Code of conduct

Note: this translation is unofficial.

Springvest strives to maintain an open business environment and high standards of business ethics. We value the safety of, and respect for, everyone our business affects, and everyone in our organisation plays an important role in our success. 

All Springvest employees and agents acting on Springvest’s behalf are responsible for acting in accordance with Springvest’s code of conduct and other applicable guidelines. Every decision we make affects client relationships, the operating environment, our relationships with others or ourselves personally.

Springvest’s code of conduct is the foundation of everything the company does, and there can be no compromise on a culture of doing the right thing.

Explore our code of conduct by clicking the headings below.

Ethical principles

Springvest operates in Finland and is committed to complying with the laws, regulations and official orders that apply to its operations. Compliance with the law and responsible, ethical conduct are the foundation of Springvest’s business.

In addition to the laws and regulations relating to its operations, Springvest respects internationally recognised human rights as defined in the UN Universal Declaration of Human Rights, as well as the fundamental standards of the International Labour Organization (ILO).

Springvest does not accept corruption, fraud or any other criminal activity in any form. Any activity that may create the impression of improper influence on a business decision, that gives an improper advantage to any party or other person, or that may otherwise be considered an attempt to influence decision-making is prohibited. Springvest staff and agents acting on Springvest’s behalf must not offer, demand, accept or receive any financial or other benefit that affects, or appears to affect, the objective and impartial performance of their duties.

Accepting a bribe is prohibited and subject to sanctions. All forms of corruption and bribery are prohibited, and action will be taken to counter them where necessary.

In work-related relationships, only customary gifts and other benefits may be given and received. Gifts and hospitality must follow the principle of transparency, and both offering and accepting gifts or invitations must be carefully considered. Their value must not exceed the level of customary hospitality. Gifts and invitations should also not be accepted repeatedly from the same people or companies.

Springvest staff and agents acting on Springvest’s behalf are always expected to act in Springvest’s best interests. Springvest employees and agents must not use their position at Springvest for personal gain. If a situation arises in which personal interests may conflict with those of the company, employees or agents in Springvest’s organisation must immediately withdraw from decision-making and pass the matter to someone who has no conflict of interest in it.

Springvest employees must obtain separate permission from Springvest’s CEO to take on a secondary occupation or to pursue a profession or business. A secondary occupation must not interfere with the person’s main role or create a conflict of interest between Springvest and the person concerned.

Springvest does not accept money laundering or terrorism, and in its operations Springvest must always comply with the laws and official regulations on preventing money laundering and terrorist financing.

We treat our clients equally and fairly. Legislation sets requirements for how Springvest must know and identify its clients and partners. Springvest cannot begin a client relationship or partnership if it cannot verify the origin of its clients’ funds or that its partners’ business is lawful and in line with good practice.

In its operations, Springvest also complies with the sanctions legislation binding on the company, and monitors its partners’ activities to avoid dealing with parties on sanctions lists binding on the company. Springvest has guidelines in place for identifying clients and partners.

In addition, the company and its employees must ensure that financial information is recorded in the accounts accurately and in a timely manner, in accordance with applicable accounting legislation, financial reporting regulations and Springvest’s policies.

Springvest is committed to protecting and processing confidential business information and the personal data of its staff and stakeholders in accordance with good data processing practice and applicable legislation. We respect everyone’s right to privacy.

Confidential Springvest information obtained through employment, office or an assignment must not be disclosed to outsiders or used for one’s own benefit or that of a third party.

The Board of Directors of Springvest Corporation has approved the company’s guidelines on inside information and its handling.

Healthy and open competition is in the interests of all market participants. Competition law prohibits agreements and other practices that restrict competition. Practices that distort competition undermine the efficiency of our business. Springvest complies with competition rules and binding regulations, and we expect our competitors and partners to do the same.

Working with stakeholders

Client relationships must be managed honestly, and clients must be treated equally and professionally. Springvest knows its clients and familiarises itself with their business and financial position to the extent the client relationship requires. When carrying out mandates, in any conflict of interest that may arise between the client and Springvest, the client’s interests must always come before those of Springvest or anyone in its organisation.

Springvest employees and agents acting on Springvest’s behalf must bear in mind that they always represent Springvest when dealing with clients. Marketing to clients must be professional, and clients must never be given an inaccurate or exaggerated picture of the investment services Springvest offers.

Springvest always strives to act in the interests of its shareholders and ensures that all shareholders are treated equally. Springvest’s management is responsible for ensuring that the company’s operations are organised carefully, efficiently and purposefully, in compliance with the company’s code of conduct and other applicable guidelines. 

Springvest’s Board of Directors has adopted a disclosure policy to ensure that the market always has accurate, sufficient and up-to-date information on Springvest’s strategy, operations, business environment and financial position. This supports the objective pricing of the company’s share.

Staff are treated fairly and equally, and we support universal human rights within our sphere of influence. Our aim is a skilled, motivated staff who are doing well, and a healthy work community. We emphasise the importance of humane and respectful treatment. Applicable laws and regulations are followed in recruitment and employment. 

As a rule, vacancies are advertised both internally and externally. People are always selected on the basis of competence, required education and suitability for the role. Pay is based on the demands of the role and performance in it. 

Employees are not treated differently without acceptable grounds on the basis of age, gender, origin, sexual orientation, political activity or any other personal characteristic. We promote equality between women and men and do not accept harassment of any kind in the workplace. 

All staff have equal and consistent opportunities. We support our people in various ways in balancing work and the rest of life. Springvest’s goal is for staff to value being part of the work community and for their creativity and expertise to be valued. Participation systems and the way work is organised give people a say in matters relating to their own work. Skills are developed taking into account each person’s level of expertise and qualifications. Expectations of staff are realistic and challenging. Springvest aims to make effective use of its people’s full potential.

Dealings with partners and competitors must be appropriate and respectful. Springvest acts honestly and ethically and complies with the legislation applicable to its operations. Within our sphere of influence, we require the same of all our partners. 

Partners must be chosen carefully and required to comply with the law in their own operations. Springvest does not enter into business relationships with partners known to act in breach of the law or good business practice.

Springvest maintains good relations with the relevant authorities and promotes cooperation and open dialogue. Within its sphere of influence, Springvest also seeks to contribute in various ways to developing the regulation of its industry in an appropriate direction.

Sustainability

A company’s ability to make a positive impact on the world, its handprint, matters to Springvest. Springvest follows the principles of sustainable development in its operations. The aim of acting responsibly and promoting responsibility is a more efficient, healthier, cleaner, fairer and safer world. From the start, Springvest has selected target companies for funding rounds whose products or services aim, in one way or another, to make the world a better place.

Springvest has separate principles in place for sustainable operations.

Implementing and monitoring the code of conduct

Everyone at Springvest and all agents acting on Springvest’s behalf have a duty to uphold the company’s reputation and ethical standards. Failure to comply with Springvest’s code of conduct, the law or other guidelines may cause reputational damage and lead to legal or administrative consequences for the person concerned, other employees or Springvest. 

If you are unsure whether a transaction or other decision complies with Springvest’s procedures, ask yourself the following:

  • Does the transaction or decision comply with the law and regulatory requirements?
  • Does the transaction comply with Springvest’s guidelines?
  • In my view, has the transaction been carried out correctly and fairly?
  • Would you be comfortable reading about it in a newspaper or on social media?
  • Does the transaction look acceptable from the outside?

If the answer to all the questions is yes, you can go ahead. If the answer to even one question is no, discuss the matter with your manager or the compliance officer.

Reporting channels

It is vital to Springvest that anyone who suspects or observes business practices or other activities that breach the law or our responsible and ethical conduct reports their suspicion without delay.

No one who reports their suspicions in good faith and takes part in investigating possible breaches of the code of conduct will suffer any negative consequences as a result. 

Reports can be made in your own name or anonymously, in accordance with Springvest’s whistleblowing guidelines.

Our whistleblowing channel is an important tool and early warning system for detecting and reducing risks. We believe it helps us promote high standards of business ethics and maintain the trust of clients and the public.