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CSR policy

1. Introduction

1.1 Nets A/S (“Nets” and together with its subsidiaries, the “Group”) is committed to act as a responsible corporate citizen. Nets works continuously to earn the trust of its stakeholders while delivering great payments, a great network and great ideas, carried out by great people. As part of this commitment, Nets has developed this CSR policy (the “Policy”), which is subject to annual review and approval by the Board of Directors.

2. Establishment and purpose

2.1 Nets plays a central role in the digitisation of the Nordic countries though the company’s focus on powering digital payments and through services with digital identities and digitisation of paper-based processes. Nets’ primary social responsibility is to help ensure that modern societies function in a safe and efficient manner within the broader area of digital payments, for the benefit of citizens and businesses alike. Nets fully recognises and respects the company’s social impact on the communities within which Nets operates.

2.2 This Policy is based on Nets’ core values and is closely linked to Nets’ ethical guidelines which address matters such as conflicts of interest, confidentiality, protection of personal data, anti-corruption and personal conduct. The ethical guidelines are anchored in the Nets’ code called ACT, which stands for Accountable, Customer driven and Together. Nets believes that ethical conduct is the foundation for corporate responsibility and the ethical guidelines provide structure and guidance for value-based decision-making as well as defining what the company sees as acceptable behavior.

2.3 The overall purpose of this Policy is to strengthen Nets’ profile as a responsible company towards customers, shareholders and general stakeholders and to ensure that Nets is an attractive workplace for both current and future employees. Nets’ goal is to make corporate social responsibility a natural and integrated part of the way in which the daily business operations are managed in order to comply with Nets’ values and ethical guidelines as well as expectations from customers and stakeholders.

3. Description of policy

3.1 Nets has decided to base its specific CSR activities on the following six cornerstones; (a) human and labour rights, including diversity, (b) supply chain management, (c) climate and environmental impact, (d) community involvement, (e) anti-corruption and bribery, and (f) social and staff matters, in line with the requirements set out in section 99a of the Danish Financial Statements Act.

3.2 Human rights, including diversity

3.2.1 The approach to human rights is firmly based on Nets’ core values and ethical guidelines. Nets has developed a Human & Labour Rights Policy which is guided by the United Nations’ Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. The purpose of the policy is to define the framework and provide a basis for the Group’s work with respect to human rights. The policy covers key issues with importance for the Group and its employees, such as non-discrimination and protection against harassment. The Human and Labour Rights Policy applies to all Group employees and is closely connected with Nets’ ethical guidelines.

3.2.2 Nets considers diversity an integral part of a healthy, forward-looking company and finds it important to include diversity as a parameter in the company’s approach to CSR. In accordance with applicable law, Nets has adopted a Diversity Policy, which sets out the company’s goals for increasing the diversity among the members of the Board of Directors of the Company and at other management levels. Nets aspires to be an attractive workplace for both current and future employees and works to ensure that men and women have equal opportunities for furthering their careers and securing management roles within the company.

3.3 Supply chain

3.3.1 Operating in an international context, Nets is fully committed to complying with legislation and recognises international business standards that apply to the company’s field of work. Moreover, Nets advocates for sound business practices throughout its value chain. Nets has developed a Supplier Code that is included in all its agreements with suppliers. Nets encourages all suppliers to ensure that the sound business practices of Nets’ Supplier Code are used throughout every supplier’s organisation, in order to ensure that also sub-suppliers aspire to act in accordance with the principles of Nets’ Supplier Code.

3.4 Climate and environmental impact

3.4.1 Nets supports a preventative approach to environmental challenges and a responsible way of conducting business operations. Nets is committed to being an environmentally conscious service provider and business partner and work strategically and systematically based on the requirements of Nets’ ISO140001 certification towards minimising the company’s environmental impact on every level of the organisation. The Group has developed an Environmental Policy that supports Nets’ aim to run every operation in an environmentally conscious way. In addition, the policy ensures that Nets complies with all environmental laws and other applicable requirements and focuses on minimising pollution and the environmental impact of Nets’ core business.

3.5 Community involvement

3.5.1 Acting as an internationally responsible corporate citizen, Nets is supporting causes which are close to Nets’ business and which Nets expects will positively impact people and societies in general. Nets has chosen primarily to promote children’s education in general within IT and ITsecurity-related areas.

3.6 Anti-corruption and bribery

3.6.1 Nets adheres to the UN Global Compact principles and is committed to a zero-tolerance policy with regard to anti-corruption and bribery. The company has established internal policies and guidelines to ensure employees act with integrity and do not engage in any actions involving corruption and/or bribery and understand the importance thereof.

3.7 Social and staff relations

3.7.1 Nets respects and prioritises the conditions of its employees across the Group. This includes a non-discriminatory, safe and healthy work place for all. In particular, this includes a continuous focus on reducing the noise level, eliminating work-related illnesses and improving the health and safety measures already installed. Further to this, the company strives to embody a culture of continual learning for its employees whilst embedding Nets’ core values in the everyday work environment.

4. Follow-up and reporting

4.1 Nets considers the company to have an open corporate culture where everyone can freely express themselves if they have knowledge of different irregularities or illegalities committed by company employees or suppliers. In 2014, Nets also implemented a whistleblower scheme under which employees, management and externals may report serious violations and misconduct, or suspicions thereof that may influence the Group as a whole or the life or health of an individual. The whistleblower system can be used to report such serious issues or any issues relating to the financial services regulation. The whistleblower system has been established with the permission of the Danish Data Protection Agency. Reports are received and investigated by an external law firm and may be submitted anonymously.

4.2 Nets is covered by section 99a of the Danish Financial Statements Act , which demands that CSR reporting is done as part of the annual financial reporting process. Nets reports on annual progress towards the targets and ambitions set out for each of the six focus areas. Reporting and policies can be found at the dedicated CSR area on


This Policy has been approved by the Board of Directors of Nets A/S on 21 December 2016.