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 decided on 27 September 2006 that the members of the Board shall comply with this Code of Conduct, supplemented with the requisite Finnish legal provisions. The Board updated the Code of Conduct on 17 May 2016.

2 Gifts or other financial benefits

Members of the Board shall not accept, request or receive personally or on behalf of someone else gifts, financial benefits or other 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 50 in value may be kept. In exceptional cases where a gift in excess of EUR 50 cannot be refused, the gift shall be turned over to the Bank of Finland, unless the amount exceeding EUR 50 is paid to the Bank.

Advantages may not be frequent or from the same source. An advantage may not influence nor be perceived as influencing the independence and impartiality of the Board member. Advantages of a customary nature, offered in the context of cooperation with other central banks, authorities, European Union institutions or international organisations may be accepted.

Members of the Board may give gifts to third parties at the expense of the Bank of Finland only if this accords with customary and generally accepted practices. If such a gift exceeds EUR 150 in value, permission from the Board shall be required.

Members of the Board shall neither entertain nor provide, at the expense of the Bank of Finland, any other benefits; 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 obligation to uphold the principle of independence and their obligation to avoid conflicts of interest, 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 is in the interest of the Bank of Finland. 

As a general rule, the Bank of Finland pays the travel costs incurred by members of the Board. It can be deemed acceptable that the organisers pay the accommodation costs incurred by members of the Board for the duration of their participation. In particular, members of the Board may accept invitations to events organised for the general public. The members of the Board shall not themselves accept remuneration for lectures or speeches given in an official capacity.

These rules shall be similarly applicable to the spouses of members of the Board if such invitations are also addressed to them and if their participation conforms to internationally accepted practices.

4 Acceptance of remuneration for activities carried out in a personal capacity

Members of the Board may teach, make academic contributions and pursue other non-profit activities. They may accept remuneration and compensation for costs incurred in activities performed in a personal capacity that are not related to the Bank of Finland, unless otherwise prescribed in 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. 

Members of the Board shall report to the Chairman of the Board once a year in writing all activities carried out in a personal capacity and the remuneration received as compensation for such activity.

5 Compliance with insider trading rules

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 to 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 and shall be without prejudice to any opportunity to temporarily use funds for the purchase 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 him- or 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 close persons, at the Bank or whenever the settlement of the matter is of particular advantage or disadvantage to them or their close persons. Officials 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 close persons 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, 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.