responsible business principles · responsible business principles - code of conduct veritas...

RESPONSIBLE BUSINESS PRINCIPLES

Code of conduct

Responsible business principles - Code of conduct

Veritas Pension Insurance is one of the oldest insurance companies in Finland still operating today. We are responsible for the pension security of some 100 000 employees, entrepre-neurs and pensioners. Our task is to invest the pension assets confided to us in a profitab-le and safe way. We also have to make sure that the pension security of our customers is sufficient.

Our operations are guided by our values and our ethical business principles

Our operations are guided by our values - a strong customer-oriented approach, inspiring collaboration and a solution-oriented focus - as well as by the codes of conduct presented

in this document. Each employee at Veritas must comply with these principles in his or her work.

Statutory pension insurance is a strictly regulated and controlled field of operation. In its activities, Veritas follows national and international laws, regulations and regulatory requirements as well as internal instructions and principles.

Veritas does not participate in political activities.

The responsible business principles have been approved by the Veritas board of directors on 17 September 2019.


We act responsiblyAt Veritas we direct and develop our activities proactively, paying attention to the demands that are imposed on us by rules and regulations, principles of good governance as well as by our corporate environmental responsibility and our social responsibility. By taking care of our solvency, we also bear the responsibility of securing the sufficiency of the pension assets and the financing of the whole Finnish pension system. We participate in developing the pension system as a means of assuming our responsibility towards future generations.

Veritas demands responsible acting also from its partners in cooperation.

Responsible business activitiesGood insurance practicesVeritas observes the law and good insurance practices in its business operations and cont-ractual relations with its policyholders. The business transactions between Veritas and the policyholders must be market-based what comes to price and other conditions. When working with our customers, we follow the principles of responsible action and we treat our customers equally.

We make our pension and insurance decisions in accordance with legislation, legal usage and the application directives provided by the Finnish Centre for Pensions. It is important for us that our decisions are fair and in line with the common praxis of decision. We endea-vour to explain our decisions in an understandable way, and we readily answer any ques-tions related to them. We aim to serve our customers swiftly but thoroughly.

We only have identified customersThe obligation of an insurance company to know its customers and their businesses is cent-ral in both the Finnish pensions legislation (Employees Pensions Act, TyEL, and Self-Emp-loyed Persons’ Pensions Act, YEL) and the Anti-Money Laundering Act (AML Act). Veritas identifies and knows its customers and the quality and extent of their businesses. In earnin-gs-related pension insurance a customer must be identified in order to fulfil the insurance conditions.

Anti-bribery principlesVeritas condemns any form of direct or indirect bribery. Gifts given or received must not endanger the company’s independence. When offering or receiving gifts or hospitality, one must always consider the requirements of legislation and the internal principles of the com-pany. Veritas has set its internal anti-bribery principles.

Conflict of interestsSituations involving conflict of interests must be recognised and the emergence thereof must be prevented. An employee of Veritas cannot participate in the processing of an agreement between him/herself and Veritas. Personal advantage must not influence the decision making. If an employee encounters an assignment that involves a relative or an ac-quaintance of him or her, the employee must transfer the handling of the case in its entire-ty to a colleague. An employee must neither participate in the processing of a matter that involves Veritas and, for example, a service provider or customer company with which the person is associated, e.g. through employment or by being a member of its governing body, and where the interests of the person in question conflicts with the interests of Veritas.

If a situation of conflict of interests arises, one’s manager must immediately be notified.


Insider transactionsSignificant business transactions that a pension insurance company performs with its insi-der members must be dealt with by the company’s board of directors and they must be published. By this, the aim is to secure that the transactions between the company and its management are in accordance with the company’s interests.

Insider transactions include all legal acts that Veritas performs with insiders, regardless of their objects or designations.

In Veritas, insider transactions are to be dealt with by the board of directors when the company’s interest exceeds 5 000 euros or when the transaction is considered significant for other reasons. The significance of a transaction is assessed separately for each case.

Secrecy directions, professional secrecy, data protectionThe information handled within the earnings-related pension system is virtually always confidential. This information can be given to others than the person concerned only by the person’s consent or in a situation where a specific legal provision thereof applies. All information is to be handled in accordance with rules and regulations and the company’s internal directions.

In all stages of handling personal details, the principles for data protection and information security approved by Veritas must be followed. The data protection and information secu-rity knowledge of the staff is maintained by regular training and up-to-date instructions.

Insider guidelinesIn Veritas, we follow the insider guidelines validated by the company’s board of directors. The guidelines have been drawn up to advance the public reliability of our investment ac-tivities and the staff ’s knowledge of the insider rules, to avoid offending against them even unintentionally.

Veritas maintains a register of the permanent insider members. The public information of the register can be viewed on the web service provided by Euroclear Finland Oy.

For further information on data protection when we handle personal data, see

www.veritas.fi./data-protection

Corporate social responsibilityWe invest pension assets responsiblyAs an investor within the earnings-related pension sector, we take our responsibilities seriously. We act in a responsible way and encourage our investment objects to do likewi-se. The activities in which we invest have to be professionally organised and in accordance with the interests of our beneficiaries. We avoid conflicts of interests, we comprehensively assess responsibility issues in our investment activities and we evaluate each object separa-tely. Our activities aim to strengthen the stability of the financial market. When evaluating responsibility issues, we follow our principles for investments and corporate governance.

Environmental liabilityWe bear our responsibility towards the environment As a company, we develop our line of conduct to become more environmentally friendly. We also develop the work processes to make it possible for environmental leadership to encompass all our activities. Through the energy efficiency of our buildings, we can direct-ly make an impact on the environment and on preventing climate change. We continuous-ly try to find ways to cut down our energy consumption and to minimize harmful environ-mental impact. We further try to be proactive in environmental questions in our role as property developer and lessor.

We promote environmentally positive actions.

We are a responsible employerIn Veritas, we follow equitable employment practices as well as work-related laws and agreements.

We treat our employees equally and we emphasize the meaning of good and responsible leadership. We take care of the well-being and know-how of our staff and we support de-veloping their skills to better meet the demands of the changing operational environment.


Whenever one observes a lack of compliance with regulations or operational principles and there are risks involved in the situation, one is obliged to make a notification to the compa-ny’s compliance function. Veritas has also a channel for reporting malpractice. Through this channel, the employees can anonymously report suspected cases of offending laws of other regulations.

Each of us is creating a culture of responsibility.

Observance of the code of conductThe Veritas code of conduct is complemented and made concrete by the internal instruc-tions and definitions of policy. They guide the employees to act right and responsibly. Every new employee gets familiarized to the company’s responsibility instructions. All members of staff are obliged to regularly complete the online compliance course that includes a presentation of the code of conduct.

Each employee at Veritas is responsible for his or her own part that the company follows laws, regulations and directives. The heads of department are responsible for securing that the roles and responsibilities as well as the reporting obligations are clearly defined within the organisation.


Q U I C K T E S T F O R E T H I C A L A C T I O N S

1 Identify

Analyse

Rules

Quick test

2

3

4

Are you in a situation that involves an ethical question?

• What facts are you provided with?• What facts are missing?• Who will be affected by the decision?

• Does your decision follow rules and regulations?• Is your decision in accordance with the company’s values and operational principles?

If the action were to become public,would it, from an outsider’s point of view, seem ethically or morally dubious?

No

you can proceed

Yes

not recom- mended

Don’t know

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