Code of Ethics

Enento Group Plc (“Enento”) is a leading Finnish company providing information services for corporate management, risk management, and sales and marketing, securing the operational possibilities of companies and individuals in matters relating to credits and trading. Confidence in Enento’s operations is a key factor in Enento’s success. The Code of Ethics introduces matters and topics, which substantially guide Enento’s operations as a company and its personnel’s activities as members of the work community. This Code guides all operations within Enento.

Informing of the Code

Every employee at Enento is responsible for complying with the Code of Ethics in their daily work. The superiors are responsible for informing of the contents of the Code, related guidance and compliance with it in their own areas of responsibility. The Code is published on our intranet. The employees are required to acquaint themselves with the Code, and familiarising oneself with the Code is part of the orientation of new personnel. The employment contracts shall include a reference to the acquaintance with the Code and oblige to comply with it.

Actions in situations contrary to the Code of Ethics

Eventual actions or situations, which conflict with the Code of Ethics, shall mainly be handled by the superiors, representative of the management, or the person in charge of the company’s legal affairs and the human resources. The entire personnel have the right and obligation to bring forth any operation conflicting with the Code. Possible misconduct and breaches shall be promptly corrected and evaluated on a case-by-case basis, taking into consideration the company’s instructions and established practices.

I Code of Ethics for Business

1. Compliance with legislation, rules and instructions

• Enento operates in a business area, which is largely under strict regulation.
• Enento’s operations are constantly assessed by the authorities.

Enento and all those employed by Enento shall comply with the laws, rules, and ethically acceptable practices. Enento takes into account the Corporate Governance guidance concerning it [and the instructions by the owners]. It is understood at Enento that the strict compliance with the regulations is an essential part of Enento’s working culture.

The employees shall comply with the provisions on insider and disclosure rules included in Enento’s guidelines and policies (e.g. the Insider Guidelines and Disclosure Policy). Each employee of the company is personally responsible for following the laws, regulations and guidelines related to inside information and disclosure rules.

2. Impartiality and objectivity

• Enento’s activities have a direct impact on the companies’ and individuals’ possibilities to operate in the modern consumer and corporate markets.

At Enento, clients and data subjects are treated impartially and objectively. Enento and its personnel understand that the requirement for objective treatment in the keeping of registers is based on law. Assessments concerning companies or individuals have to be based on investigated evidence. Enento’s personnel does not let feedback or unpleasant tone of contact affect their duties.

An employee shall not participate in consideration of a matter in which he/she has a conflict of interest or even a perceived possibility to a conflict of interest between his/her personal interests and professional relationship with respect to Enento.

Any material related party transaction, being a transaction which is not entered into in the normal course of business and which is not obviously insignificant to the parties involved, between an employee, a director or a shareholder, or any entity directly or indirectly controlled by such a person, and the Company, shall be dealt with and approved by the Board and shall be recorded in the minutes of a meeting of the Board. All terms of related party transactions shall be at arm’s length.

3. Data security, privacy and confidentiality

• Data security and respecting of privacy are essential issues in Enento’s activities.
• Enento operates in business of trust.

At Enento, we process information diligently in a manner required by law, and we ensure the protection of privacy in the processing of personal data. We act openly, but preserving confidentiality. We do not tell or disclose confidential data to parties who are not entitled to it. The employees shall comply with Enento’s information security related guidelines and policies.

The employment contracts contain a provision on the secrecy obligation.

4. Enento’s position in the society and markets

• Enento is a central operator in the financial markets.
• Enento is a visible operator in the society.
• Enento has knowledge, skills and know-how that are appreciated.
• Enento is listened to in the media and even in politics.

Enento is a company, which aims at making profit to its owners. Enento’s central purpose is also to maintain Enento’s strong competitive edge and position as expert in the field of business information. Enento’s personnel is aware of this and aims at strengthening Enento’s position in all ways possible. Enento participates in dialogue pertaining to its activities, and strives to influence in the regulatory framework of its line of business and other operational environment. Enento exerts influence in the society to fortify its position as an operator in the sector.

The CEO is the designated authorized person to make public statements on behalf of Enento. The CEO may delegate this authority to other members of the management team or to other nominated person, if deemed necessary.

Enento and its employees will not pay nor offer to pay bribes or illicit payments to government officials, or other parties, in order to obtain or retain business.

II Code of Ethics for Employer and Employees

1. Prohibition of discrimination, requirement for equality

Enento treats all its employees equally and respecting the privacy and rights of each employee. No discrimination, interference or insults of any kind are tolerated at the workplace. Enento has an equality policy, which is revised and updated annually.

When deciding upon benefits (salary etc.) concerning an individual employee, the decision is made by the superior’s superior (one-over-one principle).

2. Knowledge sharing, openness, transparency

Each employee is for their part responsible for knowledge and information being in use as widely as possible at Enento. The operations and processes are documented so that they are also accessible to others. Enento work related matters are discussed directly, openly and constructively.

3. Responsibility and obligations

Enento’s employees attend to their work duties in a responsible manner. They also take the completeness into consideration. Each employee is for their part responsible for the creation and maintaining of a good working atmosphere.

All employees may report violations of the Code to their superior or the superior of their superior. It is the responsibility of all Enento’s superiors to give advice on the proper procedure in case of violations. Enento will ensure that there will be no adverse work-related consequences for any employee making complaints of violations of this Code.

Enento’s employees must avoid any activity that can lead to a conflict of interest. This includes, but is not limited to acceptance and giving of personal gifts or hospitality to or from Enento’s stakeholders, clients or cooperation partners other than minor and reasonable gifts or reasonable hospitality given in the ordinary course of business. Even if a gift might seem minor and reasonable, it is advisable to consider how it would be understood by an outsider.

4. Protection of rights and property

Those employed by the company have to use and protect Enento’s property with care, including immaterial property such as solutions, other knowledge and self-developed methods, trademarks, brands and logos. Also information systems are core capital of the company. Immaterial rights (IPR) are not handed over from Enento’s possession without a special decision concerning this.

5. Participation in social media

Enento participates also in social media in its different forms and makes use of the social media in its business to the extent possible.

When participating in social media, Enento’s employee is allowed to disclose Enento as their workplace. Even then the employee shall bear in mind both their loyalty obligations towards the employer as well as the Insider Guidelines, the Disclosure Policy and this Code. The loyalty obligation includes that the employee has to avoid everything that is at variance with the behaviour reasonably expected of an employee at that particular position. Discretion shall be applied when commenting on issues relating to the employer and working community in social media. The employee is encouraged to remember the uncontrollability of social media; what has once been said, cannot be changed.

The official representatives of Enento in social media are those who also otherwise are authorised to represent the company.