Due diligence for the Norwegian Transparency Act - SEB Kort AB Oslofilialen
SEB Kort Bank AB ("SEB Kort") is a financial company established in Sweden and a wholly owned subsidiary of Skandinaviska Enskilda Banken AB (publ.) (“SEB”) and part of the SEB Group. Together with the German subsidiary AirPlus International GmbH, SEB Kort operations are located in both the Nordic region and Europe. This report applies solely to SEB Kort, as AirPlus and SEB Kort continue to operate as separate legal entities until August 3rd, 2026.
SEB Kort has branches in Norway, Denmark, and Finland, i.e., SEB Kort Bank AB, Oslofilialen NUF (“SEB Kort Oslofilialen”), SEB Kort Bank Danmark, filial of SEB Kort Bank AB, and SEB Kort Bank AB, Helsinki branch.
SEB Kort is a large issuer of Mastercard cards, with a focus on the Nordic market. SEB Kort issues cards under its own brands and under Co brands in cooperation with around 20 partners in various industries. SEB Kort provides both Corporate and Private customers with payment solution products and services. SEB Kort’s customers are mostly located in the Nordic countries and are active within several different industries and sectors.
SEB Kort Oslofilialen issues cards to Norwegian consumers and to Norwegian companies and public enterprises for use by their employees. SEB Kort is considered a large enterprise, and since SEB Kort conducts business in Norway and has a seat in Norway, it is SEB Kort Oslofilialen that is subject to the Norwegian Transparency Act (the “Act”).
This due diligence report includes SEB Kort Oslofilialen’ assessment of compliance with human rights and decent working conditions according to the requirements of the Act. According to the Act, companies shall perform the due diligence assessment in line with the OECD Guidelines for Multinational Enterprises. As the Act covers SEB Kort Oslofilialen’ business and cooperation with suppliers and business partners in Norway, the due diligence report will only cover suppliers and business partners that have a connection to the SEB Kort’ Norwegian business. Suppliers or business partners that only conduct business with SEB Kort in another country will be excluded from the scope of this report. The report also covers SEB Kort Oslofilialen’s customers, SEB Kort’ guidelines related to human rights and decent working conditions, and how SEB Kort Oslofilialen plans to implement changes as a result of the due diligence risk assessments.
SEB has issued comprehensive instructions and regulations for the organizational structure of the company, as well as guidelines for managing environmental, social and governance aspects of SEB Group’s operations, including routines for ensuring that fundamental human rights and decent working conditions are observed. All relevant instructions, policies and guidelines issued at SEB Group level are also applicable to SEB Kort and form an integral part of SEB Kort’s governance framework and compliance with the Act.
SEB Group’s work is based on the following global initiatives to which the Group is committed:
- Universal Declaration of Human Rights
- ILO Core Conventions on Labour Standards
- UN Global Compact
- UN Guiding Principles on Business and Human Rights
- OECD Guidelines for Multinational Enterprises
- Children’s Rights and Business Principles
SEB is part of the Swedish Financial Coalition against Commercial Sexual Exploitation of Children which seeks to prevent and obstruct payments for child abuse through the Swedish financial system.
Due diligence is conducted to identify actual and potential adverse impacts on human rights and decent working conditions that the enterprise may cause, contribute to, or be directly linked to. Such impacts may occur through its operations, products or services, including via the supply chain and business partners. According to the act the enterprise must then address these adverse impacts and track the results of implemented measures. Due diligence should be carried out regularly and is an ongoing and iterative process that must be constantly evaluated. The due diligence is proportional and risk based.
As a bank, SEB has the ability to promote human rights, for example by financing social infrastructure and engaging in responsible lending. SEB recognises the social and human rights challenges that the world faces and the negative effects that companies can have. Human rights considerations, including a due diligence process, are described in the Social and Human Rights Policy as well as in the bank’s sector policies, which also clarifies areas exempted from policy application. Human rights are considered in main processes of the bank such as lending, investments and procurement, taking a risk-based approach. In sectors with potential negative human rights risks, SEB expects large corporate customers to have appropriate labour and human rights due diligence processes in relation to the risks.
SEB Kort has customers in several different sectors, where some of the sectors are facing challenges and risks connected to human rights. The customers are generally located in the Nordics but some of the products and services can, in specific cases, also be provided to the Nordic customers’ employees in approved countries in Europe.
SEB Kort has many customers, which increases the risk of encountering counterparties that are not aligned with laws and regulations or the policies that are set out for SEB Group. Several processes are therefore in place in different parts of the organization to mitigate these risks. One of these processes defines how SEB Kort works with sustainability as well as human rights in connection with the customers.
A yearly sustainability assessment process, including social and human rights due diligence has been implemented on customers that are regarded as material exposure to the SEB Kort business. There are several facts that will determine if and on what level a sustainability assessment should be carried out on a customer.
SEB’ social and human rights due diligence process is defined in the Social and Human Rights policy (SHR Policy) and consists of 3 steps: Identify, Assess and Address material adverse social and human rights risks or impacts. SEB has identified several human rights risk sectors, where each sector also identifies key sector risks. Addressing the risks will, for example, be done through dialogue with the customer and setting expectations on how the risks should be addressed. The expectations are set by sector, and for each human right risk sector identified by SEB, there is a sector policy containing specific expectations on social and human rights.
The table below states which sectors that SEB has identified as human right risk sectors.
Identified High Human Right Risk Sectors:
- Agriculture, Fishing, Aquaculture and Animal Welfare
- Arms and Defence
- Forestry, Pulp & Paper, and Timber
- Fossil Fuel
- Gambling
- Mining and Metals
- Real Estate and Construction
- Electricity and Renewable Energy
- Shipping
- Tobacco and Tobacco-Free Nicotine Products
- Transportation
The focus for the time being is to assess the customers who are active in sectors that SEB has defined as the human rights risk sectors and where SEB Kort has a material impact on the customer. There are other sectors that also should be taken into consideration, which will be done continuously, for example, through new sector policies. The scope will also grow as the process is evaluated and becomes more integrated and systematic.
For this report, only customers that are either local to or have counterparties connected to the SEB Kort Oslofilialen are in scope and all other customers that are local to the other Nordic countries are excluded.
The sustainability assessment and due diligence process
The process of conducting a sustainability assessment as well as a social and human rights due diligence on the customers have been conducted as follows:
- A questionnaire has been created with questions regarding the customers’ sustainability work to find out if they
- Are aligned with SEB’s sector policies if in scope
- Have any material ESG related risks
- Have any sustainability risks or controversies connected to the company
- These questions have, to the extent possible, been answered by the responsible Key Account Manager at SEB Kort.
The answers may lead to a dialogue between the customer and SEB Kort.
Assessment of the result
Several customers have been identified as being in scope of the criteria where a sustainability assessment is required, and as such, have also been assessed accordingly. Conclusions from the results are:
- In general, assessed customers have not given any indications of material risks connected to social and human rights risks or other ESG-related risks that are in scope of this report.
As stated in the previous year’s report, some gaps were identified in the sustainability assessment process and therefore in need of improvement. The first, connected to the on-boarding process, is in progress of being mitigated. A new on-boarding process has been created and is being implemented throughout SEB Kort.
The second gap, connected to addressing potential social and human rights related risks has been mitigated during the year through the establishment of a new Corporate Business Committee. The committee in question will take decisions on cases where there is a breach against a sustainability policy or if there is significant reputational risk connected to the counterparty in scope. This committee will therefore be able to take decisions or escalate matters that are connecting to counterparties with identified social and human rights risks that need to be addressed. The whole process for conducting a sustainability assessment, including social and human rights due diligence will continuously be evaluated.
SEB Kort provides the following products and services:
- corporate credit cards
- private credit cards
- virtual cards
- travel account
- expense handling services
After a risk assessment of SEB Kort’ products and services it can be stated that there is little to no risk of violation of human rights. The financial services above are services of a highly technical nature, and which, to an extremely limited extent, will be able to contribute to direct financing with a negative impact on fundamental human rights and decent working conditions. Consequently, SEB Kort does not currently see a need for further risk assessment of its products and services.
The majority of SEB Kort’s suppliers are located in the Nordic countries and within the EU/EEA. The supplier base mainly consists of providers of IT, payment services, consulting and other professional services, operating in countries with strong regulatory frameworks and established standards for labour rights and human rights. For the purposes of the Act, the due‑diligence assessment covers suppliers and business partners connected to SEB Kort Oslofilialen.
Most of SEB Kort’s suppliers are centrally contracted through the Swedish entity and provide products and services to all four SEB Kort branches. In addition, SEB Kort uses local suppliers in each country of operation. Some suppliers are shared with the SEB Group, where SEB Kort is a party to the agreement, for example in cases involving shared office facilities.
The supplier base is characterized by low turnover, contributing to a stable and consistent supplier structure over time.
Certain suppliers are excluded from the scope of this due‑diligence assessment. This includes suppliers that are contracted by, or provide services exclusively to, SEB Kort branches other than SEB Kort Oslofilialen, including suppliers related only to the acquisition of AirPlus, and that have no connection to SEB Kort Oslofilialen’s Norwegian operations.
In addition, suppliers that are contracted directly by SEB Group, where SEB Kort is not the contractual counterparty, are also excluded from this assessment.
SEB Kort applies a risk based approach to supplier due diligence in accordance with the Act. Suppliers are reviewed yearly, based on their yearly costs, level of criticality and potential risk and categorized into Most Important Suppliers, Major Suppliers, and Non‑Critical Suppliers.
The human rights due‑diligence process has focused on suppliers assessed as most critical, within the categories Most Important Suppliers or Major Suppliers, where the risk of adverse impacts on fundamental human rights and decent working conditions is considered to be greatest. This prioritization is aligned with the requirements of the Act and the OECD Guidelines for Multinational Enterprises.
The due diligence process
The process for conducting a human rights due diligence assessment on the suppliers in scope has been conducted as follows:
As part of the due‑diligence process in accordance with the Act, a structured questionnaire has been distributed to the relevant Contract Manager(s) at SEB Kort. The Contract Manager is responsible for supplier oversight and relationship management. The questionnaire is designed to support the identification and assessment of risks related to fundamental human rights and decent working conditions within the supplier relationship.
The responses to the questionnaire form the basis for a follow-up dialogue between SEB Kort and the supplier, as part of the Vendor Governance process. Through this dialogue, the supplier is requested to confirm whether identified risks related to fundamental human rights and decent working conditions are addressed and mitigated, and to describe any relevant measures in place.
Assessment of the result
The result from the initial part of the due diligence process:
- The suppliers included in the due‑diligence assessment primarily operate within the IT, payment networks, insurance and marketing sectors. These sectors are generally not considered high-risk industries from a human‑rights perspective.
- Based on the due‑diligence assessment, the main identified risk factors relate to the complexity of certain suppliers’ supply chains, the geographic location of suppliers, and the fact that some suppliers conduct business in countries classified as higher risk according to SEB’s internal country risk framework.
- The majority of SEB Kort’s suppliers are based in the Nordic countries or within the EU/EEA. However, certain suppliers, particularly payment networks, operate as global actors. As a result, some non‑Nordic suppliers have operations or business activities in countries classified as higher risk from a human rights or labour standards perspective.
- Exposure to high-risk countries varies across the supplier base, ranging from limited presence through support or service centres to more decentralised operating models with globally distributed functions. In contrast, Nordic‑based suppliers generally have limited or no direct business activities in high‑risk countries.
Suppliers that operate or provide support services from countries classified as higher risk may pose an increased risk of adverse impacts on fundamental labour rights, primarily due to weaker regulatory frameworks and insufficient enforcement of labour standards in those jurisdictions.
Suppliers with operations in high‑risk countries are generally large and globally distributed organisations. As such, they are subject to increased regulatory scrutiny and stakeholder expectations, which necessitates well established, controlled, and transparent governance structures, policies, and ways of working to ensure compliance with internationally recognised human rights and labour standards.
SEB Kort mitigates identified and potential risks in its supply chain through proportionate due diligence measures. A key mechanism for ensuring that suppliers adhere to SEB Kort’s expectations regarding human rights and decent working conditions is the requirement to sign the SEB Group Code of Conduct for Suppliers, or to demonstrate adherence to an equivalent code of conduct of comparable scope and standard.
The outcome of SEB Kort’s due diligence assessments shows that the majority of suppliers have either signed the SEB Group Code of Conduct for Suppliers or confirmed the existence of their own equivalent code of conduct. For a limited number of suppliers, the status remains under clarification, or a dialogue is currently ongoing with the aim of strengthening the contractual relationship by incorporating a code of conduct as part of the agreement.
SEB Kort’s ability to influence suppliers varies depending on the nature of the supplier relationship, contractual arrangements, and the supplier’s role in SEB Kort’s value chain. In general, SEB Kort can influence how services are delivered to SEB Kort, including requirements relating to delivery location and service execution. However, in certain cases, particularly where suppliers are large, global actors that are critical to SEB Kort’s daily operations, the ability to influence the supplier’s overall way of working and global operating model is limited or, in practice, minimal.
How does SEB Kort work to address and mitigate these Supplier risks in the daily work?
In the onboarding process of a new third party (a supplier) to SEB Kort several steps of evaluation are performed. To identify and manage sustainability risks, SEB Kort carry out an initial risk assessment based on country, industry, and business criticality, supported by data from external experts. Suppliers assessed as having a higher risk are further evaluated through a well reputable external company of experts evaluating and scoring Suppliers, that can vary from time to time and the results are used both in our supplier selection process and as support for developing suppliers’ sustainability performance. At the RFP (Request for Proposal) stage several mandatory questions are asked on Environmental, Social and Governance (“ESG”) related issues (as “Do you comply with the UK modern slavery act” or “Do you carry out your activities in alignment with core labour standards”). The outcome of these numerous questions impacts the ability to select the third party. Hence there is a selection reducing SEB Kort’ exposure already at this stage. SEB Kort has a number of existing supplier contracts that have been in place for varying lengths of time. The level of ESG‑related documentation within these contracts therefore varies, ranging from limited to more comprehensive coverage.
This variation primarily reflects (i) the increased awareness and maturity of ESG‑related topics over time, and (ii) the application of a risk‑based approach to due diligence, whereby the scope and depth of ESG requirements have been adapted to the assessed risk associated with the supplier and the nature of the services provided. The risk-based approach used by SEB Kort, applies a risk‑based and proportionate due‑diligence approach. Supplier risk assessments take into account the nature of the supplier, geographical exposure, and the value and scope of goods or services procured. Suppliers that are locally established, have limited international operations, and represent a low purchase volume, are generally assessed as presenting lower risk, taking into consideration SEB Kort’s limited leverage in such relationships.
Where potential risks are identified, SEB Kort seeks to address them through dialogue and available contractual mechanisms. The timing and scope of measures are prioritised based on the severity and urgency of the risk, as well as contractual and practical feasibility. Where immediate mitigation is not possible, improvements are addressed through contract renewal or procurement processes, including structured sourcing activities where applicable.
SEB Kort’s Vendor Governance process ensures that third-party relationships are structured, controlled, and followed up in a consistent and risk‑based manner. It covers the full lifecycle of a vendor relationship, from onboarding and contracting to ongoing delivery and performance follow‑up. Vendor governance activities are supported by regular meetings, performance metrics, risk assessments and compliance follow‑up, ensuring alignment with internal policies and external regulatory requirements, including outsourcing and third‑party risk regulations.
Risk-Based Supplier Oversight and Continuous Improvement
SEB Kort continuously monitors supplier relationships and progress on identified risks. Decisions on continuation or renewal of contracts consider both supplier performance and demonstrated improvement over time, in line with the principles of responsible business conduct.
SEB Kort generally maintains long-term relationships with its suppliers and, where appropriate, seeks to work constructively with existing suppliers to support continuous improvement in ESG and human‑rights‑related practices, in line with a risk‑based and proportionate due‑diligence approach.
ESG and sustainability awareness within SEB has evolved significantly over time, reflecting regulatory developments, increased stakeholder expectations, and the growing recognition of sustainability as an integral part of long-term value creation.
During 2026 SEB Kort plan to implement a classification and risk-based method based on the newly updated Third Party Risk Management (TPRM) framework. All third-party arrangements shall be subject to third-party risk tiering. The purpose of the tiering, which is a complement to the classification, is to decide inter alia the level of due diligence, oversight and monitoring of third-party arrangements based on risk. The outcome of the classification and risk‑tiering process will be used as an important input when identifying and prioritising suppliers for further assessment.
Suppliers with higher risk tiers, or where the nature of the service or geographical exposure indicates elevated risk, will be prioritised for enhanced due diligence, in line with the principles of proportionality and risk‑based prioritisation under the Act.
Today, SEB Kort communicates ESG expectations more explicitly to suppliers, both through contractual arrangements and through supplier assessments and follow-up dialogues. Most suppliers are aware of and have acknowledged SEB Kort’s expectations related to responsible business conduct, either by signing the SEB Group Code of Conduct for Suppliers or by demonstrating adherence to an equivalent framework.
Supplier awareness is further supported through ongoing dialogue, clarification requests, and follow‑up actions, particularly for suppliers with global operations or exposure to higher risk geographies. For longstanding supplier relationships, awareness continues to be strengthened over time through contract renewals, updated requirements, and continuous engagement.
Summary relating to the findings of the supplier due diligence
Based on the nature of their services, limited presence in high‑risk countries, and generally low supply chain complexity, SEB Kort’s most important suppliers are, following a risk‑based due diligence assessment, overall assessed as presenting a low risk with regard to potential adverse impacts on fundamental human rights and decent working conditions. However, there are a few noteworthy exceptions:
- Global/Non-EU/EEA actors are in general active in many markets including high-risk countries. Most of these have either signed the SEB Group Code of Conduct for Suppliers or are utilizing their own Code of Conduct.
- The global payment networks are large, well-established actors with a decentralized organizational structure and operations across multiple markets, which entails exposure to a diverse range of risks. While SEB Kort conducts risk‑based and proportionate due diligence in relation to these suppliers, the company’s ability to influence their overall governance structures, global operations, and supply chains is limited, reflecting the nature of the relationship and their market position.
- SEB Kort maintains relationships with large global IT providers with complex, multi-market operations. While the company conducts risk-based due diligence and sets expectations for responsible business conduct, its ability to influence these suppliers overall governance structures and supply chains is limited due to their size, global presence, and the nature of the commercial relationship.
In accordance with the Act, SEB Kort has conducted risk‑based and proportionate due‑diligence assessments of suppliers within scope, covering ESG and human‑rights‑related matters. Based on the outcome of these assessments, no circumstances have been identified that would justify qualifying the supplier relationships for exit at this time.
SEB Kort recognises supplier awareness as an ongoing process. Work continues to further embed ESG considerations in supplier relationships, enhance transparency, and improve documentation and follow‑up, in accordance with the Act and internationally recognised due diligence frameworks.
SEB Kort has several different types of business partners: Loyalty partners; Financial Co brand partners; Distribution partners; Travel agency partners; Expense partners and Procurement partners. As with suppliers and customers, SEB Kort has business partners in all countries were conducting business. Most of the business partners are in the financial, travel or IT industry, providing products and services from within the EU/EEA and most often from the Nordic countries. The business partners that are residing outside Norway and that does not have any connection to the SEB Kort Oslofilialen business are disregarded for the purpose of this report.
Given that most of SEB Kort’ business partners are conducting their business within the Nordics or EU/EEA, the risk connecting to business being conducted in high-risk countries is deemed small, or even non-existent. In accordance with the SHR policy, a due diligences process is set up in SEB Kort for business partners. The due diligence process consists of an ESG and human rights due diligence assessment which is to be conducted for all new business partners and when an agreement with an existing business partner is renegotiated. This way, all SEB Kort’s business partners will be subjected to the due diligence process and continuously scrutinized.
Many of SEB Kort’s business partners are conducting business in Norway and therefore need to adhere to the Act. Their transparency act report will be regarded when they are subject for the due diligence process in SEB Kort.
The due diligence process
The process for conducting an ESG and human rights due diligence assessment on business partners, not including Financial Co brand partners, is as follows:
A questionnaire has been created with questions that will give a better understanding of how the business partner in question works with ESG as well as human rights and if a sector policy is applicable.
If a sector policy is applicable, then a sector policy assessment is also conducted.
If there are any discrepancies to the answers, possible risk factors i.e., connections to high-risk countries, or if the business partner is lacking a code of conduct or human rights policy, a series of follow-up questions are required.
The answers lead to a dialogue between the business partner and SEB Kort, to ensure that measures are taken to address and mitigate the potential risks.
The due diligence process for Financial Co brands
The process of working with Financial Co brand partners is different than that of other business partners. As mentioned in previous year’s report, a new process is being implemented in connection to the next renegotiation of a Co brand partner agreement.
The Co brand partner will also be assessed when on-boarded or when their agreement is renegotiated, but instead of a questionnaire the partner will be assessed against sustainability related pre-requirements. If the partner fulfils the pre-requirements, then they are deemed to be okay to work with from a sustainability and human rights due diligence perspective.
Assessment of the results from the due diligence process of business partners
In last year’s report, it was noted that deviations have occurred in the process of conducting an ESG and human rights due diligence on business partners. To mitigate the risk of deviations reoccurring and due to the increase in scope of business partners, soon also regarding the partners from AirPlus, a review of the due diligence process for business partners has been initiated.
During the past year, only one business partner has been subject for an ESG and human rights due diligence assessment. The business partner in question is an existing Co brand partner. The newly established process for on boarding or renegotiating agreements with Co brand partners was applied and the partner was deemed to fulfil the necessary pre-requirements.
The human resource department (“HR”) is responsible for working conditions and the recruitment process at SEB Kort Oslofilialen HR ensures compliance with applicable Norwegian labour and working environment legislation, as well as adherence to relevant internal policies and instructions, including "SEB Code of Conduct" and "SEB Inclusion and Diversity Policy". SEB Kort’s Code of Conduct sets clear expectations for ethical behaviour and applies to all employees, managers, and board members.
The Oslo branch has established routines for Health, Safety and Environment (“HSE”), annual employee surveys, annual voluntary and paid health checks, etc. SEB Kort Oslofilialen has established HSE routines in place. Annual employee surveys and conducted, as well as annual voluntary and paid health checks, among other initiatives.
All employees have individual written employment contracts. SEB Kort Oslofilialen complies with applicable regulations for working hours. Salary, overtime compensation, and supplements for unsociable working hours are paid in accordance with applicable legislation and employment contracts.
Temporary and agency personnel receive HSE training on the same basis as permanent employees. Agreements with temporary employment agencies regulate matters related to decent working conditions, equal treatment, and compliance with applicable legislation. SEB Kort Oslofilialen has established HR processes that promote equal opportunities and prevent discrimination.
During 2025, no cases of discrimination, harassment or violations of decent working conditions were identified.
Internal guidelines are available on the intranet, and relevant training and courses are provided through the SEB Group’s learning platform.
SEB Kort Oslofilialen respects employees’ fundamental rights, including freedom of religion, freedom of expression, respect for private and family life, and freedom of association. The branch applies a principle of equal pay for equal work and ensures equal treatment of employees regardless of gender, ethnic background, or other protected characteristics. Employee participation is facilitated through representation in the Working Environment Committee (“AMU”).
Both internal and external whistleblowing channels have been established, together with procedures governing the handling of investigation of reported matters. Internal whistleblowing is normally handled by SEB's compliance function. All employees are located at the office in Oslo. The risk of serious violations of human rights or labour rights affecting employees or temporary personnel is considered to be low. No violations of decent working conditions have been identified, and consequently no specific mitigating measures have been deemed necessary.
Preventive and mitigating measures:
Based on identified risks, SEB Kort implements preventive and mitigating measures, including:
- Mandatory training on ethics, Code of Conduct, and respectful workplace behaviour
- Leadership training focusing on inclusive management and employee wellbeing
- Clear procedures for handling workplace conflicts, grievances, and whistleblowing
- Continuous improvement of health, safety, and wellbeing initiatives
Monitoring and follow‑up
SEB Kort monitors the effectiveness of its measures through:
- Regular employee engagement and work environment surveys
- Follow‑up on reported incidents
- Management reviews and internal reporting
- Continuous dialogue between employees, management, and HR
In SEB Kort, work relating to the Act and due diligence is a continuous process. SEB Kort work constantly to improve the routines and processes for identifying and following up potential violations of human rights and labour rights in operations, regardless of whether this is in the role as a buyer or in connection with SEB Kort products.
SEB Kort is currently strengthening its ESG governance, which includes enhancing governance structures and clarifying roles and responsibilities.
The work with responsible purchasing will continue in 2026. SEB Kort will work continuously with training of our employees, improvement measures and compliance with rules and legislations.
Further efforts to improve how SEB Kort conducts its due diligence process, assess suppliers and potential risks will be continuously reviewed and documented in internal processes.
The next statement, detailing the findings of its due diligence conducted during the period January 1 – December 31, 2026, will be published before June 30, 2027.
Oslo, 2. Juni 2026
Tomm Fr. Olsen Branch Manager, SEB Kort Bank AB, Oslofilialen