
76Report of the Board of Directors 2024 Corporate governance
Internal audit
The Board of Directors of Employment
Fund decides on the operating model and
criteria for the Fund’s internal audit. The
Fund’s internal audit operates on the basis
of the plans discussed by the audit commit-
tee and approved by the Board of Directors.
In 2024, the internal audit of Employment
Fund was purchased from Pricewater-
houseCoopers Oy. The Fund’s internal audit
reports on its operations to the Board of
Directors and the audit committee on a
regular basis.
Principles of organising
insider administration
Employment Fund has issued publicly
quoted bonds. Employment Fund complies
with the Market Abuse Regulation (MAR)
and other applicable legislation, insider
guidelines and the rules for issuers of other
instruments of Nasdaq Helsinki Ltd. Em-
ployment Fund also has insider guidelines
approved by the Board of Directors, which
describe the most important principles
governing the insider matters of Employ-
ment Fund.
In accordance with MAR requirements,
Employment Fund maintains a list of
persons in management positions and
their related parties. The members of the
Supervisory Board, members of the Board
of Directors, the Managing Director and the
ChiefFinancialOfficerhavebeendefined
by Employment Fund as persons holding
management positions. A person holding a
management position in Employment Fund
may not, directly or indirectly, trade with an
EmploymentFund’sfinancialinstrument
for their own account or for the account of
a third party during a closed period, regard-
less of whether the person in question has
inside information at that time.
For the duration of the closed period, Em-
ployment Fund also imposes trading re-
strictionsonallseparatelydefinedpersons
participating in the preparation of Employ-
mentFund’sinterimfinancialreportand
financialstatementrelease.Theclosedpe-
riod lasts for 30 days before the publication
ofthestatutoryinterimfinancialreportor
thefinancialstatementrelease,including
the date of the publication. Employment
Fund has also decided to voluntary com-
ply with the 30-day closed period policy (i)
before the publication in spring of the es-
timate of unemployment insurance contri-
butions presented to the Ministry of Social
AffairsandHealthforthefollowingyear;
(ii) before the publication in August of the
proposal of Employment Fund’s Board of
Directors for the level of the unemployment
insurance contributions for the following
year;and(iii)beforethepublicationin
August of the budget and the Supervisory
Board’s proposal for the amounts of un-
employment insurance contributions for
the following year. This is because Em-
ployment Fund’s future developments are
assessed in these documents.
Employment Fund establishes an insider
list for each individual project, in which the
details of the persons with access to that
particular insider information is entered
(project-specificinsiderlists).Employment
Fund does not maintain the insider list’s
supplementary section listing permanent
insidersbutonlytheproject-specificlists
are used. Employment Fund has a person