Code of Conduct

I.   Taaleri Code of Conduct in General

You decide.

Everyone at Taaleri will find themselves in situations where they must decide how to act. Taaleri’s values and this Code of Conduct describe the ethical principles guiding our operations and what we think is the right way to act. This Code of Conduct serves as the foundation for all operations in Taaleri Group, and it is non-negotiable.

Taaleri Code of Conduct is based on Taaleri’s values, which are:

i) With know-how, skills and will – We are highly skilled and we understand our markets and the needs of our investors. We want to understand the future and learn something new every day. We love what we do. Together, our know-how, our skills and our will allow us to excel in our work.

ii) Dare to succeed – We are proud to say it out loud: we have a desire to succeed. For us, success means delighted investors, happy employees in a great workplace and a sustainable society. Success requires courage. Courage to challenge. Courage to try out new methods and new things. Courage to be the first.. Because we have the know-how and the skills, we can be brave.

iii) Support each other – We value each other as individuals and professionals. We understand the importance of each role at Taaleri. We help each other to succeed because we will only succeed together. Together we cherish the spirit of Taaleri. We leave no colleague behind.

In addition to the Taaleri Code of Conduct, Taaleri Plc’s Board of Directors has ratified certain principles and guidelines concerning the entire Group. They guide the operations of all companies in Taaleri Group in each business area and, based on them, the businesses can define their own, more detailed operating and working instructions. The purpose of the above-mentioned guidelines, along with this Code of Conduct, is to ensure that the administration of all Group companies is reliable, and the key methods are faultless and consistent throughout the Group, taking the differences between business areas into consideration.

Each Taaleri employee is personally responsible for following this Code of Conduct and all other applicable instructions issued by Taaleri. Non-compliance with the Taaleri Code of Conduct, laws, and other principles or instructions may result in legal or administrative consequences to the person themselves, to other employees, and to Taaleri, and such conduct may harm Taaleri’s reputation. All Taaleri employees have the obligation to maintain the reputation and ethical standards of the company.

If a Taaleri employee observes business methods or other activity that may be or is against the Taaleri Code of Conduct, laws or regulations, they are encouraged to report it to their supervisor or anonymously through the digital reporting channel following Taaleri’s whistleblowing instructions. Anonymous reports are brought to the attention of the Group’s internal audit function, which initiates the necessary follow-up measures.

Honest and ethical business and compliance with all laws is in everyone’s interests at Taaleri.

This Code of Conduct applies to all companies in Taaleri Group and the people working in them.

II.    Business Principles

Compliance with laws and regulations

Taaleri is committed to following the laws, statutes, and official regulations of all countries where it carries out its business. Compliance with laws and responsible and ethical conduct are the basis of our business.

In addition to local laws and regulations, Taaleri is committed to complying with internationally recognised human rights standards, such as the UN Universal Declaration of Human Rights and the core conventions of the International Labour Organisation (ILO). Taaleri also observes with other minimum safeguards under the EU’s sustainable finance taxonomy.

Taaleri Plc adheres to the Corporate Governance Code for listed companies maintained by the Securities Market Association, the rules of Nasdaq Helsinki Ltd (Helsinki Stock Exchange), securities market legislation and the official regulations issued by virtue of it.

Corruption and bribery

Taaleri does not accept any kind of corruption, bribery or other activity that may create an impression of inappropriately influencing a business decision, yields an inappropriate advantage to a party or person or could be seen as trying to influence decision-making in other ways.

Taaleri or its employees may never offer or pay bribes to civil servants, private persons, or companies. Neither may Taaleri or its employees ever request or accept bribes.

Employees must ensure that all payments to third parties are appropriate, have an approved commercial basis and are recorded correctly.

In business relationships, only the giving and receiving of ordinary gifts and other benefits is allowed. Receiving a gift or other benefit must not lead to any obligation towards the giver of the gift. The legislation and legal practice of each country determine what an ordinary gift or benefit is.

Donations

Taaleri may, at its discretion, grant donations for public benefit or similar purposes from the annual general meeting within the scope of the requested donation authorization. Donations are voluntary and comply with applicable laws and local regulations. Taaleri does not grant donations or other financial benefits to political parties, candidates or groups.

Conflicts of interests, and secondary occupations

Taaleri employees and those commissioned by Taaleri are always expected to act in the best interest of Taaleri. Those employed by Taaleri may not use their position at Taaleri for self-interest purposes. In situations where their personal interests may conflict with those of Taaleri, Taaleri employees must recuse themselves and transfer the matter to a person who has no conflict of interests in the matter.

Taaleri Plc’s Board of Directors has approved a conflict of interests policy identifying situations in which a conflict of interests is considered to be created, and instructions for such situations. Taaleri Plc’s Board of Directors has also approved instructions concerning the management’s business transactions with related parties.

Client relationships must be conducted with honesty, and clients must be treated equally. In case of any conflict of interests between a client and Taaleri, the client’s interest must be always prioritised over that of Taaleri or a member of its personnel. Any conflicts of interest between a client and Taaleri are managed by applying the conflict of interests policy approved by Taaleri Plc’s Board of Directors.

Marketing directed at clients must be professional, and clients may never be given an incorrect or exaggerated picture of Taaleri’s products. Taaleri makes easy appeal possible for any unsatisfied clients.

Taaleri employees must obtain a permit from Taaleri Plc’s CEO for taking a secondary occupation, exercising a profession, or running a business. The secondary occupation or the above-mentioned economic activity may not interfere with the main occupation at Taaleri or cause a conflict of interests between Taaleri and the person in question. Taaleri Plc’s Board of Directors has approved guidelines for the application and granting of permission for secondary occupations.

Prevention of money laundering and of the financing of terrorism, and related sanctions

Taaleri has zero tolerance for money laundering and the financing of terrorism. Laws and official regulations relating to the prevention of money laundering and the financing of terrorism must always be complied with in Taaleri’s business operations.

Taaleri must recognise and know its clients and partners in ways required by the law. If Taaleri cannot be certain of the origin of its clients’ funds or the compliance of its partners’ business operations with the law or generally accepted practice, Taaleri may not start a client relationship or cooperation.

In its operations, Taaleri complies with the sanctions legislation binding on Taaleri and monitors the operations of its partners to avoid cooperating with parties on sanctions lists that are binding on Taaleri.

Taaleri Plc’s Board of Directors has approved the instructions governing the entire Group on the prevention and identification of money laundering and the financing of terrorism as well as guidelines on partners.

Confidential information and insider information

Taaleri is committed to protecting all confidential information in its possession, and we will not misuse any confidential information in our possession. Taaleri’s confidential information received based on an employment or commission relationship may not be disclosed to outsiders or used for personal benefit or the benefit of third parties. Taaleri processes personal data and protects it in accordance with the laws applicable at any given time.

Taaleri communicates and protects all insider information as dictated by the security market laws and rules. To prevent abuse, insider trading and the divulgence and utilisation of insider information have been restricted, and instructions have been published for these situations.

Taaleri Plc’s Board of Directors has approved the insider and trading guidelines concerning the entire Group.

Anti-competitive behaviour

Competition legislation promotes effective competition. Taaleri only competes in a manner that complies with currently valid competition legislation. Taaleri does not restrict competition artificially or through unjustified advantages, participate in cartels or act in contravention of the Act on Public Procurement and Concession Contracts. These principles apply to our relations with competitors, subcontractors, and clients.

III.    Stakeholders

Fund investors and clients

Taaleri’s core business is the development and management of alternative funds. In carrying out this activity, Taaleri and its employees always act in the interest of their fundinvestors and clients. All fundinvestors are treated equally.

Shareholders and debt investors

Taaleri Plc always strives to act in the best interest of its shareholders.

It is the company management’s task to ensure that the operations of the company are organised in an effective and goal-oriented fashion, complying with the Taaleri Code of Conduct and Taaleri’s other policies. Taaleri treats all its shareholders equally. 

To ensure that the value of Taaleri Plc’s share is determined objectively, Taaleri ensures that the market always has correct, sufficient and up-to-date information on Taaleri’s strategy, operations, business environment and financial status. Taaleri Plc’s Board of Directors has approved a Disclosure policy for this purpose.

Taaleri treats all its debt investors equally and observes the same transparency towards them as towards its shareholders, in compliance with the currently applicable security market regulations.

Personnel

Taaleri respects and complies with universal human rights as defined in the UN Declaration on Human Rights and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work.

Every employee is treated fairly and in the same way regardless of gender, sexual orientation, age, disability, race or ethnic origin, religion, nationality or other physical characteristics and differences. Discriminatory practices are not tolerated in recruiting, promotions, remuneration or general behaviour at the workplace. Forced labour or child labour are not accepted under any circumstances.

Taaleri strives to create an equal, good and open work atmosphere. With its management culture, Taaleri aims to commit and engage its employees on all levels of the organisation. Taaleri encourages its employees to personal and professional development.

Taaleri’s Personnel Policy, Equality and Non-Discrimination Plan, Operating Instructions for Incidents of Inappropriate treatment, and other documents for personnel guidance serve as guidelines for appropriate, friendly, and professional behaviour in the work community. Each Taaleri employee is responsible for following these guidelines. Employees are obliged to report abuse, discrimination, or other unethical activities. Whistleblowing can be done anonymously through the Taaleri whistleblowing channel on our website. Other representatives of Taaleri stakeholders can also report unethical activities through our whistleblowing channel or through fund-specific grievance mechanisms.
Taaleri supports the health and well-being of its employees and provides them with a healthy and safe workplace. 

Partners

Within its sphere of influence, Taaleri strives to ensure that all its cooperation parties and other partners comply with principles that are in tune with the Taaleri Code of Conduct. Taaleri’s main partners are committed to Taaleri’s Partner Code of Conduct, if possible, or alternatively, it ensures that the partners’ own code of conduct adequately covers and reflects Taaleri’s ethical views and commitments.

Partners must be selected with care, and they must be required to follow the law in their activities. Taaleri does not cooperate or enter into business relationships with partners that are known to act unlawfully or against good business practices. In the selection of and cooperation with partners, Taaleri’s interests must always be protected.

Taaleri takes care of and manages the impacts of its value chain to the best of its ability. Taaleri investigates the background of all its partners that are not minor, such as reports under the internal due diligence process as well as credit and other economic information, and checks that the partner is not on a sanction list. Partner information is regularly checked to ensure it is up to date.

Regarding its fund products and investments, Taaleri examines the ethical nature of practices through due diligence assessments, covering commercial, financial, legal, tax and sustainability aspects.

Authorities

Taaleri strives to maintain good relationships with public authorities and cooperates with them to promote open and active interaction. Taaleri also strives to participate in different ways in the development of the regulation of its current businesses in an appropriate direction.

IV.    Taaleri and Sustainability

Sustainability is a central part of Taaleri’s strategy and means sustainability regarding people, the environment and society.

Taaleri is committed to universal human rights as defined in the UN Declaration on Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, UN Global Compact, UN Guiding Principles and UN Principles on Responsible Investment (UNPRI). In addition, Taaleri is committed to reducing its greenhouse gas emissions in accordance with the Net Zero Asset Managers (NZAM) initiative.

We consider both financial and sustainability impacts in our operations. We look at the principal adverse sustainability impacts, sustainability risks, and sustainability factors of our operations, i.e. the sustainability aspects of the environment, society, and governance (ESG). The implementation of responsibility and sustainability is supported by Group-specific and business-specific policies and guidelines, as well as descriptions of operating methods and processes.

Taaleri regularly organises mandatory sustainability training for its personnel. Every Taaleri employee’s activities must be consistent with the practices described in the Group’s sustainability policies and/or the business sustainability policy and/or principles. In their activities, employees must consider Taaleri’s commitments, climate work, sustainability aspects, -risks, and sustainability factors, aim to avoid unnecessary commuting and favour low-emission modes of travel.

Sustainability indicators are also considered in the remuneration of all Taaleri employees.

Each Taaleri employee is responsible for following the guidelines and the Code of Conduct of Taaleri and its businesses.

Taaleri Plc’s Board of Directors has adopted sustainability principles governing the entire Group.

Taaleri's Code of Conduct has been updated on 25 March 2024.

Taaleri Partner Code of Conduct