Building it right

0TO9 AB (publ) reg. no. 556976-4110, is a credit institution authorised to conduct financing business under the Swedish Banking and Financing Business Act (2004:297) and is supervised by Finansinspektionen, the Swedish Financial Supervisory Authority. With its registered office in Stockholm, Sweden. It is also the issuer of an Additional Tier 1 (AT1) bond listed on Nasdaq Stockholm.

0TO9 AB (publ) operates under several brands, including Plus 1, Fuels Capital, AOTO Capital, Flow & Partners Finance and ZEAL Capital.

Authority runs from our shareholders’ General Meeting, which elects the Board, appoints the auditor, and decides on the Articles of Association, accounts and dividends. The Board is responsible for 0TO9’s organisation and governance, sets strategy and risk appetite, and oversees the CEO, who runs day-to-day operations through the management team and its management committees.

We apply three lines of risk and control management. The first line, our Ventures and support functions, owns the risks in its daily operations and is responsible for managing them, including regulatory compliance. The second line, the independent Risk Control and Compliance functions, monitors, supports and challenges the first line. The third line, Internal Audit, independently assesses our governance, risk management and internal control. The three control functions are organisationally separate from the business and report directly to the Board.

The Board has established three committees: the Audit, Risk and Compliance Committee (ARCCO), the Credit Committee and the Remuneration Committee (REMCO). The committees prepare matters and advise, while decision-making responsibility remains with the Board.

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Our remuneration system is designed to support sound risk management, to avoid excessive risk-taking and to ensure that our customers’ interests are never harmed by how we pay our staff. It also helps us attract, motivate and retain the people we need to meet our long-term goals. Our Remuneration Policy is adopted by the Board and applies to all employees in the 0TO9 Group.

Fixed salary is the foundation of pay for everyone at 0TO9. It is set based on competence, responsibility, experience and performance, in line with market levels and gender-neutral, and we regularly review pay for unjustified differences between women and men. We do not use bonuses or other variable remuneration schemes. Individual pay is always approved under the four-eyes principle.

Commission is used only for certain customer-facing roles in our consumer credit business, and never for staff whose work materially affects our risk profile. It is based on qualitative criteria only, such as the quality of credit assessments and compliance with our credit rules. It cannot be influenced by the number, share or size of loans granted or arranged. Credit assessment is kept separate from advisers’ own remuneration interests, and we regularly sample-test lending and commission payments.

Each year, our control functions, reviews that the remuneration system is followed and does not create conflicts of interest with customers. The result is reported to the Remuneration Committee and the Board.

Trust is what we operate on. That is why we treat conduct as a core part of how we run the business.Everyone at 0TO9 is expected to act with honesty, integrity and care for our customers. We identify, prevent and manage conflicts of interest, so that the interests of customers, shareholders, founders and Ventures never take precedence over our obligations as a licensed institution.

We work actively to prevent our services from being used for money laundering, terrorist financing or sanctions evasion. We know our customers, monitor transactions, report suspicious activity to the authorities and train our staff. Our AML responsibilities are part of the independent Compliance function, which reports directly to the Board.

We do not offer, give, request or accept bribes or any improper advantage, directly or through third parties.

Employees and others can raise concerns about misconduct through a whistleblowing channel, without fear of retaliation.

Our conduct framework is adopted by the Board, applies across the whole 0TO9 Group.

We believe responsible lending plays an important role in a well-functioning economy. Our goal is to contribute to financial inclusion by offering credit that is transparent, fairly assessed and sustainable over time, and by making sure our customers get financing that suits their needs and their ability to repay.

Sustainability is part of how we run our business, not a separate initiative. As regulatory requirements and stakeholder expectations change, we keep developing our practices and regularly review our priorities, so that our sustainability framework stays relevant and aligned with our long-term strategy.