Luminor’s purpose is to support sustainable growth of the Baltic region by providing long term commitment to businesses and individuals. We are committed to running our business in a responsible, sustainable and caring manner.

The commitment and strategy on environmental, social and governance (ESG) matters is established by Luminor Supervisory Council through different policy documents and guidance, which are supported by the procedures and guidelines approved and implemented by the Management Board.
While all Division Heads of Luminor are responsible for following and implementing the ESG policies and guidelines in their respective areas of business, the Head of Group Communication is mandated with the overall co-ordinating of the field. The development, implementation and review of Luminor business integrity and sustainability matters is managed and overseen by Luminor Business Integrity and Sustainability Forum.
We proceed in our activities from Luminor’s Corporate Social Responsibility Policy, supported by other relevant policies, guidelines and procedures.
In addition, in our activities we follow the guidance provided by following international standard setters, including among other:

  • UN Global Compact
  • UN Principles of Responsible Investments
  • UNEP FI 
  • UN Guiding Principles on Business and Human Rights
  • OECD Guidelines on Multinational Enterprises
  • UK Anti-Bribery Act 2010
  • OECD Anti-Bribery and Corruption Guidance
  • US Foreign Corrupt Practices Act 

Luminor is currently also reviewing its ESG related strategy and governance, based on the recommendations of ECB guide on climate-related and environmental risks for banks, TCFD (Task Force on Climate-related Financial Disclosures) and the European Green Deal EU Taxonomy with a special focus on ESG related disclosures. The strategy will be published in the first quarter of 2021.
Responsible Business
We extend the principles of responsible and sustainable business to all our actions, including our own activities and supply chain, as well as our products and offering, investment and financing activities.
Luminor does not contribute to human or labour rights violations, corruption, serious environmental harm or other actions which may be perceived to be unethical.
We regard compliance with all laws and guidelines as the minimum standard to be achieved and go beyond compliance in fields where additional programmes could be beneficial.
Luminor strives to influence the companies we do business through dialogue, meetings and other measures and if necessary, encourage them to correct their actions.
Following entities are excluded from our direct investments and financing universe:

  • involved in the production of or trade of any product or activity deemed illegal under national laws or regulations, or international conventions and agreements, or are subject to international bans;
  • are sanctioned by the UN, EU, United Kingdom HM Treasury, United States OFAC, national regulations of Estonia, Latvia and Lithuania;
  • where it is suspected that financial crime and other illicit activities are taking place or are acting without the required license in the jurisdiction in which they or Luminor operates in;
  • related to the financing of terrorism (e.g. foreign fighters, activities in war zones, fundraising through crowd-financing platforms for purposes which could be suspected as related to the financing of terrorism activities, etc.)

In our concern for environmental sustainability, Luminor has also developed risk-adjusted environmental and social (E&S) risk evaluation procedure to be applied to all legal entities. The procedure requires E&S evaluation for every new customer and during every annual review of existing SME and Corporate customers.
The three levels of risk categories include low, medium and high risk and the assessment process includes also industry risk valuation and enhanced CSR/ESG risk assessment for high risk customers. The risk assessment is carried out in four main categories, including environmental risk, governance and transparency, compliance with human and labour rights and anti-corruption.

To support this, all relevant employees have also received necessary training, including Relationship Managers and Credit Analysts. 

Corporate values and Principles of Conduct
At Luminor, we are committed to uphold the highest standards of ethical and professional conduct and promote strong corporate and risk culture. We expect all our employees to follow our Principles of Conduct, which describe our values and expected behaviours.
Our values are focus, collaboration and curiosity.
Our Principles of Conduct are integrated with Luminor’s Anti-Bribery and Anti-Corruption policies in one comprehensive Compliance Policy and Compliance Standards, to support Luminor and its employees in their efforts to prevent bribery and corruption.
In order to foster and promote open and transparent environment, where ethical behaviour is highly valued, Luminor encourages employees to prevent and proactively detect any breaches of laws and other regulations, and bring them to attention of appropriate functions. For that purpose, we have implemented Raising Your Concern Procedure and we ensure that all reported breaches are treated seriously and where relevant, identified risks are managed appropriately. Among others, this procedure covers whistle-blowing principles and describes internal alert framework employees can use.
Prevention of Money Laundering and Terrorism Financing
Luminor is committed to remaining vigilant to prevent and detect money laundering and financial crime through the prevention, detection, and reporting of unusual activities.
We regularly review our AML practices and invest in necessary human and technological capabilities in this field. Being a subject to different legal requirements, Luminor acts in full transparency and collaboration with all relevant supervisory and regulatory authorities.
At Luminor, we recognise that preventing money laundering and identifying possible terrorist financing activities involves constant diligence, continuous professional development, awareness raising and the ability to keep pace with the trends and emerging risks in the financial crime area.
Sustainable Procurement
We recognise the influence that our activities have on the society and the environment through our supply chain and aim to work towards reducing both our direct and indirect environmental impact. We take responsibility for the impact inflicted on society and the environment as a result of our business activities, and we expect our Third Parties to do the same.
The Code of Responsible Business Conduct for Third Parties outlines the principles we expect our partners to abide by, including ethical business practices, fair employment practices, as well as sustainable business practices and environmental management. The Rules of Social Responsibility are annexed to our vendor agreements.
Transparency and engagement
Luminor is committed to being transparent in our interactions with our employees, our customers, investors, state institutions and other stakeholders. We aim to be straightforward, easy to understand and respectful in all of our communication.
We treat communication as a two-way street and aim to have regular dialogues with our stakeholders. We also want to enable our customers and other stakeholders to engage in our planning and activities, as much as possible.
We regularly monitor our customer satisfaction through Net Promoter Score and carry out surveys to receive feedback that would enable us to better serve our customers and have a voice in our community on topics that matter to us and our customers.
Luminor seeks to have good contact with all relevant authorities and keeps them informed of its operations, to ensure proactive cooperation.
Equal opportunities and a safe working environment
Luminor is committed to providing its employees with a safe and supportive working environment and ensuring that principles of diversity and equal opportunities in the workplace are always followed. We value a diverse team and facilitate independent opinions and critical challenge. Luminor has in place an Equality, Non-discrimination and Diversity Policy, defining the principles which we follow.
We have implemented routines for evaluating and enhancing diversity aspects upon recruitment of managers and employees and ensure the application of equal pay for equal work principle. We encourage anyone who feels they have been subject to discrimination to raise their concerns so that corrective measures can be applied.
Luminor focuses on the development of the competence of its employees and we facilitate professional and personal development by making sure that its employees are stimulated and given opportunity to develop their expertise, attitudes and skills.
In order to guarantee a healthy and safe working environment, we ensure that necessary work safety procedures are in place and training carried out for all employees. We regularly survey our employees’ job and work environment related satisfaction and take the results into account in our planning and activities. We recognise the importance of work and life balance and promote that through different programmes and training.  
Environmental responsibility
Although our direct environmental impact as a financial institution is rather limited, we acknowledge the importance of sustainable approach in how we operate on daily basis and work to reduce our direct environmental footprint.
We aim to reduce carbon emissions from our operations and use natural resources and energy with care and efficiency. We strive to eliminate and minimize waste and re-use or re-cycle as much as possible. Our objective is to use less paper and more digital solutions in our work, and use tap and filtered water instead of bottled water. Our Travel Standard sets forth the principle of considering environmental impact when planning our necessary business travel.
Contributing to society
Luminor wants to make a difference in our home region and have a voice in the society, to shape the economic environment with the future in mind.
We aim to contribute to the communities we operate in through different activities that promote financial literacy, raise awareness on topics of savings, investments and responsible lending, and support and promote local entrepreneurship. We do that by different educational and awareness-raising activities, contributing to education and carrying out or supporting relevant initiatives.

No consideration of sustainability adverse impacts upon investment decisions in Luminor Bank

Currently, Luminor Bank does not consider the adverse impacts of its investment decisions on sustainability factors as we do not offer portfolios that promote ESG characteristics and/or have sustainable investment as its objective. However, we plan to implement a due diligence policy with respect to the principal adverse impacts of our investment decisions on sustainability factors.