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Code of Conduct applies to all companies belonging to Sampo Group and it is the personal responsibility of every Sampo Group employee to comply with the Code of Conduct.
The Code of Conduct was updated in November 2021. The Group companies will provide training on the new Code of Conduct to all employees either separately or as a part of onboarding or other regular training.
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. These principles are manifested in the Code of Conduct, Compliance Principles, Remuneration Principles, and Risk Management Principles, which form the core of Sampo Group's internal governance framework. The principles are reviewed on an annual basis and approved by Sampo plc’s Board of Directors.
The principles aim to ensure that corporate governance is reliably organized at each Group company and that core practices are impeccable and coherent throughout the Group. On the basis of and in compliance with the group-wide principles, each subsidiary designs and implements supplementary company-specific policies, and governance and risk management frameworks.
All the Group-level principles are available on this website.
This Code of Conduct applies to all companies belonging to Sampo Group and it is the personal responsibility of every Sampo Group employee to comply with the Code of Conduct. The Group companies also offer regular training (mandatory e-learning for all employees in local languages) on the topics covered by the Code of Conduct and are committed to communicating the Code to their employees, for example through the intranet, and external stakeholders. Failure to adhere to the principles presented here can expose us, our colleagues, and the various Sampo Group companies to reputational risk, as well as legal and regulatory sanctions.
Sampo plc and the Group companies also expect their 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 this Code of Conduct must be rectified without delay. Inappropriate business or personal conduct that is considered a potential or actual violation of these principles must be reported to a manager or through the whistleblowing channel.
Any breach of Sampo Group’s internal rules may result in disciplinary action (e.g., notice, warning, or dismissal) and/or reduced variable compensation.
Sampo Group provides safety, well-being, and financial security in society.
The Sampo Group companies comply with locally applicable legislation and the rules and regulations of competent authorities in all their activities. Sampo Group’s parent company, Sampo plc, as a publicly listed company, also fully complies 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 supports the UN Global Compact and implements its principles into the Group’s principles, policies, and business practices.
The Sampo Group companies should always strive to act in the best interests of their customers, offering products and services that customers need and want. The products and services should be fair, comprehensible, and designed to help meet the evolving needs of all customers. In addition, the Group companies should aim to take environmental, social and governance (ESG) considerations, including climate change, into account in product and service development, insurance underwriting, and supply chain management.
Furthermore, the Sampo Group companies should ensure that all customers are treated equally and that no individual customer is given preferential treatment at the expense of other customers. The Group companies should only base their insurance premiums on relevant data and not on discriminating factors, such as sexual orientation, religious belief, or ethnic background, etc.
The Group companies must also take appropriate care to ensure that customers are given transparent and easily accessible and understandable information about the costs, risks, and conditions relating to the product or service in question, as well as the reasons leading to a decision regarding an application, where applicable. The Group companies also need to ensure that suitable products are sold to each individual customer in line with their specific risk profile.
Sales, marketing, and product information must be professional, comprehensive, accurate, balanced, and never misleading. In addition, the Group companies must refrain from using small print and coercive tied selling.
The Sampo Group companies are committed to fair and easy claims handling. It should also be easy for customers to provide feedback on the products and services, and complain if they are dissatisfied with the handling of their claim.
ESG issues, including climate change, have an impact on the performance, risks, and value of all companies. Hence, the Sampo Group companies must take these issues into account in investment analysis, decision-making, reporting, and engagement activities.
In order to ensure responsible investments, the Sampo Group companies should utilize various ESG strategies, such as ESG integration, screenings, and active ownership. In addition, the Group companies should continuously strengthen ESG considerations in their investment management and operations.
Compliance with relevant national legislation, together with the provisions and principles laid out by the European General Data Protection Regulation (GDPR) is required from all Sampo Group companies. Personal data is business critical for Group companies and it is collected only for the explicit and legitimate purposes necessary to carry out business. This data must never be 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, while respecting human rights in all aspects of data management. All Sampo Group companies should aim to ensure that the privacy of the employer, employees, customers, and other stakeholders is not breached, and that data privacy training is offered to all employees and contingent workers of the Group.
The Group-level guidance document regarding data privacy is the Sampo Group Data Privacy Statement, which is available here.
The Sampo Group companies are committed to performing regular risk analyses, conducting continuity planning, and having effective internal controls, high-quality systems, and infrastructure to ensure information security and cybersecurity preparedness. At Sampo Group, requirements in relation to information security and cybersecurity are set and expected to be met by both internal and external stakeholders (e.g., third-party data processors).
All Sampo Group employees must adhere to the highest standards of information security and cybersecurity by following internal rules and guidelines, using appropriate tools, and acting responsibly at all times. The Group companies acknowledge the risks related to information security and cybersecurity, and must therefore ensure that suitable training is provided to all their employees and contingent workers.
The Group-level guidance document regarding information security and cybersecurity is the Sampo Group Information Security Principles, which is available here.
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 inside 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, which is available here.
Sampo Group’s goal is to produce accurate, reliable, relevant, 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 and Communication Policy, which is available here.
Sampo Group is committed to ensuring that it observes all applicable tax laws, rules, and regulations in all jurisdictions where it conducts business. Each Sampo Group company must pay its taxes in the countries in which its actual business operations take place. All taxes must be paid on time and the Group is committed not to transfer value created to low-tax jurisdictions. All forms of tax avoidance (e.g., through transfer pricing) are strictly prohibited.
Sampo Group does not practice tax planning or tax structuring that would aim to artificially reduce the Group’s taxable income. With regard to tax-related issues, Group companies must operate within the framework of legislation and legal practice in planning the taxable profit of Group companies. In addition, Group companies’ accounting must always follow local laws and generally accepted accounting principles.
Sampo Group’s employees, suppliers, and other business partners are always expected to act in the best interests of the company. No one employed by Sampo Group may use their position at the Group to promote self-interest. In situations where personal interests may conflict with the interests of Sampo Group, employees are required to abstain from decision-making and assign the issue to a non-conflicted person.
If a Sampo Group employee wishes to take up secondary employment, an additional profession, or act as a self-employed person, they must request and receive specific permission from their leader. Such secondary employment or any of the other activities described above must neither interfere with nor cause any conflict of interest between Sampo Group and the employee.
All Sampo Group companies comply with the applicable local anti-money laundering and counter-terrorist financing rules and legislation, as well as various sanctions regimes that have been implemented by the United Nations (UN) and/or the European Union.
When providing insurance services, the Group companies must always follow authority regulations and required due diligence in order to prevent money laundering, terrorist financing, and other illegal activities. The Group companies must never enter into business relationships with customers, business partners, or other stakeholders who act contrary to the law or principles of sound business practices.
In order to meet the requirements of applicable legislation concerning the prevention of money laundering and terrorist financing, the Sampo Group companies must have sufficient controls, procedures, and training in place to ensure they prevent the use of their services and/or products for money laundering and terrorist financing purposes.
The Group-level guidance document regarding anti-money laundering and counter-terrorist financing is the Sampo Group Guideline for Required Internal Procedures to Prevent Money Laundering and Terrorist Financing, which is available here.
Corruption, the abuse of entrusted power for private and/or corporate gain, can take many forms, such as bribery, excessive business entertainment, facilitation payments (i.e. financial payments that are made with the intention of expediting an administrative process), kickbacks, extortion, fraud, and embezzlement. 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.
Only customary gifts and other such 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.
Dishonest and unfair competition will distort the markets and prevent healthy economic development. Such behavior is never 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 in every jurisdiction in which the Group companies operate. Anti-competitive practices, such as cartels and abuse of dominant market power, are prohibited.
The Sampo Group companies must treat their competitors respectfully and appropriately in competitive situations. The Group companies must not fix prices, agree on market shares, or engage in such activities with their competitors.
Sampo Group employees may only use company assets for legitimate business purposes or other approved purposes, and should always take precautions to protect company assets and property from misuse, waste, damage, or theft.
At Sampo Group, political involvement of any kind (e.g., participation in political activities and direct or indirect political contributions, such as financial donations, loans, sponsorships, and support of organizations funding political campaigns/parties) is prohibited if it is being done on the company’s behalf.
Sampo Group employees have the right to participate in political activities and may volunteer their own time and resources to support the candidates and political parties of their choice. However, these activities must in no way suggest that Sampo Group or any of the Group companies are supporting or financing the political candidate or party in question.
Sampo Group supports the transparency and integrity of lobbying practices to openly declare the Group companies’ business interests and to prevent any conflict of such practices with public international conventions (e.g., ILO, OECD, etc.) or Sampo Group’s commitments (e.g., UN Global Compact, UN PRI, etc.).
The Sampo Group companies must not obtain or try to obtain information or any decision in a dishonest manner, or to misrepresent themselves with the aim of misleading third parties and/or employees of public authorities. Furthermore, the Group companies must ensure they do not induce any employees of public authorities to contravene the rules of behavior that are applicable to them and ensure they respect their obligation of confidentiality.
The Group companies may engage either directly or indirectly with policymakers on relevant topics. However, it should be noted that activities influencing policy must be aligned with Sampo Group’s principles and public commitments.
Sampo Group always aims to be transparent in regard to donations and/or lobbying expenditures.
We promote a fair and safe workplace.
Sampo Group complies with all 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.
The Group companies should aim to prevent complicity in human rights violations through their insurance and investment activities and monitor and report on human rights matters.
The Sampo Group companies must respect each individual’s human rights and not tolerate any kind of discrimination, bullying, harassment, or any other type of abusive behavior. At Sampo Group, all employees must be treated fairly and equally. Discrimination is strictly prohibited, for example, on the grounds of age, disability, ethnic origin, family commitments (including pregnancy), gender, gender identity, political attitude, employees’ representative activities, religion, sensitive medical conditions, sexual orientation, social background, or any other personal characteristics.
In addition, discriminatory practices regarding recruitment, job assignment, training and development, promotion, remuneration and other benefits, or general conduct in the workplace, are not tolerated. The Sampo Group companies should also be committed to gender pay equality.
Ignorance and inaction do not constitute a valid excuse for discrimination.
The Sampo Group companies must ensure high standards regarding safety and mental and physical health. The Group companies should be committed to reducing and preventing the number of work-related accidents, occupational diseases, and the rate of absenteeism. In addition, 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.
The Sampo Group companies must promote the health, well-being, engagement, and professional development of their employees. This includes supporting and promoting competence development, developing leadership practices, and providing a healthy and safe workplace, e.g., by ensuring good ergonomics.
The Group companies must have well-defined organizational structures and responsibilities to support the proactive management of health and well-being. This includes, for example, objectives, programs, training, and awareness-raising.
The Sampo Group companies must guarantee the effective exercise of trade union rights in the workplace. The Group employees must be free to join organizations of their choice that represent them and which are consistent with local organizing laws. These organizations may, if recognized as an appropriate agent, engage in collective bargaining according to the applicable legal regulations.
The Group companies must respect and protect workers' representatives. Those employees who act as representatives are not to be discriminated against, disadvantaged, or favored in any way.
In locations where employees have decided not to appoint representatives, the Sampo Group companies must promote direct and open communication between employees and management.
Sampo Group strongly condemns all forms of forced and compulsory labor, as well as child labor and human trafficking, and it is committed to the abolition of such practices.
The Sampo Group companies should aim to provide a diverse, non-discriminatory, agreeable, and open working environment, which encourages entrepreneurship, and where commendable performance is duly rewarded. Sampo Group is committed to ensuring employment security and responsible workforce restructuring (i.e., the avoidance or minimization of compulsory redundancies, responsible redundancy procedures, measures to mitigate the consequences for employees who have been made redundant, cooperation with employee representatives, etc.), as well as limiting the use of non-regular employment e.g., for specialized non-core activities. The Group companies should also aim to anticipate short-term and long-term employment needs and skills requirements.
At Sampo Group all employees must have a written contract of employment with mutually agreed terms and conditions, including notice periods on both sides. All employees must also be 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 are employed. All employees must be provided with appropriate job skills training that is compatible with their individual career paths.
Sampo Group’s remuneration strategy is responsible with regard to both employees and shareholders. The starting point of any compensation mechanism is to encourage and stimulate employees to consistently do their best and exceed their targets. However, compensation mechanisms must not generate conflicts of interest and must not entice or encourage employees to engage in excessive or unwanted risk-taking.
The Group-level guidance document regarding remuneration is the Sampo Group Remuneration Principles, which is available here.
We are committed to a sustainable future.
The Sampo Group companies comply with the existing legislation and regulations regarding the environment and climate. In addition, Sampo Group supports the Paris Agreement on climate change.
The Sampo Group companies aim to raise awareness, encourage participation, and train employees on environmental and climate matters. The Group companies should also strive to protect the environment and combat climate change. To this end, the Group companies should improve and monitor their environmental and climate performance as follows:
In addition, the Group companies should encourage their customers, investee companies, suppliers, and other business partners to uphold similar environmental and climate commitments.
Sampo Group communicates its environmental and climate-related objectives and activities to all its stakeholders in the Group companies’ sustainability reporting.
Sampo plc and its subsidiaries have their own whistleblowing channels where employees and relevant interest groups can report any 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 that are relevant to the financial services industry. All whistleblowing reports are investigated promptly and in a confidential manner, while always protecting the identity of the whistleblower, in accordance with applicable legislation.