Finnfund has a zero tolerance attitude towards bribery, corruption and potential conflicts of interest. Finnfund requires its personnel, consultants and investees to comply with the principles it follows. Finnfund’s participation in financing a certain project is supposed to signal that corruption will not be approved, thereby reducing the possible corruption demands faced by the investee company. In some target countries, this is an essential part of the added value generated by the company for its clients.
The company has internal guidelines on the giving and receiving of gifts and hospitality. The company requires its personnel to behave in a good but restrained manner suitable for somebody representing a development finance institution and to avoid potential conflicts of interest and influence attempts.
Furthermore, the company has drawn up internal guidelines on potential conflicts of interest and insider information that all employees are expected to follow.
As the guidelines were being implemented, they were presented to the entire personnel and discussed in detail. New employees are familiarised with the guidelines during induction. The guidelines are permanently available on the company’s intranet.
Any consultants used by the company are required to follow the same guidelines by way of agreement.
Finnfund aims to communicate its zero tolerance attitude towards corruption and potential conflicts of interest to all investees even before making the investment decision. Finnfund also monitors the operations of the target companies throughout the financing process. Finnfund requires that all investee companies undertake to refrain from corruption as they sign an agreement with Finnfund. Any suspicions of abuse are taken very seriously by Finnfund and immediately lead to taking the measures deemed necessary under the circumstances.
The company follows an established procedure in investigating the background and potential conflicts of interest of individuals working for clients and investee companies. These investigations are carried out during project preparation.
Finnfund has registered as a party subject to the reporting obligation set forth in the Act on Detecting and Preventing Money Laundering and Terrorist Financing. The company has guidelines on anti-money laundering and terrorist financing procedures. The company has an organisation required by law, and it has implemented the procedures required by its guidelines. Employees have received training on the procedures required by the guidelines in several sessions.
Finnfund does not support political activity. It does not offer monetary gifts or other support to political parties, politicians or other parties it identifies as being close to these.
However, this does not apply to minor anniversary gifts or comparable tokens of appreciation provided to members of the company’s Supervisory Board or natural persons in a corresponding relation to the company.
At the project level, the company reviews the political conflicts of interest of all parties involved in a specific project and assesses the implications of these conflicts on a case-by-case basis.
Finnfund does not generally compete for clients with commercial investors, as its operations are guided by the requirement to focus on generating positive development impacts in the company’s target countries and to operate on a self-supporting basis in the long term. However, Finnfund may co-invest and share risks with commercial investors, provided that the other requirements set for the investment decision are met.
Increasing market competition for the benefit of consumers in the target countries is one of the developmental impacts pursued by Finnfund through financing and paid attention to in the assessment of developmental impacts.
Finnfund aims to comply with all applicable laws, regulations best practices in its operations and does not deliberately violate any of these or allow its personnel to do so.
The company also requires similar commitment from its investees, consultants and service providers.