Corporate Governance Report 2016 The Nykredit Group...Nykredit's shares are not listed on NASDAQ OMX...

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Corporate Governance Report

2016

The Nykredit Group

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Corporate Governance in Nykredit

The Nykredit Group (hereinafter "Nykredit") carries on financial business through Nykredit Realkredit A/S and the wholly-owned subsidiaries Totalkredit A/S and Nykredit Bank A/S as well as the latter's wholly-owned subsidiary Nykredit Portefølje Administration A/S.

Nykredit Realkredit A/S is wholly owned by Nykredit Holding A/S, the shareholders of which are Foreningen Nykredit

(89.8%), Østifterne f.m.b.a. (3.25%), Industriens Fond (4.7%), and PRAS A/S (2.25%). The ultimate authority of Foreningen Nykredit is the Committee of Representatives, which is composed of up to 100 representatives who are elected by the borrowers and bondholders of Nykredit Realkredit A/S.

Nykredit's shares are not listed on NASDAQ OMX Copenhagen. Therefore, the Recommendations on Corporate Govern-

ance from May 2013 (hereinafter the "Recommendations"), last revised by the Committee on Corporate Governance in November 2014, are not directly applicable to Nykredit.

However, Nykredit decided already in 2002 that, given the adjustments following from the Group's special ownership and corporate structure, it should act as a listed company for external purposes, operating on sound business terms and

taking into consideration the Recommendations.

The Managerial Code of Conduct of November 2013 of the Danish Bankers Association integrates and supplements the Recommendations and applies to Nykredit Bank A/S as a bank. Nykredit has furthermore decided that all the financial companies of the Group must address and adhere to the Code of Conduct where relevant.

This implies that the financial companies of the Nykredit Group take into consideration both the Recommendations on

Corporate Governance and the Managerial Code of Conduct. The Recommendations as well as the Managerial Code of Conduct imply that Nykredit must explain how it addresses the Recommendations and the Managerial Code of Conduct, in accordance with the "comply-or-explain" principle, ie Nykredit may either comply with the Recommendations/Mana-

gerial Code of Conduct or opt not to comply and instead explain the reason why.

To ensure suitable risk management across the Group and optimum resource utilisation, various overall objectives,

policies, etc are determined at Group level.

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Owing to Nykredit's corporate structure, a number of decision-making and reporting processes, etc in Nykredit Bank A/S, Totalkredit A/S and Nykredit Portefølje Administration A/S are carried out at Group level.

The report below is divided into a section about the Recommendations and a section about the Managerial code of conduct. The report concerns all the financial companies of the Nykredit Group unless otherwise stated.

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A. Report concerning Recommendations on Corporate Governance for the financial year 2016

Recommendation

1.1.1. The Committee recommends that the board of directors ensure

ongoing dialogue between the company and its shareholders in order for

the shareholders to gain relevant insight into the company’s potential and

policies, and in order for the board of directors to be aware of the share-

holders’ views, interests and opinions on the company.

Nykredit complies with the recommendation.

The members of the Board of Directors of Nykredit Holding A/S are

recommended for election by the Boards of Directors of Foreningen

Nykredit (main shareholder) and two of the other three sharehold-

ers, and the Board of Directors of Nykredit Realkredit A/S is elected

by Nykredit Holding A/S. The Board of Directors of Foreningen

Nykredit is elected by and among the Committee of Representa-

tives of Foreningen Nykredit, which is composed of representatives

of customers having loans with Nykredit Realkredit A/S, customers

having loans with Totalkredit A/S who have become members of

Foreningen Nykredit, and customers of Nykredit Bank A/S with total

facilities of at least DKK 50,000 as well as representatives of bond-

holders.

The small number of shareholders creates a good setting for an ac-

tive dialogue between the members, owners and Group Manage-

ment.

1.1.2. The Committee recommends that the board of directors adopt poli-

cies on the company’s relationship with its stakeholders, including share-

holders and other investors, and that the board ensures that the interests

of the shareholders are respected in accordance with company policies.


Nykredit has adopted a stakeholder policy on its conduct in relation

to its stakeholders both in- and outside the Group. This includes in-

formation on Nykredit's business concept, values and business ob-

jectives. The stakeholder policy is available at www.nykredit.dk.

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Recommendation

In addition, Nykredit is dedicated to strengthening the Group's rela-

tions with its stakeholders, which includes efforts to gain more in-

sight into stakeholder demands, expectations and interaction vis-à-

vis Nykredit. One way of doing this is through Nykredit's non-finan-

cial report, "Nykredit – Engaging with Society" and a CR fact book,

which is published together with the Annual Report.

1.1.3. The Committee recommends that the company publish quarterly

reports.


1.2.1. The Committee recommends that, when organising the company’s

general meeting, the board of directors plan the meeting to support active

ownership.


General meetings are planned taking into consideration the gener-

ally close dialogue of the narrow group of owners.

In contrast to the other companies of the Group, which are wholly-

owned subsidiaries, the Board of Directors of the Group are repre-

sented on the Boards of Directors of such subsidiaries, and there-

fore the general meetings of such companies are more formal.

1.2.2. The Committee recommends that proxies granted for the general

meeting allow shareholders to consider each individual item on the

agenda.


1.3.1. The Committee recommends that the company set up contingency

procedures in the event of takeover bids from the time that the board of

directors has reason to believe that a takeover bid will be made. Accord-

ing to such contingency procedures, the board of directors should not

without the acceptance of the general meeting, attempt to counter the

takeover bid by making decisions which in reality prevent the sharehold-

ers from deciding on the takeover bid themselves.

Nykredit does not comply with the recommendation.

The recommendation is not relevant due to the current ownership

structure of the Nykredit Group. In connection with a stock ex-

change listing of Nykredit, such contingency procedures will be es-

tablished.

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Recommendation

2.1.1. The Committee recommends that at least once a year the board of

directors take a position on the matters related to the board’s perfor-

mance of its responsibilities.


At least once a year, each company of the Nykredit Group will re-

view, evaluate and revise (where relevant) the business model of

the company in which the respective Boards of Directors take a po-

sition on the matters related to the Board's performance of its re-

sponsibilities.


directors take a position on the overall strategy of the company with a

view to ensuring value creation in the company.


At least once a year, each financial company of the Nykredit Group

will review, evaluate and revise (where relevant) the business

model of the company in which the respective Boards of Directors

take a position on the matters related to the overall strategy of the

company.

2.1.3. The Committee recommends that the board of directors ensure that

the company has a capital and share structure ensuring that the strategy

and long-term value creation of the company are in the best interest of

the shareholders and the company, and that the board of directors pre-

sents this in the management commentary on the company’s annual re-

port and/or on the company’s website.


Nykredit has arranged its capital structure so as to comply with reg-

ulatory requirements at any time and with a view to maintaining

lending activities regardless of economic trends, while retaining a

competitive rating.

A report is given in the Annual Report and at www.nykredit.dk.

2.1.4. The Committee recommends that the board of directors annually

review and approve guidelines for the executive board; this includes es-

tablishing requirements for the executive board on timely, accurate and

adequate reporting to the board of directors.


The Boards of Directors' guidelines for the respective Executive

Boards are determined primarily through the rules of procedure of

the Executive Board, as well as a number of policies with accompa-

nying guidelines.

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Recommendation


directors discuss the composition of the executive board, as well as devel-

opments, risks and succession plans.


Evaluated as part of the business model for each financial company

and discussed regularly by the Nomination Board.

2.1.6. The Committee recommends that once a year the board of directors

discuss the company’s activities to ensure relevant diversity at manage-

ment levels, including setting specific goals and accounting for its objec-

tives and progress made in achieving the objectives in the management

commentary on the company’s annual report and/or on the website of the

company.


Nykredit has adopted a diversity policy and set defined targets for

the number of women in the Board of Directors and at other top

management levels.

The targets and current situation appear from the Annual Report,

the CR fact book and www.nykredit.dk.

2.2.1. The Committee recommends that the board of directors adopt poli-

cies on corporate social responsibility.


Nykredit has adopted a policy on corporate social responsibility

which is available at www.nykredit.dk. In 2008 Nykredit adopted

the UN Global Compact, a programme for sustainable conduct.

Nykredit has also prepared a climate and environment strategy

2020.

The topic is mentioned in "Nykredit – Engaging with Society" and a

CR fact book, which is also available at www.nykredit.dk.

2.3.1. The Committee recommends appointing a vice-chairman of the

board of directors who will assume the responsibilities of the chairman in


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Recommendation

the event of the chairman’s absence, and who will also act as effective

sparring partner for the chairman.

2.3.2. The Committee recommends ensuring that, if the board of direc-

tors, in exceptional cases, asks the chairman of the board of directors to

perform special operating activities for the company, including briefly par-

ticipating in the day-to-day management, a board resolution to that effect

be passed to ensure that the board of directors maintains its independent,

overall management and control function. Resolutions on the chairman’s

participation in day-to-day management and the expected duration hereof

should be published in a company announcement.


The Boards of Directors of the financial subsidiary companies are

composed of Executive Board members and executive staff of

Nykredit who perform tasks for several Group companies as part of

their jobs.

3.1.1. The Committee recommends that the board of directors annually

accounts for

• the skills it must have to best perform its tasks,

• the composition of the board of directors, and

• the special skills of each member.


The Boards of Directors are the supreme management bodies of the

financial companies, which make decisions of a strategic and funda-

mental nature. The Boards of Directors should be composed of a

group of persons who together will best serve the interests of the

respective Group companies with due regard for all stakeholders of

the companies.

At least once a year, each financial company of the Nykredit Group

will review, evaluate and revise (where relevant) the business

model of the company in which the respective Boards of Directors

decides which skills the board requires to perform its tasks as well

as the composition of the Board of Directors and skills of each

member.

The composition of the Boards of Directors and the special skills and

experience of each board member are outlined at www.nykredit.dk

and in the Management's Review in the Annual Report.

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Recommendation

3.1.2. The Committee recommends that the selection and nomination of

candidates for the board of directors be carried out through a thorough

and transparent process approved by the overall board of directors. When

assessing its composition and nominating new candidates, the board of di-

rectors must take into consideration the need for integration of new talent

and diversity in relation to age, international experience and gender.


In addition to the professional skills mentioned in para 3.1.1, the

composition and recruitment of board members take into account

personal skills and diversity.

The selection and nomination of candidates for the Board of Direc-

tors of Nykredit Bank A/S, Totalkredit A/S and Nykredit Portefølje

Administration A/S have been adapted to the fact that the compa-

nies are wholly-owned subsidiaries, and to take into account the

special partnership model in Totalkredit A/S.

3.1.3. The Committee recommends that a description of the nominated

candidates’ qualifications, including information about the candidates’

• other executive functions, e.g. memberships in executive boards, boards

of directors, and supervisory boards, including board committees in for-

eign enterprises, be accompanied by the notice convening the general

meeting when election of members to the board of directors is on the

agenda

• demanding organisational tasks, and information

• about whether candidates to the board of directors are considered inde-

pendent.


3.1.4. The Committee recommends that the company’s articles of associa-

tion stipulate a retirement age for members of the board of directors.

Nykredit partially complies with the recommendation.

The Articles of Association of Nykredit's financial companies do not

stipulate a retirement age for members of the Boards of Directors.

In practice, a retirement age applies to the five board members of

Nykredit Realkredit A/S elected by the General Meeting, who are also

members of the Board of Directors of Foreningen Nykredit, as the

Articles of Association of Foreningen Nykredit stipulate a maximum

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Recommendation

age for election to the Committee of Representatives which implies

that board members resign at the age of 66-70 years at the latest.

It is regularly discussed whether such age limit should be included in

the Articles of Association. However, so far it has been decided not

to set such age limit to avoid excluding candidates with relevant ex-

perience. The evaluation of board members ensures that the mem-

bers are qualified. The evaluation includes age.

3.1.5. The Committee recommends that that members of the board of di-

rectors elected by the general meeting be up for election every year at the

annual general meeting.


3.2.1. The Committee recommends that at least half of the members of

the board of directors elected by the general meeting be independent per-

sons, in order for the board of directors to be able to act independently of

special interests.

To be considered independent, this person may not:

• be or within the past five years have been member of the executive

board, or senior staff member in the company, a subsidiary undertaking

or an associate,

• within the past five years, have received larger emoluments from the

company/group, a subsidiary undertaking or an associate in another ca-

pacity than as member of the board of directors,

• represent the interests of a controlling shareholder,

• within the past year, have had significant business relations (e.g. per-

sonal or indirectly as partner or employee, shareholder, customer, sup-


It has been standard practice at Nykredit that eight out of nine mem-

bers of the Board of Directors of Foreningen Nykredit elected by the

Committee of Representatives are also elected for the Boards of Di-

rectors of Nykredit Holding A/S and Nykredit Realkredit A/S and that

the last two members of the Board of Directors of Nykredit Realkredit

A/S elected by the General Meeting are also members of the Board

of Directors of Nykredit Holding A/S. This practice was changed in

2016, and currently only five (of eight) members of Foreningen

Nykredit's Board of Directors elected by the General Meeting are now

also appointed to the Boards of Directors of Nykredit Holding A/S and

Nykredit Realkredit A/S.

The recommendation is not relevant to the wholly-owned financial

subsidiaries whose Boards of Directors as a natural consequence of

the Group structure are composed of members of the Executive

Board and executive staff members of Nykredit.

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Recommendation

plier or member of the executive management in companies with corre-

sponding connection) with the company, a subsidiary undertaking or an

associate,

• be or within the past three years have been employed or partner at the

external auditor,

• have been chief executive in a company holding cross-memberships

with the company,

• have been member of the board of directors for more than 12 years, or

• have been close relatives with persons who are not considered inde-

pendent.

3.3.1. The Committee recommends that each member of the board of di-

rectors assesses the expected time commitment for each function in order

that the member does not take on more functions than he/she can man-

age satisfactorily for the company.


As a SIFI institution, the board members of the Group are generally

subject to special limitations with regard to the number of execu-

tive posts. A board member may thus serve on (i) one Executive

Board combined with two directorships or (ii) four directorships,

unless an exemption is granted by the Danish Financial Supervisory

Authority.

3.3.2. The Committee recommends that the management commentary, in

addition to the provisions laid down by legislation, includes the following

information about the members of the board of directors:

• the position of the relevant person,

• the age and gender of the relevant person,

• whether the member is considered independent,

• the date of appointment to the board of directors of the member,


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Recommendation

• expiry of the current election period,

• other executive functions, e.g. memberships in executive boards, boards

of directors, and supervisory boards, including board committees in for-

eign enterprises and

• demanding organisational tasks, and

• the number of shares, options, warrants and similar in the company,

and other group companies of the company, owned by the member, as

well as changes in the portfolio of the member of the securities mentioned

which have occurred during the financial year.

3.4.1. The Committee recommends that the company publish the follow-

ing on the company's website:

• the terms of reference of the board committees,

• the most important activities of the committees during the year, and the

number of meetings held by each committee, and

• the names of the members of each committee, including the chairmen of

the committees, as well as information on which members are independ-

ent members and which members have special qualifications.


Nykredit has set up an Audit Board, a Remuneration Board, a Nom-

ination Board and a Risk Board.

Detailed information on the boards is available at www.nykredit.dk.

3.4.2. The Committee recommends that a majority of the members of a

board committee be independent.

Nykredit partially complies with the recommendation.

Two out of three members of the Remuneration Board and the

Nomination Board are considered independent (added to this one

staff-elected board member is represented on the Remuneration

Board), while two out of four members of the Audit Board and the

Risk Board (in 2016) are also members of the Board of Directors of

Foreningen Nykredit.

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Recommendation

3.4.3. The Committee recommends that the board of directors set up a

formal audit committee composed such that

• the chairman of the board of directors is not chairman of the audit com-

mittee, and

• between them, the members should possess such expertise and experi-

ence as to provide an updated insight into and experience in the financial,

accounting and audit aspects of companies whose shares are admitted to

trading on a regulated market.


3.4.4. The Committee recommends that, prior to the approval of the an-

nual report and other financial reports, the audit committee monitors and

reports to the board of directors about:

• significant accounting policies,

• significant accounting estimates,

• related party transactions, and

• uncertainties and risks, including in relation to the outlook for the cur-

rent year.


3.4.5. The Committee recommends that the audit committee:

• annually assesses the need for an internal audit, and in such case,

makes recommendations on selecting, appointing and removing the head

of the internal audit function and on the budget of the internal audit func-

tion, and

• monitor the executive board's follow-up on the conclusions and recom-

mendations of the internal audit function.


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Recommendation

3.4.6. The Committee recommends that the board of directors establish a

nomination committee chaired by the chairman of the board of directors

with at least the following preparatory tasks:

• describe the qualifications required by the board of directors and the ex-

ecutive board, and for a specific membership, state the time expected to

be spent on having to carry out the membership, as well as assess the

competences, knowledge and experience of the two governing bodies

combined,

• annually assess the structure, size, composition and results of the board

of directors and the executive board, as well as recommend any changes

to the board of directors,

• annually assess the competences, knowledge and experience of the indi-

vidual members of management, and report to the board of directors in

this respect,

• consider proposals from relevant persons, including shareholders and

members of the board of directors and the executive board for candidates

for the board of directors and the executive board, and

• propose an action plan to the board of directors on the future composi-

tion of the board of directors, including proposals for specific changes.


3.4.7. The Committee recommends that the board of directors establish a

remuneration committee with at least the following preparatory tasks:

• to recommend the remuneration policy (including the general guidelines

for incentive-based remuneration) to the board of directors and the exec-

utive board for approval by the board of directors prior to approval by the

general meeting,


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Recommendation

• make proposals to the board of directors on remuneration for members

of the board of directors and the executive board, as well as ensure that

the remuneration is in compliance with the company’s remuneration policy

and the assessment of the performance of the persons concerned. The

committee should have information about the total amount of remunera-

tion that members of the board of directors and the executive board re-

ceive from other companies in the group, and

• recommend a remuneration policy applicable for the company in gen-

eral.

3.4.8. The Committee recommends that the remuneration committee do

not consult with the same external advisers as the executive board of the

company.


3.5.1. The Committee recommends that the board of directors establish

an evaluation procedure where contributions and results of the board of

directors and the individual members, as well as collaboration with the ex-

ecutive board are annually evaluated. Significant changes deriving from

the evaluation should be included in the management commentary or on

the company's website.


3.5.2. The Committee recommends that in connection with preparation of

the general meeting, the board of directors consider whether the number

of members is appropriate in relation to the requirements of the company.

This should help ensure a constructive debate and an effective decision-

making process in which all members are given the opportunity to partici-

pate actively.


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Recommendation

3.5.3. The Committee recommends that at least once every year the

board of directors evaluate the work and performance of the executive

board in accordance with predefined clear criteria.


3.5.4. The Committee recommends that the executive board and the

board of directors establish a procedure according to which their coopera-

tion is evaluated annually through a formalised dialogue between the

chairman of the board of directors and the chief executive officer and that

the outcome of the evaluation be presented to the board of directors.


4.1.1. The Committee recommends that the board of directors prepare a

clear and transparent remuneration policy for the board of directors and

the executive board, including

• a detailed description of the components of the remuneration

for members of the board of directors and the executive board,

• the reasons for choosing the individual components of the remuneration,

and

• a description of the criteria on which the balance between the individual

components of the remuneration is based.

The remuneration policy should be approved by the general meeting and

published on the company’s website.


Nykredit's remuneration policy complies with the detailed require-

ments of financial legislation.

Reference is made to www.nykredit.dk.

4.1.2. that, if the remuneration policy includes variable components,

• limits be set on the variable components of the total remuneration pack-

age,


Nykredit's remuneration policy complies with the detailed require-

ments of financial legislation.

Reference is made to www.nykredit.dk.

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Recommendation

• a reasonable and balanced linkage be ensured between remuneration

for governing body members, expected risks and the value creation for

shareholders in the short and long terms,

• there be clarity about performance criteria and measurability for award

of variable components,

• there be criteria ensuring that qualifying periods for variable compo-

nents in remuneration agreements are longer than one calendar year, and

• an agreement be made which, in exceptional cases, entitles the com-

pany to reclaim in full or in part variable components of remuneration that

were paid on the basis of data, which proved to be misstated.

4.1.3. The Committee recommends that remuneration of members of the

board of directors does not include share options.


4.1.4. The Committee recommends that if share-based remuneration is

provided, such programmes be established as roll-over programmes, i.e.

the options are granted periodically and should have a maturity of at least

three years from the date of allocation.


4.1.5. The Committee recommends that agreements on termination pay-

ments should not amount to more than two years’ annual remuneration.


4.2.1. The Committee recommends that the company’s remuneration pol-

icy and compliance with this policy be explained and justified annually in

the chairman's statement at the company’s general meeting.


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Recommendation

4.2.2. The Committee recommends that the proposed remuneration for

the board of directors for the current financial year be approved by the

shareholders at the general meeting.


4.2.3. The Committee recommends that the total remuneration granted to

each member of the board of directors and the executive board by the

company and other companies in the group, including information on the

most important contents of retention and retirement/resignation schemes,

be disclosed in the annual report and that the linkage with the remunera-

tion policy be explained.


5.1.1. The Committee recommends that the board of directors in the

management commentary review and account for the most important

strategic and business-related risks, risks in connection with the financial

reporting as well as for the

company’s risk management.


5.2.1. The Committee recommends that the board of directors decide

whether to establish a whistle-blower scheme for expedient and confiden-

tial notification of possible or suspected wrongdoing.


In 2014 Nykredit set up a whistleblower scheme to counter viola-

tions of financial legislation.

5.3.1. The Committee recommends that the board of directors ensure reg-

ular dialogue and exchange of information between the auditor and the

board of directors, including that the board of directors and the audit com-

mittee at least once a year meet with the auditor without the executive

board present. This also applies to the internal auditor, if any.


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Recommendation

5.3.2. The Committee recommends that the audit agreement and audi-

tors' fee be agreed between the board of directors and the auditor on the

basis of a recommendation from the audit committee.


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B. Report concerning the managerial code of conduct of the Danish Bankers Association for the financial year 2016

Recommendation

GENERAL RECOMMENDATIONS

1. The Association recommends that member companies address all

recommendations of the Committee on Corporate Governance.


Reference is made to section A with the Nykredit Group's statement

with regard to the Recommendations by the Committee on Corpo-

rate Governance.

2. The Association recommends that member companies prepare and

publish a code of conduct describing corporate values and the de-

sired conduct in respect of operation and management.


The companies of the Nykredit Group operate according to

Nykredit's corporate values and code of conduct.

RECOMMENDATIONS CONCERNING THE COMPOSITION OF THE BOARD

OF DIRECTORS

3. The Association recommends that member companies apply a

specified and structured process when recruiting candidates for the

board of directors and possibly include external competences.


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Recommendation

4. The Association recommends that member companies whose arti-

cles of association stipulate that members of the board of directors

may only be elected among a restricted group of persons account

for the basis of such restrictions.


The Articles of Association of the Nykredit Group contain no such

restrictions.

RECOMMENDATIONS CONCERNING TRAINING OF MEMBERS OF THE

BOARD OF DIRECTORS

5. The Association recommends that commence a training programme

in banking as soon as possible and not later than six months after

joining the board unless they already possess updated and specific

banking skills. The programme should reflect the size, business

model and complexity of the company.

The recommendation complies with the adjustments in the Execu-

tive Order on basic training for members of the board of directors

of banks, mortgage banks and insurance companies.

6. The Association recommends that members of the board of direc-

tors regularly participate in competency development of relevance

to their directorship. The subjects and scope should be adapted to

the size, business model and complexity of the company.


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Recommendation

RECOMMENDATIONS CONCERNING EVALUATION OF THE BOARD OF

DIRECTORS AND BOARD MEMBERS

7. The Association recommends that each individual board member an-

nually evaluates his or her work on the board of directors. As part of

the evaluation, the board members should fill in an evaluation form

that contains both managerial and banking-related topics.


RECOMMENDATIONS CONCERNING COOPERATION WITH THE DAY-TO-

DAY MANAGEMENT OF THE COMPANY

8. The Association recommends that relevant specialists be involved in

the cooperation with the board of directors and that they attend board

meetings when particularly complex issues are discussed.


9. The Association recommends that the cooperation between the ex-

ecutive board and the board of directors be discussed at a meeting

of the board of directors at least once a year. The executive board

should not be present during such discussions.


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Recommendation

OTHER RECOMMENDATIONS

10. The Association recommends that member companies publish on

their website or in a similar way a list of the attendance of board

members at board and committee meetings.


Lists of attendance of board and committee meetings in Nykredit

Realkredit A/S are published.

11. The Association recommends that member companies consider the

rules on limits to directorships laid down in the Danish Financial

Business Act.


12. The Association recommends that member companies focus on the

role of the external auditors and the quality of their services. Me-

member companies should set forth demands as to the composi-

tion of the teams of external auditors to ensure that a team in-

cludes at least two experienced auditors with complementary skills.

To be an experienced auditor, an auditor must have completed

supplementary training in the field of banking and have partici-

pated in the auditing of a bank, savings bank or cooperative bank

for at least three years.


Corporate Governance Report 2016 The Nykredit Group...Nykredit's shares are not listed on NASDAQ OMX...

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