Anti-Bribery Policy

Bribery is a crime and is explicitly prohibited in Varma’s operations. Varma does not tolerate direct or indirect bribery, corruption or unethical influencing of any kind.

Bribery is prohibited

A bribe is considered to be offering or receiving money, a gift, a loan, a payment, a reward or some other benefit if its purpose is

  • to get the bribe taker to favour the bribe giver or someone else or to reward the bribe taker for such favouring or
  • to have a dishonest or illegal act committed or to break trust in the company’s business.

Bribery also refers to the abuse of a position in order to seek personal gain.

The Policy applies to all Varma employees

The purpose of Varma’s Anti-Bribery Policy is

  • to strive to prevent all forms of bribery at Varma and to promote a culture of anti-bribery.
  • to demonstrate Varma’s commitment to anti-bribery, to increase transparency and to reinforce Varma’s corporate image.

The Anti-Bribery Policy concerns all Varma employees, the President and CEO and the Board of Directors, who are referred to collectively herein as ‘Varma employees’.

When applying the principles of the Anti- Bribery Policy, the impact of the intended action on Varma’s public image must always be taken into consideration.

The Anti-Bribery Policy also applies to situations where a Varma employee is offered a benefit seemingly as a private person, but in reality based on her/his position at Varma.

When applying the principles of the Anti-Bribery Policy, the impact of the intended action on Varma’s public image must always be taken into consideration.

Varma also requires its co-operation partners to comply with these anti-bribery principles.

Varma’s Anti-Bribery Policy is based on the Finnish guidelines on the principles of anti-bribery, which were published by the Finnish Chamber of Commerce and are based on Transparency International’s Business Principles for Countering Bribery.

Inappropriate influencing

Varma employees are prohibited from seeking personal gain by making use of their position or Varma’s property, information or services. Varma employees must avoid transactions and situations with the company’s stakeholders which could lead to a conflict between Varma’s interests and personal interests.

Varma employees must avoid conflicts of interest in everything they do.

What constitutes a gift?

A gift is a benefit received without equivalent consideration or which clearly deviates from fair value and has direct or indirect financial or sentimental value for the receiver.

Hospitality is, as part of the business relationship, mainly a free-of-charge training or networking event, meal or other similar offering that is given or received. These include but are not limited to customer lunch and dinner meals as well as food and drink offered in connection with training and customer events. Hospitality also includes trips, sports, culture or similar events that are hosted by Varma employees and which are received fully or partly without equivalent consideration. Hospitality also includes similar events in which an invited Varma employee participates.

Principles for giving and receiving gifts and hospitality

A Varma employee may give or receive a gift or hospitality if it is appropriate with respect to Varma’s business.

Varma employees must seek their supervisor’s approval for giving or receiving a gift valued at over EUR 100 or hospitality valued at over EUR 150.

In the case of gifts and hospitality that exceed EUR 100 and EUR 150 respectively, Varma’s employees and President and CEO must notify the Compliance Officer.

Acceptable gifts and hospitality

  • must be given and received openly, with no attached obligations and/or expectations
  • are legal and comply with good practice and are moderate in value
  • can stand up to public scrutiny

Co-operation partners’ own bribery guidelines and policies, as well as the gift receiver’s right to refuse a gift must always be respected.

During competitive bidding situations or other co-operation or agreement negotiations, gifts or hospitality may not be given or received.

A gift or hospitality may not be given or received if it

  • could influence or appear to influence the independence or impartiality of either party, or if it otherwise compromises the general trust in Varma’s business
  • gives rise to any doubt concerning either party’s motives or the impacts of the arrangement on the outcome of the transactions or decision-making
  • exceeds the normal and reasonable practice in the industry
  • is in the form of money or a comparable benefit
  • is intended to be given to a family member or a private individual or entity that belongs to the giver’s inner circle
  • is recurring
  • would appear unfavourable in the public eye with respect to Varma

Customer events, entertainment and trips

Varma employees may participate in events organised by other parties which are justifiably organised for a purpose related to Varma’s business or, for instance, to strengthen relationships with a customer or supplier.

If a Varma employee has been invited to an event organised by a third party outside of the capital city area or the area where she/he works, attendance always requires the permission of a supervisor. Varma pays the costs arising from the trip (at least travel and accommodation costs). The organiser of the event can, however, pay the travel costs if said organiser is Tela, the Federation of Finnish Financial Ser vices, or another organisation for which Varma is a major provider of financing.

Varma allows entertainment events that are justifiably organised for a purpose related to Varma’s business, for instance, to reinforce the company’s corporate image or to strengthen relationships with a customer or supplier. The grounds for the hospitality must be approved and objective, and it must be received without equivalent consideration and not give rise to doubts about the appropriateness of Varma’s operations or the integrity of Varma’s employees.

Events organised for customers and other co-operation partners must be planned with care and should include a programme if such is in keeping with the nature of the event. So far as possible, representatives of different customers and co-operation partners must be simultaneously invited to the event.

Customers’ and partners’ travel costs related to such events are not compensated unless there are exceptional reasons related to the type and purpose of the event.


Offering gifts and hospitality to authorities

Stakeholders or citizens may see gifts, hospitality and trips as compromising the objectivity of authorities. Restraint must be shown in hospitality and gifts aimed at authorities.

Charitable sponsorships and donations

Varma has outlined separate principles on sponsorships and donations. When selecting sponsorship and co-operation partners, Varma assesses, among other things, the sponsored party’s compatibility with Varma’s values, strategy and brand, as well as the societal impact of the co-operation.

Through donations, Varma supports non-profit activities by participating in various collaborative projects that promote disability risk management and longer careers. Our sponsorship and donation principles are published on our website.

Varma does not support political activities or give donations for political purposes.


Varma’s Board of Directors approves this policy and bears ultimate responsibility for monitoring compliance with the policy within Varma. The President and CEO is responsible for ensuring that the policy is complied with consistently. The business directors oversee compliance with the policy within their areas of responsibility and provide more detailed guidance as required with respect to their areas of responsibility. Varma’s management sets an example for the entire organisation in their compliance with the policy.

Every Varma employee is responsible for complying with the Policy. Unclear situations must be discussed with one’s own supervisor or with the Compliance Officer.

Anyone who observes actions that are in violation of the policy must notify the Compliance Officer thereof. Varma’s Compliance Officer is responsible for ensuring that the policy is up to date, provides advice and guidelines on applying the policy and ensures that the policy is complied with.


The Compliance Officer reports on compliance with the Anti-Bribery Policy to the President and CEO, the Audit Committee and the Board of Directors as part of compliance reporting.

Any actions that are potentially in violation of the Policy are reported to the President and CEO without delay.

Updated: 8/2020