Publication of the Farm Entrepreneurs' Pension Institution's Governance

Memorandum 1 (4) 3 December 2018 FIVA 8/01.00/2018 Occupational Pension Institutions Public FINANSVALVONTA (Financial Supervisory Authority) Snellmaninkatu 6, P.O. Box 103, 00101 Helsinki Switchboard 09 183 51 finanssivalvonta.fi Rules and Guidelines 8/2018 Farm Entrepreneurs' Pension Institution's Governance: Summary and Feedback on Statements Reference | Comments with justifications (and possible wording proposal) | Financial Supervisory Authority's response General comments The Farm Entrepreneurs' Pension Institution (Mela) considers the Financial Supervisory Authority's own rules and guidelines collection prepared for Mela to be highly necessary. Mela considers that the draft currently under consultation aligns well with the objectives set for it, by clarifying, among other things, the rules and guidelines concerning Mela's governance and the institution's operations. The rules and guidelines have taken into account the specific features of the legislation regulating Mela's operations compared to other pension institutions. Mela has also been able to present its comments during the draft preparation phase. The Central Union of Agricultural Producers in Finland (MTK) considers that the Financial Supervisory Authority's rules and guidelines concerning Mela's operations, along with their objectives, are good and justified. Occupational pension insurers TELA ry, the Bank of Finland, the Ministry of Finance, the Pension Security Centre, the Ministry of Social Affairs and Health, the Ministry of Agriculture and Forestry, the Competition and Consumer Authority,

Memorandum 2 (4) 3 December 2018 FIVA 8/01.00/2018 Occupational Pension Institutions Public FINANSVALVONTA (Financial Supervisory Authority) Snellmaninkatu 6, P.O. Box 103, 00101 Helsinki Switchboard 09 183 51 finanssivalvonta.fi The Confederation of Finnish Industries EK and the Central Organisation of Finnish Trade Unions SAK ry have no comments on the draft. Chapter-specific comments Chapter 13. Credit acquisition, reports to the Financial Supervisory Authority therefrom and credit risk swap agreements The Institute of Certified Public Accountants in Finland (Tilintarkastajat ry) proposes that the term "audit meeting" be replaced with "annual audit". According to Tilintarkastajat ry, annual audit is a more established concept. It is used, for example, in several other similar Fiva rules. Fiva notes that "audit meeting" is an established term for Mela, and it is also used in the Financial Supervisory Authority's rules and guidelines 4/2015 on submitting supervision documents for entities operating in the insurance market to the Financial Supervisory Authority. Does not result in changes to the draft rules and guidelines.

Memorandum 3 (4) 3 December 2018 FIVA 8/01.00/2018 Occupational Pension Institutions Public FINANSVALVONTA (Financial Supervisory Authority) Snellmaninkatu 6, P.O. Box 103, 00101 Helsinki Switchboard 09 183 51 finanssivalvonta.fi Chapter 15. Disability risk management MTK considers important the measures that promote the work well-being of farm entrepreneurs and maintain working capacity, thereby also extending working life through a reduction in the amount of disability pensions. MTK considers that guiding Mela's work well-being activities through the Financial Supervisory Authority's regulations is justified and clarifies operations. Mela states that work well-being activities are highly important for reducing the disability risk of Mela's insured persons. It is good that the Financial Supervisory Authority now provides explicit guidelines to Mela on the content of actions aimed at managing disability risk. STATEMENTS REQUESTED (those who gave statements are highlighted):

• Insurance Department of the Ministry of Social Affairs and Health
• Ministry of Finance
• Legislative Department of the Ministry of Justice
• Ministry of Agriculture and Forestry
• Bank of Finland
• Pension Security Centre (Kela)
• Competition and Consumer Authority
• Farm Entrepreneurs' Pension Institution (Mela)
• Central Union of Agricultural Producers in Finland (MTK)
• Academic Professionals' Union of Finland (Akava)
• Confederation of Professional Employees (STTK)

Memorandum 4 (4) 3 December 2018 FIVA 8/01.00/2018 Occupational Pension Institutions Public FINANSVALVONTA (Financial Supervisory Authority) Snellmaninkatu 6, P.O. Box 103, 00101 Helsinki Switchboard 09 183 51 finanssivalvonta.fi

• Central Organisation of Finnish Trade Unions (SAK)
• Confederation of Finnish Industries (EK)
• Financial Industry Finland (Finanssiala)
• Occupational Pension Insurers (TELA)
• Institute of Certified Public Accountants in Finland (Tilintarkastajat).