Ethical guidelines

Table of content

Ethical guidelines

By complying with the principles of good administration in line with the Administrative Procedure Act, Finnvera’s employees enhance the company’s reputation and help it achieve its goals as an expert valued by its clients and as a specialised financing company.


Finnvera aims to continuously ensure reliably impartial and independent operations. Finnvera values diversity and treats everyone equally.

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.

Finnvera will not promote purposes not included in its sphere of authority or otherwise misuse its authority.


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

Finnvera’s operations must not be based on inappropriate or otherwise irrelevant purposes. The employees will not participate in business ventures that might constitute a conflict of interests due to the financial position of the employee or a person with a close relationship with the employee or offer, demand or accept inappropriate gifts, payments or trips.


Finnvera’s operations must be purposeful and reasonable in proportion to the intended goals.

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


Finnvera ensures the stability of the general trust in the validity and accuracy of its operations and the permanence of its decisions.

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. The services are implemented by productively taking into account the objectives and purpose specified in legislation.

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.

The provision also prevents Finnvera from disclosing client relationships. The client’s consent is always required for disclosing client relationships or business and trade secrets. The cases and documents included in Finnvera’s own business secrets are not public.

Ensuring impartiality at Finnvera

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.

Secondary positions

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.

Gifts and hospitality

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.