1 Introduction
The members of the Governing Council of the European Central Bank (ECB) have signed, binding upon themselves, the Code of Conduct contained in the Memorandum of Understanding, dated 16 May 2002. On 29 August 2006, to complement these ethical conventions, the ECB adopted an additional Code of Conduct applicable to the members of the Executive Board of the ECB. The Board of the Bank of Finland has today decided that the members of the Board comply with these Codes of Conduct, supplemented with the requisite Finnish legal provisions as follows:
2 Gifts or other financial benefits
The members of the Board shall not accept gifts or financial benefits that are connected in any way whatsoever with the tasks or duties conferred upon them and that are not of a customary or negligible value. Gifts not exceeding EUR 100 may be kept. In exceptional cases where a gift in excess of EUR 100 cannot be refused, the gift shall be given to the Bank of Finland, unless the amount exceeding EUR100 is paid to the Bank.
The members of the Board may give gifts to third parties at the expense of the Bank of Finland only if it is in line with customary and generally accepted practices. If such a gift is in excess of EUR 300, permission from the Board shall be required.
The members of the Board shall not entertain each other or offer each other any other benefits at the expense of the Bank of Finland; this prohibition shall also apply to spouses and family members. However, this rule shall not be applicable to professional duties for which there is a pre-scheduled programme or subject matter to be dealt with.
3 Acceptance of invitations and other participation in events by external organisers
Mindful of their respect of the principle of independence and their obligation to avoid any conflict of interest, the members of the Board may accept invitations to conferences, receptions or cultural events, including relevant hospitality and entertainment, if their participation in such events is compatible with the fulfilment of their duties or in the interest of the Bank of Finland.
As a general rule, the Bank of Finland pays the travel costs incurred by the members of the Board. It can be deemed acceptable that the organisers pay the accommodation costs incurred by the members of the Board for the duration of their participation. In particular, the members of the Board may accept invitations to events which one generally attends.
The members of the Board shall not themselves accept remuneration for lectures or speeches given in an official capacity. No remuneration whatsoever is charged for appearances subject to the public service function of the Bank of Finland. Such appearances are, for example, participating at events for interested parties and for the public good. When appearing at events arranged for commercial purposes, the members of the Board may inform the organiser of the event about the possibility of paying an amount corresponding to a normal lecturing fee for charitable purposes according to the organiser’s own consideration.
These rules shall be similarly applicable to the spouses of the members of the Board if invitations are also addressed to them and if their participation is in line with internationally accepted practices.
4 Acceptance of remuneration for activities carried out in a personal capacity
The members of the Board may teach, make academic contributions and pursue other non-profit activities. They may accept remuneration and compensation for costs incurred by activities performed in a personal capacity that are not related to the Bank of Finland, unless otherwise provided by legislation governing the Bank of Finland and on condition that such remuneration and costs are in proper proportion to the work done and within customary limits.
The members of the Board shall report once a year in writing both any activity carried out in a personal capacity and remuneration received in compensation for such activity to the Chairman of the Board.
5 Compliance with insider trading rules
The members of the Board shall be governed by the insider policy currently applied by the Bank of Finland. They shall report their investment assets and financial liabilities to the Parliamentary Supervisory Council.
It is strongly recommended that the members of the Board entrust their investment portfolios in the care of one or more well-known custodians, with full authorisation to act on behalf of the Board member. This recommendation shall not apply to ordinary bank accounts, money market funds or similar short-term instruments. This recommendation shall also be without prejudice to the opportunity to temporarily use funds for purchases of specific goods or for investment in real property.
In cases of ambiguity, the members of the Board shall seek advice from the Ethics Advisor to the Board.
6 Lack of impartiality and other conflicts of interest
A member of the Board lacking impartiality shall disqualify himself/herself from participating, as decision-maker or introducer, in the handling of the relevant matter.
The members of the Board shall disqualify themselves from handling their own matters, or those of their near relatives, at the Bank or whenever the settlement of the matter is of particular advantage or disadvantage to them or their near relatives. The members of the Board lack impartiality in the handling of matters concerning guidance or supervision of agencies or institutions to whose boards or other governing bodies they or their near relatives belong. Similarly, the members of the Board lack impartiality if their impartiality is endangered for any other particular reason.
7 Continuance of duties: measures and time-limits
During the first 12 months after termination of their term of office, the members of the Board shall not engage in any new activities that could jeopardise confidence in central banking.
8 Ethics Adviser
In order to ensure uniform application of these rules, the members of the Board shall turn to the Board's Ethics Adviser if ambiguity arises from the practical application of any ethical code confirmed by these rules. The secretary to the Parliamentary Supervisory Council acts as Ethics Adviser.