Ethical principles

1. Introduction

These Evli Group (“Evli”) Ethical Principles approved by Evli’s Board of Directors outline the general principles and guidelines related to Evli’s operations and practices that each person involved in the governance of the Evli Group must adhere to, regardless of their position, role or workplace. It is also the responsibility of the Board of Directors of each company in the Evli Group to see that these ethical principles are adhered to in the companies of the Evli Group.

It is the responsibility of each supervisor to ensure that these ethical principles are known and applied in their area of responsibility. It is the responsibility of the business units to decide whether more detailed guidelines are in some respects necessary.

Non-compliance with or neglect of these ethical principles, or any regulations, procedures and guidelines that come into force later, may lead to disciplinary measures against a person violating these principles, regulations, procedures, or guidelines.

2. Values

Evli’s objective is to be the leading Finnish asset manager and Evli’s mission is to help clients increase their wealth. Evli offers a comprehensive range of products and investment and wealth management services, backed by robust professional skills.

Evli’s goal is that each conceived product and service solution meets a client’s needs and benefits them over the long term. Evli is constantly developing its employees’ professional skills to ensure that Evli remains at the head of the pack and can offer innovative, market-savvy solutions.

Evli’s operations are founded on entrepreneurial spirit, valuable relationships, continuous learning, and development. Integrity and transparency characterize Evli’s everyday work. Evli’s employees undertake their responsibilities honestly and loyally, and behave correctly towards clients, officials, the general public, and other stakeholders, as well as towards colleagues.

In organizing its operations, Evli applies the principles of good corporate governance while complying with all applicable laws, official regulations, and approved policies and guidelines.

While Evli’s goal is primarily to gain a good return on clients’ investments, it also considers environmental and social factors in its investment and corporate activities. Evli strives, through responsible investment, to promote transparency and open dialogue between clients and its investment professionals.

3. Relationships with clients

Evli’s business idea is to provide clients with a versatile, high-quality service. Evli knows its clients and becomes familiar with their business and financial situation to the extent required by the client relationship. Furthermore, Evli is committed to executing orders in such a way that the client’s best interests are always the top priority. Employees must be constantly aware that they are representing Evli when they work with clients. They must always act professionally and treat all clients equally. If there is any possibility of a conflict of interest arising between Evli and the client, every attempt must be made to identify and prevent it in advance, or, if such a conflict has already occurred, the client must always be treated fairly. Measures for prevention, control, and handling of conflicts of interest are described in a separate Conflict of Interest Policy.

In identifying and getting to know its clients, Evli complies with the regulations and procedures valid at any given time. More detailed instructions and procedures are given in the Board of Directors’ approved policy on identifying and knowing clients and in the related internal guidelines.

Client feedback and complaints are always taken seriously. Client complaints are dealt with immediately, as laid down in Evli’s procedural guidelines and process concerning client complaints.

4. Relationships with stakeholders

Communications with different stakeholders, such as business partners, competitors, and the authorities, must be constructive and respectful.

Evli takes responsibility for its operations and chooses its partners carefully to ensure the high quality and continuity of operations. We insist on our partners’ compliance with the law, official regulations, and the applicable operational guidelines. Our partners must act in conformity with Evli’s ethical principles. All outsourcing follows procedures laid down in separate outsourcing guidelines.

Evli or persons acting on its behalf may not enter into agreements that could be considered to restrict free competition by agreeing on, for example, service fees, interest rate margins, or other price restrictions.

5. Relationships between employees and Evli

Evli has a written Human Resources Policy that outlines the central policies in the various sectors of HR management affecting the Evli Group. Competent and highly motivated personnel are essential for Evli’s continued existence, growth, and development. Evli’s goal is to produce added value for its clients, and this is furthered by creating a flexible, efficient, and well-balanced work community characterized by innovation and the willingness to adapt and achieve change.

One of the main duties of the management is to attend to, maintain, and develop the competence of the employees and to proactively contribute to coping at work and job satisfaction. Implementation of the HR Policy requires dedicated effort from the employer and all employees to achieve and sustain an open, correct, and trustful atmosphere.

In our work community we respect and consider each other’s needs, because we are cooperating to achieve the company's common goals. Evli treats all its employees even-handedly and fairly, independent of gender, nationality, age, religion, political affiliation, or any other similar ground. Evli Group has a separate Equality Plan.

Evli Group has a remuneration model covering the whole personnel. The purpose of remuneration is to motivate employees to implement the Group’s strategy and ensure profitable growth.

The implementation of business strategies is also ensured by continuous training. Evli Group has a separate Personnel and Training Plan. Each Evli personnel member should have the opportunity to learn and develop themselves, provided they take personal responsibility for their own learning and progress. Continuous training and support for supervisors is also a permanent feature of Evli’s training policy. There is a separate internal guideline for attendance in seminars and training trips. 

Evli’s employees do not offer, solicit, or accept improper gifts, trips, or payments. More detailed guidelines on representation and business gifts can be found in section 6 of these principles.

The same principles apply to Evli’s internal communications as to communications with clients. Internal service and cooperation must be flexible and must take Evli’s overall interests into account.

Employees’ own investment activities must comply not only with the binding regulations, but also with the need for ethical behavior. In all situations the client’s interests must be primary and may not be trampled on. Evli employees may not pursue their own financial interests and their decisions must hold up under public scrutiny. When investing their own assets, employees must take full account of the trading rules and restrictions laid down in separate guidelines.

Secondary occupations or positions of trust that are external to the employment relationship with Evli must not influence the employee’s ability to perform their work or undermine trust in Evli.

Each Evli employee is a part of compliance, risk management, and the quality chain. Any problems related to compliance with laws and regulations, risk management, or quality must be reported as quickly and accurately as possible to the responsible persons or to one’s own supervisor. Falsifying or withholding information is not appropriate or permissible under any circumstances.

Whistleblowing

Evli also provides an opportunity to report violations through a separate whistleblowing procedure. If an employee suspects that unethical activities or activities violating the law, regulations, the authorities’ instructions, or Evli Group’s internal guidelines have occurred, they may initiate a whistleblowing procedure in accordance with separate guidelines.

6. Representing Evli and business gifts

The hospitality shown to clients must be reasonable and appropriate to the circumstances. Hospitality must not result in the client's position being jeopardized or the client's work or other matters being adversely affected. When representing Evli, employees must exercise sound judgment and behave in such a manner that their actions will not even give rise to a suspicion of unethical behavior or independence.

The purpose of giving business gifts is to give the client a good memory of a joint event or cooperation. Receiving a gift must be trouble free for the client, and the business gift must not be such that the client finds it embarrassing or corrupt. In all situations, business gifts and hospitality must hold up under public scrutiny. 

Bribery and especially giving of a bribe to a public official is always prohibited. As to hospitality shown to authorities, particular caution must be exercised, and such hospitality must not result in a suspicion of bribery.

Receiving hospitality is subject to the same considerations as offering it. Consideration must be given to current conditions, the nature and purpose of the hospitality as well as the position of the giver or receiver of the benefit and their connection to Evli’s business. Receipt of a business gift or hospitality must not lead to a conflict of interest, act against the interests of Evli's clients for the benefit of a third party, or violate the provisions of the Markets in Financial Instruments Directive on incentives. Evli employees can accept regular business gifts. If the value of a business gift or hospitality is not deemed to be regular, Compliance must always be notified of it. A business gift cannot be money, benefits, or shares of commissions or income.

7. Communications

Internal communications

At Evli, internal communication is part of a well-functioning work community. At the unit and management levels, communications take the form of open, face-to-face dialogue. Email is mainly used for one-on-one and small group communication. For matters of interest to the whole Group, the communications department maintains an internal information network, the Evli Intranet. News concerning the Group is uploaded on the Intranet, which acts as a general source of information. Employees are urged to read the Intranet daily to be fully informed on matters affecting the Group.

External communications

The vital elements of Evli’s external communications are coherence and consistency. The goal is for all communications to reflect Evli’s policies. The information disclosed must be correct and truthful, and its veracity must always be checked before publication. It is vital for Evli that external communications comply with the standards set and that they support Evli’s corporate image.

Evli encourages its personnel to participate in social media to promote the company’s corporate image. Evli’s employees are professionals in their field, and highlighting this professionalism and creating visibility for the organization are important for Evli’s corporate image. In line with Evli’s values, each Evli employee needs to operate honestly and truthfully in social media. Furthermore, on social media, communications must be based on openness, good taste, and voluntarism. 

The duty of confidentiality is always observed in Evli’s external communications, including those on social media. More detailed instructions on the standards to be upheld in external communications and on the principles and restrictions guiding the use of electronic communications are given in Evli’s internal guidelines.

Separate internal guidelines have been prepared for personnel on appearing in public as Evli's representative and on the use of social media.

8. Trust and confidentiality

Evli’s employees are bound by strict rules of confidentiality. Whenever information is exchanged or processed, Evli complies with the secrecy and data protection rules and regulations in force at that particular time. Any knowledge gained of a client's financial status, business secrets, or other non-public matters during the course of work must not be disclosed to outsiders.

The confidentiality obligation is also observed in Evli’s internal operations, with confidential data always being handled only to the extent required to perform a work task.

Moreover, data related to Evli’s own business, employees, and persons involved in governance is confidential, and the processing of such data is subject to the same rules and regulations as client data.

To fulfil its trust and confidentiality obligations, Evli complies with the Information Security Policy set by the senior management. Evli’s Information Security Policy sets the requirements and defines the responsibilities for implementing information security at Evli.

9. Conflicts of interest

At Evli, conflicts of interest are prevented and managed through various administrative and organizational measures as described in the Conflict of Interest Policy approved by the Board of Directors. Organizational and administrative measures for the prevention and management of conflicts of interest can also be described in more detail in other internal guidelines, e.g. adherence to these ethical principles is part of the prevention and management of conflicts of interest.