Internal controls

Auditors
An independent accounting firm is elected annually at the AGM on the recommendation of the Board of Directors.

Topdanmark's Board of Directors employs an internal audit manager and has adopted a policy/list of duties for the internal audit. Furthermore an agreement has been put in place between the external and internal auditors ("the auditor agreement") which describes the tasks to be undertaken by the external and internal auditors respectively.

The creation of the list of duties and the auditor agreement" has been based on the executive order on the preparation of an audit of financial services companies and groups.

The auditors report regularly to the Board of Directors via an audit book

Topdanmark has set up a joint Audit Committee in accordance with the rules of the Danish Audit Act comprising three members of the Board of Directors.

Shareholder agreements
As far as Topdanmark is aware, no agreements have been made between its shareholders.

Nor have any agreements been made between Topdanmark and individual shareholders on restrictions in the trade of Topdanmark's shares in the form of strategic cross-holdings or similar agreements.

As far as Topdanmark is aware no agreements have been made between closely connected parties except those in the normal course of business.


Accounting standards
Topdanmark Group's Annual Report has been prepared in accordance with International Financial Reporting Standards as adopted by the EU and the additional Danish disclosure requirements of NASDAQ, Copenhagen and the Danish Financial Business Act on annual reports prepared by listed financial services companies.

The annual financial statements for the parent company Topdanmark A/S have been prepared in accordance with the Danish Financial Business Act, including the executive order issued by the Danish Financial Supervisory Authority (DFSA) on financial reports for insurance companies and lateral pension funds (nationwide, occupational pension funds specific to Denmark).


Compliance policy
In Topdanmark, the Group and its employees are required to know and observe the relevant legislation and internal rules and routines. This is important in the interest of the Group's reputation and in order to protect the Group and Topdanmark's customers against incurring losses and expenses due to official sanctions, claims for compensation or errors which may have a direct or indirect financial impact on our customers.

To achieve this, the Board of Directors has adopted a policy for operational risks, compliance and internal control, and Topdanmark has established a central compliance function which controls and advises the business sectors and administrative departments and reports on compliance to the Executive Board and the Audit Committee of the Board of Directors.

As part of creating an appropriate internal control environment, following the establishment of the central compliance function, Topdanmark has set up decentralised compliance units in the relevant business sectors and administrative departments. In terms of compliance, the compliance units refer and report to the central compliance function.