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Code of Conduct

Sampo Group's general governance rests on the idea that Sampo plc, as the parent company of the Group, provides its subsidiaries with a framework of general principles within which the parent company expects the subsidiaries to organize and carry out their businesses.

The principles of the Code of Conduct are reflected in the way Sampo Group organizes corporate governance, the way people treat each other in the workplace, the way Sampo Group’s personnel serve customers, and the way employees deal with other stakeholders, such as investors, suppliers, business partners, tax authorities, and supervising authorities.

In addition to this Code of Conduct, Sampo plc’s Board of Directors has approved group-level principles regarding remuneration (Remuneration Principles), compliance (Compliance Principles), and risk management (Risk Management Principles), which guide the operations and form the basis for company-specific policies. These principles aim to ensure, 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 into account the differences between the subsidiaries and their business areas.

Sampo Group 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, also complies fully with the Finnish Corporate Governance Code, the rules of Nasdaq Helsinki and other essential exchanges, applicable securities market legislation, and authority regulations based on such legislation. Sampo Group also supports the UN Global Compact and implements its principles (Appendix) into the Group’s principles, policies, and business practices.

Scope

This Code of Conduct applies to all companies belonging to Sampo Group. It is the personal responsibility of every Sampo Group employee to comply with the Code of Conduct. Group companies also offer regular training on the topics covered by the Code of Conduct. Failure to adhere to the principles presented here can expose ourselves, colleagues, and Sampo Group companies to reputational risk, as well as legal and regulatory sanctions.

Sampo plc and the Group companies also expect suppliers and other business partners to comply with the principles of this Code of Conduct throughout their own operations and supply chains.

Any breaches of the Code of Conduct must be rectified without delay. Inappropriate business or personal conduct that is a potential or actual violation of these principles must be reported to a manager or through the whistleblowing channel.

Business Principles

Sampo Group is committed to providing safety, well-being, and financial security in society, as is in the interests of and expected by the company and its customers, shareholders, business partners, supervisory authorities, and other stakeholders.

Sampo Group’s core values are ethicality, loyalty, openness, and entrepreneurship.

Responsible Products and Services

Sampo Group companies should always strive to act in the interests of their customers, providing products and services that are fair, comprehensible, and designed to help meet the evolving needs of customers. Customers shall be treated equally, and no individual customer may be unfairly favored at the cost of other customers.

As requirements related to products, services, and sales and marketing practices are constantly evolving, appropriate care shall be taken to ensure that customers are given transparent and easily understandable information about the costs and conditions related to the product or service. Marketing and product information should be professional, comprehensive, accurate, balanced, and not misleading. It should also be easy for customers to appeal, if they are dissatisfied.

Responsible Investments

Sampo Group believes that environmental, social, and governance (ESG) issues have an impact on the long-term performance, risks, and value of all companies. Hence, taking these issues into account in investment analysis, decision-making, reporting, and engagement activities is an important instrument to improve the risk-return profile of investments, and it is a critical success factor for investment activities. Sampo Group has signed the UN Principles for Responsible Investment (PRI) and is dedicated to further strengthening ESG considerations in investment management and operations.

Data Privacy

Regarding data privacy, Sampo Group complies with the relevant national legislation, together with the provisions and principles imposed by the European General Data Protection Regulation (GDPR). Personal data is business critical for Group companies and collected only for the explicit and legitimate purposes necessary to carry out business. The data is not further processed in a manner that conflicts with these purposes.

Sampo Group is committed to processing personal data in a lawful, fair, and transparent manner. All Group companies aim to ensure that the privacy of the employer, employees, and customers is not breached, and that adequate data privacy training is offered to employees of the Group.

The Group-level guidance document regarding data privacy is the Sampo Group Data Privacy Statement, available at www.sampo.com.

Information Security and Cybersecurity

Information security refers to the processes and tools designed and deployed to protect business information from modification, disruption, destruction, and unlawful inspection. Cybersecurity comprises technologies, processes, and controls that are designed to protect systems, networks, and data from cyber events. Information security and cybersecurity are both important factors in ensuring that Sampo Group companies are successful in their business operations.

In Sampo Group, the protection of information and the handling of information are given special attention, and requirements on information security and cybersecurity are set and expected to be met by internal and external stakeholders. Sampo Group companies are committed to performing regular risk analyses, conducting continuity planning, and having effective internal processes, high-quality systems, and infrastructure to ensure an adequate level of information security and cybersecurity preparedness.

All employees must adhere to the highest standards of information security and cybersecurity by following internal rules and guidelines, using appropriate tools, and acting responsibly. Sampo Group acknowledges the risks related to information security and cybersecurity, and ensures that suitable training is provided to employees of the Group companies.

Inside Information and Other Confidential Information

As a publicly listed company, Sampo plc complies with the Finnish Securities Market Act and the EU Market Abuse Regulation, as well as other applicable insider rules and guidelines prohibiting employees, management, and members of the Board of Directors from engaging directly or indirectly in insider trading, or unlawfully disclosing inside information or other confidential information.

The Group-level guidance document regarding inside information is the Sampo Group Guidelines for Insiders, available at www.sampo.com.

Communication

Sampo Group’s goal is to produce accurate, essential, coherent, sufficient, and up-to-date information about the development, strategy, and financial position of its businesses, taking into account applicable laws and regulations, the rules of Nasdaq Helsinki and other essential exchanges, and Sampo Group’s internal guidelines.

The Group-level guidance document regarding communication is the Sampo Group Disclosure Policy, available at www.sampo.com

Tax Obligations

As a responsible taxpayer, Sampo Group is committed to ensuring that it observes all applicable tax laws, rules, and regulations in all jurisdictions where business is conducted. Group companies pay their taxes in the countries in which their actual business operations take place. All taxes are to be paid on time, and a commitment is made not to transfer value created to low-tax jurisdictions.

Sampo Group does not practice tax planning or tax structuring that would aim to artificially decrease the Group’s taxable income. In tax-related issues, Group companies operate within the framework of legislation and legal practice in planning the taxable profit of Group companies. Group companies’ accounting always follows local laws and generally accepted accounting principles.

Professional Ethics

Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF)

Sampo Group complies with the applicable local AML and CTF rules and legislation, as well as various sanctions regimes imposed by the United Nations and/or the European Union. When providing insurance services, Sampo Group companies always follow authority regulations and required due diligence to prevent money laundering, terrorist financing, and other illegal activities. Group companies do not enter into business relationships with customers, business partners, or other stakeholders who act contrary to the law or sound business practices.

In order to meet the requirements of applicable legislation concerning the prevention of money laundering and terrorist financing, Sampo Group must have sufficient controls, procedures, and training in place to prevent the use of Group companies’ services and/or products for money laundering and terrorist financing purposes.

The Group-level guidance document regarding anti-money laundering and counter-terrorism financing is the Sampo Group Guideline for Required Internal Procedures to Prevent Money Laundering and Terrorist Financing, available at www.sampo.com.

Conflicts of Interest

Sampo Group’s employees, suppliers, and other business partners are always expected to act in the best interest of the company. No one employed by Sampo Group may use their position in Sampo Group to promote self-interest. In situations where personal interest may conflict with the interest of Sampo Group, employees are required to abstain from decision-making and assign the issue to a nonconflicted person.

If a Sampo Group employee wishes to take up secondary employment, practice a profession, or act as a self-employed person, they must have 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 Group and the employee.

Corruption and Bribery

Corruption, the abuse of entrusted power for private and/or corporate gain, can take many forms, such as bribery, excessive business entertainment, facilitation payments, kickbacks, and extortion. Sampo Group does not accept any kind of conduct that could create the appearance of improper influence and expects its employees, customers, suppliers, and other business partners to behave in the same way. Employees must ensure that all payments to third parties are appropriate, for a legitimate business reason, and 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.

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 Group. The Group’s policy is to compete in a way that is compliant with all applicable anti-trust and competition laws everywhere the company operates. Sampo Group treats its competitors respectfully and appropriately in competitive situations. Group companies do not fix prices, agree on market shares, or engage in similar activities with competitors.

Use of Company Assets

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

Political Contributions

Sampo Group does not participate in political activity or make any direct or indirect political contributions using company resources.

Human Rights and Labor Practices

Sampo Group is committed to ensuring compliance with applicable human rights, labor, and employment legislation. In addition to national laws and regulations, Sampo Group is committed to respecting the Universal Declaration of Human Rights, the Core Conventions of the International Labour Organization (ILO), the OECD Guidelines for Multinational Enterprises, and the UN Global Compact.

Non-Discrimination

Sampo Group respects each individual’s human rights and does not tolerate any kind of discrimination, bullying, or harassment. At Sampo Group, all employees are treated fairly and equally, regardless of age, disability, ethnic origin, gender, political attitude or workers’ representative activities, religion, or sexual orientation.

Discriminatory practices regarding recruitment, promotion, or remuneration, or in general conduct in the workplace, are not tolerated. Ignorance and inaction do not constitute excuses for discrimination.

Health and Safety

Sampo Group has high standards for health and safety. Employees have a duty to take every reasonable precaution to maintain a safe and healthy working environment and to avoid the possibility of personal injury or putting others at risk.

Sampo Group values and promotes the engagement, health and well-being, and professional development of its employees. This includes developing leadership practices, supporting competence development, and providing a healthy and safe workplace.

Freedom of Association and Collective Bargaining

Sampo Group employees are free to join organizations of their choice that represent them, consistent with local organizing laws. These organizations may, if recognized as an appropriate agent, engage in collective bargaining according to the applicable legal regulations. Employees who act as representatives are neither disadvantaged nor favored in any way.

In locations where employees have decided not to appoint representatives, Sampo Group promotes direct and open communication between employees and management.

Child Labor or Other Forms of Forced or Compulsory Labor

Sampo Group strongly condemns all forms of forced and compulsory labor, as well as child labor, and is committed to the effective abolition of such practices.

Compensation, Working Hours, and Other Conditions of Work

Sampo Group aims to provide a diverse, non-discriminatory, agreeable, and open working environment, which encourages entrepreneurship, and where commendable performance is duly rewarded. All employees will have a written contract of employment with agreed terms and conditions, including notice periods on both sides. All employees are entitled to fair compensation, working hours, facilities, holiday leave, and maternity, paternity, and parental leave in accordance with the legislation of the country where they work. All employees are provided with appropriate job skills training.  

Sampo Group's remuneration strategy is responsible toward employees and shareholders. The starting point of any compensation mechanism is to encourage and stimulate employees to do their best and exceed their targets. However, compensation mechanisms shall not generate conflicts of interest and shall not entice or encourage employees to excessive or unwanted risk-taking.

The Group-level guidance document regarding remuneration is the Sampo Group Remuneration Principles, available at www.sampo.com.

Environment and Climate Change

Sampo Group complies with the existing legislation and regulations regarding the protection of the environment and the prevention of climate change. In addition, Sampo Group is committed to improving its environmental performance; to integrating environmental and climate considerations into its own operations and business activities; to reducing consumption of resources (e.g. energy, water) and improving the efficient use of those resources; to reducing pollution, emissions, and waste generated from business operations, incorporating reduction, re-use, and recycling; and to promoting and undertaking initiatives to encourage greater environmental responsibility and a sustainable future.

Sampo Group aims to raise awareness, encourage participation, and train employees in environmental matters, and to encourage customers, suppliers, and other business partners to uphold similar environmental commitments. Sampo Group communicates its environmental objectives and activities to employees and external stakeholders in the Group’s Corporate Responsibility Report, which is published annually.

Whistleblowing

Sampo plc and its subsidiaries have their own whistleblowing channels where employees and relevant interest groups can report cases in which they have reasonable grounds to suspect that somebody employed by Sampo plc or any of the Group companies has breached legislation, regulations, or other rules relevant to the financial services industry. All whistleblowing reports are investigated promptly in a confidential manner, while protecting the identity of the whistleblower.

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

Appendix: The Principles of the Global Compact

Human rights

Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and
Principle 2: make sure that they are not complicit in human rights abuses.

Labor

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labor;
Principle 5: the effective abolition of child labor; and
Principle 6: the elimination of discrimination in respect of employment and occupation.

Environment

Principle 7: Businesses should support a precautionary approach to environmental challenges;
Principle 8: undertake initiatives to promote greater environmental responsibility; and
Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

Documents

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

Updated 11 Dec 2019