GrønlandsBANKEN A/S : » Corporate Governance Statement 2022

Form for reporting on the recommendations on corporate governance

The BANK of

Greenland

Template for reporting - version of January 2021

"Comply or explain"

Section 107 b of the Danish Financial Statements Act states that a company that has shares admitted to trading on a regulated market must

include a report on corporate governance in the management's review.

This means that the BANK of Greenland must state which recommendations the company has chosen to comply with or deviate from. A company's report must relate separately to each recommendation, regardless of whether a recommendation is complied with or deviated from.

Under Section 107 b(1) para (3) of the Financial Statements Act, the BANK of Greenland must explain the reasons if the Bank has decided to deviate from the recommendations. The BANK of Greenland must state why it has chosen not to comply with a recommendation and what it has chosen to do instead.

This means that if the Bank does not comply with a recommendation, but explains why and how the Bank has taken a different approach, the company will be deemed to comply with the recommendation.

The reporting must reflect the current management form at the time of the presentation of the financial statements. In the event of significant changes during the year, or after the balance sheet date, descriptions of the changes should be included in the corporate governance report.

It is important that the Bank considers and reports on each individual recommendation, so that it is clear to investors and other stakeholders how the Bank relates to the individual recommendations.

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The report concerns the accounting period from 01.01.2022 to 31.12.2022

Recommendation	The company complies	The company explains1

Why?How?

1. Interaction with the company's shareholders, investors and other stakeholders

1.1. Communication with the company's shareholders, investors and other stakeholders

1.1.1. The Committee recommends that the management through	The Bank's material for shareholders
ongoing dialogue and interaction ensures that shareholders, investors	can be found on the BANK of
and other stakeholders gain the relevant insight into the company's	Greenland's website.
affairs, while also giving the board of directors the opportunity to hear	The Executive Management also
and include their views in its work.	responds to shareholder enquiries.
	The strategy plan is the Bank's
1.1.2. The Committee recommends that the company adopts policies on	guidelines for its relationship with
its stakeholders. Furthermore, a
the company's relationships with its shareholders, investors and if	communication strategy and
relevant other stakeholders in order to ensure that the various interests	investor relations policy, as well as a
are included in the company's considerations and that such policies are	CSR policy, have been adopted,
made available on the company's website.	which also involves the Bank's
	investors and other stakeholders.

1 If a recommendation is not complied with, the company must explain why the recommendation is not complied with and how the company has taken a different approach. An adequate explanation answers both questions and categorises the answer as compliance with the recommendation. It is therefore important that the company answers both questions in its explanation.

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	Recommendation		The company complies		The company explains1
					Why?	How?
	1.1.3. The Committee recommends that the company publishes		The Bank publishes quarterly
		reports in accordance with its
	quarterly reports.
		financial calendar.
	1.2. The general meeting
	1.2.1. The Committee recommends that the board of directors organises		The Bank has established an
	the company's general meeting in a manner that allows shareholders,		investor portal as an opportunity to
	who are unable to attend the meeting in person or are represented by		attend the annual general meeting
	proxy at the general meeting, to vote and raise questions to the		via webcast or another digital
	management prior to or at the general meeting. The Committee		solution and thus make the investor
	recommends that the board of directors ensures that shareholders can		able to vote and ask questions.
	observe the general meeting via webcast or other digital transmission.
	1.2.2. The Committee recommends that proxies and postal votes to be		On the Bank' proxy vote form,
	used at the general meeting enable the shareholders to consider each		shareholders may consider each
	individual item on the agenda.		item on the agenda.
	1.3. Takeover bids
	1.3.1. The Committee recommends that the company has a procedure		Takeover bids will be presented to
	in place in the event of takeover bids, containing a "road map" covering		the shareholders. The Board of
	matters for the board of directors to consider in the event of a takeover		Directors will be informed of the
	bid, or if the board of directors obtains reasonable grounds to suspect		formal content and, depending on
	that a takeover bid may be submitted. In addition, it is recommended		the content of the bid, the Bank will
	that the procedure states that the board of directors shall abstain from		consult external advisers. Without
	countering any takeover bids by taking actions that seek to prevent the		the approval of the general meeting,
	shareholders from deciding on the takeover bid, without the approval of		the Board of Directors will not seek
	the general meeting.		to accommodate a takeover bid.

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	Recommendation			The company complies		The company explains1
									Why?	How?
	1.4. Corporate Social Responsibility
	1.4.1. The Committee recommends that the board of directors adopts a			The BANK of Greenland has
	policy for the company's corporate social responsibility, including social			established a CSR (corporate social
	responsibility and sustainability, and that the policy is available in the			responsibility)	policy, which	is
	management's report and/or on the company's website. The Committee			described	in	the management's
	recommends that the board of directors ensures compliance with the			review. The material is also
	policy.			available at the Bank's website.
	1.4.2. The Committee recommends that the board of directors adopts a			The BANK of Greenland has a tax
			policy which can be found at the
	tax policy to be made available on the company's website.
			Bank's website.
	2. The duties and responsibilities of the board of directors
	2.1 Overall tasks and responsibilities
				Among other things, the Board of
				Directors adopts a strategy for the
				Bank and a business model that is
	2.1.1. The Committee recommends that the board of directors in			based on the Bank's mission, vision
	support of the company's statutory objects according to its articles of			and values, as well as a policy for a
	association and the long-term value creation considers the company's			sound corporate culture. The Bank's
	purpose and ensures and promotes a good culture and sound values in			management's review describes the
	the company. The company should provide an account thereof in the			Bank's efforts to promote long-term
	management commentary and/or on the company's website.			value creation and the Bank's
				values,	sustainability,	CSR
				initiatives, and the Bank's social
				responsibility.
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Template for reporting - version of January 2021