requirements and that it can maintain business under normal and stressed conditions, Swedbank has low risk appetite for risk to capital and liquidity. In 2025, the capital remained stable with a comfortable distance to both the regulatory requirements and the risk appetite. The CET1 capital ratio was 17.82 per cent of the total risk exposure amount (REA) by year-end and the leverage ratio was 6.56 per cent.

Credit risk comprises around 82 per cent of Swedbank's total REA. Swedbank's credit exposure has low risk, which is confirmed in stress tests. Swedbank aims to build long-term relationships with customers in its home markets and assumes credit risks in a conscious and controlled manner to support its customers. Swedbank's customer base, which mainly consists of private individuals and corporates of all sizes, operating in different sectors in Sweden and the Baltic countries, is the foundation for the low risk. The diversification in terms of number of customers is large and the geographical distribution over Swedbank's home markets is wide. Private mortgages are Swedbank's largest loan segment and amounted at the end of 2025 to SEK 1 070 bn, 57 per cent of Swedbank's total loans to customers, with historically low credit losses.

Swedbank is willing to accept market risk only as part of managing the Group's own financial risks and supporting customer needs. Market risks shall be managed with the aim of having low earnings volatility and preserving the long-term value of the Group while ensuring regulatory compliance. Risk exposure is governed by the risk appetites, which limit the nature and size of market-risk taking. Both qualitative risk appetite statements and quantitative risk appetites in the form of board limits are set to cover market risk in the trading book and banking book respectively. The Group's activity is designed to satisfy the long-term needs of customers.

The Group's low risk appetite for liquidity risk ensures that the Group always is able to continue to serve its customers and shall therefore maintain resilience towards both short-term and long-term liquidity stress without relying on forced asset sales or other business disrupting activities. For the purpose of ensuring that liquidity risk stays within appetite, and ultimately for supporting the Group's strategic goals, the maintenance of a liquidity-generating capacity together with funding planning and risk identification, are central processes within Swedbank's liquidity risk management. Throughout 2025, Swedbank's liquidity position was strong with all key metrics remaining well above internal and regulatory requirements.

Swedbank continuously conduct capital and liquidity stress tests to increase awareness of potential effects from disruptions in the financial markets. The stress tests focus on both Swedbank specific and market related disruptions, and consider combined effects, i.e. scenarios where multiple disruptions occur simultaneously. A key objective of Swedbank's Internal Capital Adequacy Assessment Process (ICAAP) is to ensure that Swedbank's business model remains viable in different scenarios, ranging from adverse to severely adverse developments. In addition to stress testing scenarios, the economic capital calculations consistently demonstrate Swedbank's capital strength. |

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| | | As a bank for the many private and corporate customers, key operational risks are often those related to the availability of Swedbank's services, fraud prevention and the integrity and confidentiality of the data entrusted to Swedbank. The risk appetite for operational risk is expressed in terms of tolerance for levels and types of risks with respect to Swedbank's overall low operational risk appetite. During 2025, Swedbank has continued to strengthen its operational resilience and ensure high level of availability for the Bank's customers. In addition, Swedbank continuously enhances its fraud monitoring system to effectively identify and prevent fraudulent transactions.

The low risk appetite for Environmental, Social and Governance (ESG) risks is supported by the Group's commitment to align its business strategy to the Paris Agreement and to contribute to the fulfilment of the UN Sustainability Developments Goals. The impacts of ESG factors on other risks are considered throughout the risk management process.

The risk appetite for compliance risk is low. During recent years, Swedbank has continued to strengthen its control environment through clear and detailed standards in policies and procedures, supported by Group Compliance's mandate to test and monitor adherence. In addition, Swedbank continuously enhances its oversight mechanisms to effectively identify prohibited and restricted activities, implement expected controls, and maintain focus on financial crime prevention and conduct risk matters.

There has been no intragroup transaction or transaction with related parties of such nature that it has had material impact on Swedbank's risk profile during 2025. |
| --- | --- | --- |
| Point (b) of Article 435(1) CRR | (b) | Risk governance structure
Risk arises in all financial operations, hence a profound understanding of risks, a sound risk governance structure and solid risk management are vital to ensure sustainable and profitable operations. A robust and sound risk culture throughout the Group is an essential part of risk management and necessity to accomplish a strong long-term risk-adjusted return. The responsibilities and duties of the Board of Directors of Swedbank AB (publ) (Board) are primarily set out in the Swedish Companies Act, the Banking and Financing Business Act, the Securities Market Act and the Articles of Association of Swedbank. The Board is responsible for ensuring that Swedbank's organisation is properly designed to identify, assess, manage, monitor and report the risks associated with its operations. To execute its responsibility, the Board ensures that there are adequate and effective governance and internal control structures in place by establishing internal governing documents, for both its own work and the work performed by the organisation. Chief Executive Officer (CEO) has the overall responsibility for ensuring that internal control and governance structures are satisfactory and in accordance with applicable laws, regulations and generally accepted practices or standards. The duties and responsibilities of the CEO are clarified through the Board's instruction for the CEO. The CEO is responsible for ensuring that the internal control is implemented and well-functioning within the organisation. The CEO has established the Group Executive Committee (GEC) to support in the effective management and governance of the Group. Based on the internal governing documents adopted by the Board, the CEO issues more detailed instructions for the operational management and control of Swedbank's risks. The CEO also sets the details of the operational structure and steering, and delegates authority and responsibilities in the Governance Instruction.

Risk management framework
The Board is also responsible for ensuring that a group-wide risk management framework is established. Through the annually reviewed Policy on Enterprise Risk Management and Risk Appetite Statement Policy the Board defines and communicates the Group's risk strategy and risk appetite as well as provides the foundation of a strong and sound risk culture and risk awareness throughout the organisation. Each licensed subsidiary has mirroring structures and processes in place and the Group's risk management framework, risk strategy and risk appetite, are implemented consistently both on a consolidated and sub-consolidated basis within the Group. In accordance with its responsibility for ensuring that the risks associated with Swedbank's operations and strategy are managed in accordance with the risk strategy, the Board sets the Group's risk appetite for the risk types defined in the Group's risk taxonomy on an annual basis. The risk appetite is expressed qualitatively and, where applicable, quantitatively through limits in the Risk Appetite Statement Policy adopted by the Board. The risk appetite limits Swedbank's risk-taking and ensures that capital and liquidity are kept at adequate levels. The qualitative risk appetites and quantitative board limits are implemented through a risk limit framework. In the risk limit framework, limits, Escalation Triggers (ETs) and Key Risk Indicators (KRI) are decided on CEO level, executive management level and, where applicable, lower management level. The risk limit framework is a tool for monitoring and controlling risk exposures, risk concentrations and risk build-ups. Ultimately, its purpose is to ensure that the risks are kept within the risk appetite.

Main committees
To support the Board in matters related to risk management, governance, capital requirements and remuneration as well as preparing items for decision, the Board has established four Board committees, the Risk and Capital Committee (RCC), the Audit Committee (AC), the Remuneration and Sustainability Committee and the Governance Committee. For further information on these committees, please refer to Swedbank's Corporate Governance Report available in Swedbank's Annual and Sustainability Report for 2025.

In addition to GEC, the Group Risk and Compliance Committee (GRCC), chaired by the Chief Risk Officer (CRO), provide recommendations to the CEO, and supports senior management in decisions about management of non-financial risk and compliance matters. This includes reviewing, monitoring, and challenging the Group's risks based on trends, stress tests, losses, management actions and actual risk profile versus the applicable risk appetite. The GRCC supports the accurate management of findings by Group Internal Audit, Group Risk and Group Compliance. To further strengthen the risk management arrangements in group functions, business areas and product area, the GRCC is supported by Business Area Risk and Compliance Committees. In addition, Group Financial Crime Committee is established to ensure adequate and effective management of financial crime risk.

The Group Asset Allocation Committee (GAAC) is chaired by the Chief Financial Officer (CFO), with the CRO as one of the members. GAAC assists the CFO in discharging his/her duties in matters related to the management of assets, liabilities, capital, balance sheet structure, as well as ensuring that the Group's financial risk exposures stay within the risk appetite and the distributed risk limits, while also ensuring that the risk appetite and internal capital allocation adequately cover the underlying financial risks. |

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| | | Three lines of defence
The concept of three lines of defence is the basis for Swedbank's risk management.
First line of defence is accountable for the risks and risk management within their operations. To identify, assess, manage, monitor and report risks in accordance with the risk management framework and to ensure risks are kept within the established risk appetite, business management shall have appropriate processes and internal control structures in place within their respective area of responsibility. Business management is also responsible for communicating to the responsible head of group functions, business areas and product area when they identify risks that will impact areas outside their own responsibility.
Second line of defence consists of the independent internal control functions Group Risk and Group Compliance. The risk management framework, which is defined by these two functions, governs how to identify, assess, monitor, manage and report risks. The functions monitor and assess that effective risk management processes and controls are implemented by the first line of defence. The second line of defence challenges and validates the first line of defence's risk management activities and controls. Further it analyses the Group's material risks and provides independent risk assessment, assurance and reporting to the CEO and the Board.
Third line of defence refers to Group Internal Audit, which is governed by and reports to the Board. Group Internal Audit is independent from the first and second lines of defence and is responsible for evaluating governance, risk management and the internal control processes within the first and second line of defence.
The Board shall on a continuous basis and at least once every year review and evaluate the effectiveness of Swedbank's first and second lines of defence risk management functions and assess whether there are sufficient resources allocated in that area.

Group Risk and Group Compliance
Swedbank's risk and compliance organisation respectively, are regulated in separate policies adopted by the Board. The heads of Group Risk and Group Compliance, the CRO and the Chief Compliance Officer (CCO), report to the CEO, but are also independently reporting to the RCC, AC (only Group Risk) and to the Board. The above-mentioned policies include delegation of authority and responsibilities from the Board to the CRO and the CCO. Group Risk and Group Compliance advise and support the business operations by developing and maintaining e.g. internal governing documents and independently monitor that key risks are identified, assessed, and properly managed by the business operations. Decisions taken within the organisation shall be in line with the established risk strategy and risk appetite. The CRO and the CCO are responsible for critically reviewing and challenging decisions affecting the risk exposure of the Group within their respective areas of responsibility and for having ongoing dialogues with the Board and the CEO regarding these matters. The appointment or removal of the CRO or the CCO, requires prior approval by the Board.

Group Internal Audit
Group Internal Audit is the independent internal audit function in Swedbank. The Chief Audit Executive is appointed by and reports to the Board. Based on the Policy for Internal Audit adopted by the Board, Group Internal Audit provide independent, objective assurance and consulting services designed to add value and improve the Group's operations. Group Internal Audit evaluates that governance, risk management and internal control processes are adequate and functioning in a manner to ensure inter alia that significant risks are identified and managed to support organisational objectives and align with the organisation's strategy.

Code of Conduct and incident management
Swedbank has established a Group-wide Code of Conduct and has a mandatory annual ethics training and sign off of Code of Conduct for all employees. Swedbank fosters an inclusive workplace where employees are encouraged to act ethically, take responsibility and when necessary, voice concerns and speak up against alleged irregularities and violations of the Code of Conduct, internal rules, laws and regulations. All employees shall be aware of circumstances and events in their daily work which can have a negative impact on the Group. There are internal rules, such as escalation routines, providing guidance for managers and employees on required actions based on the severity of the incident. All incidents must be handled in such a way that the negative impact is minimised. Employees and other stakeholders have the possibility to report potential or actual irregularities and violations of the Code of Conduct, internal rules, laws and regulations through the internal alerts process, i. e. whistleblowing. The channel is independent, autonomous and provides the possibility to submit alerts outside the regular reporting lines in an open or anonymous manner. |
| --- | --- | --- |
| Point (e) of Article 435(1) CRR | (c) | Risk Declaration
Swedbank has established a solid and well-structured risk management framework to ensure that Swedbank's risks are kept within the established risk strategy and risk appetite, and that Swedbank's strategic targets are met. |
| Point (c) of Article 435(1) CRR | (d) | Detailed descriptions of the scope and nature of risk disclosure and/or measurements systems can be found in the respective sections for risk to capital, credit risk, market risk (incl counterparty credit risk), liquidity risk, and operational risk. |
| Point (c) of Article 435(1) CRR | (e) | Main features of risk disclosure and measurement systems
In accordance with the Policy for Group Risk, adopted by the Board, the CRO submits a monthly risk report to the CEO, the RCC and the Board. The report includes the risk exposure in relation to the risk appetite per risk type and comments on any risk appetite breach as well as limits and KRIs and recent risk-related events such as incidents. This report is complemented quarterly with results and follow up of assurance reviews and model validation. The assurance reviews are also submitted to the AC.
In accordance with the Policy for Group Compliance, adopted by the Board, the CCO provides a Compliance report to the CEO, the RCC and the Board on a quarterly basis. The reports include the quarterly Data Protection Officer report and the status from the AML/CTF Officer for Control and Reporting (OCR). The OCR also issues the Annual Activity Report. |
| Point (a) of Article 435(1) CRR | (f) | See disclosures under "Points (a) and (d) of Article 435(1) CRR" below. |

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Table EU OVB – Disclosures on governance arrangements, CRR Article 435(2)

Board and CEO

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Jens Henriksson
Jens Henriksson has extensive experience from leading roles in government, public institutions and private companies. He has in depth knowledge of financial markets, international economic affairs and public finances, with a broad network within and over several industries.
BA Economics, MSc Electrical Engineering, Control Theory, and Fil. Lic. Economics
Operative: 6 years
Three Board of Directors assignments (all related to his role as CEO of Swedbank, and all within organisations with no predominant commercial objective).

1) As per 31 Dec 2025. Includes directorships in Swedbank.
2) The abbreviation CEO as defined in the table Terminology and abbreviations is not applicable to these columns.

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Section 3 - Disclosure of the scope of application

Template EU LI1 - Differences between the accounting scope and the scope of prudential consolidation and mapping of financial statement categories with regulatory risk categories, CRR Article 436(c)

Breakdown by liability classes according to the balance sheet in the published financial statements

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Template EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statements, CRR Article 436(d)

Template EU LI3 - Outline of the differences in the scopes of consolidation (entity by entity), CRR Article 436(b)

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Table EU LIA – Explanations of differences between accounting and regulatory exposure amounts, CRR 436(b)

Table EU LIB – Other qualitative information on the scope of application, CRR Article 436(f,g,h)

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Template EU PV1 - Prudent valuation adjustments (PVA), CRR Article 436(e)

Prudent valuation is a regulatory requirement which takes into account uncertainties in the valuation of assets and liabilities carried at fair value. The prudent valuation adjustment is deducted from the CET1 capital in accordance with the CRR Article 105. In addition to the fair value adjustments made in the accounts, Swedbank calculates Additional Valuation Adjustments (AVAs) for fair valued positions in the trading and banking book. The purpose of the prudent valuation adjustment is to ensure, with an appropriate degree of certainty, that the valuations are sufficiently prudent taking into account the factors corresponding to the AVAs.

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Section 4 - Disclosure of own funds

Template EU CC1 - Composition of regulatory own funds, CRR Article 437 (a,d,e,f) and Article 444(e)

EU-33a Amount of qualifying items referred to in Article 494a(1) CRR subject to phase out from AT1

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CET1 ratio decreased by 183 bps to 17.82 per cent as compared to Q3 2025. CET1 capital decreased by SEK 11.0bn, which decreased CET1 ratio by 117 bps, mainly due to special dividend, which decreased profit after anticipated dividend by SEK 8.1bn and increased deductions for intangible assets, which decreased CET1 capital by SEK 2.0bn. REA increased in total by SEK 31.3bn, which decreased the ratio by 66 bps. As detailed in OV1 and CR8 parts, REA increase was mainly driven by changes in credit risk and operational risk.

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Template EU CC2 - Reconciliation of regulatory own funds to balance sheet in the audited financial statements. CRR Article 437(a)

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Template EU CCA - Main features of regulatory own funds instruments and eligible liabilities instruments, CRR Article 437(b,c)

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'N/A' if the item is not applicable

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Section 5 - Disclosure of countercyclical capital buffers

Template EU CCyB1 - Geographical distribution of credit exposures relevant for the calculation of the countercyclical buffer, CRR Article 440(a)

No changes in countercyclical buffer rates compared to Q2 2025.

Template EU CCyB2 - Amount of institution-specific countercyclical capital buffer, CRR Article 440(b)

Institution specific countercyclical capital buffer requirement increased by SEK 0.7bn compared to Q2 2025.

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Section 6 - Disclosure of leverage ratio

Template EU LR1 - LRSum: Summary reconciliation of accounting assets and leverage ratio exposures, CRR Article 451 (1)(b)

Leverage ratio exposure measure decreased by SEK 92.2bn, as compared to Q2 2025. Leverage ratio exposure measure decrease is in line net effect of total assets and adjustment for entities which are consolidated for accounting purposes but are outside the scope of regulatory consolidation.

Template EU LR2 - LRCom: Leverage ratio common disclosure, CRR Article 451 (1)(a,b,c), 451(2), 451(3)

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Leverage ratio decreased by 12 bps and reached 6.56 per cent as compared to Q2 2025, mainly due to decrease in Tier 1 capital (SEK 9.4bn), driven by special dividend, which decreased profit after anticipated dividend.

Template EU LR3 - LRSpl: Split-up of on balance sheet exposures (excluding derivatives, SFTs and exempted exposures, CRR Article 451 (1)(b))

Total on balance sheet exposures decreased by SEK 26.9bn as compared to Q2 2025 mainly due to decreased sovereign (SEK 54.6bn), institutions (SEK 28.5bn) exposures and trading book exposures (SEK 35.8bn), which have been partially offset by exposures secured by mortgages of immovable properties (SEK 31.0bn), corporates (SEK 20.6bn), other banking book exposures (e.g. equity, securitisations, and other non-credit obligation assets) (SEK 39.0bn).

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Table EU LRA: Disclosure of LR qualitative information, CRR Article 451(1)(d,e)

| Row | | a
Disclosure of LR qualitative information |
| --- | --- | --- |
| (a) | Description of the processes used to manage the risk of excessive leverage | Swedbank takes the risk of excessive leverage into account in the forward-looking capital planning process by forecasting the leverage ratio at least on a quarterly basis. Other business steering or asset-and-liability management tools are also considered as means to affect the total exposure measure and may be accessed, should such a need arise. As a part of the capital planning process, Swedbank performs an assessment if the entire Group, as well as the parent company and its subsidiaries, are adequately capitalised. In case of a deterioration, Swedbank Group can also increase the Tier 1 capital by issuing Additional Tier 1 capital. Likewise, a capital injection to support subsidiaries may be performed. In addition to the injection of equity capital, the total capital in a subsidiary may also be strengthened through subordinated loans within the Group. To the extent that non-restricted equity is available in subsidiaries, funds can be transferred back to the parent company as dividends. Swedbank regularly reviews the capitalisation of the Group and the individual legal entities. The outcome of such reviews may trigger adjustments deemed necessary to ensure compliance with regulatory requirements and an efficient capital management within the Group. Further, there are no current or foreseen material practical or legal impediments to the prompt transfer of own funds or repayment of liabilities to or from the parent company and its subsidiaries. |
| (b) | Description of the factors that had an impact on the leverage ratio during the period to which the disclosed leverage ratio refers | The leverage ratio decreased by 0.24 percentage points from 6.80 per cent to 6.56 per cent during 2025. The Tier 1 capital decreased by SEK 8.6bn, whereof CET1 capital decreased by SEK 6.5bn and AT1 capital decreased by SEK 2.0bn. The leverage ratio exposure amount decreased by SEK 29.4bn, where the main drivers were off balance which decreased by SEK 26.1bn, derivatives (decreased by SEK 11.3bn) that were offset by Other assets (by SEK 13.1bn). |

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Section 7 - Disclosure of liquidity requirements

Table EU LIQA - Liquidity risk management, CRR Article 435(1), 451a (4)

The liquidity-generating capacity comprises two components.
First, the Group's liquid assets, which comprise the liquidity reserve, i.e. liquid assets under the direct control of Group Treasury, as well as eligible unencumbered assets held elsewhere in the Group. Second, over-collateralisation in the cover pool, which represents liquidity-generating capacity as it can be used to issue covered bonds.

The inclusion criteria for liquid assets correspond to the definition of High-Quality Liquid Assets (HQLA) in the delegated regulation on the Liquidity Coverage Ratio (LCR). The size and currency distribution of the reserve is determined by the maturity structure and composition of asset and liabilities and internal and external requirements, e.g. risk appetite, limits, and regulations applicable for Group and its subsidiaries.

Swedbank's funding strategy is based on three objectives: diversification, commitment, and proactivity. Funding shall be diversified based on long-term and short-term debt, different products, the maturity profile, geographies, and the currency distribution. Commitment is shown by maintaining a regular presence in the chosen markets and by providing liquidity. In order to be proactive in funding decisions, the Group monitors market developments and trends in the capital markets, including regulatory requirements, accounting changes and demands from rating agencies and investors. The funding strategy supports liquidity risk management, as it aims to ensure reliable access to funding markets.

The Group's funding strategy forms the basis for a more granular and tactical funding plan for issuance of debt where planned actions and activities are outlined. The funding plan spans a three-years period and is revised at least yearly, or when deemed appropriate due to changes in internal or external circumstances.

Liquidity risk identification is mainly managed through the Risk Identification Process, which is an annual process where liquidity risk topics are discussed. As part of this, a gross risk inventory is established and maintained. Liquidity risk factors stemming from on- and off-balance sheet items are well known and covered by the risk inventory. |
| (b) | Structure and organisation of the liquidity risk management function (authority, statute, other arrangements). | Group Treasury is responsible for measuring, monitoring and analysing liquidity risk, and for developing, implementing and maintaining Group-wide regulatory-driven methodologies for its measurement. Group Treasury is further responsible for implementing and maintaining the governance structure for liquidity risk management.

Group Risk is responsible for ensuring that liquidity risks are identified and properly managed by Group Treasury. Group Risk is further responsible for governance and strategies within liquidity risk control and provides independent review of liquidity risk management.

The division of responsibilities between Group Treasury and Group Risk with respect to liquidity risk management and control is defined in internal policies.

The Baltic subsidiary banks have separate risk functions. The Baltic subsidiary banks' risk functions are responsible for ensuring that liquidity risks are identified and properly managed by treasury function in subsidiaries and for governance and strategies within the area of liquidity risk control. Local liquidity risk control operates within governance and strategies set on Group level. |
| (c) | A description of the degree of centralisation of liquidity management and interaction between the group's units | Swedbank Group employs a centralised liquidity management, in the sense that regardless of where the liquidity reserve is located, Group Treasury is responsible for monitoring and coordinating the management of the reserve in different legal entities. Regulatory or other reasons are taken into account in the allocation of liquidity, why parts of the liquidity reserve may be held by different legal entities within the Group when deemed necessary.

Besides the central Group Treasury function, treasury functions in subsidiaries are established with responsibilities for local liquidity management. Due to the centralised approach, the Group Treasury function operates in close collaboration with the subsidiaries. |
| (d) | Scope and nature of liquidity risk reporting and measurement systems. | The liquidity position is regularly reported to the management body through a range of channels. The monthly reports by the CFO and CRO target different committees and are reported to the Board. The scope covers the key liquidity metrics, including point in time outcomes, historical comparisons and forward-looking perspectives. In addition, the ILAAP and the Risk Management and Capital Adequacy reports are well anchored throughout the management lines and is ultimately targeting the Board. Besides the internal risk reporting, external reporting is made to supervisors and other stakeholders. The liquidity systems provide information required in supporting the liquidity risk management processes and cater for measurement of key external and internal liquidity metrics as well as for data for analysis. The system solutions source relevant information and logic for generating cash flows and for structuring and compiling the data in accordance with common rules. |

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Template EU LIQ1 - Quantitative information of LCR, CRR Article 451a(2)

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Table EU LIQB on qualitative information on LCR, which complements template EU LIQ1, CRR article 451a(2)

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Template EU LIQ2 – Net Stable Funding Ratio, CRR Article 451a(3)

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The Net Stable Funding Ratio (NSFR) decreased slightly during Q4 2025, from 128 per cent to 124 per cent. The main driver behind this change was a slight increase in Required Stable Funding (RSF), mainly due to growth in the loan portfolio and a decrease in Available Stable Funding (ASF), mainly due to a decrease in short term funding and own capital.

The ASF is mostly composed of funding from deposits and long-term issued debt.

The RSF is mostly composed of funding needed to give out residential mortgage loans and loans to non-financial corporate clients. It is relevant to note that there is a slight interdependence between residential mortgage loans and long-term issued debt in the form of covered bonds. When a covered bond is issued, more stable funding is made available in the category wholesale funding. However, this also encumbers a corresponding volume of residential mortgage loans that then receive a slightly higher factor weight which in turn increases the required funding.

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Section 8 - Disclosure of credit risk quality

Table EU CRA: General qualitative information about credit risk, CRR Article 435(1)(a,b,d,f)

Credit policy – The credit policy establishes and describes the high-level principles and rules within the Group on credit risk management and credit operations. It provides basis for the Group's credit strategy and serves as a guide to create long-term customer relationship and maintain a low risk in the credit portfolio as well as good risk-adjusted profitability.
Prudent banking is one of the main governing principles. It means sound and reasonable risk management practices in line with Swedbank values and low risk appetite. It also considers responsible lending from a consumer protection perspective as well as from a societal perspective.
The credit portfolio shall have low risk and be well-diversified. Diversification is obtained by geographical and industrial spread, a diversified customer base and by avoiding undesirable risk concentrations of any kind. Low risk is developed and maintained through relevant credit risk steering principles as well as clear credit strategy and appropriate targets within each business unit that are in line with the strategy and risk appetite of the Group. A continuous and structured monitoring of the credit portfolio is essential to maintain a desired risk level and long-term quality of the business relations.
The credit operations shall strive towards long-term customer relationships and rest on sound business acumen to achieve solid profitability. A customer's sustainable cash flow, solvency and collateral are always key lending variables. Credits shall only be granted to customers with a demonstrated repayment ability and a sufficient financial situation. Duality and segregation of duties are essential in all credit operations within the Group to ensure sound credit operations including well-founded decisions. It shall be reflected in the organisation of the credit risk management with an independent credit function and applied in decision-making and otherwise in the credit process.
The credit framework shall always be read in conjunction with policies, position statements and other internal guidelines in the ESG area. The ESG risk perspective shall be an integrated part of all credit risk assessments to mitigate such risk and identify opportunities.

Credit operations processes – The main processes of the credit operations include credit risk assessment, decision on credit risk, and credit monitoring and review, as described below. Credit risk assessment, including business analysis, is the basis for a credit decision. The credit assessment covers the counterparty's capacity to repay. It also includes collateral considerations and other risk mitigating actions, as well as terms and conditions for the credit arrangement. Risk-classification of the counterparty is an important part of the credit risk assessment. Relevant ESG aspects is included in the analysis of the counterparty's opportunities and risks.
Decisions on credit proposals are made according to an established structure of credit decision-making bodies. The primary credit decision is made in a credit decision-making body within the business area responsible for the borrower and its credit risk. Credit proposals implying higher risks are reassessed and finally decided by an upper credit committee. For smaller standardised credits automated solutions for credit assessment and decision-making may be used.
Credit monitoring and review of individual credit risk exposures is performed continuously to early identify any change in credit risk. In addition to continuous monitoring, corporate customers, financial institutions, and sovereigns are also reviewed at least annually. If a counterparty's risk has deteriorated, several corrective measures are considered and implemented, with the objective to avoid impairment, and/or minimise the risk of loss in case of default.

Hedging and mitigation of credit risk – There are several ways to mitigate credit risk, including mainly:
• The credit policy and credit strategy with a clear guidance on Swedbank's low risk appetite.
• The credit risk limit framework including key risk indicators to monitor and protect against unwanted risk-taking.
• The use of financial and physical collateral valued using Group common valuation methodologies, risk transfer mechanisms such as guarantees and insurance, and covenants in credit documentation.
• The use of hedging strategies, netting agreements, and clearing through central counterparties.
• Diversification or increasing the portfolio mix of customers within different markets and segments.
The main types of collateral, collateral valuation and netting policies are described in EU CRC – Qualitative disclosure requirements related to CRM techniques.

Credit risk limits – The purpose of the risk limit framework is to integrate the risk appetite into the Group's daily operations and to facilitate effective and structured monitoring and reporting to keep the Group's risk exposure within the established Group risk appetite. The framework includes risk limits, escalation triggers, and key risk indicators, which are defined on Group level and business area level. The CRO has overall responsibility for the risk limit framework, which is reviewed annually to secure that set limits reflect that Swedbank operates within the risk appetite. The risk limits are decided by the CEO and by executive management.
Control and monitoring of credit exposures against risk limits are performed monthly and reported to the CRO, risk limit issuers and risk owning managers in a credit risk limit report. In case of a limit breach, the risk owner reports the incident and mitigating actions to the risk organisation and relevant managers. |

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| (c) | Monitoring and reporting of credit risk – Group Risk oversees the Group’s credit risk development and reports monthly to the CRO, who informs the CEO and the Board. Important parts of the monthly risk reports are credit portfolio trends, findings from stress tests and other analysis, and the credit risk limit report.
Group Risk annually performs a thorough and comprehensive stress test of the entire Group, the ICAAP, described in EU OVC - Internal Capital Adequacy Assessment Process", which includes a credit loss stress of the total credit portfolio. In addition, Group Risk conducts stress tests on selected sectors, typically the largest sectors, and specific segments or exposure types with potentially increased risks. |
| --- | --- |
| (d) | Credit governance structure and responsibilities
Swedbank’s governance structure for risk management including the three lines of defence is described in EU OVA - Institution risk management approach. In the credit risk area, the governance structure details as follows.
The business units, the first line of defence, are responsible for the operational credit management of their customers and own all credit risks that arise within their area of operation. The head of the unit ensures that all credits are assessed, decided, administrated, and followed-up in accordance with the credit framework, including establishing an integrated internal control of high quality in the credit process. The head of each business unit shall also make sure that the credit transactions are in line with Swedbank’s strategies, policies, and instructions. The business unit is furthermore accountable for the profitability connected to the credit decision.
Group Risk, the second line of defence, is responsible for independent monitoring and control of the credit risk management carried out by the business operations. This includes verification that internal rules and processes defined in the credit risk framework are complied with, and that the first line of defence has adequate controls in place. Group Risk also has the responsibility to maintain, develop and monitor the risk classification system, and the responsibility to perform independent assessment of challenging credit proposals. Group Risk shall independently report relevant risk information to the CEO and the Board.
Group Compliance, also within the second line of defence, is in the credit risk area responsible for screening and control of regulatory compliance. Group Internal Audit, the third line of defence, is governed by and reports to the Board. It performs independent periodic reviews of the credit management, and the credit control processes within the first and second line of defence. |

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Table EU CRB: Additional disclosure related to the credit quality of assets, CRR Article 442(a,b)

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Template EU CR1 - Performing and non-performing exposures and related provisions, CRR Article 442(c,f)