Ethical business

The Code of Conduct translates Terveystalo’s values into concrete principles that constitute the foundation for Terveystalo’s day-to-day operations and decision-making. Ethics, responsibility and compliance are essential in Terveystalo’s operations, also due to the sector the company operates in. Terveystalo’s business is guided by the legislation governing the industry and private healthcare services, as well as the regulations and requirements established by the authorities. The work of healthcare professionals is also guided by the ethical standards of their specific professional groups.

The Code of Conduct supports Terveystalo's corporate culture and provides a framework that helps ensure compliance with Terveystalo’s values, internal guidelines and the applicable legislation. The Code of Conduct also reflects Terveystalo’s commitments to its key stakeholders. Terveystalo is committed to promoting ethical business practices and requires that all of the company’s operations are conducted in compliance with the applicable laws and regulations. In addition to compliance with legislation and Terveystalo’s Code of Conduct, Terveystalo aims to observe widely accepted ethical standards, such as the UN Global Compact (UNGC) principles. Terveystalo also continuously develops its compliance program and the related processes and controls to ensure that they correspond to the changes in the operating environment.

The Code of Conduct serves as a shared compass for everyone at Terveystalo. The Code of Conduct comprises Terveystalo’s key principles regarding compliance with legislation and ethical business principles, anti-bribery and anti-corruption, avoidance of conflicts of interest, fair competition and the prevention of money laundering, environmental compliance, ensuring privacy and patient safety, employee equality, non-discrimination and the freedom of association, compliance with insider regulations, responsible communications and the reporting of misconduct, among other things. The Code of Conduct is connected to the following material sustainability matters related to business conduct as defined by Terveystalo: corporate culture, responsible supply chain, prevention of corruption and bribery, and respect for human rights.

Everyone at Terveystalo is required to observe the Code of Conduct, regardless of their business unit or role. The same Code of Conduct is also observed at Feelgood in Sweden.

Terveystalo’s Board of Directors approves the Code of Conduct. Management and supervisors are responsible for the communication and implementation of the Code of Conduct, and monitoring compliance with the Code of Conduct. Terveystalo’s Legal and Compliance department supports the organisation with issues related to the Code of Conduct and provides training to the personnel on the Code of Conduct. Terveystalo’s Code of Conduct is published and available to everyone on the company’s external website.

Terveystalo Group also expects its suppliers to observe high standards of sustainability with regard to ethical, social and environmental perspectives, as well as occupational health and safety. Each year, Terveystalo purchases services, materials and supplies for its clinics from approximately 4,400 suppliers. Of these, the 180 largest suppliers account for about 80 percent of total purchasing expenditure. The largest procurement categories are ICT purchases, the rental of premises and subcontracted services, such as laboratory services.

Terveystalo Group’s Supplier Code of Conduct sets out the minimum requirements that all suppliers and partners need to satisfy in order to engage in business with Terveystalo and its subsidiaries. All of Terveystalo’s contract suppliers and suppliers participating in tendering processes are required to accept Terveystalo’s Supplier Code of Conduct. The topics covered by the Supplier Code of Conduct include health and safety, environmental protection, human rights, labour rights, ethics and integrity in business, responsible tax payment and systems for managing the sustainability of operations. Sustainable operating practices are developed in cooperation with Terveystalo’s contractual partners. The Supplier Code of Conduct is connected to all material sustainability matters related to business conduct as defined by Terveystalo: corporate culture, responsible supply chain, prevention of corruption and bribery, respect for human rights and responsible tax payment.

Terveystalo’s Supplier Code of Conduct was last updated in late 2023 and is available on Terveystalo’s external website. Terveystalo Plc’s Board of Directors approves the Supplier Code of Conduct. Other policies and documents that support Terveystalo’s sustainable procurement and supplier cooperation include Terveystalo’s procurement policy, the related procurement guidelines, the supplier management handbook, and audit plans.

One important aspect of Terveystalo’s culture of doing the right thing is that everyone who acts on behalf of or with Terveystalo Group, and every customer, partner and supplier, can freely report any suspicions of misconduct and trust that Terveystalo will take appropriate measures to investigate the matter. Terveystalo Group encourages all of its employees and private practitioners to report any potential misconduct without delay. Terveystalo has online training on the Code of Conduct aimed at everyone in the organisation. The training includes instructions on highlighting and reporting misconduct. The training is described in more detail below in the section on targets related to business conduct on pages 106–107 and in the section on actions related to business conduct on page 109.

Terveystalo Group's Code of Conduct emphasises that actual or suspected violations of the Code of Conduct must be reported to the supervisor, the supervisor’s supervisor or Terveystalo’s Legal and Compliance department. As regards patient safety, everyone at Terveystalo is under the obligation to submit an incident report if they observe, or are made aware of, an issue that jeopardises patient safety, customer safety or data protection. Anyone can submit an incident report via Terveystalo’s website if they observe that patient safety or data protection has been compromised. In HR-related matters, the primary contact channel is Terveystalo’s HR unit.

Suspected misconduct can also be reported via Terveystalo’s reporting channel, which is open to everyone. The reporting channel can be used, for example, if the suspicion concerns serious misconduct or if, due to the sensitivity of the matter, it is necessary to report it anonymously. The reporting channel enables anonymous reporting of observed or suspected misconduct at https://www.report.whistleb.com/en/terveystalo . The reporting channel has been in place since 2017, and it has become established as one possible avenue for reporting suspected misconduct or violations. In Sweden, Feelgood Svenska AB and its subsidiaries have their own reporting channel, which is intended for internal use within Feelgood. Terveystalo and Feelgood use technical reporting channel platforms developed by external service providers, but process and investigate the received reports themselves as described below. All reports and suspicions of misconduct are investigated without delay, independently and impartially regardless of the channel used to report the suspected misconduct, or whether the suspicion of misconduct arises in connection with normal operating activities.

The reporting channel can be used to submit reports concerning actual or suspected misconduct related to the following topics, for example: consumer protection, the prevention of money laundering and terrorist financing, violations of financial market rules and regulations, violations of procurement legislation or unfair competition, environmental protection, violations of data protection legislation and regulations governing the security of network and information systems, taxation, product safety and compliance, as well as actual or suspected violations of the applicable industry-specific regulations, including the Radiation Act and the Medicines Act.

The identity of whistleblowers and the subjects of whistleblower reports, as well as other matters related to the reports, are kept confidential in accordance with the law, and whistleblowers are protected in compliance with the national legislation enacted in Finland and Sweden to implement the European Union’s Whistleblower Protection Directive (Directive (EU) 2019/1937). If a suspected violation proves to be unwarranted, there are no negative consequences to the reporter provided that the reporter has acted in good faith. No retaliation of any kind is allowed. This includes threats, punishments or discrimination against persons who submit reports or persons participating in investigations of reports. Actions to prevent reporting, or to influence the content of a report, are also prohibited.

Reports received via Terveystalo's reporting channel are processed only by persons designated to process reports in the HR or Legal and Compliance function and, where necessary, specialists and Terveystalo’s external advisors appointed on an investigation-specific basis. The designated persons are updated as necessary. The persons who process reports are clearly indicated on the pages of each language version of the reporting channel. If any of the persons who process reports are potentially disqualified from processing a report, the reporter is encouraged to point this out when submitting their report so that the persons who process reports can take the necessary measures to ensure the impartial processing of the report. Disqualified persons will not participate in the processing of the report. Terveystalo’s Senior Vice President, Human Resources and the HR Director process reports concerning HR matters, the Chief Administrative Physician and Chief Medical Officer of the Healthcare Services process reports concerning medical matters, and the Data Protection Officer processes reports concerning data protection. Reports concerning other matters are processed by Terveystalo’s Legal and Compliance department. During the course of an investigation, other specialists can also be appointed to the investigation team if necessary. Where necessary, in investigations of reports concerning a particular employment relationship, the supervisor of the reporter’s supervisor is also engaged in the investigation at an early stage, unless the supervisor’s supervisor is the subject of the report or if engaging them in the investigation is otherwise not appropriate. The subject of the report is heard during the investigation if possible. Where necessary, assistance can be sought from external advisors who are specialists in the subject matter of the report. The persons handling reports are trained on current themes related to whistleblower protection as necessary. Reports received through Feelgood’s internal reporting channel are processed by Feelgood’s Legal Department and/or Quality Manager. If necessary, other specialists can also be appointed internally to the investigation team, and the assistance of external advisors can be requested as necessary.

Any identified incidents of material misconduct are reported to Terveystalo’s senior management and the Audit Committee of the Board of Directors, which monitors the procedures for handling complaints and concerns raised anonymously or otherwise regarding financial reporting, internal control or auditing, potential violations of the rules governing the financial markets, other breaches of legislation or the company’s Code of Conduct, or other violations. In Sweden, any identified incidents of misconduct are reported to Feelgood’s CEO, who is also a member of the Terveystalo Group's Executive Team. If the CEO is disqualified, the misconduct is reported to the Board of Directors of Feelgood Svenska AB or Terveystalo’s General Counsel. The potential findings arising from reported incidents and completed investigations are taken into consideration in the development of Terveystalo Group’s processes.

The data protection policy sets out the principles, obligations, responsibilities, organisation, operating practices and monitoring practices that Terveystalo observes in the implementation and development of data protection. The data protection policy serves as the basis for data protection procedures and guidelines, and its purpose is to ensure the realisation of the rights and freedoms of Terveystalo’s customers, personnel and individual stakeholders with regard to personal data. The data protection policy sets out the principles and methods for ensuring the appropriate processing of personal data throughout the life-cycle of personal data; these principles and methods guide all activities at Terveystalo. It also ensures compliance with legislation governing privacy, data protection and other applicable special laws. The principles underpinning the policy are legal compliance and transparency, purpose limitation, data minimisation, accuracy, restriction of storage, integrity and confidentiality. All Terveystalo personnel must comply with the data protection policy. The data protection policy is confirmed by Terveystalo Group’s CEO and maintained by Terveystalo's Legal Affairs department. The policy is updated as necessary. In Sweden, Feelgood has its own data protection policy, which sets out the principles, obligations, responsibilities, organisation, operating practices and monitoring practices that Feelgood observes in the implementation and development of data protection.

In addition to the data protection policy, Terveystalo has a comprehensive data protection handbook for patient care. Its purpose is to provide guidance on the manner and criteria of processing patient data and personal data, the circumstances in which data can be disclosed, and to which parties data can be disclosed. The data protection handbook for patient care is intended particularly for use by Terveystalo professionals who work with patients. The handbook contains instructions on, among other things, the processing of patient data, informing patients and patient consent, the disclosure of patient data, the data subject's right of access, the rectification and erasure of patient record entries, log data requests, suspected misuse and data protection incidents, and the storage and destruction of patient records. The data protection handbook for patient care is approved by the Data Protection Officer and confirmed by the Chief Administrative Physician.

The objectives, responsibilities, and implementation methods of information security at Terveystalo are set out in the information security policy. The key objectives of the information security policy are the protection of personal data that is in Terveystalo’s possession (e.g. customer and patient data), as well as material subject to intellectual property rights and copyright, and ensuring their appropriate processing; compliance with obligations stipulated by laws, decrees, norms, official regulations and contracts; the identification of threats to Terveystalo’s operations and the appropriate management of information risks, and ensuring the reliability and cost-effectiveness of information processing. The information security policy is developed according to the observations made. The Chief Information Security Officer is in charge of the development efforts.

Terveystalo’s internal control and risk management policy sets out the purpose, objectives and responsibilities of internal control and risk management, and describes the risk classification and risk management structures and the risk assessment process. The internal control and risk management policy is connected to all material sustainability matters related to business conduct as defined by Terveystalo: corporate culture, responsible supply chain, prevention of corruption and bribery, respect for human rights and responsible tax payment.

The purpose of internal control is to ensure that Terveystalo’s operations are efficient and effective, the information used by the senior management in decision-making is reliable, policies are observed, and Terveystalo operates in compliance with laws and regulations. Internal control supports the supervisory work of the Board of Directors and comprises any measures and procedures aiming to ensure the achievement of said goals. Internal control covers the organisation’s internal operating environment, goal-setting, risk management, control measures, information flow, communications, and monitoring. Internal control is integrated into Terveystalo’s management and reporting system. Internal control is carried out by Terveystalo Plc’s Board of Directors, the Audit Committee, Group management, operational management and employees, and the Group’s internal audit and quality assurance function. The Group has an outsourced internal audit function.

The purpose of risk management is to support the achievement of business goals by supporting decision-making. It helps to ensure the fulfillment of the customer promise, patient safety and occupational safety, high-quality services, financial performance, business continuity, a good public image for the company, and corporate social responsibility. Risk management also involves conscious risk-taking to seize opportunities. The objectives of risk management include ensuring Terveystalo’s clinical quality and patient safety, the fulfillment of customer promises, business continuity and the achievement of strategic and operational targets, as well as ensuring personnel competence and occupational safety, information security and data protection. Terveystalo Plc’s Board of Directors is responsible for the adequacy of risk management. The CEO is in charge of the organisation of risk management and guides and monitors risk management at the executive level. The other members of the Executive Team support the CEO in implementing risk management, monitoring operational risks, assessing risks, and implementing measures related to risks.

The internal control and risk management policy is approved by Terveystalo Plc's Board of Directors. Terveystalo’s internal control, risk management and internal auditing are described in more detail in Terveystalo’s Corporate Governance Statement.

Terveystalo is committed to respecting the fundamental rights and freedoms of all individuals in accordance with international human rights standards. Terveystalo’s first human rights policy, approved in January 2025, emphasises the company’s commitment and approach to respecting human rights. Terveystalo’s mission to “fight for a healthier life” is the foundation of the human rights policy. The human rights policy is connected to following material sustainability matters related to business conduct as defined by Terveystalo: corporate culture, responsible supply chain, and respect for human rights.

In accordance with Terveystalo’s human rights policy, the company is committed to respecting human rights in accordance with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. Terveystalo is also committed to the international human rights framework (Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights) and the ILO Declaration on Fundamental Principles and Rights at Work (freedom of association, the right to collective bargaining, the elimination of all forms of forced or compulsory labour, the abolition of child labour, the elimination of discrimination in respect of employment and occupation, a safe and healthy working environment). Should any activities have the potential to affect vulnerable groups, Terveystalo also takes into account other international norms and principles, such as the Convention on the Rights of the Child. 

The human rights policy describes the company’s most significant human rights risks and impacts, the processes for managing, mitigating and eliminating the most significant risks, and whistleblowing mechanisms. The human rights impact assessment carried out in late 2024 constitutes the basis for the policy, and will be taken into account as part of the update of the double materiality assessment in 2025. The process for managing, mitigating and eliminating the most significant risks will be further developed in 2025, particularly with regard to the supply chain. Terveystalo’s human rights policy is approved by Terveystalo's Board of Directors. Terveystalo’s Executive Team is responsible for ensuring that the principles set out in the policy are taken into account in the Group’s strategy and day-to-day operations.

Terveystalo’s Code of Conduct includes a commitment to fair, honest and legally compliant competition. All Terveystalo employees are required to comply with laws, regulations and internal guidelines pertaining to competition, including Terveystalo Group’s competition law guidelines. The Group's competition law guidelines include instructions on compliance with competition rules in relation to competitors, suppliers, independent private practitioners and customers, as well as instructions pertaining to memberships in industry associations, among other things. The competition law guidelines are connected to following material sustainability matters related to business conduct as defined by Terveystalo: corporate culture, responsible supply chain, prevention of corruption and bribery, and responsible tax payment.

The Executive Team member in charge of legal affairs is responsible for the competition law guidelines. Each member of the Executive Team is responsible for compliance with the guidelines in their respective areas of responsibility. Terveystalo’s Legal and Compliance department is responsible for maintaining and updating the competition law guidelines.

In the area of anti-corruption and anti-bribery, Terveystalo complies with the law and other applicable regulations and guidelines. Terveystalo is also committed to the UN Global Compact (UNGC) initiative and its anti-corruption principles. Terveystalo’s operations are also guided by the Code of Conduct, which lays down the main principles for the prevention of corruption and bribery including, for example, giving and accepting gifts and hospitality, the avoidance of conflicts of interest, and fair competition. Terveystalo has an anti-corruption and anti-bribery compliance programme that includes policies, process instructions and other supplementary instructions on the subject. The guidelines cover, among other things, gifts and hospitality, disqualification, fair competition and a sustainable supply chain and value chain.

The prevention of corruption and bribery is included in Terveystalo’s Code of Conduct, which addresses the giving and accepting of gifts and hospitality, sponsorships, accepting and making donations, understanding and avoiding conflicts of interest, and fair competition. All of Terveystalo’s contract suppliers and suppliers participating in tendering processes are required to accept Terveystalo’s Supplier Code of Conduct, which includes guidelines and requirements concerning the prevention of corruption and bribery, conflicts of interest, and fair competition, amongst other things. 

Terveystalo’s Code of Conduct emphasises that Terveystalo does not give or accept gifts or other benefits that could affect business decisions or have considerable personal or financial value. Any gifts given and hospitality offered must support a clear business objective, be of reasonable value and be appropriate with regard to the nature of the business relationship. In accordance with the Code of Conduct, all decisions and transactions made at Terveystalo must be in Terveystalo’s best interest and not based on anyone’s personal interests. Friends and relatives must be treated like any other partners, and personal relationships with partners must not influence decision-making. Everyone at Terveystalo must recognise and avoid conflicts of interest and refrain from making decisions that involve, or may involve, a conflict of interest. Any circumstances that may be considered a conflict of interest must be reported to the supervisor immediately, and the matter must be resolved in accordance with Terveystalo's interests.

In addition to customers, personnel, private practitioners, shareholders and suppliers, Terveystalo’s key stakeholders include the public authorities and societal decision-makers that influence the legislation governing Terveystalo’s industry and the drafting of such legislation. The development and renewal of healthcare is a shared goal for Terveystalo, the authorities and decision-makers. Terveystalo engages in open dialogue on issues related to the healthcare sector with the authorities and societal decision-makers. The channels of interaction include open dialogue, meetings and staying in touch through participation in various working groups and events, among other things. Terveystalo also has representatives in several organisations. The most significant of these are the Confederation of Finnish Industries, the Finland Chamber of Commerce, the Helsinki Region Chamber of Commerce, the Finnish Association of Private Care Providers HALI, the Association of Finnish Private Healthcare Providers, the Finnish Association of Purchasing and Logistics LOGY, and FIBS ry. Terveystalo conducts open dialogue with industry organisations on topics related to the industry and engages in diverse cooperation with organisations such as the Finnish Association of Private Care Providers HALI and the Association of Finnish Private Healthcare Providers. The cooperation channels include working groups and various events.

According to the Code of Conduct, Terveystalo does not support political activities. Terveystalo does not sponsor political parties or organisations, directly or indirectly, nor does Terveystalo fund the election campaigns of individual candidates.

Terveystalo’s Code of Conduct includes a commitment to fair competition. Terveystalo competes fairly, with integrity, and in compliance with the applicable legislation. All Terveystalo employees are required to comply with laws, regulations and internal guidelines pertaining to competition, including Terveystalo Group’s competition law guidelines.

Terveystalo has mandatory online training on the Code of Conduct and compliance for all employees. The aim of the training is to provide an improved understanding of key compliance-related themes, such as the avoidance of conflicts of interest, the prevention of bribery, and fair competition. The content concerning the prevention of corruption and bribery was compiled into a separate course section in the revised online course on compliance in 2023. Among Terveystalo’s internal functions, public services, B2B sales and procurement are the most susceptible to corruption and bribery. The aforementioned online training on the Code of Conduct, which also includes content on the prevention of corruption and bribery, is mandatory for all Terveystalo employees and therefore also for all employees working in the functions identified as having an elevated risk.

Terveystalo is committed to promoting and ensuring the ethical and responsible use of artificial intelligence. Our purpose is to fight for a healthier life through pioneering advancements that help reform the healthcare sector, always guided by medical science and centred around human beings. Digital solutions, including AI, are integral to our strategy; we aim to drive innovation that contributes positively to society.

Terveystalo Ethical Principles for AI offer high-level guidance on how AI initiatives are developed and utilized within our organization. These principles help prioritize our efforts and ensure we make the right decisions in this rapidly evolving landscape. They are complemented by more detailed internal policies and guidelines on the development and use of AI. This document will be reviewed and amended as necessary to keep pace with technological advancements.

1. Sustainable

Terveystalo’s sustainability commitments and goals also drive our AI agenda. Addressing the care gap is a significant societal challenge, where AI brings great potential to expand access to care for more people whilst maintaining a high degree of medical quality. We promote the health and well-being of our customers and build humane and efficient work communities. We aim to positively impact society and uphold ethical business practices in our value chain. We also strive to minimise our environmental impacts across all operations, including the resources needed to run AI. AI should help us achieve these goals, and our focus on sustainability inform our decisions on where to utilize AI, ensuring it brings the most significant benefits.

2. Human-centric

We use AI in a manner that prioritizes human rights, health, and well-being, supporting human agency in alignment with our values. While AI may alter the ways we work in the future, this transformation should lead to more meaningful work for our healthcare professionals and other staff. Ultimately, AI should be integrated into our operations to benefit patients, whether indirectly through more efficient use of resources or directly by improving access to care, care outcomes, and customer experience. 

3. Accountable

Trust in new, rapidly developing technologies necessitates accountability. Terveystalo remains accountable for the AI technologies it uses. Individual employees are responsible for using AI technologies in accordance with Terveystalo’s guidelines and policies. Accountability is further supported at Terveystalo by increasing employees’ awareness of the responsible use of AI.

4. Valid

We develop and train AI using reliable data and relevant use cases, with clearly stated intended purposes. Terveystalo adheres to medical research, technological advancements, and relevant regulations and guidelines for the use of AI.

5. Safe and secure

We only use AI systems that are robust, reliable, and resistant to misuse or harm. This involves implementing measures to protect against vulnerabilities and maintain integrity. We develop AI systems to ensure they perform accurately and consistently and evaluate regularly our partners’ AI systems’ security and compliance measures. Robust cybersecurity measures are essential to protect AI systems from cyber threats and vulnerabilities. We monitor AI systems continuously to detect and address any issues that may arise during their use.

6. Transparent and explainable

Ethical use of AI includes providing transparency and explainability into how we utilize AI. Measures to promote transparent and explainable AI are tailored to the specific technology in question and the target group’s need for information. As a starting point, we aim to provide clear and accessible information on where and how AI is applied within our operations. The functioning of AI should be explainable and can be implemented in various ways, such as documenting the technical set-up of AI and logging and traceability features to track and review the steps taken by AI in making decisions.

7. Private

Privacy and data protection remain a priority when developing and using AI, and we strive to ensure compliance with applicable privacy and data protection legislation at all stages of operating with AI. 

8. Fair

We require that AI systems do not discriminate against individuals. This includes evaluating AI outputs for fairness and non-discrimination across different demographic groups. We design AI systems to provide equitable treatment and recommendations for all individuals, regardless of their background.

9. Continuously improved

Terveystalo continuously evaluates and re-evaluates AI developed or used by us throughout its lifecycle, implementing the necessary improvements and adjustments. Continuous improvement also applies to our approach to AI Governance and these Principles.

Terveystalo’s tax position is guided by Terveystalo's tax policy, which covers the group-level guideline, and is a publicly available document. Terveystalo's tax policy is revised regularly. The responsibility for keeping the tax policy adequate and updated lies with Terveystalo's tax team within the finance unit. Changes to Terveystalo's tax policy are approved by Terveystalo's CEO. The tax policy is based on Terveystalo's strategy and values, according to which the company aims to be the leader and policy maker in its industry. Further, Terveystalo’s intention is to positively impact society. Matters related to taxation always have business reasons at Terveystalo – taxation does not drive the conduct of business abroad.

In accordance with Terveystalo’s policies related to the payment of taxes, the company pays, collects, remits and reports its indirect and direct taxes in full at the right time and place, i.e. where the economic activity, value-added and work generating the profit actually take place. This means that Terveystalo, as a Group, pays the majority of its taxes to Finland, which is where most of its operations take place. In addition, taxes were paid in 2024 to Sweden for the Feelgood business and to Estonia for the operations of Terveystalo Estonia Oü. Terveystalo’s responsible tax policy ensures that the company’s financial profit is divided fairly between its key stakeholders, namely customers, shareholders, municipalities, and the state. Tax revenue, in turn, is used to finance public services and investments that support the state’s capabilities, sustainability, and responsiveness.

Terveystalo publishes its tax footprint annually. The tax footprint describes the total sum and distribution of taxes and tax-like charges paid to society. Terveystalo’s direct taxes include corporate income tax, transfer tax and real estate tax, and the company’s indirect taxes include value added tax, for example. Terveystalo’s income taxes are reported on a cash basis, which is why the amount of corporate income tax varies between financial periods. The amount of corporate income tax depends on the taxable profit of the separate companies, and the taxable profit is affected by the Group companies’ business operations and changes during the financial period. In accordance with the Tax Accounting Act, a share of the corporate income tax Terveystalo pays is distributed to the municipalities where Terveystalo’s employees have worked, based on the number of employees. This means that all of Terveystalo’s clinics and outsourcing operations accrue tax revenue for the municipality they operate in.

As a basic rule, private healthcare companies are not eligible to deduct value added tax on purchases, which means that VAT is a substantial factor for companies. Indeed, the proportion of value added tax that is not deducted increases Terveystalo’s tax footprint. The healthcare services sold by a private service provider are tax-free for customers. As in previous years, Terveystalo’s tax footprint reporting describes the share of VAT that is recognised as an expense for Terveystalo Group. However, some services – such as cosmetic surgery – may not be exempted from VAT for the customer, which means Terveystalo collects and remits VAT. Starting from the financial period 2022, Terveystalo has added its net remitted VAT to its tax footprint. This consists of the VAT remitted to the Finnish Tax Administration for Terveystalo’s services subject to VAT. The amount of net remitted VAT depends on the extent of business operations subject to VAT, which varies from one financial period to the next. Period-specific fluctuations in volume are reflected in period-specific differences in the amount of net remitted VAT.