Ethical principles

1. Introduction

These Evli Group (”Evli”) Ethical Principles approved by Evli Bank’s Board of Directors outline the general principles and guidelines related to Evli’s operations and practices that each person involved in the governance of the Evli Group must adhere to, regardless of his/her position, role or workplace. It is also the responsibility of the Board of Directors of each company in the Evli Group to see that these ethical principles are adhered to in the companies of the Evli Group.

It is the responsibility of each supervisor to ensure that these ethical principles are known and applied in his/her area of responsibility. It is the responsibility of the business units to decide whether more detailed guidelines are in some respects necessary.

Non-compliance with or neglect of these ethical principles, or any regulations, procedures and guidelines that come into force later, may lead to disciplinary measures against the person(s) violating these principles, regulations, procedures or guidelines.

2. Values

Evli’s objective is to be the leading Finnish private bank and Evli’s mission is to help clients increase their wealth. Evli offers a comprehensive range of products and investment and wealth management services, backed by robust professional skills. Evli’s goal is that each conceived product and service solution meets an individual client’s needs and benefits him/her over the long term. Evli is constantly developing its employees’ professional skills to ensure that Evli remains at the head of the pack and is able to offer innovative, market-savvy solutions.

Evli’s operations are founded on entrepreneurial spirit, well-working relationships, and continuous learning and development. Integrity and transparency characterize Evli’s everyday work. Evli’s employees undertake their responsibilities honestly and loyally, and behave correctly towards clients, officials, the general public and other stakeholders, as well as to colleagues.

In organizing its operations, Evli applies the principles of good corporate governance while complying with all applicable laws, official regulations, and approved policies and guidelines.

While Evli’s goal is primarily to gain a good return on clients’ investments, it also considers environmental and social factors in its investment and corporate activities. Evli strives, through responsible investment, to promote transparency and open dialogue between clients and its investment professionals.

3. Relationships with clients

Evli’s business idea is to provide clients with a versatile, high-quality service. Evli makes sure that it knows its clients and is familiar with their businesses and financial status to the extent required by the client relationship. Furthermore, Evli is committed to executing orders in such a way that the client’s best interests are always the top priority. Employees must be constantly aware that they are representing Evli when they work with clients. They must always act professionally and in a way that treats clients as equals. If there is any possibility of a conflict of interest arising between Evli and the client, every attempt must be made to identify and prevent it in advance, or, if such a conflict has already occurred, the client must always be treated fairly (see section 8, Conflicts of Interest).

In identifying and becoming familiar with its clients, Evli complies with the regulations and procedures valid at any given time. More detailed instructions and procedures are given in the Board of Directors’ approved policy on identifying and knowing clients and in the related internal guidelines.

Client feedback and complaints are always taken seriously. Client complaints are dealt with immediately, as laid down in Evli’s procedural guidelines and process concerning client complaints.

4. Relationships with stakeholders

Communications with all stakeholders, including business partners, competitors and the authorities, must be constructive and respectful.

Evli takes responsibility for its operations and chooses its partners carefully to ensure the high quality and continuity of operations. We insist on our partners’ compliance with the law, official regulations and the applicable operational guidelines. Our partners must act in conformity with Evli’s ethical principles. All outsourcing follows procedures laid down in separate outsourcing guidelines.

5. Relationships between employees and Evli

Evli has a written Human Resources Policy that outlines the central policies in the various sectors of HR management affecting the Evli Group. Competent and highly motivated personnel are essential for Evli’s continued existence, growth and development. Evli’s goal is to produce added value for its clients, and this is furthered by creating a flexible, efficient and well-balanced work community characterized by innovation and the willingness to adapt and achieve change.

One of the main duties of senior management is to attend to, maintain and develop the competence of the employees, and to proactively contribute to employee health, endurance and work satisfaction. Implementation of the HR Policy requires dedicated effort from the employer and all employees to achieve and sustain an open, correct, and trustful atmosphere.

In our work community we respect and consider each other’s needs, because we are cooperating to achieve the company’s common goals. Evli treats all its employees even-handedly and fairly, independent of gender, nationality, age, religion, political affiliation, etc.

Evli Group has an incentive system covering the whole personnel. The purpose of the incentives is to motivate employees to implement the Group’s strategy and ensure profitable growth.

The implementation of business strategies is also ensured by continuous training. All Evli employees should have the opportunity to learn and develop themselves, provided they take personal responsibility for their own learning and progress. Continuous training and support for supervisors is also a permanent feature of Evli’s training policy.

Evli’s employees do not offer, solicit or accept improper gifts, trips or payments. Separate internal guidelines exist for cases of representation and business gifts.

The same principles apply to Evli’s internal communications as to communications with clients. Internal service and cooperation must be flexible and must take Evli’s overall interests into account.

Employees’ own investment activities must comply not only with the binding regulations, but also with the need for ethical behaviour. In all situations the client’s interests must be primary and may not be trampled on. Evli employees shall not pursue their own financial interests, and all their decisions must hold up under public scrutiny. When investing their own assets, employees must take full account of the trading rules and restrictions laid down in separate guidelines.

Secondary jobs or positions of trust that are external to the employment relationship with Evli must not influence the employee’s ability to perform his/her work and must not weaken the clients’ trust in Evli.

Each Evli employee is a part of compliance, risk management and the quality chain. Any problems related to compliance with laws and regulations, risk management or quality must be reported as quickly and accurately as possible to the responsible persons or to one’s own supervisor. Falsifying or withholding information is not appropriate or permissible under any circumstances.

Whistleblowing

Evli has also facilitated whistleblowing through a separate “whistleblowing procedure”. If an employee suspects that unethical behavior or actions in violation of laws, regulations, official guidelines or Evli’s own internal guidelines have occurred, he/she may initiate a whistleblowing procedure in accordance with separate guidelines.

6. Communications

Internal communications

At Evli, internal communications are seen as part of a well-functioning work community. At the unit and top management levels, communications take the form of open, face-to-face dialogue. Email is mainly used for one-on-one and small group communication. For matters of interest to the whole group, the communications department maintains an internal information network, the Evli Intranet. News concerning the Group is uploaded on the Intranet on a daily basis and acts as a general infobank. Employees are urged to read the Intranet daily in order to be fully informed on matters affecting the Group.

External communications

The vital elements of Evli’s external communications are coherence and consistency. The goal is for all communications to reflect Evli’s policies. The information disclosed must be correct and truthful, and its veracity must always be checked before publication. It is vital for Evli that external communications comply with the standards set and that they support Evli’s corporate image.

Evli encourages its personnel to participate in social media to promote the company’s corporate image. Evli’s employees are professionals in their field and highlighting this professionalism and creating visibility for the organization are important for Evli’s image. In line with Evli’s values, each Evli employee shall operate honestly and truthfully in social media. The communications in social media must also be based on openness, good taste and voluntarism.

The duty of confidentiality is always observed in Evli’s external communications, including those on social media. More detailed instructions on the standards to be upheld in external communications and on the principles and restrictions guiding the use of electronic communications are given in Evli’s internal guidelines.

7. Trust and confidentiality

Evli’s employees are bound by strict rules of confidentiality. Whenever information is exchanged or processed, Evli complies with the bank secrecy and data protection rules and regulations in force at that particular time. Any knowledge gained of a client's financial status, business secrets or other non-public matters during the course of work must not be disclosed to outsiders.

The confidentiality obligation is also observed in Evli’s internal operations, with confidential data always being handled only to the extent required to perform a work task.

Moreover, data related to Evli’s own business, employees and persons involved in governance is confidential, and the processing of such data is subject to the same rules and regulations as client data.

In order to fulfil its trust and confidentiality obligations, Evli complies with the Information Security Policy set by senior management. Evli’s Information Security Policy sets the requirements and defines the responsibilities for implementing information security at Evli.

8. Conflicts of interest

A conflict of interest is an exceptional situation related to the provision of investment services between Evli and a client, for example, and that may pose a significant risk to the interests of the client. Conflicts of interest may also arise between Evli and its personnel, or between one client and another.

Evli offers clients a broad range of products and services. Although it is always possible for conflicts of interest to arise when providing investment and related services, Evli seeks with all possible means to prevent any conflicts of interest that may pose a significant risk to the interests of the client. This is done primarily by actively identifying and preventing potential conflicts of interest by organizational and administrative means. Their aim is to ensure that Evli’s executives and employees perform their duties with integrity and loyalty and execute transactions with sufficient independence to protect the interests of clients.

Evli pays special attention to identifying and preventing conflicts of interest in its investment advice, investment research, asset management, transmission and execution of orders, and in its services related to new issues of securities.

The management of conflicts of interest is dealt with not only in these Ethical Principles, but also in the Risk Management Policy, and the Policy on Identifying Clients and Preventing Money Laundering, among others. The steps taken to manage conflicts of interest vary according to the business or service in question.

Conflicts of interest may be managed by the following means:

  • Preventing and monitoring the exchange of information between persons and functions by means of separate information systems and user authorizations and by the physical segregation of functions (so-called Chinese walls)
  • Preparing a code of conduct governing situations in which the offering or accepting of gifts or benefits is part of a normal business relationship
  • Compliance with predetermined principles governing the execution of transactions
  • Drawing up principles governing the secondary occupations and positions of trust held by Evli employees and executives
  • Drawing up trading regulations for Evli employees and executives, and guidelines for investment research

If, despite the above-mentioned measures, a conflict of interest cannot be prevented, the nature of and reasons for the conflict of interest must be explained to the client prior to the execution of a transaction. The client will then independently consider whether to go ahead with the transaction despite the conflict of interest. Evli may also decline to provide an investment service if there is a conflict of interest.

The contents and relevance of the Board of Directors’ approved policy on the identification and prevention of conflicts of interest are updated regularly.

 

Updated: November 13, 2015