Code of conduct

SATO is a business entity owned by private corporate bodies and private persons. It conducts business in an uncompromisingly honest and ethical manner and it does not participate in any fraudulent activity.

Our operations are subject to many national and international laws and regulations, the compliance of which is a minimum requirement in our business.

We also follow strictly norms and official guidelines that concern our social housing stock.

Every employee is required to work in accordance with the laws and regulations that effect his/her tasks. We understand that failing in obeying the laws and regulations may have serious consequences for the employee and for the company.

We report to the authorities and stakeholders about SATO’s operations, its financial position and about the manner SATO fulfils the obligations regarding sustainability in accordance with the laws and regulations.

In financial reporting all our units observe the harmonised International Financial Reporting Standards (IFRS) and national accounting legislation.

SATO delivers to the tax authorities up-to-date and relevant information which is needed in order to correctly determine the taxation. Compliance with regulations also includes transfer pricing based on market principles.

Internal control and risk management systems are planned to produce sufficient certainty of the reliability of reporting and to ensure that applicable laws and regulations are obeyed.

Conflicts of interest

Our business decisions always take into account the benefit of SATO. Employees shall not use their position or influence for the benefit of any party other than SATO. Decisions shall not be based on personal relations or pressure.

All our employees must recognize situations where might be a conflict of interest and avoid such situations. Through instructions and guidance we help our employees to recognize such situations.

All conflicts of interest or suspicions thereof must be reported immediately to a supervisor or reported in SATO’s Whistleblowing channel.

We do not support financially any political parties or groups or politicians.

Competing

We compete fairly and in compliance with competition legislation. We believe in open and fair competition and we do not seek a competitive advantage by illegal means.

We do not conclude agreements that limit competition, neither do we conduct business that limits competition.

We do not discuss confidential matters or exchange confidential information with our competitors.

Contacts and agreements concluded with competitors and participation in the activity of organisations in our business field must always comply with the provisions of competition legislation.

Bribery and corruption are strictly forbidden in all their forms. We never offer or pay bribes. Neither do we ask for or accept bribes.

In our business we never accept, ask for or offer gifts that are above the reasonable hospitality. We never accept gifts repeatedly from the same persons or organizations, neither do we accept or offer monetary gifts or gifts that could harm the reputation of SATO or endanger the trust in our company, our employees or our business partners.

All our operations shall be in accordance with the laws, good business practices and our Code of Conduct. During the tender process we avoid every action that could affect the orderer’s decision-making.

Participation in an event that is above reasonable hospitality and organised by a supplier or other business partner is acceptable only if there is a legitimate business-related reason for the participation. In such situations, the participant shall have a prior approval for the participation and SATO shall pay our own travel and accommodation expenses.

Customers

Customers are SATO’s most important stakeholders. We want to offer them a safe and healthy home and an excellent customer experience.

We communicate with our customers in an open and truthful way.

We want to be a reliable and long-term landlord for our residents.

We improve our operations by developing new housing concepts and utilizing information received from our customers in a high-quality way and cost efficiently. SATO is always ready to improve itself.

SATO follows good rental practice and operates in accordance with good business practice and regulations concerning marketing and advertising.

SATO makes its best efforts at ensuring the quality of the apartments and services it offers.

In our customer relations we obey international sanctions and anti-money laundering norms.

Stakeholder cooperation

SATO's key stakeholders are the customers, personnel, shareholders and financiers as well as goods and service suppliers and public bodies.

Our relationship with stakeholders is based on honesty and trust. We select our partners carefully.

Our Code of Conduct and separate guidelines for combating the grey economy create a foundation for cooperation. We comply with the legislation aiming at countering the money laundering and funding of terrorism and we ensure that we do not work with parties on international sanction lists.

In construction and repair works we require professionally-skilled working practices that prevent defects in construction.

We require that our partners comply with not only the laws and regulations but also good business practice with us. This includes social obligations, fair competition, opposing corruption, respecting the provisions of the International Labour Organization (ILO) and conducting operations in an environmentally sustainable way.

Insider information means information which has not been made public and which investors may consider important when making decisions on buying or selling financial instruments that SATO has issued.

Insider information is confidential until it has been published or otherwise made available to the market.

A person possessing insider information may not carry out trading in financial instruments that the insider information concerns neither may he/she divulge the information to outsiders prior to its publication.

Insider trading and the use of insider information are regulated by EU Market Abuse Regulation and the Finnish securities market act, compliance with which is monitored by the Financial Supervisory Authority in Finland.

SATO’s internal insider guidelines specify the practices which all persons possessing and handling insider information are required to observe.

We maintain SATO’s property including the company’s fixed assets, inventories, financial assets and other tangible and intangible assets and confidential information.

Each of our employees must protect our property against damage, unauthorised use and disappearance.

The company’s property may not be used for any external purpose without permission.

Information is a valuable asset of our company. We protect the confidentiality, integrity and availability of the information we possess.

The work input or skills of SATO’s employees may not be used against the interests of SATO.

We also handle confidentially information which customers, contractors, suppliers and our other partners have entrusted into our possession.

Privacy

We respect the privacy of our current, former and future customers, employees and partners.

We handle all personal information confidentially and in accordance with data protection legislation and regulations as well as SATO’s data protection and data security guidelines.

Human rights and working life

We comply with fair and just employment practices, employment legislation, collective bargaining agreements and freedom of association, the regulations of the International Labour Organization (ILO) and internationally acknowledged human rights. SATO does not use forced or child labour.

We value diversity and promote equal treatment and equal opportunities in recruitment, remuneration, personal development and career development.

Our target is to guarantee a safe and healthy working environment.

We do not accept the exploitation, harassment or bullying of employees, contractors, goods and service providers, customers or other persons in our working community.

In our annual personnel survey we chart the development needs of our working community which we improve.

Our target is to prevent and reduce the harmful effects of our operations on the environment, nature, people and property and to promote the energy efficiency and efficient use of natural resources.

Efficient functions, material selection, the management of sustainable supply chain and increasing environmental awareness help us to reach our goal. We reduce the load on the environment in our existing housing stock and new construction projects.

We maintain organisation, operational systems and working practices in accordance with the environmental legislation, regulations and operating standards.

SATO’s sustainability programme and strategy guide SATO’s operations in order to reach the increasingly stringent environmental targets through the life cycle of the property.