Aerial picture taken from the back of Retoriikka. Solar panels are on the roof of the colorful building. Green Kupittaa park is in the background and part of Turku in the horizon.

Responsible investment principles

It is Veritas’ duty to invest pension funds in a profitable and secure manner. Veritas contributes to the implementation of the statutory earnings-related pension scheme in Finland and it is our duty to act in accordance with the long-term interests of our beneficiaries. As part of this position of trust, we believe that environmental, social and governance (ESG) issues can, over time, affect investment returns to varying degrees across companies, sectors, regions and asset classes. Responsible investment is our way to endeavour to secure the return on our investments in the long term and, at the same time, to ensure that risks and opportunities are taken into consideration as comprehensively as possible in our investment decisions.

Our responsible investing activities are guided by our strategy, our investment plan and the following factors:

• Incorporation of responsibility factors in all investment decisions
• Compliance with international norms
• Ownership steering and engagement with investments
• Investment-related climate policy.

Veritas’ Responsible Investment Principles apply to all asset classes, and their application varies depending on the specific asset class and investment method. The Board of Directors of Veritas approves the Responsible Investment Principles on an annual basis. The Sustainability Manager is responsible for updating and drafting the principles, and the investment team for their implementation in the investment activities.

Incorporation of responsibility factors in all investment decisions

We broadly incorporate responsibility factors in all our investment activities, ensuring that we take environmental (E), societal and social (S), and governance (G) perspectives into consideration. The ESG factors vary between asset classes, so we conduct analyses using different criteria for different investments. In accordance with our views, organisations that genuinely and thoroughly consider ESG factors in their activities succeed better financially and encounter fewer risks in the long term.

The reliable management of our investments is of primary importance to us if we are to achieve a profitable and secure investment return that is in keeping with our mandate. We always ensure that our investments and our own activities are sound and in accordance with the principles of good governance.

Compliance with international norms

We undertake to comply with international norms as part of our investment activities. We consider the essential norms to be the principles of the UN’s Global Compact and the separate guidelines issued by the Organisation for Economic Co-operation and Development (OECD) and the International Labour Organization (ILO). We screen our investment portfolio regularly, and in norm violation cases, we primarily seek to influence a change in the operating methods deployed by the investment and, secondarily, to exclude the investment from our portfolio if our influence does not bring about the desired change.

Ownership steering and engagement with investments

The Ownership Policy of Veritas defines our actions and our expectations as an owner and investor. As regards our direct equity investments, Veritas primarily complies with the active ownership model. Veritas believes that addressing problems primarily on the basis of its ownership policy benefits all parties: as an owner, we are able to maintain opportunities for influence from within the company. This enables us to address issues on the societal level as well as to steer our interests in terms of our yield requirements for investments.

As regards indirect investments, Veritas encourages fund managers to employ transparency and open dialogue as a means of resolving possible problems and changing operating practices.

If the ownership steering does not have the desired impacts, we will investigate other ways to intervene in the practices of our investments. Such ways may include disinvestment, an exit from investments or the termination of a contractual relationship. The matter is decided upon on a case-by-case basis with consideration for Veritas’ legislative obligation to realise the statutory management of pension security. As far as possible, we influence the activities of our investments and the markets, alone and through cooperation with others, whenever necessary.

Exclusion

In Veritas’ view, excluding investments reduces the investment universe and increases investment risk due to weaker diversification. Exclusion is also not an effective way to address real‑world sustainability challenges, as it merely shifts the problems for others to solve. For these reasons, Veritas resorts to exclusions only as a last resort, if the desired change cannot be achieved through active ownership.

Defence industry

The principles guiding Veritas’ investment activities allow investments in companies operating in the defence industry. Investment targets are assessed using the same criteria as in other sectors, taking into account our mandate to invest pension assets productively, securely and responsibly. Due to the risks associated with the defence industry, Veritas seeks to limit direct investments to companies whose headquarters are located in an EU or NATO member state. Under the same principles, Veritas may also invest in companies involved in the manufacture of controversial weapons , provided that activities directly related to such weapons are not significant and the company’s main business relates to conventional weapons, supporting functions, or other activities. In addition, Veritas’ responsible investment principles guide the monitoring of human rights violations and norm breaches among investment targets.

Investment-related climate policy

According to The investment-related climate policy of Veritas, our long-term climate policy goal is for our investments to be in line with the Paris Agreement.

Our goal is to select and influence our investments so as to advance the prevention of climate change. At the same time, we believe that we will support beneficial innovations and sustainable growth in the long term. We strive to avoid investments in companies that use nonrenewable energy and in carbon-intensive companies that show no intention of making changes for the better.

We encourage our investee companies to report on climate risks — including physical and transition risks that may affect their business, strategy, and assets — in accordance with internationally recognized frameworks such as the TCFD , or applicable legislation.

Cooperation with other investors

As far as possible, we work collaboratively with other institutional investors on initiatives that support the development of responsible investment activities. As investors, our investment analyses rely on public information, and we therefore advocate increased transparency and essential reporting.

We have undersigned the UN Principles for Responsible Investment (PRI). Additionally, we have undersigned the Fiduciary Duty in the 21st Century Investor Statement. We are also members of the CDP (Carbon Disclosure Project) and Climate Action 100+ and Nature Action 100 initiatives. In addition, we are a member of Finland’s Sustainable Investment Forum (Finsif).

Tax Principles for investment activities

The Tax Principles for Veritas’ investment activities are determined as part of our Responsible Investment Principles. Furthermore, the purpose is to enhance the administrative transparency of the company, prevent misconduct and define the process should acts of misconduct occur.

Veritas endeavours to plan its investment activities in such a way as to avoid double taxation and, thus, facilitate a larger return after taxes.

Double taxation refers to a situation in which two or more countries have, based on their national legislation, the right of taxation on the same income for the same period of time. Such situations occur particularly when investments are made internationally. Unnecessary double taxation unduly weakens investment yields and, in turn, impacts the entire Finnish pension system.

We do our part to promote efficient and fair competition in the market by complying with national and international tax rules, and we condemn tax evasion and aggressive tax planning. Aggressive tax planning refers generally to a situation aimed at artificially reducing the tax liability of a taxpayer by means of arrangements that are inconsistent with the applicable tax legislation. Veritas refrains from aggressive tax planning in all its investment activities. The avoidance of double taxation takes place exclusively within the framework of international tax treaties and is not intended to avoid or reduce the payment of taxes by questionable means.

Veritas also expects both its direct and indirect investments (as well as the relevant fund managers) to be committed to compliance with all international and national tax rules. If it is discovered that some aspect of the investments are in violation of Veritas’ principles, Veritas will intervene as it deems appropriate.

Jurisdictions to avoid

Veritas contributes to the advancement of tax transparency and supports international initiatives to increase transparency on the OECD and EU level. In keeping with these principles, Veritas avoids direct and indirect investments that are registered or subject to taxation:

(a) In jurisdictions that, at the moment of investment, are classified as ‘non-compliant’ in accordance with the Global Forum (Current OECD list: https://www.oecd.org/tax/transparency/documents/exchange-of-information-on-request-ratings.htm) operating under the OECD, or
(b) In jurisdictions that, at the moment of investment, are included on the EU list of non-compliant tax jurisdictions (https://taxation-customs.ec.europa.eu/common-eu-list-third-country-jurisdictions-tax-purposes_en).

Approval of the Responsible Investment Principles

The Board of Directors of Veritas Pension Insurance approves the Responsible Investment Principles on an annual basis. This policy was adopted by the Board of Directors of the company on 16 December 2025.