Due to FIN-FSA’s role as the authority responsible for financial market supervision, its staff must meet certain specific ethical requirements. In their conduct, FIN-FSA staff must bear the authority’s objectives in mind and work towards their achievement. They must not develop too close ties to, or economic interests in, supervised entities, or otherwise have such ties or interests in supervised entities as would compromise their independence. Staff are subject to a broad requirement to disclose close ties (securities holdings, loans, guarantees, other commitments and secondary positions).
In addition, detailed provisions apply to securities and insurance investment by FIN-FSA staff. According to instructions approved by the Board of FIN-FSA on securities trading and insurance investment by FIN-FSA staff, the following restrictions must be observed:
- Prohibition on purchasing: FIN-FSA staff may not purchase shares or bonds issued by supervised entities or other financial corporations established in the European Union, or their derivatives or other financial instruments whose value is determined by reference to the abovementioned instruments. Furthermore, FIN-FSA staff may not purchase shares or bonds issued by foreign supervised entities with a branch in Finland or which has a subsidiary that is supervised by the FIN-FSA, or their derivatives, or other financial instruments whose value is determined by reference to the abovementioned instruments. Neither may FIN-FSA staff invest in such collective investment schemes whose main purpose is to invest in the abovementioned instruments.
- Application for a trading permit: FIN-FSA staff may engage in trading shares of listed companies other than supervised entities or EU financial corporations or securities carrying entitlement to such shares if a separate permit for this is obtained from the FIN-FSA Compliance Officer prior to trading. If, at the time of the permit application, FIN-FSA holds information essentially affecting the value of the security, permission will be denied.
- Prohibition on short-term transactions: FIN-FSA staff may make short-term investments in exceptional circumstances only, with the permission of the Director General. An investment is regarded as short-term when the duration between purchase and sale – or between sale and purchase – of an asset of similar type is three months at maximum.
- The same instructions also cover insurance investment: They also apply to unit-linked insurance, where the value of an insurance policy is tied to the value performance of a security covered by the instructions, and where the insured party himself chooses the investment object in which the premium is invested.
Information on securities holdings and trading by FIN-FSA staff is public. It can be viewed at Euroclear Finland Ltd's customer information desk (Urho Kekkosen katu 5C, Helsinki) on weekdays from 9 am to 4 pm.