Varma’s core task, securing pensions, is a significant social mandate that requires a high level of ethics and transparency. The Code of Conduct was approved by Varma’s Board of Directors on 27 October 2022.
In addition to the Code of Conduct, we comply with the laws and official regulations that are in effect at the time. Our ethical business principles complement the applicable laws and regulations and describe how we operate.
The Code of Conduct is complemented by other internal policies and guidelines that Varma has established to ensure, among other things, data security and privacy, conflict of interest identification, money laundering prevention and compliance with insider regulations. There are also separate anti-bribery principles in use, compliance with which is monitored, for example, by means of a gift register maintained by the Compliance Officer. Our tax accountability is guided by a separate tax policy.
Varma is politically and religiously unattached. Nor does it support political activities or donate for political purposes.
Prevention of the grey economy and money laundering
Varma co-operates within the earnings-related pension system to combat the grey economy. We promote conditions for honest work and business. In order to help identify the grey economy, we participate in joint audits of the pension system and we disclose information in accordance with the Act on the Contractor’s Obligations and Liability when Work is Contracted Out. Our operations comply with the regulations and regulations on the prevention of money laundering, which includes, for example, customer due diligence. The anti-money laundering guidelines are part of our processes. Our staff receive regular training to ensure compliance.
Bribery is strictly forbidden at Varma
Bribery is a crime and strictly forbidden in Varma's activities. Varma does not tolerate direct or indirect bribery, corruption or undue influence in any form.
Varma’s employees do not offer or accept from third parties gifts, payments, hospitality or other benefits whose purpose is to influence a decision. Gifts that are given or accepted must not call into question the giver’s or receiver’s independence. The supervisor must be asked for prior approval if the value of the gift exceeds EUR 100 or the value of the hospitality exceeds EUR 150. Such gifts and hospitalities must always be reported to the Compliance Officer.
If a Varma employee has been invited to an event organised by a third party outside of the Helsinki Metropolitan Area or his/her business area, attendance always requires the permission of a supervisor. In such cases, Varma will pay the 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 Services, or another organisation for which Varma is a major provider of financing.
Varma has drawn up a separate anti-bribery policy.
We avoid conflicts of interest
A conflict of interest arises when a Varma employee who is involved in making a decision is motivated not by Varma’s interests, but rather by his or her own, a friend’s or a family member’s interests, for example. Every Varma employee has a duty to act with loyalty to Varma.
Conflicts of interest can also be caused by parallel work, business activities or external board membership in a business.
Conflicts of interest can be avoided by not accepting work from another earnings-related pension company or from Varma’s partners. No Varma employee commits to a third party’s operations that will consume time and require measures to be taken during their working hours.
Varma’s senior and middle management and employees who make investment decisions decisions must always seek the approval of their supervisor for board membership in companies outside Varma.
An exception to this rule is board membership in housing companies, sports clubs, unions, political parties or other similar organisations.
In addition to the Conflict of Interest Guidelines approved by the Board of Directors, there are also department-specific Conflict of Interest Guidelines.
In pension insurance operations, Varma is also bound by the provisions on disqualification in the Administrative Procedure Act.
We co-operate responsibly in the employment pension system
Varma carries out statutory employment pension insurance and the placement of pension assets in such a way that we compete for the performance of this task with others carrying out the same task.
In our operations, we take into account the requirements of competition law and promote the competitive advantage of Varma. At the same time, we carry out statutory co-operation in matters requiring the implementation of jointly managed matters in the employment pension system and take care of the equal treatment and legal protection of clients of the employment pension system. We assess participation in co-operation in the field of employment pensions from the point of view of competition law.
Abuse of insider information is prohibited
Varma follows insider guidelines confirmed by the Board of Directors. The purpose of the guidelines is to promote the public reliability of the company’s investment operations and the personnel’s knowledge of insider regulations, so that they are not unintentionally violated.
The abuse of insider information concerns all Varma employees. Varma has additionally appointed individuals who must comply with insider information guidelines in all securities trading.
The use of insider information is considered to be actions in which someone uses non-public, important information related to securities to their own or another person’s advantage in securities trading. Insider information must also not be shared with another person, unless it is a regular part of the work or tasks being performed.
Varma’s public insider register can be accessed through Euroclear Finland Oy’s online service.
Data protection and information security
Ensuring data protection and information security is part of Varma’s responsible operations. We process confidential information in accordance with laws and good data processing practice, while respecting insurance confidentiality.
Confidential information includes, for example, the personal data of our customers and Varma employees, and information relating to the business and financial condition of Varma, our client companies and partners. This information is processed only by Varma employees whose jobs entail it. We adhere to the guidelines issues on confidentiality, data protection and data security. We continuously maintain the legality of our operations and our personnel's data security and data protection expertise, for example, by reviewing these matters in an online course every year.
We explain the processing of personal data at Varma in our privacy statement.