The decision-making process and background of the real estate transaction of Hamina Tullimakasiini

On 1 June 2026, the Hamina City Board made a decision on the sale and lease of the property complex consisting of Tullimakasiini, Suolamakasiini and Tapas bar. Since the sale of the property located in Tervasaari has sparked a lot of public discussion and incorrect information is being spread in the public, the City of Hamina wants to open up the decision-making process, stages and grounds to ensure transparency.

Background and objectives of the sales process 

Tullimakasiini has been publicly sold for over a year, since March 2025. The property was classified in the D portfolio of properties for sale in the city's real estate and business premises program. The sale is based on the city's goal to divest itself of unnecessary properties with repair debts to responsible operators. The Tullimakasiini property has a repair debt of approximately one million euros, and the sale will reduce the city's investment needs by that amount. The market price of the property was confirmed by two external and independent appraisals (Newsec Advisory Oy and Catella Property Oy).

Processing of tenders and consultation with tenderers 

The city received two purchase offers for the property (Offer A and Offer B), both of which exceeded the retail price determined by an independent property appraiser. The decision-making process was based on an open consultation, and the city council invited both bidders to its meeting on May 18 to present their plans.

• Bidder A submitted detailed and accurate plans with investment estimates to the city on May 17 and supplemented them later.
• Bidder B presented its plans orally and supplemented them through a lawyer on 25 May. However, Bidder B subsequently withdrew its bid on 28 May, which is why it had to be urgently removed from the agenda during the preparation phase. The bidder announced that its bid would only be valid again on the day of the city council meeting, 1 June. Since the bid came just before the meeting, it was not possible to change the text of the agenda. However, since bid B was withdrawn at such a late stage, the preparation had been properly carried out and both bids had been compared before the decision was made, as is also evident from the public minutes.

Official procedures and decision-making information base 

The city's official address is the Registry Office, through which all official documents, such as offers and reports, must be submitted to the drafters electronically, unless otherwise agreed. All plans and ideas must be presented in connection with the submission of the offer and at the latest before the municipal authority makes a decision. The city has an obligation to provide the parties concerned with a clear opportunity to present the arguments that are decisive in the matter, and the city has done so. 

In this regard, it is worth noting that, according to Section 31 of the Administrative Procedure Act, the party concerned must present an explanation of the grounds for their claim and that the party concerned must otherwise contribute to the investigation of the matter they have initiated. Accordingly, it is the responsibility of the bidder to present their justifications and plans clearly before a decision is made. Due to this formal procedure, it is also important to note that individual members of the City Council cannot hold separate negotiations with the bidders; only the chairman has the right to do so when representing the City Council.

The information that was subsequently made public about the 1,5 million euro investment planned by Bidder B only came to the attention of the city on 3 June, i.e. after the decision was made, and therefore could not have been involved in the official preparation. When the decision was made, the city government had sufficient and extensively prepared information on both bids, and the additional notifications and documents submitted by Bidder B have not caused the need to change the preparation or the rapporteur's proposal for a decision. 

Both bidders were aware of the preparation and decision-making schedule, according to which they had the opportunity to submit the information they wanted to support the processing before the final decision-making. The binding nature of the decision made and the appropriateness of the process also reflect the principle of protection of legitimate expectations in Section 6 of the Administrative Procedure Act, the key content of which is that individuals must be able to trust in the correctness and correctness of the actions of the authorities and the permanence of the administrative decisions made by the authorities. It must be stated that from the perspective of the rule of law, we are moving on dangerous roads if the authorities start to repeal decisions made in accordance with the legal process on their own initiative only because it appears that there is some opposition to the decision.

The decision and its grounds 

At the City Council meeting on June 1, a vote was taken between the basic proposal (accepting Bid A) and rejecting it. As a result of the vote, Bid A was accepted by a vote of 5–4. No other proposals regarding either bid were raised in the City Council during the discussion. No one in the City Council made a motion to accept Bidder B's bid.

The decision was not personal, but was made strictly based on the city's strategy and vitality goals. Bidder A was seen as the overall better option:

• It strongly supports the tourism and business development of Tervasaari by bringing new year-round services to the area.
• The planned business will bear the property's large repair debt at private risk, bring new jobs to the city, and collect community and property taxes.
• The preparation also assessed that the public benefit association activities planned by Bidder B would have been more dependent on city support in the future than a business-led model.

The municipality is not legally obliged to hold a tender for the transfer of the property or to sell the property to the highest bidder. However, the municipality must of course take into account, for example, the general legal principles of administration when making its choice.

Currently, several requests for rectification have been made regarding the City Board's decision regarding the sale of Tullimakasiini, which will in principle be discussed at the City Board meeting on August 10, 2026. After examining the request for rectification, the authority may amend the administrative decision, revoke the decision, or reject the request for rectification. 

City representatives are also actively discussing the matter with both bidders in order to find a solution that satisfies all parties.