Statement of the Fair advertising and marketing policy

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The Fair Advertising and Marketing Policy aims to define how we market, communicate and advertise our brand, products and services to consumers. Our goals are to:

• communicate in an ethical and transparent manner, which includes sustainability;
• produce value-added content, enabling consumers to make informed decisions worthy of trust and the Spuerkeess brand image;
• follow the 2030 Sustainable Development Agenda and the United Nations Sustainable Development Goals, more specifically goals 12 “Responsible Consumption and Production” and 17 “Partnerships for the Goals”.

This policy covers:

1. production of commercial content promoting our brand, products/services and business initiatives;
2. distribution of content via Spuerkeess communication channels, such as S-Net, Newscenter, Spuerkeess.lu, blogs and digital screens;
3. distribution of content via external communication channels, such as cinema, television, radio, press, bus shelters, Google, etc.

and applies to all staff and third parties working for Spuerkeess.

There are no exceptions to this policy, barring exceptional circumstances or cases where the policy is clearly not applicable.

We comply with all laws, guidelines and regulations relating to advertising and marketing practices, as well as European and national industry codes, relevant to our Bank’s communications, which include multiple additional requirements for the promotion of certain financial products and services: MiFID II, DSP2, consumer credit for residential properties.

The validation process for an advertisement or marketing campaign calls for the validation of the submitting departments and Marketing.

Spuerkeess also has an External Communications Committee (COMCOMEXT), whose duty is to maintain the quality as well as validate and ensure the correctness (form, substance, regulatory compliance) of our external communications.

The Spuerkeess Marketing Business Unit is responsible for the content of this policy and undertakes to:

• communicate this policy within Spuerkeess;
• train new employees and third parties;

to ensure that all internal stakeholders adopt and observe the policy.

No communication may be liable to adversely impact the trust and brand image of Spuerkeess.

Our advertising and marketing approach must be decent, fair and sincere.

We design communication with a fair sense of social and professional responsibility and do not carry out comparative advertising.

Any communication must enable our consumers to make informed decisions about our brand, products and services.

Spuerkeess undertakes, through its advertising and marketing, to ensure:

1. transparency and clarity
2. non-discrimination and accessibility
3. promotion of responsible practices
4. reduced paper consumption
5. employee communication
6. the application of external regulations and codes of conduct

to all communications.

Any communication that is incorrect, misleading, deceptive or inconsistent with the policy will be analysed and corrected.

The Fair Advertising and Marketing Policy is updated once a year or whenever there are changes in strategic objectives, organisational practices or legislation.