Chapter I
Scope and introduction
§ 1 The purpose of the Code of Ethics and its application
(1) Finantsinspektsioon bears the serious responsibility of independent national financial supervision, working in some cases with the European Central Bank or other institutions and organisations, and this is the foundation for the Code of Ethics. This responsibility demands integrity and the highest ethical standards from the staff who take it on.
(2) The purpose of the Code of Ethics is to ensure that the staff of Finantsinspektsioon uphold the highest standards of professional principles of ethics and integrity, and that confidential supervisory information is consequently not misused and conflicts of interest do not arise, and that the risks of any such incident are mitigated.
(3) This Code of Ethics of Finantsinspektsioon sets out the expectations of professional ethics for the staff of Finantsinspektsioon arising from the responsibility described here, the terms of § 31 (1) and (2), § 32 (6) and § 321 (8) of the Financial Supervision Authority Act, and the requirement for staff to abide by the internal rules.
(4) The Code of Ethics applies to and must be followed by all those covered by § 2 (1) a. of the code. It does not affect the legal or contractual rights or obligations of Members of the Management Board.
§ 2 Terms used in the Code of Ethics
The following terms are used throughout this Code of Ethics:
a. Staff member. A person who has been appointed or elected to a position within Finantsinspektsioon and who has an employment contract, an authorisation agreement or a similar contract with Finantsinspektsioon. It also covers people such as trainees or interns who are engaged in financial supervision under a non-permanent agreement. External auditors and other external experts or legal entities engaged by Finantsinspektsioon to provide financial supervision are not considered staff members.
b. Subject of financial supervision. A subject of financial supervision as defined in § 2 (2) of the Financial Supervision Authority Act.
c. Single supervisory mechanism. As defined in Article 2 (9) of Council Regulation (EU) No 1024/2013 conferring specific tasks on the European Central Bank concerning policies relating to the prudential supervision of credit institutions.
d. Connected person of a staff member. A person defined in § 7 of the Anti-corruption Act.
e. Confidential information. Information about the single supervisory mechanism or any other information that a staff member has encountered in their work that is not available to the public, as defined in § 54 (2) of the Financial Supervision Authority Act.
f. Financial instruments. The securities listed in § 2 of the Securities Market Act.
§ 3 Presentation and explanation of the Code of Ethics
(1) Staff members are expected first of all to read and understand the Code of Ethics independently.
(2) The Chair of the Board can present the Code of Ethics to a Board member if asked to do so. The other Board members may also be present for the presentation of the Code. The members of the Finantsinspektsioon Management Board can together present and explain the Code of Ethics to the Chair if the Chair so requests.
(3) Members of the Management Board present the Code of Ethics to the heads of departments who report to them, if asked to do so.
(4) The heads of department present and explain the Code of Ethics to the staff members in their department if asked to do so.
(5) Staff members should interpret the requirements for professional ethics that are set out in the Code of Ethics by following the law, the decisions of the Finantsinspektsioon Supervisory Board and the Management Board, the explanations provided here, the standard practice of Finantsinspektsioon, and their own good conscience.
(6) A staff member who is unsure which course of action to follow in order to avoid a breach of the Code of Ethics should seek clarification from the person designated here as responsible for presenting the Code to them.
Chapter II
Principles of professional ethics
§ 4. Public trust
(1) Being a staff member and working for Finantsinspektsioon is a matter of public trust. Staff members must put their loyalty to the constitution, the law, other legislation and the values set out in the Code of Ethics above their own personal interests. Staff members respect and follow the Code of Ethics in order to maintain the trust of the people of Estonia in the integrity of the national governing bodies.
(2) Activities at work at Finantsinspektsioon involve applying state power directly through restrictions and sanctions and indirectly through advice and consultation, and also cover relations between staff members and with outside parties.
§ 5. Ethical conduct
(1) Staff members acting ethically creates and reinforces trust in their work.
(2) Ethical conduct is understood in this Code of Ethics to mean honesty, competence, independence, objectivity, respect, discretion, balance, and a sense of duty, which are values that should be applied in all dealings.
§ 6. Honesty
Staff members must act honestly in all their work.
§ 7. Competence
(1) Staff members are diligent and apply their best knowledge and skills in their work so that Finantsinspektsioon can most efficiently fulfil the mission that it has set itself as stated by law.
(2) Staff members keep their professional knowledge up to date at all times and work constantly to expand it.
(3) Staff members share their professional knowledge and skills with other colleagues in their work. They may also share knowledge and skills that are not specific to their work in supervision with subjects of supervision and other people they meet through their work. Some knowledge and skills that are specific to work in supervision such as supervision tactics and techniques may in certain circumstances be shared with law enforcement authorities.
§ 8. Independence
(1) Staff members are guided in their professional activities by the law and other legislation, the internal rules of Finantsinspektsioon, their job description, and orders, resolutions and other instructions given by the Member of the Management Board responsible for their area and their head of department, and by best practice.
(2) Members of the staff do not submit in their professional activities to unreasonable direct or indirect influence from the media, national or local authorities, subjects of financial supervision, or anyone else.
(3) Staff members are not guided in their professional activities by their political or religious beliefs.
§ 9. Objectivity
(1) Staff members are objective and free from prejudice in their work, and they consider circumstances in full from all sides and apply the law, best practice and their own expertise.
(2) Staff members do not give or allow to be given any advantage or restriction of rights in their work because of a person’s sex, nationality, skin colour, race, mother tongue, social background, religious, political or other convictions, attitude to compulsory military service, marital status, family commitments, health, or membership of civil society organisations.
(3) Staff members do not take advantage for their own personal benefit of any relationships with subjects of financial supervision that arise from their work.
§ 10. Respect, sustainability and prudence
(1) Staff members treat their surroundings with respect, sustainability and prudence in their attitude and actions. They maintain their composure, modesty and dignity in their work.
(2) Staff members act and behave with respect towards Finantsinspektsioon, its Supervisory Board, other members of staff, their own work and that of other staff members, the subjects of financial supervision and their managers, employees and representatives, and anyone else who they encounter in their work. They dress in a neat and presentable manner and avoid activities that could cast their professional activities in a bad light.
(3) Staff members refrain from any conduct in their work that could be damaging to the reputation of Finantsinspektsioon.
§ 11. Discretion
(1) Staff members must act with discretion in all their work. They communicate with the media on professional matters only through the Members of the Management Board or the Head of Communications of Finantsinspektsioon, unless arranged otherwise by the Management Board or a Member of the Management Board.
(2) Staff members do not present themselves as an employee of Finantsinspektsioon, a financial supervisor or some other public official in their private affairs to promote their own personal interest unless it is unavoidably necessary for them to do so in order to avoid harmful consequences for themselves, other people or the general public.
Chapter III
Conflict of interest and managing them
Principles and disclosure of conflicts of interest
§ 12. Definition and principles of conflicts of interest
(1) A conflict of interest arises when the work of a staff member is or may be influenced by their own interests or those a connected person. It also arises when a staff member is forced or incentivised to pursue interests that do not coincide with the professional activities of Finantsinspektsioon or with the mission that it has set itself as stated by law.
(2) Conflicts of interest may be caused by:
a. direct or indirect economic or financial interest;
b. the work of the staff member being directly affected by a direct or indirect personal relationship;
c. past, present or future interests or connections such as employment with a subject of financial supervision or leisure time activities.
(3) Staff members act only in the interest of Finantsinspektsioon in their work, putting those interests ahead of their own interests or those of other parties.
(4) Staff members organise their life and activities in such a way as to minimise any possible risk of a conflict of interest arising.
(5) Staff members may continue their work when there is a conflict of interest only with the approval of the Member of the Management Board who is responsible for their area, the Chair of the Management Board, or the Management Board.
(6) Staff members must disclose any possible conflict of interest without delay in accordance with § 13 of the Code of Ethics.
§ 13. Disclosure of conflicts of interest
(1) Staff members must immediately disclose any circumstances that have created or could create a conflict of interest to their direct manager.
(2) They must also immediately inform the Chair of the Management Board if the circumstances described in § 33 (2) of the Financial Supervision Authority Act arise.
(3) Members of the Management Board meet the requirement for disclosure by disclosing the conflict of interest to the Chair of the Management Board and the Chair of the Management Board meets it by disclosing to the Management Board.
(4) The person to whom the information is disclosed as described here informs the internal auditor about the conflict of interest, and also the Member of the Management Board responsible for the area where possible.
(5) Staff members must disclose information about investments as described in § 19 (4).
Communication with external parties
§ 14. Principles of communication with external parties
(1) Staff members must maintain neutrality with external parties, particularly those from the financial sector, and observe the principle of equal treatment and avoid any behaviour that could appear to provide advantages, including advantages of a commercial or reputational nature, to external parties.
(2) Staff members may not disclose confidential information when communicating with external parties.
(3) Staff members may disclose confidential financial supervisory information or other confidential information only if this is permitted by law and has been expressly agreed in advance with the Member of the Management Board responsible for the area or with the Management Board, while also following § 11 (1) of this Code of Ethics.
§ 15. Lobbyist and lobbying
(1) This Code of Ethics understands a lobbyist as a person who promotes their own interests or those of their client, whether for remuneration or free of charge, which includes promoting private interests or the public interest, or those of another social group.
(2) Lobbyists can include trade associations defending the interests of subjects of financial supervision or other concerned parties, law firms, legal services firms or other consultants, chambers of commerce and industry, professional or business associations, trade unions, voluntary and consumer protection groups, or other organisations and people representing interests that affect the public sphere.
(3) Subjects of financial supervision, parties to administrative procedures, public officials, civil servants, research students, diplomats and political parties acting within the scope of their work are not considered to be lobbyists.
(4) Lobbying is direct or indirect, structured and organised interaction by a lobbyist with a staff member that aims to influence decisions taken by Finantsinspektsioon, shape the activities of the financial supervisor, achieve a beneficial result for the lobbyist or their client, or represent their own interests or those of their client.
(5) Staff members are prohibited from engaging in lobbying work.
§ 16. Recording and publication of meetings
(1) Staff members compile and record reviews of meetings with people from the financial sector that take place outside the normal supervisory dialogue.
(2) A list of the most important meetings with lobbyists attended by Members of the Finantsinspektsioon Management Board or heads of department is published each quarter on the Finantsinspektsioon website.
(3) The list of important meetings with lobbyists gives the following information:
a. the subject of the meeting;
b. the name and organisation of the lobbyist or their representative;
c. the names of Finantsinspektsioon staff members attending the meeting;
d. the date of the meeting.
(4) This information remains on the Finantsinspektsioon website for at least a year.
(5) Finantsinspektsioon may withhold the information and not publish it if it has good reason, which may include ensuring the stability and the fair functioning of the financial sector.
Investing
§ 17. Principles of investing
(1) Staff members may not use any confidential information that they may possess for making investment decisions that benefit themselves, connected people, or any other parties. This covers both direct instructions and indirect recommendations about whether to make a transaction or not, and applies to transactions made by the staff member themselves, connected people or other parties.
(2) The restrictions set in § 17–21 of the Code of Ethics also apply to investments made by a staff member through an entity that is controlled by the staff member as defined in § 9 and 10 of the Securities Market Act.
(3) Staff members must take great care that their activities do not qualify as market abuse as defined in Chapter 21 of the Securities Market Act, the directly applicable European Union legislation that supplements and supersedes it, and § 398 and 3981 of the Penal Code.
(4) Staff member should make their investment decisions to a long-term plan and avoid short-term trading and investing in a way that could damage the reputation of Finantsinspektsioon.
(5) The provisions of § 18–20 of the Code of Ethics do not apply to transactions where a staff member has delegated the management of their personal investments to an independent party under a written portfolio management service agreement.
§ 18. Making investments with subjects of the financial supervision of Finantsinspektsioon
(1) Staff members are prohibited from making financial transactions with:
a. financial instruments issued by subjects of supervision;
b. derivatives of those financial instruments;
c. units of investment funds whose main investment policy is investing in or intermediating those financial instruments or derivatives of them.
(2) This prohibition also applies to the consolidated groups and associated enterprises of subjects of supervision.
(3) These prohibitions also apply to entities that are supervised by the single supervisory mechanism.
§ 19. Making investments in markets under the financial supervision of Finantsinspektsioon
(1) Staff members may make transactions with financial instruments issued and traded on a regulated market supervised by Finantsinspektsioon, with the exception of those securities referred to in § 18, within the restrictions set out in this section.
(2) Staff members may not dispose of the financial instruments from the regulated market within six months of purchasing them, nor repurchase instruments that they have previously disposed of within the preceding six months.
(3) Staff members may dispose of the financial instruments from the regulated market within less than six months with the approval of the Finantsinspektsioon Management Board if the issuer of the securities is involved in a merger or is subject to a takeover bid, or in other exceptional circumstances that are disclosed to Finantsinspektsioon.
(4) Staff members must submit a summary of their investments and of their holdings of financial instruments issued and traded on a regulated market supervised by Finantsinspektsioon as stated in § 32 (7) of the Financial Supervision Authority Act, and they must keep this information up to date.
§ 20. Issues of financial instruments
(1) Staff members may not acquire subscription rights or any other tradable right concerning issues of securities that are or will become subject to § 18 or 19 of this Code of Ethics.
(2) If a staff member acquires a subscription right automatically, they must refrain from exercising that right and from making transactions with it.
(3) Once the issue of securities has been completed, staff members must apply § 18 and 19 of this Code of Ethics.
§ 21. Selling financial instruments that were bought previously
(1) Financial instruments acquired by staff members before they started working for Finantsinspektsioon are subject to § 18 and 19 of this Code of Ethics.
(2) Financial instruments previously acquired by a new staff member that come under § 18 must be disposed of during the staff member’s probationary period or placed under management as described in § 17 (5).
(3) If the new staff member has previously acquired financial instruments that come under § 19, they must follow the restrictions on trading for those instruments.
(4) If a staff member holds financial instruments issued by an entity that becomes a subject of financial supervision, they must dispose of those instruments or place them under management within six months from the time that those instruments become subject to § 18.
Gifts
§ 22. Gifts
(1) Staff members who receive gifts in connection with their professional activities must ensure that doing so is not an illegal activity such as bribery or corruption.
(2) Staff members may not receive gifts in connection with their professional activities if the value of the gift offered to them exceeds 50 euros.
(3) Staff members must immediately inform their manager, Members of the Management Board must inform the Chair of the Board, and the Chair must inform the Management Board if they are given a gift that exceeds 50 euros in value and that was presented to them unexpectedly and would be impolite or impractical to return.
(4) In such cases, the staff member and their manager, the Chair and the Member of the Board, or a Member of the Management Board appointed by the Board arrange for the gift to be given to Finantsinspektsioon and taken into storage.
§ 23. Lunches, dinners and other events
(1) The rules on gifts also apply to staff members attending business lunches, dinners and other events in connection with their work when these have been organised by external parties. Business lunches and dinners are a good opportunity for staff members to showcase professional activities, but should not become too frequent and should not often exceed 50 euros.
(2) Staff members considering whether to accept an invitation to an event should:
a. independently assess the information about the event, including whether it may have any undesirable impact on the independent activities of Finantsinspektsioon such as any unusual costs that may be incurred by those attending the event;
b. consult § 3 of the Code of Ethics if there are doubts about whether attending the event would be a breach of the Code, or turn the invitation down.
(3) Staff members may not accept gifts or other benefits while carrying out on-site inspections or audits, except for hospitality of insignificant value during the inspection.
Suspicious transactions
§ 24. Transactions that differ from market conditions
(1) Staff members may not enter contracts that are signed with conditions that differ significantly from those prevailing in the market and that are offered to the staff member because they work for Finantsinspektsioon or because of the nature of their work.
(2) If a staff member receives an offer that differs significantly from the prevailing market conditions, they must verify whether the conditions are different because they work for Finantsinspektsioon or because of the nature of their work.
(3) This does not apply to contracts signed by Eesti Pank and Finantsinspektsioon.
Cooling-off periods and restrictions on activity
§ 25. Restrictions before leaving employment at Finantsinspektsioon
(1) Staff members whose period of employment is soon to end, if they have submitted their resignation for example or given notice of termination, must tolerate additional measures taken by Finantsinspektsioon to ensure that there will be no conflicts of interest.
(2) These measures may include restrictions on the staff member’s access to data held by Finantsinspektsioon and suspension of their professional activities, with their salary still paid for the duration of their contract.
(3) The restriction on access to data can be applied for up to 30 days before the end of the employment of the staff member.
§ 26. Non-compete agreements after leaving employment at Finantsinspektsioon
(1) Finantsinspektsioon signs a non-compete agreement with staff members who supervise subjects of financial supervision, including at those companies that are expected to become subjects of supervision within six months, and with those who have been involved in such supervision procedures in order to assess and manage possible conflicts of interest for a reasonable period after employment ends.
(2) Finantsinspektsioon assesses whether a non-compete agreement needs to be signed or amended and how long the restrictions in it should last for each staff member separately.
(3) Signing and applying non-compete agreements starts from the terms of the internal rules for work.
§ 27. Presentations and speeches
(1) If a staff member wishes to publish a document, article or book, whether alone or with others, or to make a public presentation that concerns the financial supervisory work of Finantsinspektsioon, the article must first go through the regular publication process of Finantsinspektsioon.
(2) Articles that meet this definition but are published for scientific purposes, such as Bachelor’s, Master’s or doctoral theses, may be published without undergoing the publication procedure provided that it is clearly indicated that the work is the personal opinion of the staff member and that confidentiality has been properly maintained.
(3) Articles that meet the definition and for which a fee will be paid must be declared to the internal auditor.
(4) Members of the Finantsinspektsioon Management Board are not required to comply with the provisions of this section for articles, but they must inform the Management Board about any articles and their contents before they are published, while the Chair of the Management Board has the right under § 23 (2) 3) of the Financial Supervision Authority Act to restrict or prohibit publication of the article.
Chapter IV
Supervision
§ 28. Monitoring of compliance with the Code of Ethics
(1) The Chair of the Management Board and the head of human resources ensure that the Code of Ethics meets the needs of Finantsinspektsioon and complies with the law, and that it is implemented properly.
(2) If a staff member identifies a contradiction in the aims of the Code of Ethics or a conflict with the law, they should notify the head of human resources, stating what they have found. If a staff member identifies that another staff member may have breached the Code of Ethics, they should apply § 29.
(3) The head of human resources analyses reports about breaches of the Code and passes them on to the Chair of the Management Board.
(4) The Chair of the Management Board may submit a summary to the Supervisory Board of any notifications received from the head of human resources.
Informing about breaches of the Code of Ethics
§ 29. Informing about breaches of the Code of Ethics
(1) Staff members should report any breach of the Code of Ethics or of the principles in it to the head of human resources by email.
(2) If a staff member wishes to report on a breach of the Code by the head of human resources, they report orally or by email to the Chair of the Management Board.
(3) If a staff member wishes to report on a breach of the Code by the Chair of the Management Board, they report by email to the head of human resources, who passes the information on to the other Members of the Management Board.
§ 30. Receipt and processing of reports
(1) The head of human resources analyses any reports received as described in § 29(1) and collects any further information that is needed. Once sufficient information has been gathered, the head of human resources forwards the report, together with any relevant documents, to the Chair of the Management Board within two weeks.
(2) The head of human resources and the Chair of the Management Board analyse the report and decide within three months on any measures that need to be taken to remedy the situation or prevent further breaches of the Code.
(3) If the Chair of the Management Board receives a report from a staff member about the head of human resources, they organise, the collection of additional information and apply any measures that need to be taken to remedy the situation or prevent further breaches of the Code.
(4) If Members of the Management Board receive a report about the Chair of the Management Board, they organise the collection of additional information and send the report and any supporting documentation to the internal auditor, who informs the Chair of the Supervisory Board if necessary.
(5) If the person who has submitted the report has requested a summary of the measures taken or the reasons why none were taken, they are informed accordingly.
§ 31. Procedure if a breach of the Code of Ethics is discovered
(1) If a breach of the Code of Ethics is discovered, proceedings may be started against the staff member who committed it to establish whether the law or a contract signed with that staff member has been broken and to decide on any legal sanction or remedy that may need to be applied.
(2) The Chair of the Management Board informs the European Central Bank of any significant breach of ethical standards that they discover if it relates to work with the single supervisory mechanism. If such an incident occurs, notification is given to:
a. the Governing Council of the European Central Bank via the Organisational Development Committee and the Supervisory Board. In urgent cases, the report may also be sent directly to the Governing Council of the European Central Bank; and
b. the Audit Committee of the European Central Bank.
(3) If the breach of the Code of Ethics indicates that the staff member responsible committed or attempted to commit a crime, the Chair of the Management Board informs the investigative authorities.
§ 32. Anonymity of the person who submits the report
(1) The head of human resources and the Chair of the Management Board ensure that the identity of the person submitting the report under § 29 of the Code of Ethics remains anonymous to other members of the staff.
(2) Information on the person who submitted the report is only disclosed to the extent necessary if:
a. the person who submitted the report expressly stated that they want this to be done at the time they made the report; or
b. it must be done in order to comply with the legal requirements on Finantsinspektsioon.
Chapter V
Application
§ 33. Application of the Code of Ethics
(1) Staff members must ensure that their activities comply with the provisions of this Code of Ethics no later than by 01.12.2026.
(2) Staff members must submit the information on crypto assets required in § 19 (4) of the Code of Ethics to Finantsinspektsioon for the first time by no later than 13.11.2026.
(3) Any staff member who is unwilling or unable to fulfil these obligations by the deadline for them must inform their direct manager and the Member of the Management Board responsible for their area by 13.11.2026 at the latest.
(4) In this case, the Management Board arranges for the resolution of the conflict between the staff member and the Code of Ethics.