Sustainability management and good governance

The Savings Banks Group’s Code of Conduct is aimed at ensuring that the Savings Banks Group operates responsibly, ethically and in compliance with laws as well as orders and instructions issued by the authorities. All Savings Banks Group employees must know the Code of Conduct and follow it.

The Code of Conduct covers topics such as regulatory compliance, taking sustainable development into consideration, cooperation and fairness, the prevention of corruption and bribery, conflicts of interest, and the handling of confidential data and inside information.

Complying with regulations

Compliance with laws and regulations is a top priority for the Savings Banks Group in all its operations. To ensure compliance with laws and regulations, the Savings Banks Group has prepared guiding principles and instructions that all employees must follow.

Taking sustainable development into account

For us, promoting sustainable development goals means taking environmental impacts, social impacts – such as human rights – and the principles of good governance into account and incorporating them in all our business operations. We take climate change factors into account in our operations and aim to reduce the strain on the climate that we cause.

We want both our customers and partners to be able to rely on our judgment and responsibility in all situations. The Savings Banks Group supports and respects fundamental and internationally recognised human rights (including labour and consumer rights) and norms and ensures that our business operations do not negatively affect human rights.

In our sustainability strategy, we are committed to reducing our ecological footprint and increasing our positive environmental impacts in our own operations and value chain. We aim to promote the achievement of the goals of the Paris Agreement, and we have set climate targets in our responsibility strategy.

Cooperation and fairness

All our work is based on good cooperation both within the Savings Banks Group and with our partners. Good cooperation requires proper and respectful treatment as well as open and fair communication.

We accept each other’s different backgrounds, differences and personal characteristics and treat everyone equally. We value diversity and consider different people a source of strength. The Savings Banks Group does not condone discrimination based on ethnicity, gender, religion, age, sexual orientation or any other characteristic. No bullying, discrimination or harassment is permitted.

Preventing corruption and bribery

Corruption refers to the abuse of influence in pursuit of an advantage. This abuse may be illegal or otherwise unethical. Corruption can take the form of, for example, the provision or taking of unlawful benefits, conflicts of interest or the favouring of friends or relatives. The Savings Banks Group does not condone corruption in any form, neither in business activities nor in business partnerships.

We are very careful about accepting and offering gifts and hospitality. We never give or accept gifts, hospitality or services that can be interpreted as a bribe or an attempt to influence business activities

Conflicts of interest

A conflict of interest refers to a situation where the interests of a customer conflict with those of Savings Bank or a company belonging to the Savings Banks Group or its management or personnel representative or another customer. We actively identify and prevent conflicts of interest that may affect the interests of the customer. If a conflict of interest cannot be prevented, we will also clearly inform the customer of its existence.

The Savings Banks Group has a policy for managing conflicts of interest.

Processing confidential information

Our operations are based on trust. This means that protecting the confidentiality of customer data and ensuring the data protection of personal data, as well as ensuring information security and the protection of trade secrets, are absolutely essential for us.
Compliance with banking and insurance secrecy is an absolute requirement for all our operations. We only process confidential information in the manner and to the extent required by our duties.

Processing inside information

Using or distributing inside information is prohibited. Inside information refers to information of a precise and undisclosed nature relating to an issuer or a financial instrument which, if disclosed, is likely to have a significant effect on the price of that financial instrument. The staff of the Savings Banks Group may receive inside information in the course of their work through, for example, discussions with customers.

We follow Finance Finland’s trading guidelines. In accordance with the guidelines, we do not trade in our own personal securities or other financial instruments by misusing inside information or other confidential information, or in such a way that our own interests take precedence over the interests of the customer. We also do not, for example, advise or direct another person close to us to trade in a way that would be forbidden to us.

Whistleblowing

The Savings Banks Group values an environment that encourages open exchange of information. We have established a special independent whistleblowing channel for the reporting of breaches of regulations and policies. Whistleblowing notifications are handled by designated persons representing independent functions, and the processing of the notifications is carried out in compliance with the confidentiality provisions laid out in the Whistleblower Act.

Suppliers and partners are key stakeholders to us, and we actively promote responsibility in all of our partnerships. Our aim is to enhance positive impacts on the environment and society and to reduce negative impacts, also through our partnerships.

That is why responsibility is a key evaluation criterion in our selection of partners. Particularly when making external fund investments, we aim to select partners whose investment philosophy and approach are aligned with our sustainability priorities.

We conducted a materiality analysis in 2022 to identify our key sustainability themes and assess their financial significance to our business operations. The identified measures for managing and preventing the related risks included, for example, adequate contractual arrangements in the selection of partners, and monitoring the operations of partners. Sustainability has also been taken into account in the Savings Banks Group’s supply chains by incorporating sustainability-related questions into the broader supplier survey.

The purpose of the sustainability policy is to serve as a guideline for the sustainability of the Savings Banks Group, alongside the sustainability programme and roadmap. The sustainability policy defines the scope and basic principles of the Savings Banks Group’s sustainability efforts. Among other things, the sustainability policy describes the Savings Banks Group’s sustainability principles, approaches concerning sustainable investment, lending and advisory services, exclusion principles applied in investing and lending, and reporting related to the sustainability policy.

Our basic principles of sustainability are as follows:

• We are committed to good corporate governance, and we operate transparently and in accordance with ethical principles.
• We are committed to assessing and managing risks. We do not tolerate corruption, bribery, money laundering or terrorist financing.
• We are committed to promoting occupational wellbeing, good leadership, diversity and equality.
• We are committed to social responsibility and promote positive impacts such as growth, wellbeing and financial skills in the local communities we are members of. We also promote responsibility in our partnerships.
• We are committed to assessing our footprint and promoting eco-efficiency and positive impacts on the environment and climate together with our customers and partners. We finance and invest responsibly, developing sustainable financing and services.

More information is available in our sustainability policy.

Responsibility is also taken into account in the investment activities of Savings Banks’ Asset Management. We adhere to our Responsible Investment Policy in all of our funds. The implementation takes place through the various approaches defined here and varies slightly between asset classes.

The topics covered by the Responsible Investment Policy include the responsible investment process, the management and organisation of responsibility, taking sustainability factors into account in investment activities, compliance with international norms and agreements, active ownership and influence, thematic investing and impact, exclusion, prioritisation and reporting related to the Responsible Investment Policy.

More information is provided in our Responsible Investment Policy (pdf, in Finnish).

The purpose of ownership steering in Sp-Fund Management Company is, above all, to promote the common interests of the unit holders. The common interest of the fund unit holders refers to the best possible development of the value of the fund units held by them, compared to the investment policy and risk level specified in the rules of the fund. In terms of exercising the ownership policy, acting in compliance with the common interests of the fund unit holders means that the interests of others should be treated as secondary if they deviate from the interests of the unit holders.

Sp-Fund Management Company considers fund investing to be a long-term activity 
by its nature, and primarily recommends equity funds to its customers as long-term investments. Therefore, the power of ownership should be used so that the value of the companies and the related fund units develop well in the long term. The ownership policy describes the means of ownership steering and their use, conflicts of interest, and reporting related to the ownership policy. 

More information is available in our ownership policy (pdf, in Finnish).

The Savings Banks Group observes principles of responsible and sustainable lending, which serve as a guideline for responsible lending in the Savings Banks Group together with the Savings Banks Group’s sustainability strategy, sustainability policy and other lending-related policies. The principles define how ESG factors and risks, exclusion criteria and the ESG criteria for sustainable lending are taken into account in the Savings Banks Group’s lending activities, and what kind of sustainable lending is supported.

The goals of the Savings Banks Group’s sustainability strategy include increasing the share of green assets and sustainable investments, reducing the ecological footprint and increasing positive environmental impacts in the Group’s own activities and across its value chain. The Savings Banks Group’s goal is to establish environmental, social and governance (ESG) criteria that support the climate for funding in 30% of business loans in selected sectors. With regard to residential and commercial real estate loans, the Savings Banks Group aims for carbon neutrality by 2050 at the latest. These objectives help the Savings Banks Group support the development and integrity of sustainable lending.

Sustainable lending

The sustainable lending process has been integrated into the general lending process. With regard to sustainable lending, potential financing targets in personal and business lending are assessed by using the ESG criteria valid at the time, along with the guidelines for responsible lending. Monitoring the lending process is part of the Savings Banks Group’s general management and control processes, to which the Savings Banks Group’s internal guidelines apply. 

To promote a consistent lending process, the Savings Banks Group’s lending guidelines establish ESG criteria for selected activities which the Group aims to support and which create opportunities for the Savings Banks Group’s customers. Examples of such activities include sustainable agriculture, forestry and fishing, sustainable industry, a sustainable energy sector, a sustainable construction and real estate sector, sustainable transport, storage and wholesale and retail of motor vehicles, and sustainable water and waste management and cleaning. 

The ESG criteria have been established by applying the European Investment Fund (EIF) criteria for sustainable projects, the Green Bond Principles of the International Capital Market Association (ICMA), the EU taxonomy criteria, and market practices, where applicable. The lending guidelines also include more detailed exclusion principles concerning certain industries, including the tobacco and cannabis industries, the production of adult entertainment, the military use of controversial weapons, child labour and payday loan companies. In addition, careful discretion criteria apply to the gambling business, energy companies that make significant use of fossil energy sources, industries with major environmental impacts, large-scale or chemical forestry, animal industry operators engaged in intensive livestock farming that have violations of animal rights on their record, and companies with current legally valid violations of human rights, labour law, environmental law, tax law or competition law that are known to the Savings Banks Group or otherwise publicly known.

Ensuring a high level of data protection and information security is paramount in all operations of the Savings Banks Group, as we operate in a sector requiring particularly high confidence. Data protection is a part of customer-oriented operations, and we comprehensively take personal data processing issues into account in all of our activities.

The Savings Banks Group complies with the EU’s General Data Protection Regulation (GDPR) and other data protection legislation in its operations. The data of all savings banks and their customers is covered by banking secrecy, insurance secrecy or corresponding duty to secrecy regardless of whether the customer is a private or a corporate one. We also participate in data protection cooperation in the financial industry.

We develop and maintain our data protection processes and operational models to ensure the rights and freedoms of our customers and other stakeholder groups in the processing of personal data. We have conducted comprehensive audits of our operations, revised our policies and guidelines and enhanced our Data Protection Impact Assessments in connection with new products and services, exceeding the legal requirements. 

An independent data protection organisation led by the data protection officer has been set up to support the data protection officer’s work. The data protection organisation comprises the persons in charge of data protection of the savings banks and companies, as well as the Data Protection Team, which includes representatives of the Central Institution’s risk control, human resources and information management departments. Every employee of savings banks has the duty to observe the data protection rules and instructions according to their roles, including the duty to report any observations or issues.

Our operations are steered by the data protection principles and guidelines approved by the amalgamation’s central institution, implemented by the Boards of Directors of each savings bank and entity. The executive and top management of the savings banks, entities belonging to Savings Banks Group and the central institution is responsible for the realisation of data protection. The Savings Banks Group employs appropriate technical, organisational and administrative procedures to protect all data in our possession against loss, misuse, unauthorised use, disclosure, modification and destruction. 

In addition, the position and duties of the data protection officer are specified in the data protection officer policy, which has been approved by the amalgamation’s central institution and implemented by the Boards of Directors of each savings bank and entity. The data protection officer policy is based on the binding provisions of the GDPR and the guidelines of data protection authorities.

Information security

Information security and the provision of secure services to customers are the foundation for successful banking. Extensive phishing and scam attempts have been targeted at the customers of Finnish banks in recent years. This may continue in the years to come. The Savings Banks Group has developed the security of its services and IT systems on a long-term basis. Different cyber threats and changes in the activities of cybercriminals require that security in its various forms is one of the focus areas in our operational development in the future as well. In addition, the changing operational environment requires increasing investment in guiding, supporting and educating customers in the safe use of digital services.