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The operations of Employment Fund are guided by Code of Conduct 

The purpose of responsible and ethical operations and the Code of Conduct that guides them is to help everyone in Employment Fund act correctly in all situations, even when there is no one present to witness it. The Code of Conduct aims to ensure and guide our operating culture to act transparently, honestly and as a unified team.  

Employment Fund’s Board of Directors has approved the Fund’s Code of Conduct, which is updated on a regular basis. 

The Code of Conduct comprises the following sections: 

  1. Employment Fund’s main duties are determined in an act and decrees
  2. We comply with the law and internal guidelines
  3. We prevent bribery and corruption
  4. We identify and prevent conflicts of interest
  5. We comply with the Act on Public Procurement and Concession Contracts and internal guidelines
  6. We act openly and transparently, taking confidentiality obligations into account
  7. We ensure data protection, data security and information management
  8. We use Employment Fund’s assets appropriately
  9. We look after one another
  10. Employment Fund does not participate in or support political activities
  11. We want to act right and report any suspected abuse 

To view the Code of Conduct in detail, please click the link below. Employment Fund’s internal instructions provide more detailed information on the subject areas. 

Employment Fund’s Code of Conduct (PDF)

 

Whistleblowing system 

The whistleblowing system is Employment Fund’s confidential reporting channel. It is of the utmost importance for Employment Fund to respond to any suspected or alleged misconduct. By preventing and responding to misconduct, we provide Employment Fund with financial security, but also influence the reputation of Employment Fund as well as the trust of the personnel and other stakeholders. 

The Fund’s employees and stakeholders can use the whistleblowing system to report any information or justifiable suspicions of which the whistleblower has become aware in conjunction with their work, task or job regarding matters specified in the Whistleblower Act or violations of Employment Fund’s Code of Conduct, including suspected breach of the rules and regulations of the financial market. The whistleblower must have a factual connection to Employment Fund, either through employment or some other contractual relation. 

According to the law, a report pursuant to the Whistleblower Act may pertain, for example, to the following matters: 

  1. Public procurement, excluding defence or security procurement
  2. Financial services, products and market
  3. Preventing money laundering and terrorism financing
  4. Product safety and compliance
  5. Traffic safety
  6. Environmental protection
  7. Radiation and nuclear safety
  8. Food and feed safety, animal health and well-being
  9. Public health in accordance with Article 168 of the Lisbon Treaty of the EU
  10. Consumer protection
  11. Privacy and personal data protection, network and information system security as well as 

 

  1. Breach of the laws or regulations pertaining to the EU’s financial management, implementation of expenditure or collection of the EU’s income or assets
  2. Breach of the laws, terms or conditions applicable to the granting, use or claim for recovery of any EU or national subsidies or government support
  3. Breach of EU or national competition rules
  4. Breach of legislation applicable to EU taxation or the taxation of national companies or corporations, or an arrangement aimed at gaining a tax benefit contrary to the objective or purpose of legislation applicable to the taxation of companies or corporations
  5. Breach of legislation other than the legislation to protect EU or national consumers in accordance with the Whistleblower Act, section 1, subsection 10 

 

In HR-related matters (such as harassment, discrimination, occupational safety or workplace atmosphere), the primary communication channel is Employment Fund’s HR department. In this case, the current labour laws and other applicable laws shall apply.  

Misconduct may result in consequences for Employment Fund and its employees, investors, our customers, other stakeholders or individuals. 

Although you do not need to have proof to support your suspicions, you should submit your report in good faith. 

A report can be submitted without concrete evidence or absolute certainty of whether an offence has taken place or not. The whistleblower may have either knowledge or a justified suspicion of the occurrence of an offence. 

In order to ensure anonymity, the whistleblowing system is administered by our third-party partner, WhistleB (Whistleblowing Centre). The whistleblowing procedure is encrypted and password-protected. All reports are processed in strict confidence and in compliance with confidentiality provisions. 

All reports submitted via the whistleblowing system are processed by a separate report processing team established by Employment Fund. On a case-by-case basis, it may be necessary to use specific other experts to investigate a matter. Both members of the processing team and any experts assisting with the investigation of the case must be familiar with the general principles of disqualification and recuse themselves from processing an individual report if its content is linked to the person processing the report for work-related reasons. Periodically, statistical data regarding the number and nature of reports received is also reported to governing bodies. 

An acknowledgement of receipt is issued to the whistleblower within seven days of the receipt of the report through the whistleblowing system and the further measures pursuant to the specified report processing procedure are taken to verify the validity of the report and, if necessary, intervene. Once the investigation is complete, or at the latest within three months of issuing the acknowledgement of receipt, the whistleblower will be notified of the measures taken on the basis of the report. 

The personal data and other information of whistleblowers or other parties concerned is processed in compliance with legislation valid at the time of processing as well as our data protection policy. 

For detailed information on personal data processing, see our data protection notice. 

Please note that the system is not intended for customer feedback. You can submit customer feedback using our general contact information.  

Employment Fund’s whistleblowing system is the primary channel for reporting suspected offences. You can submit a report here. 

Suspected misconduct may be reported through the centralised external reporting channel of the Office of the Chancellor of Justice provided that the matter is subject to the scope of the Whistleblower Act and 

  • the whistleblower has reason to believe that measures have not been taken within the given period of time or the breach cannot be effectively handled on the basis of an internal report, or 
  • the whistleblower has justified reason to believe that they are at risk of countermeasures as a result of the report. 

For more information on whistleblowing, see the Office of the Chancellor of Justice website. 

Page updated: 15/10/2024