ILMARINEN'S CODE OF CONDUCT

Ilmarinen’s mission is to safeguard the statutory employee pension cover of employees and self-employed persons, as well as to manage the investment assets that cover future pensions. As we are a pension insurance company owned by our clients, responsibility is an inherent part of our daily operations and one of our corporate values alongside openness and success through teamwork.

Ilmarinen’s way of operating is determined in the company’s Code of Conduct. The Code of Conduct applies to all of our employees regardless of their position.

We comply with laws and respect human rights

Ilmarinen complies with applicable laws and regulations in all of its operations. In addition, we abide by the human rights determined in the UN’s Universal Declaration of Human Rights, which include, among other things, freedom of opinion and religion, equality and the elimination of discrimination. We do not tolerate forced labour or child labour. As an employer, we follow the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

We comply with good insurance practice

Ilmarinen complies, in its operations, with good insurance practice according to the guidelines approved by the company’s Board of Directors. Our pension and insurance decisions are governed by earnings-related pension legislation, the Finnish Administrative Procedure Act and the application guidelines issued by the Finnish Centre for Pensions. Our core operating principles include to issue fair and quick pension decisions and to disclose the grounds of the decisions to the pension applicant in an understandable manner.

We treat our clients fairly and equally.

In marketing, we strive to provide all the information on our products and services that may be relevant for clients’ decision-making.We do not approve of inappropriate or indecent marketing.

We do not give or accept bribes

Ilmarinen’s employees are not allowed to seek personal advantage by making use of their position or Ilmarinen’s property or information. Ilmarinen’s employees are not allowed to participate in decision-making on issues concerning Ilmarinen’s business transactions with companies in which they or their related parties are involved.

We are not allowed to accept or offer gifts or hospitality that are inconsistent with usual business practice or may affect independence.

Insider rules guide our operations

The use of insider information is prohibited.Ilmarinen complies with the insider guidelines of NASDAQ OMX Helsinki Ltd insofar as possible for an unlisted, mutual pension insurance company. Ilmarinen’s Board of Directors has approved insider guidelines aimed at promoting public reliability. The guidelines also aim at increasing insider knowledge within the company to prevent any unintentional breach of the rules.

Competition in the earnings-related pension industry

Pension insurance companies must take into account the requirements of the competition legislation in their operations. Pension institutions responsible for statutory insurance cover must, however, co-operate as far as required for the equal treatment of the clients of the earnings-related pension system and the implementation of legal protection. The collaborative aspects pertain to the essence of the social security role of statutory earnings-related pension insurance. In certain aspects, co-operation has been made possible for pension insurance companies through explicit provisions in the earnings-related pension legislation.

We process information with great care

To handle statutory earnings-related pension cover, Ilmarinen maintains and processes confidential information. We process information with great care as required by legislation and ensure privacy in processing personal information. The obligation of non-disclosure is emphasised in work induction and in internal training.

Responsibility for employees

Responsibility for the company’s employees is an essential part of Ilmarinen’s social responsibility. The cornerstones of Ilmarinen’s operations are a good working environment and respect for the individual. We comply with labour legislation and the collective agreement of our industry. We maintain equality and do not tolerate bullying, harassment or discrimination. We provide a safe working environment and take care of our employees’ well-being.

We pay attention to environmental impacts

Although Ilmarinen’s direct environmental impacts are relatively minor, we pay attention to environmental issues in all of our operations. We are committed to choosing environmentally friendly products and solutions in our sourcing. Environmental responsibility is particularly highlighted in the assessment of the environmental impacts of the real estate and other investment objects owned by the company. In our own premises, we comply with WWF’s Green Office environmental management system.

Responsible sourcing

We also expect our suppliers and service providers to commit to similar responsible practices. This is the starting point for the creation and maintenance of our business relationships.

What to do in case of violation of the Code of Conduct

Any acts or situations that are in conflict with Ilmarinen’s Code of Conduct shall be addressed primarily through the supervisor, a representative of the management or the head of internal control. These cases shall be processed as quickly as possible, with confidentiality and impartiality, and actions shall be taken based on them, in co-operation with the Human Resources or Legal department where necessary. Depending on the nature of the issue at hand, Ilmarinen’s sustainability working group can also take a stance on the interpretation of the Code of Conduct and address conflict situations at a general level.

- Code of Conduct (pdf)