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Code of Conduct

This Code of Conduct applies to all companies belonging to Sampo Group (hereinafter "Sampo"). The Code of Conduct is a general policy guideline supported by Sampo's core values, ethicality, loyalty, openness and entrepreneurship.

The principles of this Code of Conduct are reflected in the way Sampo organizes Corporate Governance, the way people treat each other in the workplace, the way Sampo's personnel serves customers and the way employees deal with other stakeholders, such as investors, co-operation partners, tax authorities and supervising authorities.

In addition to this Code of Conduct, Sampo plc's Board of Directors has approved group level policies regarding remuneration (Remuneration Principles), compliance (Compliance Principles), risk management (Risk Management Principles) and communication (Disclosure Policy), as well as a policy regarding the trading with securities of Sampo's insiders (Insider Guidelines), which guide the operations, and form the basis of company specific policies, on the respective areas of activity in each group company.

These policies aim at ensuring, together with this Code of Conduct, that corporate governance is reliably organized in each Group company and that core practices are impeccable and coherent in all parts of the Group, taking, however, into account the differences between business areas.

It is the personal responsibility of every Sampo employee to comply with this Code of Conduct. Failure to adhere to the principles presented here can expose ourselves, colleagues and Sampo to reputational as well as legal and regulatory sanctions.

If you detect inappropriate business or personal conduct that is a potential or actual violation of these principles, you are encouraged to report it to a manager or report it through the whistleblowing channel.

General Business Principles

Sampo complies in all its activities with locally applicable legislation and the rules and regulations of competent authorities. Sampo Group's parent company, Sampo plc, as a publicly listed company, complies fully also with the Finnish Corporate Governance Code, the rules of the Nasdaq Helsinki, applicable securities market legislation and authority regulations based on such legislation.

In addition to national laws and regulations, Sampo is committed to upholding internationally recognized human rights as defined in the United Nations' Universal Declaration of Human Rights and the core standards of the International Labor Organization (ILO).

Corruption and Bribery

Sampo does not accept any form of corruption, bribery or conduct that could create the appearance of improper influence. Employees must ensure that all payments to third parties are appropriate, for a legitimate business reasons and are correctly recorded.

Gifts and Hospitality

Only customary gifts and other benefits may be given and received in relationships connected to work. Accepting a gift or other benefit must not lead to any kind of relationship with or dependency on the party presenting the gift. The applicable standards shall be evaluated in accordance with the legislation and legal practice of each jurisdiction.

Conflicts of Interest

Sampo's employees and business partners are expected to always act in the best interest of the company. Anyone employed by Sampo may not use his/her positions in Sampo to promote self-interest. In situations where personal interest may conflict with the interest of Sampo, the employees are required to abstain from decision making and assign the issue to a non-conflicted person.

If a Sampo employee wishes to take up secondary employment, practice a profession or act as a self-employed person, they must have a specific permission from their superior. Such secondary employment or other activity described above must not interfere with or cause any conflict of interest between Sampo and the employee.

Confidential Information

Any confidential or proprietary information received in connection with employment may not be disclosed to non-permitted recipients nor used for personal benefit of family members or anyone else. In particular, personal data must be handled and protected in accordance with applicable laws and regulations.

Use of Company Assets

Sampo employees shall use company assets only for legitimate business or other approved purposes and take precautions to protect company assets and property from prevent the misuse, waste, damage or theft.

Anti-trust and Anti-competitive Behavior

Dishonest and unfair competition will distort the markets and prevent healthy economic development. Such behavior is not accepted at Sampo. Sampo's policy is to compete in a way that is in compliance with all applicable anti-trust and competition laws everywhere the company operates.

Money Laundering

Sampo does not enter into business relationships with customers who act contrary to the law or sound business practices. When providing insurance services, Sampo always follows authority regulations and required due diligence to prevent money laundering, terrorist financing and other illegal activities.

Relationships with Stakeholders

Personnel

Sampo aims to provide a non-discriminative, agreeable and open working environment, which encourages entrepreneurship and where commendable performance is duly rewarded.

Each and every employee is treated fairly and equally, regardless of gender, race, religion, nationality, age or physical ability. Discriminatory practices with regard to recruitment, promotion, remuneration, or in the general conduct in the workplace is not tolerated.

Sampo values and promotes the engagement and well-being of its employees. Sampo is committed to developing leadership practices, supporting competence development and providing a healthy workplace.

Customers

Customer satisfaction is the corner stone of successful business. Sampo's customer relationships shall be conducted with integrity, fairness, loyalty, confidentiality and service mindedness. Customers shall be treated equally and no individual customer may be unfairly favored at the cost of other customers.

When providing insurance services to a customer, Sampo business areas shall strive to always act in the interests of their customers, providing products and services that are fair, clear and designed to help meet the evolving needs of customers. Appropriate care shall be taken that the customer receives information which is transparent and marketing activities shall be professional and the market or individual customers may never be given an erroneous or exaggerated image of company's products. Sampo shall also make it easy for customers to appeal, if they are dissatisfied.

Sampo handles and safeguards the personal data of customers according to relevant local laws in the countries where the company operates.

Shareholders and Debt Investors

Shareholders are the key stakeholders of Sampo plc. Sampo plc always acts in the interest of its shareholders with the aim of increasing shareholder value in the long run. As a starting point, all corporate activities shall serve this purpose. It is the duty of the management to ensure that business operations are effective and target-oriented and in conformity with Sampo's general principles.

Sampo treats all shareholders equally. This ensures the attractiveness of Sampo's shares to all investors.

In addition to shareholders, also the holders of bonds and notes issued by Sampo Group companies have invested their wealth in Sampo. Sampo treats also its debt investors equally and with similar principles of openness as it treats the shareholders, always, however, within the rules of relevant exchanges and applicable securities legislation.

Business Partners

Within the perimeter of its influence, Sampo aims at ensuring that all its business and co-operation partners are following business principles which are in conformity with Sampo's principles.

Sampo will never knowingly engage in business with parties who act contrary to the law or sound business practices.

Tax Authorities

Sampo's accounting always follows local laws and generally accepted accounting principles. This ensures that each local tax authority will receive its due share of the profits generated by Sampo's businesses.

Supervisory Authorities

Sampo values and promotes open and active dialogue and interaction with supervisory authorities. Complying with this Code of Conduct contributes towards that goal and also advances the development of regulation to a direction meaningful for the industry.

Sampo's Role in Society

Sampo is committed to promoting the principles of economic, social and ecological sustainability as is required by the interests of the company and its stakeholders.

Sampo promotes general social welfare and economic security of its customers by offering high quality insurance products in conformity with locally applicable legislation and authority regulations. Profitable business also facilitates Sampo to promote the healthy development of society not only as a reliable employer but also as a significant tax payer.

As a significant asset manager, Sampo can also promote the principles of sustainability in its investment approach. Sampo believes that integrating environmental, social, and governance (ESG) criteria in investment decision-making may have a positive impact on long-term returns. Sampo is currently developing Group level carbon footprint analysis and considering ways to integrate ESG criteria into investment decision-making.

Documents

The official Sampo Group Code of Conduct approved by the Board of Directors of Sampo is available in English and Finnish:

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Updated 07/06/2018