Protocol and Code of Conduct

The role of Gildi Pension Fund is to guarantee pensions to fund members, surviving spouses and children in accordance with the fund’s Articles of Association and laws and other regulations that apply to the operation of pension funds. Furthermore, Gildi plays an important social role.

The role of the Fund’s Board of Directors is to manage it as stipulated in the Articles of Association, laws and regulations. This includes i.a. regular general strategy, decisions on key issues and active follow-up of the decisions made. The Board also plays a supervisory role and ensures that all relevant supervisory actions within the fund are carried out in accordance with laws, regulations and good practices and procedures. The Board follows through on its decisions.

The role of the fund’s employees is to take care of its operation and services and communication with customers, public bodies and others concerned with the fund’s affairs. The Managing Director and the fund’s staff are clear about the requirements that are made of them and the responsibility that they have, both formally according to the statutes, laws and regulations, agreements or decisions and also informally due to the expectations of fund members, employers and society as a whole regarding the responsible and effective operation of the fund.

In all their tasks for the fund, the Board and employees emphasise common sense and judgment. This is done with moderation and forethought, but at the same time, the Board and employees must be true to their convictions and work according to their best conscience.

The Board and employees of the fund serve paying fund members, pensioners, employers and borrowers with loyalty and respect for the fund’s role. Emphasis is placed on an open flow of information, but also on the necessary and normal confidentiality and obligation of secrecy, and furthermore on respect and fairness in conduct, replies and processing of cases. Information is not misused.

Communication with participants in the capital market is based on respect for partners and efforts to maintain and strengthen the fund’s credibility. Employees are alert to potential conflicts of interest and are actively responsible for responding to potential irregularities as appropriate. Information is not misused and confidentiality with business partners is maintained for all legitimate transactions.

The Board and employees of the fund strive in their relations with public bodies and regulatory authorities to create trust in the fund on the basis that laws and regulations are respected. Respect is given to the aims and purposes of the law, and the fund’s activities do not attempt to cross the boundaries of what is legal. We work with regulatory authorities as positively as possible and take the initiative in communicating with them if there is any doubt as to whether individual decisions or actions are in accordance with laws and regulations.

The Board and employees of Gildi maintain the utmost professionalism in their relations with the public and the media. Equally, questions must be answered to the best of their knowledge and without any attempt to mislead the questioner or distract the person in question. If a question cannot be answered because the information is not available or due to confidentiality, this should be stated openly and explained.

The Board and employees are ambitious on behalf of the fund. This means having its best interests at heart and making an effort to achieve success on its behalf. The Board and employees are encouraged to be advocates for the fund when the opportunity arises.

Gifts are not accepted, nor is the payment of expenses for employees or Board members by others, if this gives reason to question the trustworthiness of the fund or gives reason to believe that it will influence the decisions of the Board or employees. Gifts must not have any financial significance for the recipient, and all expense payments, e.g. for meetings or presentations, must be appropriate, modest and in accordance with the occasion and good business practices.

When hiring, employees must be presented with the fund’s protocol and Code of Conduct. The same applies to Board members who sit on the fund’s Board of Directors. Violations of these rules by employees may result in reprimand or dismissal. These rules must be published on the fund’s website.

Approved at the Board of Directors’ Meeting on 8 January 2015.