Code of conduct
Areas:
- Responsibility
- Conflict of interests
- Inside information
- Related party transactions
- Anti-corruption
- Data protection and information security
- Working life rules
- Responsibility
The Seafarers’ Pension Fund is committed, in all its activities, to compliance with the valid legislation, the regulations and guidelines of the authorities and an ethically sustainable operational approach. The Pension Fund also requires corresponding compliance from its co-operative partners.
Responsible activities ensure pension security and a solid solvency for seafarers and advance the operating environment for Finnish seafaring.
Within its activities, the Seafarers’ Pension Fund focuses on the following UN Sustainable Development Goals:
3. Good Health and Well-being
8. Decent Work and Economic Growth
12. Responsible Consumption
13. Climate Action
16. Peace, Justice and Strong Institutions
Conflict of interests
The pursuit of personal interests cannot compromise the independence and impartiality of decision-making carried out by the Seafarers’ Pension Fund. An individual cannot participate in the decision-making process or related preparation if the decision concerns business with a company in which the individual or a family member have an interest.
Employees of the Seafarers’ Pension Fund and members of its administrative body must identify any possible aspects of bias in their own activities and refrain from performing any task that might compromise the state of independence.
In terms of conflicts of interest, the Code of Conduct of the Seafarers’ Pension Fund is complemented by separate guidelines concerning related party transactions and inside information.
Inside information
The investment activities of the Seafarers’ Pension Fund are primarily managed using external asset managers. An individual who is employed by the Seafarers’ Pension Fund or who serves as a member of its administrative body might, however, as part of their own activities or outside of these activities, receive undisclosed and essential information concerning an individual security. The misuse of this type of inside information is prohibited.
The misuse of inside information refers to, for example, trade of such securities on a person’s own or another’s behalf, the provision of investment advice concerning such securities, and the provision of such information about securities to another person when such information is not necessary to perform their work tasks. A person who has received inside information must also refrain from participating in any preparation, processing and decision-making concerning such securities.
Related party transactions
Any transaction considered to be significant that is to be carried out with a related party shall be approved by the Board of the Seafarers’ Pension Fund. The significance of the transaction is assessed on a case-by-case basis and is affected by the monetary value of the transaction and other factors such as the realisation of activities that depart from normal commercial conditions.
Related parties include the members and deputy members of the Board and Delegation, members of the Executive Group, others in supervisory positions, auditors as well as the spouses and wards of these persons. Any community in which an aforementioned person serves in a controlling position is also considered to be a related party.
The Seafarers’ Pension Fund regularly publishes on its website information concerning related party transactions that have been approved by the Board.
Anti-corruption
All forms of direct and indirect corruption are prohibited by the Seafarers’ Pension Fund. No person who is employed by the Seafarers’ Pension Fund or who serves as a member of its administrative body can receive or give any gifts or hospitality that exceeds the reasonable or normal practice within business life.
When a stakeholder or co-operative partner organises an event related to the activities of the Seafarers’ Pension Fund and the aforementioned person participates in the event, the Seafarers’ Pension Fund shall pay this person’s travel and accommodation costs.
The Seafarers’ Pension Fund also requires that its subsidiaries, stakeholders and co-operative partners commit to a corresponding anti-bribery and corruption policy.
Data protection and information security
The Seafarers’ Pension Fund processes confidential information concerning shipping companies, the insured, pension and benefit recipients, residential applicants and tenants, and personnel only to the extent necessary to manage its duties. Stored information can be disclosed only to the extent allowed by law with respect to the management of data protection as determined by the Seafarers’ Pension Fund. The website of the Seafarers’ Pension Fund contains detailed privacy policy statements regarding data security and registered persons can make requests concerning their own information through our online service.
The Seafarers’ Pension Fund complies with a data security policy that endeavours to safeguard important information, also under exceptional circumstances.
The personnel of the Seafarers’ Pension Fund have signed a non-disclosure agreement that obligates them to keep secret all information received in the course of their work, also after their employment at the Fund ends.
Working life rules
Employees of the Seafarers’ Pension Fund are treated equally. All forms of discrimination, bullying and harassment are forbidden.
Special attention is paid to ensure a safe and healthy working environment that promotes well-being at work.
The competence and coping abilities of employees are supported through the provision of thorough task orientation. Competence is maintained and developed by offering sufficient further training.
Dealing with misconduct
The Seafarers’ Pension Fund requires of all its employees and members of its administrative body to comply with the valid laws and regulations, the Code of Conduct and supplementary guidelines, as well as to report any observed misconduct or suspicion of misconduct.
Reports are processed confidentially and any guilty parties shall be sanctioned as appropriate depending on the gravity of the act. Any report made in good faith will not have any adverse consequences for the informant.
The report can be made to a supervisor, a compliance officer, by email: compliance(at)seafarerspensionfund.fi or anonymously through the website.