OP-Pohjola Group’s
Code of Business Ethics
Contents
1
Introduction
2
We build our operations on our shared
values
3
We work with our customers
4
Our cooperation with all stakeholders is
open and fair
5
We identify conflict-of-interest situations
and know how to avoid them
6
We are in control of handling information
7
Together we can create a safe, inspiring
and equal workplace
8
Everyone at OP-Pohjola Group is
responsible for following this Code
OP-Pohjola Group’s Code of Business Ethics
02
Introduction
The Code of Business Ethics forms the ethical
background for the conduct of all employees and
members of governing bodies of OP-Pohjola Group
irrespective of their roles, positions and business
locations.
1
Approved by the Supervisory Board of OP-Pohjola
Group, this Conduct applies to the Group as a whole. It
is the responsibility of each OP-Pohjola Group entity's
Board of Directors to make sure compliance with this
Code.
In addition to this Code of Business Ethics, we adhere
to applicable national and international laws,
regulations and generally accepted practices.
OP-Pohjola Group has signed the UN Global Compact
initiative which the Group employees follow in their
work.
All OP-Pohjola Group employees and members of
governing bodies are expected to be familiar with the
Code of Business Ethics to the extent that they can
follow it in their everyday work. In addition, we have a
number of more detailed policies and guidelines that
help in putting the Code into practice.
OP-Pohjola Group’s Code of Business Ethics
03
We build our operations on our
shared values
We are on a mission
We promote the sustainable prosperity, well-being
and security of our owner-members, customers and
operating regions through our local presence.
Cooperative principles lie at the core of our operations,
which help us to promote prosperity and well-being
and support businesses on a local level.
Our customers are also our owners. Rather than
focusing on seeking short-term profits, we aim at
continuous and long-term prosperity together with our
customers and society.
OP-Pohjola Group is made up of Group member
cooperative banks and OP-Pohjola Group Central
Cooperative which they own, including its closely
related companies. These companies include
OP-Services Ltd, Pohjola Bank plc and Helsinki OP
Bank Plc.
The mission of each Group company is to provide its
customers and owners with competitive services
tailored to their needs.
Shared values create trust
2
Providing individuals, families, businesses and
institutions with banking and insurance services
requires that our customers can trust us in all
situations. This trust and permanent customer
relationships have their foundation on our solid value
base.
In addition to guiding us in customer work, our shared
value base also creates internal unity. Committing to
our values means that they will truly steer our everyday
decisions.
Corporate governance ensures a welldefined division of responsibility
We pay attention to the requirements of corporate
governance in organising our operations. We organise
our tasks with a view to be able to control them
efficiently. We publish any information required for
ensuring good corporate governance.
We adhere to confirmed policies and guidelines in our
work. We make decisions only within the framework of
authorisations granted to us. We are all responsible for
doing our share in implementing efficient internal
control.
Our core values
People-first approach
OP-Pohjola Group has a human focus. A genuine concern
for customers and co-workers is the starting point of our
operations.
Responsibility
We operate locally, regionally and nationally as an
exemplary and ethically responsible company. Bolstered
by our strong professional skills, we bear responsibility for
the high quality and reliability of our services.
We bear responsibility for society
OP-Pohjola Group aims to be the forerunner of
corporate social responsibility in the Finnish financial
sector. Our cooperative principles lay a solid foundation
for this goal. We should also bear in mind that
reliability and a strong sense of responsibility are
prerequisites in the financial sector.
Corporate social responsibility is an integral part of our
everyday operations. For that reason, responsibility
steers our decisions together with our shared values.
Prospering together
Prospering together with our customers points the way to
the development of our operations and services.
Operating as a unified group gives our customers greater
security and improves our service capabilities.
OP-Pohjola Group’s Code of Business Ethics
04
We work with our customers
We know our customers and always
operate fairly
3
We know our customers and familiarise ourselves with
them and their background to the extent required for
the good management of customer relationships.
Knowing customers is helpful in identifying their needs,
thereby enabling us to provide the best possible
products and services.
In compliance with good practice, we treat our
customers equally and with a professional approach.
We adhere to the regulations on customer due
diligence/KYC and consistent practices. We are engaged
in active efforts to prevent money laundering and
terrorist financing.
Customer feedback is invaluable for us
Receiving feedback from customers is our opportunity
to improve our service. For that reason, we take
customer feedback and complaints seriously. We
handle customer complaints without delay as part of
internal control and reporting by using specific systems
and processes.
In case our customers are not satisfied with our
decision related to their complaint, we will provide
them with instructions on how to submit their case for
further investigation by impartial bodies.
OP-Pohjola Group’s Code of Business Ethics
05
Our cooperation with all stakeholders
is open and fair
4
We require ethical conduct of our
partner companies
We build success together with other
players
In outsourcing, purchasing and subcontracting, we
operate on a coordinated and market-driven basis. Our
selection criteria for our partners are objective,
including factors such as quality, availability, price and
service level.
Thanks to our extensive service network, we have a
strong local presence through which we are dedicated
to promoting prosperity, well-being and security in our
operating regions.
Our service providers undertake to comply with
applicable laws, regulations issued by the authorities
and best practices within their industry. In addition,
their operations must comply with the ethical principles
and practices of OP-Pohjola Group.
We engage in intense dialogue with decision-makers
and authorities. In addition, we maintain regular
contacts with financial regulators, as well as the media
and NGOs. By supporting educational institutions and
teaching financial skills to new generations, we are
building the foundation for future success.
We bear ultimate responsibility for our operations.
Therefore, we must be able to be sure that outsourcing,
purchasing or subcontracting will not jeopardise the
quality or continuity of our business.
Our approach towards our competitors
is respectful and businesslike
We are involved in improving practices within our
industry by participating in the work of trade
associations.
Our approach towards competition and our competitors
is respectful and businesslike. We do not fix prices,
agree on market shares or similar activities with our
competitors.
OP-Pohjola Group’s Code of Business Ethics
06
Our communications are based on
transparency and timeliness
We aim at active and open external
communications
Our internal and external communications are steered
by OP-Pohjola Group's strategy and values. Reliability,
initiative, long-term approach and open interaction are
the principles of our communications.
The two key factors in external communications are
transparency and timeliness. We maintain active
contacts with the media and help media representatives
in their work.
Internal communications form an integral part of a
prospering
workplace
and
leadership
work.
Considering that efficient exchange of information,
shared understanding and commitment to shared goals
are crucial for the Group's success, we encourage all
employees to engage in open dialogue. All Group
employees are responsible for doing their share in
internal communications.
The expert most familiar with the issue in question is
always the first person to comment on the issue for the
media. The senior management provides the media
with any information on the Group's strategy, business
principles and financial standing.
In order to make sure that our employees and members
of governing bodies have sufficient information on their
tasks and goals, we use several communication
channels, personal meetings and get-togethers in our
internal communications. In addition, we have
channels for giving feedback.
We have agreed on principles for using social media
together with our employees and the same principles
also apply to the management and administration.
Our communications under the Securities Markets Act
are governed by legislation and guidelines issued by the
relevant authorities and marketplaces. In this respect,
we provide the marketplace with a true, reliable and fair
view of OP-Pohjola Group's status and operations.
In addition, we will not use incorrect or misleading
information in our marketing communications. We
follow the marketing guidelines defined by the
International Chamber of Commerce and the good
marketing practice.
OP-Pohjola Group’s Code of Business Ethics
07
We identify conflict-of-interest
situations and know how to avoid them
5
We identify conflict-of-interest
situations
We keep our personal issues separate
from business
As we provide our customers with banking, investment,
insurance and real estate agency services, we have
several roles vis-à-vis our customers. Although
preventing any conflict of interest from arising is always
our priority, conflicts might still arise for various
reasons and in a variety of situations. Our customers'
interests may be in conflict with the interests of our
employees, members of governing bodies, other
customers or OP-Pohjola Group.
No one has the right to promote his personal issues by
acting as the presenter, decision-maker or executor in
these matters. No employee, executive or member of a
governing body representing OP-Pohjola Group may be
involved in his personal financial transactions or those
of his related parties, nor may he in any way influence
the handling of such transactions. This also applies to
the documents, information, terms and conditions and
payments related to the transactions.
In case we consider that a conflict of interest has arisen,
we will provide the customer with sufficient
information on the nature and causes of the conflict
before we execute the transaction on behalf of the
customer.
Each Group employee and member of a governing body
demonstrates professionalism and responsibility by
managing his personal finances well.
Our objective is to increase long-term customer
relationships.
However,
long-term
customer
relationships may involve a risk of a conflict of interest.
For that reason, we follow this Code even if we know
our customers personally.
In order to avoid conflicts of interest, we must keep
personal issues separate from business. In addition, we
may not engage in any activities competing with Group
operations. For example, an employee in charge of
purchasing decisions may not opt for a service provider
with whom he is friends, unless the employee has
objective reasons for preferring this particular service
provider.
We avoid all situations where we or OPPohjola Group may become suspected of
bribe-taking
We never offer or accept a present, service or
entertainment which could be interpreted as an attempt
to influence business decisions. An outsider may
interpret services also as bribery. We identify any
suspicious situations and prevent them from arising in
the first place.
Maintaining good stakeholder relations requires
interaction in various situations in which we observe
reasonableness.
Practices related to acceptable gifts must be
transparent. Furthermore, the gift donor shall have no
expectations or obligations with respect to the donee.
Money gifts or gift vouchers comparable to money are
always prohibited.
OP-Pohjola Group does not support political parties or
organisations. In addition, we as a company do not
support electoral campaigns of individual candidates.
OP-Pohjola Group’s Code of Business Ethics
08
We are in control of handling
information
We never breach bank and insurance
secrecy
Guaranteeing bank and insurance secrecy is an
absolute prerequisite in everything we do.
We may utilise customer data internally across
functions, provided that sharing such information will
help us improve customer service and risk
management.
6
Data security is an integral part of
professionalism
Data security lies at the core of OP-Pohjola Group's
operations and good data processing practices.
We should bear in mind that our systems are not the
only places where information can be found. Print-outs,
lunchtime discussions and emails saved in our mobile
phones are examples of places where such information
is stored. Ensure that the privacy of your employer,
organisation, co-workers and customers will not be
breached, neither offline nor online. We take pride in
our solid data security practices.
We only process data related to our
business
An integral part of our work is handling information
that needs to be kept secret in order for our customers
to maintain their trust in us.
This data may never be distributed more than is
required for the performance of our duties. All data
must be handled in accordance with applicable
legislation in force and the best practices within the
industry.
In addition to customer data, other confidential
information includes details related to our business
operations, employees and members of governing
bodies.
Using confidential information or inside information for
one's personal benefit or that of others is always
prohibited.
OP-Pohjola Group’s Code of Business Ethics
09
Together we can create
a safe, inspiring and equal workplace
7
We appreciate others and their skills
We are all equal
Good management and leadership lay the foundation
for our corporate culture. We appreciate all of our
employees and their skills. The objective of human
resources management at OP-Pohjola Group is to
support our long-term performance while constantly
enhancing our individual and shared competencies. We
all have the duty to work in a responsible way and
promote the interests of the Group and its companies.
Diversity means differences among people with respect
to personality, sexual orientation, ethnicity, functional
capacity, age and other aspects of life. We treat
everyone equally regardless of any differences.
Our objective is to constantly reinvent ourselves, as
individuals and as an organisation. In order to become
committed to our work and keep our motivation high,
we all need predictability, reliability and openness. The
purpose of our management culture is to meet these
needs.
Equality is manifested in employee selections,
remuneration, career development, training and general
practices in the workplace. This principle also applies
outside our organisation – in governing bodies, among
customers and partners.
Long-term commitment also means that we pay
attention to the life situation and age of each employee
in our management and leadership, organising,
planning and development activities.
Our remuneration policy is fair and the criteria under
our incentive schemes are transparent. In all decisions
related to recruiting, career development and
remuneration, the most important selection criteria are
the person's qualifications and competencies.
We appreciate diversity as it is good for workplaces,
Group companies, administration, customers and
society.
We monitor gender equality annually and in a
transparent manner. and report the results to
management and employees.
Workplace well-being means
everyone likes coming to work
that
Promoting the mental and physical well-being in the
workplace is a task shared by management, each
organisation and each employee.
No one may jeopardise workplace safety for themselves
or others. In our work, mental risks are often more
greater and more difficult to identify than physical ones.
In order to prevent work-related health hazards, we
need not only knowledge and skills but also a culture
where we identify risks and learn how to avoid them.
We have zero tolerance to misbehaviour and
misconduct and workplace harassment. Anyone who
notices disturbing or insulting behaviour must take
actions to stop it.
OP-Pohjola Group’s Code of Business Ethics
10
Everyone at OP-Pohjola Group is
responsible for following this Code
Ethical responsibility cannot be
outsourced
8
It is easy for us to think that acting ethically is
something we do without paying much attention to it.
However, each of us may suddenly face a situation
where we need to make an ethical choice.
Remember that we are all involved in creating an
ethically sustainable corporate culture. Following
guidelines and policies is everyone's task – no one can
outsource his ethical responsibility to someone else.
This also applies in situations that are unrelated to your
own actions.
Any breaches of this Code must be rectified without
delay. In the event of continuous or material breach of
the Code, the Group's Supervisory Board will issue a
reprimand to the Board of Directors of the entity in
question.
If you are not certain about something, ask yourself the
following questions:
• Is this legal, fair and ethical?
• What would this look like in public – would such
publicity harm the reputation of OP-Pohjola Group?
• Will we be able to face our customers, co-workers and
other stakeholders while being open about this
action?
We are all responsible for knowing the most recent
guidelines related to our duties.
If you are unsure about how to follow the Code of
Business Ethics, please discuss the matter with your
immediate superior, HR Services or Compliance. In
addition, you may contact the Chief Audit Executive
confidentially in matters related to breaches of this
Code.
OP-Pohjola Group’s Code of Business Ethics
11