Finnlines Keula

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Anti-corruption and anti-bribery policy statement

Finnlines Plc and its subsidiaries (hereinafter Finnlines Plc and its subsidiaries separately and together referred to as “Finnlines” or the “Company”) acknowledge the following policies, standards, procedures and applicable laws and regulations regarding anti-corruption and anti-bribery:

General

As a listed company Finnlines is supervised by the Financial Supervisory Authority in Finland. Supervision is to ensure that the Company is professionally managed and that it has adequate risk management systems in place.  Ethically and professionally qualitative business principles and practices, such as anti-corruption and anti-bribery policies are key requirements of such listed company.

Finnish legislation prohibits giving or receiving bribes that are intended to have the recipient favor the briber or another person, or to reward the bribed person for such favoring.

Furthermore, the Company follows the Finnish Chamber of Commerce’s guidelines on principles of ethical business activity, and of anti-bribery which are part of Transparency International’s Business Principles for Countering Bribery (2003).

Finnlines also applies the Finnish Corporate Governance Code entered into force on 1 October 2010 for listed companies. A well-organized Corporate Governance and internal auditing system are essential also in doing business in accordance with anti-corruption and anti-bribery policies. Also the Company has an internal auditing system and the Company follows the Financial Supervisory Authority’s standards and recommendations what comes to reporting on these matters.

As a part of Finnlines Corporate Governance Statement, the Company therefore disallows all corruption and bribery activities under these policies, standards, procedures and applicable laws and regulations both domestically as well as whilst doing business abroad.

Specific guidelines for the employees of the Company and its business partners

Decisions related to the activities of the Company are made exclusively based on the benefits to the company and not to the benefit of any individual person. This applies e.g. to person's position in the company, other work relationships, political activity, gifts, favor and other benefits to an individual.

Finnlines employees who are in a position to make commitments on behalf of the company or members of their families shall not solicit, accept, offer or give gifts, favors, and loans or similar indulgences from/to outside parties, who do or might do business with the Company. Cash gifts and gift checks and gifts having an investment value such as stock, bonds etc., are strictly prohibited.

There are specific instructions provided by the corporate management about offering discounts on the trips onboard Company's vessels in promotional or occupational purposes to representatives of customer organizations, media or other stakeholder. 

This policy applies to all employees of the Company and specifically employees who are involved in:

  1. placing purchase orders with suppliers or subcontractors
  2. selecting, recommending or approving suppliers
  3. receiving testing inspection or quality functions and technical functions
  4. evaluating supplier proposals, paying invoices or collecting money from customers
  5. selling Finnlines services to potential customers
  6. approving or signing sales contracts with customers
  7. dealing with the authorities and civil servants and other stake holders in questions which influence Company's operating environment.

Handling of conflicts of interest

Conflicts of interest may not always be clear-cut, so if an employee is not sure about correctness of an action, he/she should consult with one's supervisor or manager or if circumstances warrant, the Legal Councel of the Company. Any covered party who becomes aware of a conflict should bring it to the attention of a supervisor, manager or other appropriate personnel.

Accountability

If the Company's Board of Directors (BoD) or the President and CEO determines, that this policy has been violated, either directly, by failure to report a violation, or by withholding information related to a violation, the offending Covered party may be disciplined for non-compliance with penalties up to and including removal from office or dismissal. Such penalties may include written notices to the individual involved that a violation has been determined, censure by the BoD or the president and CEO, demotion or re-assignment of the individual involved and suspension with or without pay of benefits. Violation of this policy may also constitute violations of law and may result in criminal penalties and civil liabilities for the Covered Party and the Company. All Covered Parties are expected to cooperate in internal investigation of misconduct.