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Welcome to our press conference 19 September 2018

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Page 1: Welcome to our press conference - Danske Bank...Welcome to our press conference 19 September 2018 2 Use this layout page when you have a picture that is dark. The logo is different

Welcome to our press conference

19 September 2018

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Participants

Ole Andersen,

Chairman of the Board of Directors of Danske Bank

Carol Sergeant,

Vice Chairman of the Board of Directors of Danske Bank

Ole Spiermann,

Partner at the Bruun & Hjejle law firm

Jørn P. Jensen,

Member of the Board of Directors of Danske Bank and

Chairman of the Audit Committee

Thomas F. Borgen,

CEO of Danske Bank

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Danske Bank has not

lived up to its

responsibility

We take the combating

of money laundering

and financial crime

very seriously

The case in no way

reflects the bank we

want to be

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The firstwarnings cameback 2007

Inadequate AML procedures in Estonia

The problems were much largerthan originallyassumed

Lack of management in Estonia and at Group level

The investigations conclude that

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The investigations have had consequences

Research, training, projects and other initiatives aimed at

combating financial crime

42 reports to the authorities

8 reports to the police

Reporting to authorities

Warnings

Dismissals

Loss of bonus payments

Staff-related

consequences

Donation

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Reflections of the Board of Directors

1

2

3

Great caution when making acquisitions outside core markets

Focus on integration and effective implementationof controls and systems

Cultural integration is decisive for transparency and trust

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Governance of the investigationCarol Sergeant, Vice Chairman of Danske Bank’s Board of Directors

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• Text 1

The investigation

Comprehensive and objective investigations led by the Bruun & Hjejle law firm

What exactly

happened at the

branch in Estonia

Around 70 persons

have worked full-time

on the investigations

Wish for objective and

complete investigations

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Two overall tracks of investigation

Investigation of the

non-resident portfolioInvestigation of accountability

• 15,000 customers

• 9.5 million payments

• Internal collusion

• Institutional and individualaccountability

• 12,000 documents

• 8 million e-mails

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Non-Resident Portfolio at Danske Bank’s Estonian branch, 2007-20171 9 S E P T E M B E R 2 0 1 8

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Flow of the customers of the Non-Resident Portfolio

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Development of the Non-Resident Portfolio

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0

500

1.000

1.500

2.000

2.500

3.000

3.500

4.000

4.500

2007 2008 2009 2010 2011 2012 2013 2014 2015

CORPORATE ENTITIES PRIVATE PERSONS TOTAL

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Inadequate AML procedures at the Estonian branch

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Obligations AML failings re Non-Resident Portfolio at the Estonian branch

Due diligence

Lacking knowledge of customers

Lacking identification of (ultimate) beneficial owners and “controlling interests”

Customers included so-called intermediaries, which were unregulated and represented unknown end-customers

Monitoring

Insufficient attention to customer activities

Lacking identification of the source and origin of funds

No screening of customers against lists of politically exposed persons

No screening of incoming payments against sanctions or terror lists

In general, no automatic screening of incoming payments

Reporting Lack of response to suspicious customers and transactions

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Sources and participants – customers, transactions and potential internal collusion

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Sources

Information on customers

Approx. 10 mill. payments

Other material

CIM TEAM

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Sources and participants – course of events and accountability

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Sources

More than 8 million emails

and attachments

Review of more than 12,000

documents, including 4,000

emails

74 interviews with 49

persons

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Deposits for non-resident customers in Baltic banks

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0

2

4

6

8

10

12

14

16

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

DEPOSITS OF THE NON-RESIDENT PORTFOLIO IN THE ESTONIAN BRANCH

TOTAL DEPOSITS OF NON-RESIDENTS IN ESTONIA

TOTAL DEPOSITS OF NON-RESIDENTS IN THE BALTICS

EU

RB

ILL

ION

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The Non-Resident Portfolio – and other customers subject to investigation

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15,000 non-resident customers pursuant to broader definition

10,000 customers in the Non-Resident Portfolio

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Geographical distribution of the Non-Resident Portfolio

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Applied model of analysis

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Geographical distribution of flow of the Non-Resident Portfolio

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Incoming funds Outgoing funds

Customers in the Non-Resident

Portfolio

Estonia (23 %)

Russia (23 %)

Latvia (12 %)

Cyprus (9 %)

UK (4 %)

Other (30 %)

Estonia (15 %)

Latvia (14 %)

China (7 %)

Switzerland (6%)

Turkey (6 %)

Others (52 %)

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Historical SARs and inquiries from the Estonian FIU

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Suspicious non-resident customers

Approximately 6,200 customers deemed suspicious

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Key events from 2007 to 2014

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Inquiries from the DFSA to Group in 2012 and 2013

Meeting with the EFSA i 2013

Termination of correspondent banking relationship in 2013

Business review of the Non-Resident Portfolio in 2013

Whistleblower report at the end of 2013

Acquisition of SampoPank

Critical inspection report by EFSA

Letter from the Russian Central Bank

No integration of IT-platform for Group and the Baltics in 2008

EFSA inspection report in 2009

Reassuring reporting from Group Internal Audit and Group Compliance & AML

2007 2008-2012 H1 2014

Group Internal Audit reports in January and February

Working group established

Customer review of the Non-Resident Portfolio

2012-2013

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Reponses to whistleblower and GIA reports in 2014

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Reporting to FSAs

Whistleblower allegations

Customer review

HR action

Identified AML risk

Responsibility for reporting is unclear

Reporting to neither the Danish FSA nor the Estonian FSA takes place

Responsibility for investigation into allegations is unclear

Insufficient investigation of allegations takes place

Customer review is organised and executed inadequately

No action against branch management

No effective response to the identified AML risk

No ”look back”

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Key events from 2014 to 2017

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New policy regarding the Non-Resident Portfolio

Strategy discussions regarding the Baltics at both the Executive Board and the Board of Directors

New, highly critical EFSA inspection report

H2 2014 2015 2017

“Russian Laundromat”

Promontory’s root-cause analysis

“Azerbaijani Laundromat”

Extended investigations

Highly critical inspection report from the DFSA with reprimand

2016

Termination of correspondent banking relationships

Final precept by EFSA with orders

Termination of the Non-Resident Portfolio

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Termination of the Non-Resident Portfolio

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Note: Historical graph reported by Danske Bank in 2017.

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Standards of accountability

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Employment contracts and employment law

The duties of members of Board as found in statutory law and internal procedures

Fitness and propriety

Civil liability (tort)

Criminal liability

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Involved persons and departments

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Baltic Banking/ International Banking

Executive Board

CEO

Board of Directors / Audit Committee

Estonian branch

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Danske Bank’s compliance and AML workJørn P. Jensen, Member of the Board of Directors of Danske Bank and Chairman of the Audit Committee

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We have taken a number of initiatives to address the problems in Estonia

The portfolio of non-resident customers wasclosed down by the end of 2015

New management across the Baltic countries

Independence of local control functions has beenstrengthened

The Baltic units have been transferred to the joint IT platform

In future, we will serve only subsidiaries of Nordic and international customers

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Initiatives to improve general efforts across the Group

1

2

3

Stronger compliance culture and more knowledge

Investments in more employee resources, new IT systems and stronger competencies

Stronger organisation and internal procedures

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In coming years, we will continue to improve our

efforts to combat financial crime

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Ongoing implementation of orders from the Danish FSA

New Chief Compliance

Officer to take up office

Group assessment of

management and

governance at the

branch in Estonia

New initiatives and

procedures to ensure

prompt investigation and

escalation of issues

Implementation of

Pillar II capital add-on

Integration of compliance

as a fundamental part of

the culture

Central unit at Group level to

ensure transparency and

completeness in our interaction

with the Danish FSA

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Disclaimer

Important Notice

This presentation reproduces statements from Bruun & Hjejle’s Report on the Non-Resident Portfolio at Danske Bank’s Estonian branch, dated 19 September 2018, to which we refer. In the event of any discrepancy or ambiguity, the report from Bruun & Hjejle takes precedence.

This presentation does not constitute or form part of and should not be construed as, an offer to sell or issue or the solicitation of an offer to buy or acquire securities of Danske Bank A/S in any jurisdiction, including the United States, or an inducement to enter into investment activity. No part of this presentation, nor the fact of its distribution, should form the basis of, or be relied on in connection with, any contract or commitment or investment decision whatsoever.

This presentation contains forward-looking statements that reflect management’s current views with respect to certain future events and potential financial performance. Although Danske Bank believes that the expectations reflected in such forward-looking statements are reasonable, no assurance can be given that such expectations will prove to have been correct. Accordingly, results could differ materially from those set out in the forward-looking statements as a result of various factors many of which are beyond Danske Bank’s control.

This presentation does not imply that Danske Bank has undertaken to revise these forward-looking statements, beyond what is required by applicable law or applicable stock exchange regulations if and when circumstances arise that will lead to changes compared to the date when these statements were provided.