Provide your due diligence (KYC) information - why is it important?

Like all other pension insurance companies, Elo is obliged to identify and know its company customers, the individuals who have control over those companies and the nature of the companies’ business. This obligation is based on the Act on Preventing Money Laundering and Terrorist Financing (444/2017), and due to our due diligence obligation, we need the relevant information concerning you and your company. Due diligence information is only collected and maintained for these purposes.

You can provide your due diligence information easily through Elo’s Online Service

You only need your online banking codes to log in and, if necessary, our Online Service will begin by providing you with instructions on how to take the service into use. Our Online Service contains additional information about the notification of due diligence information in addition to serving as a convenient tool for the ongoing management of your pension insurance.

Log in to the Online Service

What information do we need from you?

Primarily, we require that our customers provide the due diligence information listed below.

From a company:

The company’s primary business address,
The company’s beneficial owners and
Whether or not the beneficial owners are politically exposed persons or related parties of such persons (PEP).

From an entrepreneur or household employer:

Whether the individual is a politically exposed person or related parties of such a person (PEP).

Actual beneficial owners

Who is considered an actual beneficial owner?

Organisations must always specify their beneficial owner(s) (excluding listed companies, municipalities, joint municipal authorities and unincorporated municipal enterprises). A beneficial owner refers to a natural person who can, by virtue of a specific share of ownership or controlling interest, affect the decisions of the organisation in question.

Controlling interest, for example, in a company is established if a person owns or holds more than 25 % of the company’s shares or votes, or if the person has the right to appoint or dismiss the majority of the members of the company’s board or similar body. A beneficial owner can exercise control either directly or indirectly through one or more companies or organisations.

If it is not possible to identify a beneficial owner based on the criteria specified above, the board or managing director of the company or other person in a similar position are considered to be the beneficial owners. This is referred to as control based on position.

Limited liability companies and cooperatives

A beneficial owner is a natural person who

directly or indirectly owns more than 25% of the scompany shares or otherwise has an equivalent ownership interest in the company
directly or indirectly holds more than 25% of the voting rights in the company, and this share of voting rights is based on ownership, membership, articles of association, a partnership agreement or equivalent instrument, or
in any other way exercises effective control over the company (e.g. through a shareholders’ agreement).

If no individual natural person owns directly or indirectly more than 25% of the company, name the managing director and/or members of the board as the company’s beneficial owners.

General partnerships and limited partnerships

The responsible partners are considered beneficial owners in general partnerships or limited partnerships.

Listed companies

Listed companies do not report their beneficial owners.

However, any subsidiary fully owned (100%) by a listed company must specify their beneficial owners. The managing director and/or board of the subsidiary are considered as beneficial owners.

Foundations, associations, limited liability housing companies and mutual real estate limited companies as well as religious communities

The beneficial owners of a foundation include the members of the board and supervisory board as stated in the Finnish Register of Foundations. If a foundation has no supervisory board, only the members of the board will be considered the beneficial owners of the foundation.

The beneficial owners of an ideological association include the members of the board as stated in the Finnish Register of Associations.

The beneficial owners of limited liability housing companies and mutual real estate limited companies are members of the board as stated in the Finnish Trade Register.

The beneficial owners of religious communities include the members of the board as stated in the Finnish Register of Religious Communities.

The beneficial owners of other organisations include individuals that exercise control over the organisation, such as members of the board.

Private traders

Private traders and entrepreneurs can provide their PEP information by adding themselves as the beneficial owner, if the online service of the (YEL insured) policyholder is not in use.

You can also provide us with the due diligence (KYC) information by using the relevant form

Complete the pdf form online and print and sign it. Send the form to us as a scanned attachment using the secure e-mail service found at www.elo.fi/e-mail or by post to our business reply address:

REPLY PAID
FINLAND
Elo Mutual Pension Insurance Company
Code 5010419
FI-00003 HELSINKI
FINLAND

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