The
e Finnaiir Way Our Code of Con
nduct and the attributes of success
ponsibility is an integral part of all Fiinnair opera tions. Succe
essful organissations havee an eye on tthe future an
nd Resp
invest in responssible and susstainable competitiveneess. This Cod
de of Conducct is based onn the princip
ple that ndards. everrything we do at Finnair must – and will be – evaaluated against the highest ethical bbusiness stan
Bacckground Wha
at is a code o
of conduct an
nd why do w
we need onee? Finnaair is a comp
pany in a com
mplex, highlyy technical buusiness, and it has operations and suupply chain p
partners in doze
ens of differeent countriess, each with vvarying lawss and custom
ms. Moreoverr, our workfoorce is not on
nly culturallyy diverrse, but high
hly specialised and thus n
not always faamiliar with o
other aspects of Finnair ooperations. In such an envirronment, a ccode of cond
duct gives us all a wider, sshared framework in which to suppoort each othe
er and pursue our ultim
mate businesss goals in a ggoal‐oriented, developinng, encouragging, caring a
and fair atmoosphere. The
ese are in facct the kkey leadership and emplo
oyee attributes of Finnaiir personnel – and they a
are the essenntial ingredie
ents for leadiing ourselves and ou
ur company tto success. This Code of Con
nduct has beeen approved
d by Finnair'ss Executive B
Board and Bo
oard of Direct
ctors. It will b
be evaluated and revissed as necesssary at regular intervals. I. Good governance All Fiinnair's operrations are governed by llaws and reggulations and
d supervised by the relevvant authoritties. We com
mply with internationaal and local laws and regulations eveerywhere we operate, and require thee same from
m our businesss partn
ners. This Co
ode of Condu
uct further urges us to exxceed minimum requirem
ments, while also detailin
ng our unco
ompromisingg ethical stan
ndards. The responsibilitty for regulattory compliance lies withh the personss defined and approved bby the autho
orities. Finnaair is also subject to su
upervision reelating to finances and innformation security. The company’s iinstructions ffor internal control state that the managger in charge of each unitt or function is responsib
ble for arrangging internal control with
hin his o
or her unit orr organisation. The internal conttrol environm
ment compriises roles, reesponsibilitie
es, documentted principlees for interna
al control as well as th
he company'ss values and ethics. The roles and ressponsibilitiess are complia
ant with the Finnish Com
mpanies Act, the Finnish Corporatte Governancce Code for LListed Compaanies and the regulations governing the aviation industry. Th
he interrnal audit fun
nction regulaarly reports tto the Audit Committee of Finnair's B
Board of Direectors. The results of thee workk related to tthe Audit Committee's co
ontrol functi on are reporrted to Finna
air's Board off Directors. ety: Our com
mmitment to
o openness Socie
Resp
ponsible com
mmunication is one of the
e fundamenttal requirements for maintaining goood relations w
with all stake
eholders. Wee are open, h
honest and ttimely in all our commun
nications. We
e take differeent perspecttives into conssideration an
nd respect all stakeholders’ views of oour operatio
ons. We welcome open a nd constructtive discussio
on, both
h internally and externally. Every employee has the dutyy to commun
nicate matte rs related to
o their area o
of responsibillity to the relevant target groups. Those in supervisoryy roles have a
a further dutty to communicate goals,, operations and results to their own
n workk communityy and create a work envirronment thaat enables ge
enuine constructive discuussion. In lin
ne with thesee principles, Finnair’s com
mmunicationns are also in
n compliance
e with regulaations govern
ning listed companies and liimited liability companie
es, as well as the obligations of the Finnish Act onn Cooperatio
on within ertakings and the communications guidelines of the State Ow
wnership Ste
eering Departtment. Unde
d lobbying Public affairs and
d industry. A
As such, it is iimportant fo
or us to participate in disccussions and
d decision‐
Aviattion is a stricctly regulated
making that conccern Finnair's operating cconditions.
Finnaair pursues its interests iin an ethicallly sustainabl e manner byy appropriate
ely introduciing its views,, perspectivees and ttechnical exp
pertise wherre necessary. The aim of Finnair's lob
bbying activitties is to maiintain relatio
onships conccerning relevvant policy an
nd to particip
pate in relevvant negotiattions. Finnairr is a membeer of various aviation industry associations, succh as AEA and
d IATA. Finnaair monitors the legality and ethicalitty of public aaffairs and lo
obbying activvities as part of the comp
pany's general supe
ervision and aaudit processses. Corruption and b
bribery: Zero
o tolerance Finnaair does not condone corruption in a
any form. Ideentifying and
d assessing co
orruption rissks are part o
of the generaal risk aassessment ccarried out b
by the compa
any and its bbusiness unitts. Finnaair's procureement policyy sets clear p
principles to eensure ethiccal purchasing. Finnair exxpects its sup
ppliers also to act in acccordance wiith the comp
pany's ethical standards. Finnair's pro
ocurement o
operations arre based on tthe objectivee and fair ttreatment off suppliers. TThe persons m
making proc urement deccisions at Fin
nnair must allways be fully independeent of the b
business parttners concerrned. A Finna
air employeee must declare himself/herself disquaalified due to
o bias wheneever they are required
d to make a decision perrtaining to a contract or b
business rela
ationship invvolving familyy relationships, oncerned (w
with the exce ption of a re
easonable share of owne rship in a listted companyy) or ownership in thee company co
any o
other busineess or debt reelationship e
external to Fiinnair. Supe
ervision relatting to the prrevention off corruption iis the respon
nsibility of ea
ach Finnair eemployee as well as thosee in charge of business functions and the inte
ernal audit. TThe internal audit monito
ors compliannce with the key principlees of Code of Cond
duct as part of analysing and control ling businesss processes a
and through special inspections. the C
Acce
epting or giving bribes is strictly forbidden. Givingg and accepting business gifts should be avoided where possiible without acting co
ontrary to go
ood mannerss. We expectt our employyees to be ca
apable of usinng their own
n best discrettion, and if in doubt, o
of consultingg their superiiors. Where necessary, re
elevant train
ning will be aarranged. No cchild labour Finnaair does not condone thee use of child
d or forced laabour at anyy stage of its value chain. The compan
ny complies with law iin all its operrations and rrequires the same from i ts business p
partners. We
e also requiree that our em
mployees and partn
ners comply with the principles of the UN Declarration of Hum
man Rights in
n all Finnair ooperations. Fair competition
n Finnaair complies with compeetition law in all operatio ns. The Finnair Legal Affa
airs Departm
ment regularlly assesses th
he risks related to competition llaw associate
ed with part nership agre
eements and other operaations. The d
department is uctions and a
arranging tra ining on com
mpetition law
w. responsible for isssuing instru
Spon
nsorships an
nd other com
mmercial sup
pport ojects under the Finnaair only engaages in paid ssponsorships. The compaany chooses its partners carefully. Chharitable pro
company's corpo
orate responsibility initiatives do not generally involve any fin
nancial consiideration. More detailed provided in tthe sponsorsship guidelinnes. instrructions are p
II. O
Our promiise to custtomers ustry constitutes a deep and heavily regulated vaalue chain of numerous ssuppliers of p
products and
d The aaviation indu
serviices. Finnair,, as an airlinee and as a service compaany at the top
p of this chain, creates vaalue for the customer byy offerring a single, seamless an
nd high qualiity service foor transportin
ng people an
nd their posssessions to th
heir destinattions safelly and on tim
me. This means we have a
a responsibillity to the cu
ustomer for tthe overall qquality of tha
at experiencee, regardless of wh
hether we prroduce a parrticular serviice ourselvess or outsource it to a bussiness partner. ng honestly and respectinng the promiises it makess while also ccomplying with industry Finnaair is committted to actin
regulations. We w
welcome cusstomer feedback in all ci rcumstancess, because it gives us thee opportunityy to rectify mistakes, develo
op customer service and evaluate bussiness partne
ers. Safety Fligh
ht safety is always the number one prriority in all ooperations and the comp
pany makes nno comprom
mises on safeety unde
er any circum
mstances. Saffety is also FFinnair’s first priority in ground opera
ations and att every stage
e of the custo
omer journ
ney. duct liability Prod
The most significcant product liability considerations iin Finnair's o
operations arre related to maintenancce, catering aand ground service o
operations ass well as dam
mage to and ddelays with p
passengers, baggage andd cargo. Therre are also significant indem
mnification liaabilities relatted to EU an d United Staates legislatio
on on consum
mer protectiion and erspective, t he most imp
portant product informattion is that re
elated to thee passenger rights. From the customer's pe
cond
ditions of carrriage and cu
ustomer righ
hts. Customer data Finnaair respects tthe privacy o
of its custom
mers and is coommitted to ensuring that personal ddetails and o
other custom
mer inforrmation are p
processed ap
ppropriately. We do our best to guarrantee the co
onfidentialityy, security an
nd accuracy of custo
omer data under all circu
umstances. A
At all stages oof travel we process perssonal detailss in complian
nce with the legislation on personal data aand regulatio
ons issued byy the authorrities in the ccountries in w
which we operate Packkage tours Packkage travel operations carried out by Finnair subssidiaries com
mply with the
e Finnish Packkage Travel A
Act and geneeral industry terms and condition
ns. The Finnissh Consumerr Ombudsmaan supervises the contra ctual practicces of packagge el service pro
oviders and ccompliance w
with the req uirements co
oncerning gu
uarantees aggainst bankru
uptcy. The trave
guarrantees of tour operatorss belonging tto the Finnai r Group are in the form o
of bank guarrantees. Carggo pany is responsible for traansporting customers’ ca
argo in the coondition in w
which it has b
been In caargo transporrt, the comp
entru
usted to us, and in comp
pliance with iinternationa l and national regulation
ns. Resp
ponsible Finn
nair bility is refleccted in its strrategy, as we
ell as its key ssuccess facto
ors of freshn
ness, Finnaair's committment to social responsib
creattivity and qu
uality. Our Vision 2020 also expressess our desire tto be a respo
onsible citizeen of the world and the b
best choicce for passen
ngers who prioritise quality and envi ronmental aand social aw
wareness. rting on its en
nvironmentaal Finnaair historically has been aleading airline in the fieeld of corporrate responsibility, report
impaact since 19997, and becoming the firsst airline to rreport accord
ding to GRI g
guidelines in 2008. The co
ompany takees envirronmental perspectives into consideration in all operations aand supportss the IATA obbjective of ze
ero‐emission
ns aviattion. We com
mply with exiisting environmental legiislation while
e striving to exceed the rrequirementts set by the authorities. Finnaair aims to continue bein
ng a pioneer in evaluating, reporting and reducinng the environmental imp
pacts perations. of op
III. P
Personnel Finnaair employeees conduct their persona
al and work‐rrelated affairrs in a way th
hat preventss conflicts of interest and
d doess not compro
omise imparttiality. We rrespect indivviduality For tthe sake of jo
ob satisfactio
on, occupatio
onal wellbeinng and motivvation, it is im
mportant thaat we respecct and value all Finnaair employeees as individu
uals and give
e everyone t he opportun
nity for self‐e
expression w
within the lim
mits set by thee requ
uirements of their job. Prom
moting equality in a plan
nned and goa
al‐oriented m
manner Finnaair does not discriminatee based on gender, age, eethnic or nattional origin,, nationality,, language, re
eligion, convviction, opinion, health, d
disability, sexxual orientattion or otherr personal reasons or circcumstances. Other perso
onal reaso
ons or circum
mstances maay refer to, fo
or instance, w
wealth, famiily or domicile. Finnaair does not condone dissturbances o
or harassmennt in the worrk community. Reporting g infractions is every employee's rightt and the com
mpany is determined to ttake steps to
o intervene in all cases. Finnaair offers equal opportun
nities for eve
eryone with regard to reccruitment, w
work perform
mance, career progression and developmen
nt. Finnair im
mplements th
he equal pay principle based on the F
Finnish Equallity Act. Finnaair gives both men and w
women equa
al opportunitties for balan
ncing work an
nd family lifee. ne's responssibility Safety is everyon
Finnaair's general principles o
on occupatio
onal and corpporate safetyy are the bassis for develooping safety. Everyone shares the respo
onsibility for ssafety. Everyy employee iis expected tto be prepare
ed to identify
fy hazards, prevent damaage and, where neceessary, act co
orrectly in exceptional cirrcumstancess and in respo
onse to an acccident or otther event involving damagee. Every Finn
nair employe
ee complies w
with safety in
nstructions a
and guidelinees, and assumes responsibility forr the safety o
of their workk environmennt. No tolerance forr harassment Finnaair complies with proced
dures jointly agreed by thhe employer and employyees for the pprevention o
of harassmen
nt and inappropriatte conduct. TThe procedure is based oon the Finnish Act on Occcupational Saafety and He
ealth and complies with the model recommended by the Finnissh Ministry o
of Social Affa
airs and Heal th. How
w can I ensuree compliancce with the C
Code of Condduct? Code of Conduct applies to every Fin
nnair employyee and boarrd member. The C
If a FFinnair emplo
oyee suspectts, or knows, that anotheer employee
e is in violatio
on of companny rules, legiislation or accepted practices, he or shee must reporrt this to his oor her superrvisor or, alte
ernatively, too the personnel managerr of his o
or her unit. Iff the supervissor who rece
eives the repport, determine that the observed vioolation warra
ants further actio
on the matteer is investigaated and the necessary aaction taken upon having
g determinedd the facts off the case. W
When the e
existence of a violation iss ambiguous or the violattion is significant in magnitude, the m
matter must always be repo
orted to the u
unit's executtive team or, if the matteer concerns m
members of an executivee team, to th
he company'ss Execcutive Board or Board of Directors. Finnaair takes violations of thee Code of Co
onduct seriouusly and the company is determined to take actio
on if employees, execcutives or anyy members o
of the Board of Directorss are in violattion of these
e principles. PPenalties and other conssequences att Finnair are determined by the naturre of the violation. Violattions of the CCode of Conduct that aree also violations off the law aree also subjectt to further ccivil or crimin
nal penalties, as determinned by the a
authorities.
The w
way forward
d Our ethical princciples requiree that we are
e open and ddirect and haave the coura
age to highligght occasion
ns when the Code of Co
onduct is nott being adheered to, even
n when they may be unplleasant. Rem
maining silennt in the face
e of misconduct is aggainst our priinciples. d their repressentatives haave a mutual obligation tto foster onggoing, constrructive dialoggue, Management, peersonnel and
in an
n open and tiimely manneer, on the isssues and cha llenges facin
ng Finnair. The business environmen
nt we operatee is subje
ect to rapid cchanges, and
d it is in our b
best interestt to face them
m together.
omplying witth these prin
nciples we ca
an develop a n effective, ttrust‐based w
work commuunity – and b
build a strongg By co
foun
ndation for our future.