Finnvera's ethical guidelines

Ethical guidelines

In its operations, Finnvera complies with the principles of good administration, as specified in the Administrative Procedure Act, and with the guidelines on ethical conduct compiled on the basis of these principles for the organisation’s internal use. All of Finnvera’s employees are bound by the ethical guidelines.

Finnvera regularly assesses the effectiveness of its ethical principles by Internal Audit and other independent internal and external assurance functions. Ethical matters, including policies, key processes and related control procedures are reviewed using a risk-based approach through individual audit engagements and continuous monitoring across the entire organisation.

Ethical principles and official liability

Finnvera’s operations are guided by its Code of Conduct and internal practical level ethical guidelines, which bring together the ethical principles and legal rules followed in its activities. These principles include good administration, equality and impartiality in decision-making, objectivity, proportionality, trust, high-quality service, transparency subject to confidentiality obligations, and careful management of conflicts of interest, gifts and hospitality, and insider information.

In addition, Finnvera personnel are subject to criminal-law official liability when performing public administrative tasks, in particular when carrying out Finnvera’s statutory financing functions. This means that the ethical principles described above are not merely guiding principles: when performing public administrative tasks, breaches of these obligations may ultimately constitute breaches of official duties and may give rise to criminal liability in accordance with the applicable provisions of Finnish criminal law.

Employee training on ethical standards

Finnvera’s Compliance function provides annual mandatory training on ethical principles for all personnel. Completion of the training is monitored by Compliance, and training completion status is reported by Compliance function to Finnvera’s senior management.

Statistics (completion percent) of the mandatory training on ethical principles for the last three years: (this year’s training will be carried out in November)

2025              97,3%
2024              100 %
2023              100%

Principles of good administration

In its operations, Finnvera complies with the principles of good administration, as specified in the Administrative Procedure Act.

Equality

Finnvera’s decision-making processes comply with generally accepted and equally applied principles. Finnvera’s decision-making is consistent and impartial and ensures that facts are always analysed with consistent criteria.

Commitment to purpose

Finnvera will only use its authority for purposes specified in the legislation applicable to Finnvera.

Objectivity

Finnvera’s operations are independent and justifiable both objectively and appropriately. Finnvera’s decisions are based on impartially analysed facts.

Proportionality

Finnvera must ensure that its operations are justified and correct in proportion to the nature and significance of each case to be processed.

Trust

In its operations, Finnvera complies with legislation, its previous decisions and its promises.

Service principles

Finnvera provides its clients high-quality, reliable and competent services. Finnvera advises its clients and ensures the sufficient and appropriate processing of cases.The decision contents of Finnvera are justified, coherent and comprehensible. The cases are processed without undue delay and avoiding unnecessarily prolonged procedures.

Principle of publicity

Subject to applicable legislation, the operations of Finnvera are based on transparency and openness as comprehensive as possible. However, Finnvera must not disclose the financial status of a client or other person, private and personal information or business and trade secrets to outsiders.

Ensuring impartiality

The impartiality guidelines are meant to ensure the impartiality, neutrality and independence of Finnvera’s operations. The guidelines include procedures related to disqualification, secondary positions, gifts and hospitality. In practice, Finnvera employees must personally assess and state their disqualification in the case under processing and withdraw from participating in the processing.

Finnvera employees must withdraw from decision-making, its preparations, espousal and presentation in situations where they are disqualified. The disqualification principles are included in the Administrative Procedure Act.

In order to secure general trust, the disqualification situation should always be analysed objectively, in other words how would it look to an outsider, even if the disqualification would likely not influence or could not influence the processing of the case or the related decision.

Finnvera employees must personally assess and state their disqualification in the case under processing. The member or presenter of a multi-member organ does not, however, make the decision on their disqualification; instead, it is assessed and settled by the entire organ after hearing the person in question.

The disqualified person must not participate in the processing of the case or be present when the case is being processed. The disqualification applies to the decision-making process, the presentation or the case and the preparations of the decision contents but not to ordinary office work, such as copying and sending documents.

A secondary position refers to an office, salaried work and position as well as profession, livelihood and business. A secondary position can be a service or employment relationship with an employer other than Finnvera, other type of service relationship as well as the practice of private commissions or business operations.

Secondary positions may cause commitments that weaken trust in the impartiality of Finnvera’s decision-making or the preparation of a case. For this reason, all secondary positions must be reported to the employer and they are only allowed on the employer’s permission.

When considering granting permission for a secondary position, Finnvera will analyse whether the secondary position will undermine trust in Finnvera’s impartiality or whether it will otherwise hinder the appropriate performance of the task or damage the employer as a competing operation. The permission cannot be granted if the secondary position would disqualify the Finnvera employee from their key work duties, with the exception of occasional or temporary disqualification.

Corruption refers to the abuse of power to gain unfair advantages. Bribery is a form of corruption. It means that, by offering a monetary or other kind of gift, the bribing party strives to influence the behaviour of the bribed party or some other matter related to the them.

All forms of corruption, such as giving or taking a bribe, are prohibited in Finnvera's operations. The precautionary principle must be observed when accepting gifts, benefits or hospitality. Ultimately, Finnvera employees are subject to criminal liability for acts in office as regards the offence of bribery.

The impartiality and independence of Finnvera employees constitute an essential foundation for Finnvera's financing operations. In addition to the actual prohibition of bribery, Finnvera employees are not allowed to accept or receive any financial or other benefit if it is likely to undermine confidence in the party concerned or in the impartiality of Finnvera’s actions.

According to the prudence principle, Finnvera employees should refrain from accepting a benefit if they suspect whether doing so would be acceptable. Trust may be undermined even if the financial or other benefit would not actually impact our duties.

Receiving a reasonable and ordinary financial benefit or gift that Finnvera employees also offer their clients and cooperation partners is allowed. It is acceptable to receive reasonable and ordinary anniversary gifts and Christmas presents, for example.

Receiving a benefit or a sign of hospitality always requires case-specific consideration. The following criteria is helpful in analysing the situation:

Value of the benefit in euros
Reasonable and ordinary nature of the benefit
The necessity of the benefit in terms of work duties
Nature of Finnvera cases concerning the party offering the benefit
Position and influencing opportunities of the party receiving the benefit
Motivation of the party offering the benefit