Sustainability management and good governance

Corporate responsibility is part of the savings bank ideology, values and the mission of the Savings Banks Group’s operations, which is to responsibly promote the financial wellbeing and prosperity of our customers. Corporate responsibility is, therefore, an integral part of our strategy and operations, both in the short and long term.

In the Savings Banks Group, sustainability is managed systematically in accordance with the sustainability governance model approved by the Board of Directors of Savings Banks’ Union Coop. Sustainability is part of everything we do and it is integrated into all of our business areas.
The Management Group and Board of Directors of Savings Banks’ Union Coop regularly monitors sustainability management, performance indicators and achievements. Sustainability matters, such as economic, social and environmental responsibility and sustainability risks, are regularly on the agenda of the Savings Banks’ Union Coop’s Management Group and Board of Directors.
The Audit Committee of Savings Banks’ Union Coop presents sustainability matters to the Board of Directors of the Savings Banks’ Union Coop for approval, and the Risk Committee reviews and approves the estimates, targets and limits of ESG (environmental, social, governance) risks and opportunities as part of other risk reviews.
The Head of Group Sustainability & ESG is in charge of corporate responsibility performance. This includes managing and coordinating sustainability, sustainability-related projects and communication as a whole, and taking ownership of operational responsibility for these areas. The Head of Group Sustainability & ESG is in charge of the Savings Bank Centre’s sustainability working group and steering group, and reports to the person designated as the sponsor for sustainability in the Management Group.
The sustainability steering group includes representatives of the Management Group of the Savings Banks’ Union Coop and savings banks, while the sustainability working group includes sustainability specialists from the Group’s support functions and business units, representing broad expertise in various functions.
Savings banks integrate sustainability into their operations and participate in the implementation of the sustainability strategy and roadmap at the bank level, ensuring competence, training, resources and compliance with the guidelines. Stakeholder panels on sustainability are also organised for savings banks.

Sustainability policies and guidelines

The Savings Banks Group’s sustainability efforts are guided by the Group’s sustainability strategy, sustainability policy (pdf, in Finnish) and sustainability roadmap. The sustainability strategy includes both long-term and short-term targets. The five main themes of the sustainability strategy, and the related targets, also support the UN Sustainable Development Goals. Our other key principles and guidelines include the Code of Conduct for our personnel, our Responsible Investment Policy, our responsible and sustainable lending principles as part of our lending policy, our principles concerning the diversity of the Board of Directors, and our equality and non-discrimination plan.

To protect employees, the Savings Banks Group also has a whistleblowing channel for reporting observed or suspected unethical conduct. Read more about how we develop employee wellbeing and competence.

We also observe good governance practices and ethical principles in our operations at the Savings Banks Group. We comply with, for example, the principles for reliable management and internal control, policies concerning conflicts of interest and the Code of Conduct. We prevent money laundering and corruption, assess and manage risks, in accordance with our principles and policies.

The activities of the Savings Banks Group comply with the provisions of current legislation, orders issued by the authorities, the sustainable financial industry principles, good banking practices, good insurance practices and trading instructions confirmed by Finance Finland, and other internal guidelines.

We organise training on material topics to increase awareness and promote the organisation’s commitment to sustainability. Each year, our employees also participate in mandatory training on topics including the prevention of money laundering and terrorist financing and the Code of Conduct.

Code of Conduct and reporting violations

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.

Responsibility among suppliers and partners

Sustainability policy

Principles for responsible investment and ownership policy

Principles of responsible and sustainable lending as part of the lending guidelines

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.

Our data protection policies and information security

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.