Code of conduct
1 We comply with the law and act responsibly
The Seafarers' Pension Fund is committed in all its activities to complying with applicable legislation, regulations and guidelines issued by the authorities, and to operating in an ethically sustainable manner. We do not accept breaches of the law, nor do we ever encourage or instruct anyone to violate applicable legislation. Key legislation includes, among other things, laws concerning the status of employees, equality, protection of privacy, the prevention of bribery and other corruption, occupational safety, and environmental protection. The Seafarers' Pension Fund requires similar conduct from its partners as well.
Responsibility is a theme that runs through everything the Seafarers' Pension Fund does. For us, it means responsibility for people, including seafarers, pension recipients, those who work for us, and tenants. It also means responsibility for the environment and for society.
Responsible operations safeguard seafarers' pension security and strong solvency, and support the operating conditions of Finnish shipping.
The following UN Sustainable Development Goals are particularly emphasised in the operations of the Seafarers' Pension Fund:
The main goals are:
• 3. Good Health and Well-being,
• 13. Climate Action, and
• 16. Peace, Justice and Strong Institutions.
The supporting goals are:
• 8. Decent Work and Economic Growth, and
• 17. Partnerships for the Goals.
2 We do not accept bribery and follow these principles regarding gifts
We do not accept bribery in any form. We do not promise or pay bribes or illegal payments to any party, nor do we encourage or instruct anyone to accept or give them.
The Seafarers' Pension Fund also requires its subsidiaries, stakeholders and partners to commit to anti-bribery practices.
No person employed by the Seafarers' Pension Fund, or serving as a member of one of its governing bodies, may accept or offer any gift or hospitality that cannot be regarded as reasonable and part of normal business practice.
Where a stakeholder or partner organises an event related to the activities of the Seafarers' Pension Fund and such a person attends, the Seafarers' Pension Fund will pay that person's travel and accommodation expenses, where applicable.
3 We avoid conflicts of interest
Seeking personal gain, or gain for a related person, in the performance of work duties is not acceptable.
The independence of the Seafarers' Pension Fund in decision-making must not be compromised by the pursuit of personal benefit.
Any circumstances that may be perceived as a conflict of interest must be reported without delay, and solutions must be considered together. No person may participate in decision-making or in the preparation of a decision if the matter concerns a transaction with a company to which that person or a related person has a connection.
Any transaction considered significant and entered into with a related party of the Seafarers' Pension Fund must be approved by the Board of the Seafarers' Pension Fund. The significance of a transaction is assessed on a case-by-case basis and depends not only on its monetary value but also on other factors, such as whether it is carried out on terms that deviate from normal commercial terms.
Related parties of the Seafarers' Pension Fund include members and deputy members of the Board and the Delegation, members of the Executive Group, others serving in a comparable position, auditors, and the spouses and persons under guardianship of the persons referred to above. Related parties also include any entity over which any of the above-mentioned persons exercises control.
The Seafarers' Pension Fund keeps up-to-date information on Board-approved related party transactions available on its website. In addition, it publishes information on positions of trust held outside the Pension Fund by Board members and senior management.
4 We respect human rights and treat each other equally
We treat and serve all customers equally and without discrimination.
We treat employees equally and comply with applicable employment legislation. We respect the dignity of the individual, privacy, and freedom of religion and conscience. We do not accept discrimination, harassment, threats or insulting behaviour. We actively ensure safe working conditions.
Creating and maintaining a good working atmosphere is a shared responsibility. A functional and fair work community, in which everyone can feel comfortable at work, is built on mutual trust, respect for people, genuine care, willingness to help, and team spirit.
Managers are responsible for promoting open and constructive discussion on all work-related matters and for encouraging employees to ask questions, make development proposals and raise any concerns. They also play their part in the induction of new employees and intervene, where necessary, in matters requiring correction.
5 We communicate openly
We communicate openly, directly and honestly. The Seafarers' Pension Fund website contains extensive information about us, and in addition the Albatrossi magazine is published four times a year. The magazine is also published online. We publish our annual report and sustainability report annually as online publications.
However, the Seafarers' Pension Fund has an obligation to take into account insider rules and confidential business secrets that we cannot disclose.
In social media, we follow the same principles as in all other communication and interaction with regard to the confidentiality and accuracy of information. We never act in a way that could damage the reputation of the Seafarers' Pension Fund.
6 We protect business secrets and ensure information security
We keep confidential any information obtained through our work concerning the Fund's operations, personnel, customers and partners, and we do not disclose or hand over such information to anyone other than those entitled to receive it. Information relating to security arrangements is also confidential, including information on cash handling, information security, alarm systems and instructions for exceptional situations.
We use information systems and software in accordance with agreements and user rights. We always ensure that confidential or important information is not lost and does not end up in the hands of outsiders. We handle electronic tools and information with due care. When leaving our workstations, we do not leave records or materials containing confidential information on our desks.
The personnel of the Seafarers' Pension Fund have signed a confidentiality undertaking that obliges them to keep information obtained in the course of their work confidential even after their employment has ended.
7 We process customer data and other personal data confidentially
At the Seafarers' Pension Fund, confidential information concerning shipping companies, insured persons, pension and benefit recipients, and personnel is processed only to the extent necessary for the performance of duties. Stored data is disclosed only within the limits permitted by law and in accordance with the Seafarers' Pension Fund's data protection management model. Detailed privacy notices have been published on the Seafarers' Pension Fund website, and data subject requests concerning one's own data can be made through the electronic service.
8 We comply with insider regulations and the Seafarers' Pension Fund's insider guidelines
A person employed by the Seafarers' Pension Fund or serving as a member of one of its governing bodies may, in the course of their duties or outside them, become aware of non-public and material information relating to an individual security. Misuse of such inside information is prohibited.
Misuse of inside information includes, for example, trading in such a security on one's own behalf or on behalf of another person, giving investment advice concerning the security, and disclosing information concerning the security to another person when this is not related to the normal performance of work duties. A person who has obtained inside information must also refrain from participating in the preparation, handling and decision-making of matters concerning such a security.
A permanent insider list has been established for the Seafarers' Pension Fund. The insider guidelines have been distributed to all persons included in the permanent insider list. In addition, there may be project-specific insider lists, and the persons included in them are always instructed separately.
9 Reporting concerns or violations
The Seafarers' Pension Fund requires compliance with laws and instructions. Everyone has a duty, where necessary, to ask for help and to report suspected or detected violations without delay.
Reports are handled confidentially, and misconduct will result in consequences for the person responsible, based on the seriousness of the act. A report made in good faith will not result in adverse consequences for the reporting person.
A report may be made to a supervisor, to the compliance officer, by email to compliance(at)merimieselakekassa.fi, or anonymously through the website.