Investment Information

Advisory basis - Risk capacity and risk tolerance

In connection with your advisory basis, your risk capacity and risk profile will be assessed based on the following basis

Business partners in connection with investment advisory services

We must inform you about all forms of consideration, including commission, which we receive from our business partners.

No Jyske Bank employee receives commission or bonus from Jyske Bank or from any of our business partners.

Samarbejdspartnere i forbindelse med investering (in danish) [PDF]

Se provisioner for de enkelte afdelinger - indland (in danish) [PDF]

Se provisioner for de enkelte afdelinger - udland (in danish) [PDF]

Calculation of risk on derivative financial instruments

Here you find information about how to calculate market value, market risk and credit risk.

Calculation of risk on derivative financial instruments [PDF]

Complaints to the Bank and to the Danish Complaints Board of Banking Services

You should always contact your branch in case you are dissatisfied with your relationship with Jyske Bank or if you are dissatisfied with the outcome of any inquiry.

If, after having discussed the problems with your branch, you do still not agree with Jyske Bank, you may file a complaint with: Jyske Bank A/S, Juridisk Afdeling, Vestergade 8-16, 8600 Silkeborg. See more information

If you still disagree with Jyske Bank, you may submit a complaint to: Pengeinstitutankenævnet Østerbrogade 62, 4. sal, 2100 København Ø, tel.: +45 35 43 63 33 - www.pengeinstitutankenaevnet.dk

You should submit your complaint using a special form which is available from the Danish Complaints Board of Banking Services and can be downloaded from the Board’s website listed above. The Complaints Board currently charges DKK 150 for hearing a complaint. The amount will be refunded if your complaint is sustained in part or in full, or if your complaint is rejected, withdrawn or lapses.

EU Taxonomy

Financial products’ consideration of EU criteria for environmentally sustainable economic activities. According to Regulation (EU) 2019/2088 (“Disclosure Regulation”), financial products must be categorized according to their approach to sustainability.

  • "Article 9 products" are products having sustainable investments as their goal.

  • "Article 8 products" are products marketing environmental and/or social characteristics.

  • "Article 6 products" are all other products which cannot be categorized as Article 8 or Article 9.

Financial products at Jyske Bank, which are not individually in each agreement categorized as an Article 8 product or an Article 9 product, are categorized as an Article 6 product.

According to Regulation (EU) 2020/856 (”Taxonomy Regulation”), we are obliged to inform you that the investments underlying these Article 6 financial products do not take into account the EU criteria for environmentally sustainable economic activities.

Execution venues

Click on this link to see the stock exchanges and financial institutions with which Jyske Bank does business.

Execution venues [PDF]

Exclusion list

With respect to its asset management activities, Jyske Bank excludes a number of companies from investing as appears from the sections about norm-based and activity-based screening in Policy on responsible and sustainable investment in Jyske Bank.

We pursue a zero-tolerance policy with respect to investments in companies related to weapon types violating international conventions ratified by Denmark. All companies with this type of products will be placed on the exclusion list. Furthermore, investing in a number of companies that in other ways violate the principles for norm-based and activity-based screening may be blocked. These types of companies will only appear from the list if the bank’s internal forum for responsible and sustainable investments (FABI) has specifically assessed and rejected that investments can be made.

In a number of mandates with special sustainability considerations there will be additional exclusion criteria.

See the complete exclusion list here.

Facts about deposit guarantee

As from 1 October 2010, all deposits up to 100,000 euros (about DKK 750,000) per depositor are guaranteed by the Danish Guarantee Fund for Depositors and Investors. That is an increase of the amount guaranteed before Bank Package I was introduced, of up to 50,000 euros (about DKK 375,000) per depositor.

Special deposits (such as savings under pension schemes) will be covered to an unlimited extent.

Read more about Jyske Bank’s financial strength (in danish)

How are you covered?
As a client of a bank you will be covered against loss to a wide extent through The Danish Guarantee Fund for Depositors and Investors, should the bank be subject to compulsory winding up or suspend payment.

The Guarantee Fund covers the deposits of both private and corporate clients including associations and enterprises.

Coverage will be paid out after deduction of the client’s debt, if any, to the same financial institution. If you have borrowed money from the bank, the sum you owe will be withdrawn from your deposit when the coverage of the Guarantee Fund is calculated. This does not apply to special coverage bonds (SDOs) which cannot be offset.

Fully-covered deposits
The coverage of a number of account types is unlimited. In other words, your deposits, if any, in the undermentioned account types which are supported by law will be fully covered.

The account types are, among others:

  • ‘Kapitalpensionskonti’
  • ‘Selvpensioneringskonti’
  • ‘Ratepensionskonti’
  • ‘Børneopsparingskonti’
  • ‘Etableringskonti’

This also applies to deposits in a number of account types which can no longer be created:

  • 'Indekskonti'
  • 'Uddannelsesopsparing'
  • 'Boligopsparing'

Several account holders
If an account is held by several account holders, the holders are regarded as individual depositors (provided every person is registered as a holder of the account).The deposit in the account is shared between the account holders and included in the amount guaranteed for every depositor by the Guarantee Fund (up to 100,000 euros/about DKK 750,000).

Securities
The compulsory winding up of a bank will not affect the delivery of securities held in individual custody accounts, e.g. at the Danish VP Securities Services. If the bank fails to deliver securities which it has held in custody, administered or managed, the Guarantee Fund covers investors’ losses by up to 20,000 euros per investor.

More information
The website of the Guarantee Fund www.gii.dk offers more information about the Fund's coverage.

You are always welcome to contact your adviser if you have any questions or would like to discuss your savings.

Facts about EMIR

Rules for trading in derivative financial instruments
In 2009, the G20 countries adopted a resolution of which the purpose is to prevent a new financial crisis as a consequence of failure to manage the risk on derivative financial instruments, hereinafter termed derivatives. In Europe, the resolution is implemented, among other things, under the European Market Infrastructure Regulation (EMIR).

EMIR imposes various different obligations, of which the most important are illustrated in the chart.

EMIR - obligations

The various obligations in the risk mitigation, clearing, reporting and collateralisation area depend on the company’s client and counterparty category.

EMIR distinguishes between five client and counterparty categories:

  • Financial counterparties (FC)
    Banks, insurance companies, investment firms and other parties that are subject to the clearing obligation.
  • Financial counterparties (FC-)
    Financial counterparties that are not subject to the clearing obligation.
  • Large non-financial counterparties (NFC+)
    Companies with a volume of derivatives that exceeds the thresholds in the respective categories, and which are therefore subject to the clearing obligation.
  • Small non-financial counterparties (NFC-)
    Companies and business operators with a volume of derivatives that does not exceed the thresholds in the respective categories, and which are therefore not subject to the clearing obligation.
  • Private individuals
    Private individuals who trade derivatives under their own Danish personal registration number.

The client and counterparty category influences whether, and to what extent, the respective rules under EMIR are of significance to the company, and how they are to be applied.

Calculation of status as NFC- or NFC+
A status as NFC- gives significant administrative savings. It is therefore a requirement to provide annual verification that the conditions for NFC- status continue to be met. This takes place by calculating the current trading volume in various categories of derivative trades and comparing this to the thresholds stated under EMIR.

If the company does not wish to make the calculation, it will be considered to have NFC+ status in accordance with EMIR. The status of NFC+ entails that the company is subject to the clearing obligation, and that the company itself must report its derivative trades.

Since the thresholds for the transition from NFC- to NFC+ are relatively high, and the cost and administrative savings are considerable, most Danish companies will be interested in making the calculation in order to retain the NFC- category status.

Derivatives with the following characteristics must be included in the calculation:

  • Traded “over the counter” (OTC) and not on an exchange, for example.
  • Transactions that are not intended to limit commercial risks and are therefore of a speculative nature.
  • Active, not yet expired transactions.
  • Intragroup transactions are included in the calculation.

The calculation is made by:

  • Allocating the derivative trades to the following categories.
  • Adding up the gross nominal value of all derivative trades in each category.
  • The sum of the gross values in each category is compared to the following thresholds.

As of 18 June 2020, the following thresholds apply to the individual derivative types:

  • Credit derivatives: equivalent of EUR 1,000,000,000
  • Equities derivatives: equivalent of EUR 1,000,000,000
  • Fixed income derivatives: equivalent of EUR 3,000,000,000
  • Currency derivatives: equivalent of EUR 3,000,000,000
  • Commodities derivatives: equivalent of EUR 3,000,000,000

See the current thresholds at https://www.esma.europa.eu/post-trading/clearing-thresholds.

The bank does not know the companies’ and any intragroup transactions with other counterparties and therefore cannot make the calculation.

Clearing obligation

  • Financial counterparties (FC)
    FC are obliged to clear all derivative trades that are subject to the clearing obligation (see current overview here), and not only in the categories that are exceeded, if the company has a volume of active derivative trades in one or several categories that exceed the aforementioned thresholds.
    A company that is not subject to the clearing obligation is categorised as FC-.
  • Non-financial counterparties (NFC)
    NFC are obliged to clear their derivative trades in the category(ies) that are exceeded, and if they are subject to the clearing obligation they are categorised as NFC+. NFC- are not subject to the clearing obligation.

The advantage of clearing is that the company does not have different claims and obligations, arising from derivative trades, in relation to different counterparties.

By using a clearing house for settlement of derivative trades, you can net various offsetting claims and reduce the risk for all parties.

If your company is subject to a clearing obligation, the required contractual and technical measures must be taken in good time.

Reporting obligation
EMIR imposes a reporting obligation on the bank and all clients. However, Private individuals trading derivatives under their own Danish personal registration number are exempt from the reporting obligation.

Jyske Bank is obliged to make reporting for the clients categorised as NFC- clients. As an NFC- client you may, however, inform Jyske Bank in writing if you wish to make the reporting yourself. NFC+ clients are obliged to report their derivatives transactions to a transaction register themselves. To ensure that the supervisory authorities may access trade data. As an NFC+ client you may, however, enter into a written agreement with Jyske Bank to the effect that Jyske Bank makes reporting on behalf of the client and itself.

All derivative trades must be reported to an approved transaction register.

For Jyske Bank to be able to report correctly on a client's behalf, the client must have a LEI code, and enter into a reporting agreement. The reporting agreement is a supplement to the existing agreement on trading in derivative financial instruments.

All companies subject to the reporting obligation must have a LEI code. The LEI code is an international code for identification of companies that trade in derivatives. See more about LEI codes on the Danish FSA's website (in Danish).

Jyske Bank’s LEI code is: 3M5E1GQGKL17HI6CPN30

If the client chooses to report its derivative trades itself, these trades must be identified by the UTI (Unique Trade Identifier) assigned by Jyske Bank.

Jyske Bank’s UTI codes will usually have 42 digits, with the following structure:

(10 digits: QGKL17HI6C) + (10 digits: digits 7-16 of the client's LEI code) + (4 digits: Year of the trade) + (18 digits: Trade ID from the confirmation, including characters with preceding zeros).

EMIR statutory requirements concerning collateral arrangements and risk mitigation
Financial counterparties (FC/FC-) and non-financial counterparties (NFC+) that exceed the thresholds are obliged to have risk management procedures that require timely, accurate and appropriately segregated exchange of collateral with respect to OTC derivative contracts.

The exchange of collateral consists of two types of margin:

  • Variation margin:
    Must protect the parties from value fluctuations related to the market value at any time of the established, non-cleared OTC derivative contracts.
  • Initial margin:
    Must be provided on the establishment of a non-cleared OTC derivative contract and be subject to ongoing adjustment. Its purpose is to protect a party from potential losses that may arise in a closure situation during the period between the last exchange of variation margin and until the OTC derivative contracts have been replaced or their risks equivalently hedged.

The requirement for the exchange of collateral solely applies to new, non-cleared OTC derivative contracts that are entered into on or after the date of entry into force of the margin requirement.

There are a few conditional exemptions from and deferrals of the requirement for the exchange of collateral in relation to certain contracts – see more on the Danish FSA's website.

Notification of status changes to the bank
Any change of status from NFC- to NFC +, or vice versa, must immediately be notified to the bank. After any change of status from NFC- to NFC+ the bank may still handle reporting on behalf of the NFC+, although this will require a separate agreement.

Reconciliation of trades
EMIR also sets the requirement that the terms for all ongoing derivative trades and their valuation be reconciled at least once a year. However, if more than 100 trades have been made between the client and the bank the requirement is at least once per quarter. If the client disagrees with the terms or the calculated market value, the client must notify the bank, so that the parties can come to an agreement.

At Jyske Bank, this reconciliation takes place at the end of the year or quarter.

On a daily basis, Jyske Bank sends an overview of existing derivative trades between the client and the bank, with details of calculated market values, to the client's online banking mailbox.

Resolution of disputes
There must be agreed rules for handling disputes. Jyske Bank's terms are that the client must check the confirmation of the trade before it is signed. The client must also check the daily overview of calculated market values. If the client disagrees, the client must contact their adviser at the bank. If the client cannot reach agreement with the adviser, the client must send a written complaint by email to [email protected].

More information
For further information about EMIR, see the Danish FSA's information about EMIR (in Danish).

FX Global Code of Conduct

Jyske Bank has adopted and signed the FX Global Code of Conduct (FXGCC). Hence, we back the unique cooperation between central banks and market participants around the world. The code consists of 55 principles and aims to promote a robust, fair, liquid, open and transparent foreign exchange market. 

More information about the FX Global Code can be found below.

Instrument categories

At Jyske Bank you can trade the below non-complex instrument categories via self-service channels such as Jyske Netbank and Jyske Mobilbank.

If you are interested in advisory services concerning these instrument categories, it is a statutory requirement that we make sure that you have knowledge of the instrument categories you want to trade via a relationship manager at the Bank. You may obtain knowledge of the non-complex instrument categories through your relationship manager or your investment adviser.

You may also gain trading access to more complex securities, such as US equities, ETFs, complex corporate bonds, EM bonds, ADR, certificates etc. This only requires that your knowledge of such types of securities is tested. Such testing is a statutory consumer protection measure, cf. MiFID II. If you are interested in trading with complex instrument categories, please call +45 89896999 during 8 am and 5 pm.

Complex instruments

The Jyske Bank Group’s declaration on principal adverse impacts on sustainability factors

Here you can read Jyske Bank’s annual analysis of how the investments made on behalf of clients may affect the outside world, and what initiatives we can take to minimise negative impacts.

The Jyske Bank Group’s policy for responsible and sustainable investment

At the Jyske Bank Group, we consider it our primary responsibility, in the best way possible, to optimise the return for our investors. We assume corporate social responsibility in relation to its investments, which means that environmental, social and governance (ESG) issues are taken into consideration in the investment decision process.

The basis of the Jyske Bank Group’s work with responsible investment is UN PRI’s Principles for Responsible Investment (PRI). UN PRI is a joint declaration on taking corporate social responsibility in connection with investments and compliance with six central principles for responsible investments.

Read about our policy for responsible investment

Statement of changes to policy for responsible and sustainable investment


Key Information for PRIIPs

When you trade in financial instruments in Jyske Bank, you must be able to understand and compare the most important aspects and risks of the investment you wish to make. Therefore we are under the obligation to make a number of information documents on financial instruments available to you - PRIIPs key information.

See the information documents

MiFID categories

In accordance with the Danish executive order on investor protection in respect of securities trading, we are required to categorise all clients according to the Markets in Financial Instruments Directive (MiFID). MiFID categories determine the degree of investor protection that the client enjoys and which is described under each category.

There are three MiFID categories prescribed by law:

  • Retail clients - enjoy the highest level of investor protection
  • Professional clients - enjoy a slightly lower level of investor protection
  • Eligible counterparties- enjoy no investor protection

In addition, it is possible for retail clients to be categorised as an “elective professional client” for one or more asset classes. This means they will be treated as professional clients in respect of the asset classes for which they fulfil certain criteria.

Retail Client

As a retail client you obtain the highest level of investor protection, which implies, among other things, that:

  • you must receive information about our prices and services in good time before you execute transactions
  • we must ensure that you have sufficient knowledge or experience in trading in relevant financial instruments (securities)
  • before purchasing selected investment certificates and certain other investment products you may request a PRIIPs KID
  • when we advise you, we must obtain knowledge about your investment purposes so that we can offer you advice matching your needs including also knowledge about:
    • Your educational background
    • Your occupation
    • Your time horizon and risk tolerance
    • Your financial affairs
  • advisory minutes (suitability assessment) are prepared every time you have received advisory services and before any transactions are executed
  • we are obliged in connection with the execution of orders to obtain the best possible price inclusive of trading costs unless we execute the order according to other criteria determined by you
  • every three months we send you a list of holdings
  • one every twelve months, we send you a total overview of the amount paid in investment service costs and product costs

All clients who do not fulfil the requirements of being categorised as a professional client or eligible counterparts cf. below will be categorised as retail clients. Retail clients may hence be both personal clients and business undertakings.

Elective professional client in connection with one or more asset classes

Retail clients trading very actively in some types of financial instruments may request re-categorisation as an "elective professional client” in connection with one or more asset classes. This means that in respect of these asset classes, a client can be treated as a professional client even though the client is a retail client. The client has to apply to the bank to be re-categorised as an elective professional client. In accordance with the law, the Bank must make a thorough assessment whether the client is capable of making his own investment decisions and understanding the risks involved. In addition, at least two of the following three criteria must be satisfied:

  1. the client has carried out transactions, in significant size, in the relevant market – at an average frequency of 10 per quarter over the previous four quarters
  2. the size of the client’s financial portfolio, defined as including cash deposits and financial instruments, exceeds EUR 500,000
  3. the client works or has worked in the financial sector  for at least one year in a professional position, which requires knowledge of transactions or service envisaged

Seen in relation to the categorisation as a retail client, the categorisation as an elective professional implies lower protection in the form of:

  • with respect to information about costs and fees the client and the Bank may agree to give less detailed information
  • there is no requirement of the bank to prepare advisory minutes after the provision of advisory services and before any transactions are executed
  • before purchasing selected investment certificates and certain other investment products you may request a PRIIPs KID
Per se professional clients

A per se professional client is a large undertaking meeting two of the following three size requirements on a company basis:

  1. own funds of EUR 2,000,000
  2. balance sheet total of EUR 20,000,000
  3. net turnover of EUR 40,000,000

Seen in relation to the categorisation as a retail client the categorisation as a per se professional client implies a lower degree of protection in the form of:

  • that the Bank may take its point of departure in the per se professional client having knowledge and experience in trading relevant financial instruments (including securities)
  • the Bank may take its point of departure in the client’s financial affairs being sufficient to make the desired investments and understanding the financial consequences of the investments
  • there is no requirement that the Bank prepares advisory minutes after the provision of advisory services and before any transactions are executed
  • with respect to information about costs and fees the client and the Bank may agree to give less detailed information
  • before purchasing selected investment certificates and certain other investment products you may request a PRIIPs KID
Eligible counterparty

The legislation defines eligible counterparties as a specific type of undertaking, for instance: financial institutions, pension funds, insurance companies.

Eligible counterparties only benefit from a moderate degree of investor protection in the form of:

  • information on investment services and financial instruments
  • information about costs and fees for investment services
  • reporting on transactions and services rendered

An eligible counterparty receiving advisory services or portfolio management services is treated in the same way as professional clients.

Order Execution Policy

Order types

See a list of the various order types which Jyske Bank offers you.

Order types [PDF]

Policy for conflicts of interest

Jyske Bank has prepared business procedures designed to identify and handle conflicts of interest.

Policy for conflicts of interest [PDF]

Price list, services

Here is a complete list of the costs of various services at Jyske Bank. At the moment the information is only available in danish.

Price book (in danish)

Sales commission

Jyske Bank has entered into cooperation agreements with several investment associations, and as we offer advice on their investment products, the bank is not an independent investment adviser. When you own certificates in these investment associations, the bank receives payment (called sales commission) from the association.

The bank receives this commission for making its distribution network available to the association and for offering advice in relation to the association’s certificates.

See here for a comprehensive outline of the bank’s cooperation partners in the area of investment. And gain a full overview of the rates of commission applicable to the various investment association certificates.
Before you buy certificates from an investment association, you will be informed of the annual sales commission applicable to your certificate. You will also receive the annual report “Årlige Investeringsomkostninger” (Annual Investment Costs), which will show the total amount you paid in the form of sales commission.

Quality-enhancing services

When Jyske Bank receives sales commission, the bank offers services to its clients, which will enhance the quality of your client experience when investing. The higher the commission the bank receives, the more services you will be offered. 

If you wish to see the stage you are at right now and the quality-enhancing services that you are entitled to, please contact your adviser.

Please note: If you are a private banking client with the bank, you will receive a description of your personally adjusted service and value propositions from your adviser.

SI information

Below you find a list of the products for which Jyske Bank is a systematic internaliser and our commercial policy for the area.

Overview [PDF]

Detailed list - Equities, Bonds and Exchange-traded funds [PDF]

Commercial policy – systematic internaliser [PDF]

Supervisory authority

The Danish Financial Supervisory Authority, Gl. Kongevej 74 A, DK-1850 Frederiksberg C supervises Jyske Bank's compliance with current legislation and with executive orders.

Sustainability risks – integration in investment advice

Here you can read how Jyske Bank integrates sustainability risks in investment advice.

Sustainability risks in our investment advice [PDF]

Sustainability risks – integration in investment decisions

Here you can read how Jyske Bank integrates sustainability risks in our investment decisions.

Sustainability risks in our investment decisions [PDF]