Corporate social responsibility in Luminor

Sustainability in our core

Sustainability in our core

Luminor is determined to run our business and foster its growth in the Baltic region in a responsible, sustainable and caring manner by setting objectives for reaching positive impact on environment and society while developing financial products and openly disclosing achievements thereof by means of periodic reports and committing to support its customers in achieving their sustainability goals.

Luminor’s Sustainability Policy

In our activities we follow the guidance provided in Luminor’s Sustainability Policy (Summary statements and key principles are provided here), supported by other relevant policies, guidelines and procedures. The policy is effective from November 2021 and integrates the key regulatory requirements and recommendations.

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 Sustainability is mandated with the overall coordination of the field. In addition, we have defined the climate risk related accountabilities and decision bodies and documented in the Sustainability Policy.

Sustainability Report 2021

In 2021, we made great progress on our main sustainability focuses:

  • Responsible and CO2 neutral in our own operations.
  • Support the transition to low carbon economy.
  • Caring for issues in local societies – Estonia, Latvia, Lithuania.

We committed to aligning ourselves to Paris Climate Agreement and to carbon neutrality by 2050. We are the first in our home markets to have disclosed our financed emissions for our corporate lending portfolio.

Read more about our sustainability related activities and other ambitious targets in our first Luminor Sustainability Report 2021.

ESG Due Diligence Guidelines

We have ESG Due Diligence Guidelines in place that define the principles for due assessment and management of any negative impacts on society and environment that might be caused by our business activities. The statement on the ESG Due Diligence Guidelines providing a brief description of the established processes is published here.

Furthermore, we have established ESG Risk Assessment Guidelines that describe and integrate the assessment process of ESG risks of the legal entities into the existing overall creditworthiness assessment process.

ESG seminars in Luminor

In 2022, we are offering online seminars on various aspects of climate impact relevant to our business customers. Read further and register here.

Our responsible practices


Due to both increasing extreme weather incidents as well as the changing technology, regulatory framework and customer demand, the business environment is changing. Exposed to a possible climate related risk, our customers need to make smaller or larger changes to their operations and business models. People need to change their lifestyle, ways of working and consuming. If not adapting, they might face increasing costs and revenue decrease consequences, for some of them leading eventually to the existential challenges.

It is our objective to walk on this journey together with our customers and ensure that those, who are exposed to high climate, social or governance risks have a plan and a strategy in place to ensure their resilience. 

  • Sustainability policy: We have a Sustainability Policy in place that ensures the achievement of our ESG strategic aspirations
  • Exclusion list: We have defined our exclusion list in our Sustainability Policy.
  • Requirements for our vendors and suppliers: In all our contracts, we include our Third Party Code of Conduct that require the Third Parties to have a written environmental policy and environmental management system, if required by applicable regulations, that is appropriate to the size, nature and risks of the Third Party’s operations; we require them to implement an effective system to identify and minimize potential hazards to the environment.  
  • Transformation to low carbon economy

    Measuring emissions: We joined Partnership for Carbon Accounting Financials (PCAF) on 28.07.2021 and have implemented the accounting standard for GHG accounting of our financed projects´ and investments´ emissions. We expect to be able to disclose our emissions on Scope 1 (direct fuel use and waste generation), Scope 2 (electricity and heating use) and Scope 3 (influenced emissions such as supply chain emissions, business travel, employee commuting and our financed projects´ and investments´ emissions) in Q1 2022. 

    EU taxonomy: We are implementing EU taxonomy reporting and aim to disclose our EU taxonomy eligible portfolio in line with the regulatory expectations in the scope of our annual reporting.

    Sustainable finance: We are determined to build a green product portfolio to support the transition to low carbon economy. Currently, we offer credit for low emission cars, sustainable pillar 2 and 3 pension funds: Luminor Index Pension Fund Sustainable Future and sustainable exchange traded funds (ETFs) with morning star sustainability rating through our Luminor Investor platform. We are building sustainable investment services and products that support sustainable development of businesses and incentivize homeowners to invest in energy efficient housing.

    Environmental risk assessment: We perform an environmental and social impact assessment on the total consequences of large scale high environmental impact projects and customers.

    Sector strategies: We are analyzing the industry segments, where we have high climate and/or social risk exposure to the clients and are developing sector specific strategies that outline the key risks per sector and the mitigation actions that we would expect our customers to undertake. Furthermore, we are developing a series of seminars with a partner to build climate risk and transition related knowledge among our customers.    

Human rights

Employees and labor rights

We ensure gender-sensitive zero tolerance policy commitment towards all forms of gender-based discrimination in employment and occupation, including psychological harm and verbal, physical and sexual harassment.

  • This is supported by our Remuneration Policy and Base Salary Management Standard and internal processes, our recruitment and development practices and processes.
  • All our policies and processes are gender neutral.
  • We do our best to ensure health and safety for employees, clients and visitors. All internal and local regulations are ensured, including as described in the ILO conventions and the MNE Declaration. 
  • We require our third parties to ensure fair employment practices:

    Discrimination: The Third Party shall ensure fair treatment of employees.

    Freedom of Association: The Third Party shall respect the right of the Third Party’s employees to establish, join trade unions, and any other association of their choice.

    Prohibited Labour: The Third Party shall ensure that no forced labor or child labor is used.

    Working Conditions: The Third Party shall ensure that working conditions, hours and voluntary overtime are in accordance with the local regulation and industry practice, and that remuneration and benefits meet legally mandated minimums without unauthorized deductions.

    Health and Safety: The Third Party shall ensure a safe and healthy workplace for all employees, which is appropriately documented and implemented considering the  size, nature, and risks of the Third Party’s operations.

Corruption and financial crime

We are determined to fight financial crime, such as tax evasion or money laundering and to prevent financing of terrorism, breach or evasion of international sanctions and proliferation of weapons of mass destruction through any of our products, services or channels. To that end, we carefully follow area-specific legislation of our operating countries – Estonia, Latvia and Lithuania, as well as international best practices and have adopted policies to ensure that we:

  • Remain constantly alert to the risks we face in these areas and take proportionate and effective measures to mitigate them.
  • Know our customers and their beneficial owners properly and understand the purpose and intended nature of our business relationships.
  • Implement any international financial sanctions imposed by the United Nations, the European Union, Estonia, Latvia, Lithuania, Sweden, Norway, the United States or the United Kingdom without delay.
  • Participate in exchange of financial information within frameworks of US Foreign Account Tax Compliance Act (FATCA) and OECD Common Reporting Standard (CRS).
  • We find unacceptable offering, promising, giving and requiring, either directly or indirectly, bribes and other undue advantages in order to acquire and to maintain assignments and other undue advantages.
  • We do not involve ourselves in business relationships, which directly or indirectly enable bribery and corruption.
  • Luminor enters arrangements with business partners that share the same values and principles on prevention of bribery and corruption. We expect that our business partners apply the same principles of responsible business conduct as Luminor, which are defined in Luminor’s Third Party´s confirmation to the code of responsible business conduct.

    We expect that our third parties shall act in an ethical, fair, and professional manner in all contact with Luminor.

    We expect that our third parties shall comply with all applicable laws and regulations concerning anti-bribery, anti-corruption, fraud, and any other prohibited business practices.

    We expect that our third parties confirm to comply with applicable laws and regulations concerning bribery, corruption, fraud and any other prohibited business practices.
  • We have mandatory trainings for all employees about anti money laundering, financial crime, corruption, gifts and events. We have set up a gifts and events registry and we have practical principles in place to receive notifications from law enforcement agencies if a suspicion arises that any of our local Baltic employees is guilty of corruption.  
  • We do not support tax evasion and have integrated tax as part of our exclusion list in our Sustainability Policy. 
  • Luminor is an organization that values responsibility and integrity and adheres to the highest ethical standards in its business operations. We have a Raise Your Concern channel in place, through which both employees and customers can report their concerns confidentially and with the knowledge, that the reports will be taken seriously. In addition to our external Raise Your Concern form our customers may also use third party reporting tools and whistleblowing procedures, such as those provided by local Banking Associations or supervisory authorities. Read further on our Raise Your Concern page. 

Further information on combating money laundering and terrorism financing can be found here.

Customer privacy, data security and complaints

  • Customer privacy and data security
  • Complaints and feedback handling
  • We take data protection and the storage and processing of customer data and information in the course of business very seriously. It is important to us that the customer feels safe. The information we provide on our website is designed to help the customer to exercise their individual rights and to provide a quick and satisfactory resolution, as well as explaining how to make a complaint if this is unsuccessful.
     Information Security Protection

Caring for Baltic issues

We aim to contribute to the local Baltic communities through community investment, through active engagement with organizations  for Baltic issues and through promotion and support of social entrepreneurship in the Baltics. We aim to do that by dedicated product and service solutions aligned to our existing capabilities and educational and awareness-raising cooperation projects such as financial and digital literacy and other education or social entrepreneurship promotion programs. 

Information on upcoming partnerships will be published here in January, 2022.