Finnfund Code of Conduct

Finnfund’s business operations are based on financing financially profitable, sustainable projects that generate development impacts, under demanding conditions. We are committed to complying with the highest standards concerning business operations and the ethics thereof in our operations.

The Code of Conduct, together with the regulations, definitions of policies, and procedures concerning our business operations, forms the operating culture and values of Finnfund.

The Code of Conduct applies equally to all Finnfund employees, supervisors and directors (hereinafter referred to as “personnel”). Finnfund expects the entire personnel to comply with these principles, act as an example to others and notify the company if the principles are violated. The company’s senior management and supervisors bear a special responsibility for ensuring that the personnel are familiar with these guidelines and that the all levels of the organisation comply with the guidelines. Employees with questions about the Code of Conduct or the application thereof should contact the Director, Administration or the company’s Lead Counsel for additional information.

Each employee’s familiarisation and compliance with the Code of Conduct are assessed in the annual development discussions conducted with the employees. Finnfund takes all violations of the Code of Conduct seriously, addresses them and takes the measures required for preventing the recurrence of similar violations in the future. Ultimately, violating these guidelines may result in termination of employment.

Integrity

Compliance with laws

Compliance with laws governing our operations is the foundation of our business. All Finnfund’s operations must be well aligned with the applicable laws and regulations. Finnfund requires that all employees understand the regulatory requirements that apply to their area of responsibility and never encourage customers or colleagues to break any laws or rules or assist them in such activities. All suspected illegal, fraudulent or otherwise dishonest activity must be immediately reported to the company (see section Reporting of violations).

Confidentiality

The trust of our customers and stakeholders is the prerequisite of our successful business operations. We respect the confidentiality of the materials submitted to us by our customers and their trade secrets. Finnfund expects all employees to keep all information they receive from customers and other stakeholders confidential unless it has otherwise been separately published or intended to be published. Examples of confidential customer information include materials that contain commercial or business-related information or personal data. All Finnfund employees are expected to handle electronic data or information in paper format with care and to exercise special care when processing materials outside of Finnfund’s facilities.

Finnfund is committed to respecting privacy and to processing personal data in a responsible manner in compliance with the data protection legislation. With regard to the processing of personal data, the personnel should comply with Finnfund’s data protection policy.

Anti-corruption activities

Finnfund does not approve of corruption in any form. Finnfund’s employees may not, directly or indirectly, promise, offer, request or accept any types of bribes. Apart from actual financial benefits, such as monetary gifts, considerable discounts or purchase benefits, bribes or inappropriate influencing may manifest as other benefits, such as those concerning travel, accommodation or other services that are provided without consideration or that are considerably inexpensive. With regard to business gifts, the personnel should be familiar with and comply with the company’s internal guidelines concerning the giving and receiving of gifts and hospitality.

Activities against money laundering and financing of terrorism

Finnfund complies with all relevant laws, regulations and procedures in its operations in order to prevent money laundering, financing of terrorism and other illegal activities. Finnfund’s personnel are required to comply with the company’s internal guidelines on the activities concerning money laundering and the prevention of financing of terrorism.

Interests, conflicts of interest and insider information

Finnfund’s personnel are not allowed to make private investments based on confidential information or insider information. Each employee shall refrain from all private investment activities or professional activities (such as consulting) if these may result in a conflict of interests with their position at Finnfund. Finnfund does not approve of disclosing insider information to external parties or using such information for one’s benefit in any form. The personnel are required to be familiar with and to comply with the guidelines concerning the interests of the company’s employees and Board memberships.

Transparency

Finnfund respects and values transparency, reliability and open communication with customers, employees, business partners, shareholders, other stakeholders as well as the society at large. Finnfund’s employees should always act as transparently as possible in their work while taking into consideration the principles concerning confidential information.

Finnfund encourages its personnel to present themselves as experts in their sector in the traditional and social media, supported by the communications team. All media inquiries should first be referred to the communications team. Training is available concerning the activities in social media, and the company’s general operating principles should be complied with when using social media.

Responsibility

Finnfund’s business operations require respect for human rights, as well as environmental, social and financial responsibility. The responsibility of Finnfund’s operations is governed by the Finnfund Act, Finland’s development policy and ownership steering, Finnfund’s strategy, and the policy on environmental and social responsibility, which applies international best practices and cooperation with other European Development Financiers (EDFIs).

Finnfund is committed in its operations to complying with several international declarations and treaties concerning, among other things, environmental and social responsibility, respect for human rights, gender equality and responsible tax (https://www.finnfund.fi/en/impact/corporate-responsibilitys/), including:

• the United Nations’ Declaration of Human Rights and Conventions; Sustainable Development
  Goals; Guiding Principles on Business and Human Rights; as well as Convention on the Rights of the
  Child;
• ILO Declaration on Fundamental Principles and Rights at Work;
• the World Bank Group’s environmental and social responsibility policies; environmental, health
  and safety guidelines (“EHS Guidelines”); IFC’s environmental and social responsibility standards
  (“Performance Standards”);
• the harmonised environmental and social requirements agreed between the European Development
  Financing Institutions (EDFI).

As an employer, Finnfund acts responsibly and respects its employees. The employer and all employees are expected to maintain a working culture of mutual respect both within the working community and with customers or other stakeholders. Finnfund values diversity. No activity that is interpreted as discrimination, bullying, harassment or inappropriate is accepted.

Professionalism

Finnfund is committed to offering customers and other stakeholders a high-quality service, fulfilling its promises and acting in a professional manner, efficiently and without delay. Finnfund’s operations are based on risk-taking and professional management of risks. Finnfund engages in professional investments operations and is committed to managing the assets trusted to it in a meticulous manner. All employees are expected to act in a professional manner and impartially in accordance with the aforementioned principles.

As an employer, Finnfund requires its employees to have adequate professional, linguistic and technical skills with regard to their job duties. Finnfund encourages its employees to continuously develop their competence and, when needed, ask for assistance and support other colleagues when a need arises.

Reporting of violence

All reported violations of the Code of Conduct are processed and addressed in a manner required by the severity of the violation.

All employees are encouraged to contact the Director, Administration or the Lead Counsel if they have questions concerning the compliance with or application of the Code of Conduct.

Finnfund’s personnel are encouraged to report suspected violations of the Code of Conduct to their superior in the line organisation, the Director, Administration or the Lead Counsel, the occupational safety and health organisation or the CEO. If using these channels is not possible, reports can be submitted anonymously either through the Arkku feedback form on the intranet or through the reporting channel available on Finnfund’s external website.

Parties external to Finnfund are encouraged to report all suspected violations of the Code of Conduct through the reporting channel available on the company’s website.

This Code of Conduct was approved by Finnfund’s Board of Directors in its meeting on 31 May 2019, after which they are presented to the entire personnel and published on the company’s intranet and its external website. The Code of Conduct are effective starting from the same date.