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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 August 2020. 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.
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 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 our 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 to be a potential or actual violation of these principles must be reported to a manager or through the whistleblowing channel.
Sampo Group is committed to providing safety, well-being, and financial security in society, as this is in the interests of and expected by the company and its customers, shareholders, business partners, supervisory authorities, and other stakeholders.
In all its activities, Sampo Group complies 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 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.
Furthermore, Sampo Group supports the UN Global Compact and implements its principles into the Group’s principles, policies, and business practices.
Sampo Group companies should always strive to act in the best interests of their customers. This means they should provide products and services that are fair, comprehensible, sustainable, and designed to help meet the evolving needs of all customers. Furthermore, 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.
As requirements related to products, services, and sales and marketing practices are constantly evolving, appropriate care must be taken to ensure that customers are given transparent and easily understandable information about the costs and conditions relating to the product or service in question. Marketing and product information should be professional, comprehensive, accurate, balanced, and never misleading. Sampo Group companies must refrain from using small print. It should also be easy for customers to complain if they are dissatisfied with the product or service they have received.
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 for improving the risk-return profile of investments, and it is a critical success factor in regard to investment activities. Furthermore, in order to ensure responsible investment, Sampo Group is committed to utilizing various ESG strategies, such as ESG integration, screenings, and active ownership.
Sampo Group has also signed the UN Principles for Responsible Investment (PRI) and it is dedicated to further strengthening ESG considerations in investment management and operations.
In regard to data privacy, Sampo Group complies with all of the relevant national legislation, together with the provisions and principles laid out by the European General Data Protection Regulation (GDPR). Personal data is business critical for Group companies and it is collected only for the explicit and legitimate purposes necessary to carry out business. The data is never 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 Sampo Group companies aim at ensuring the privacy of the employer, employees, and customers is not breached, and that data privacy training is offered to all employees of the Group.
The Group-level guidance document regarding data privacy is the Sampo Group Data Privacy Statement.
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.
At Sampo Group, the protection of information and the handling of information are given special attention, and requirements in relation to information security and cybersecurity are set and expected to be met by both 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 information security and cybersecurity preparedness.
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. Sampo Group acknowledges the risks related to information security and cybersecurity, and therefore ensures that suitable training is provided to all employees of the Group companies.
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.
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.
As a responsible taxpayer, 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 pays its taxes in the countries in which its actual business operations take place. All taxes must be paid on time and we are committed to not transfer value created to low-tax jurisdictions.
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 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.
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 Sampo 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 nonconflicted 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 superior. 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.
Sampo Group complies with the applicable local anti-money laundering and counter-terrorist financing rules rules and legislation, as well as various sanctions regimes that have been implemented by the United Nations and/or the European Union. When providing insurance services, Sampo Group companies always follow authority regulations and required due diligence in order to prevent money laundering, terrorist financing, and other illegal activities. Sampo 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, Sampo Group must have sufficient controls, procedures, and training in place to ensure it prevents the use of Sampo 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.
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 company operates. Sampo Group treats its competitors respectfully and appropriately in competitive situations. Sampo Group companies do not fix prices, agree on market shares, or engage in similar activities with its competitors.
Sampo Group employees must 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.
Sampo Group does not participate in political activities or make any direct or indirect political contributions (e.g. financial donations, loans, sponsorships, support of organizations funding political campaigns/parties) using company resources.
At Sampo Group, political involvement of any kind is prohibited on the company’s behalf. Sampo Group employees have the right to participate in political activities and may volunteer their own time and resources in order to support the candidates and political parties of their choice. However, these activities must in no way suggest that Sampo Group supports or finances the political candidate or party in question.
Sampo Group is committed to ensuring it complies 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. The Group companies aim to prevent complicity in human rights violations through their insurance and investment activities.
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, family commitments, gender, gender identity, political attitude, employees’ representative activities, religion, sensitive medical conditions, sexual orientation, or social background.
Discriminatory practices regarding recruitment, job assignment, promotion, remuneration and other benefits, or in regard to general conduct in the workplace, are not tolerated. Ignorance and inaction do not constitute a valid excuse for discrimination.
Sampo Group ensures high standards in regard to safety and mental and physical health. Sampo Group is committed to reducing 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.
Sampo Group promotes the health, well-being, engagement, and professional development of its employees. This includes developing leadership practices, supporting competence development, and providing a healthy and safe workplace. All Sampo Group companies must have well-defined organizational structures and responsibilities to support the management of health and well-being. This includes, for example, objectives, programs, training, and awareness-raising.
Sampo Group is committed to guaranteeing the effective exercise of trade union rights in the workplace. Sampo Group employees are 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. Those employees who act as representatives are neither disadvantaged nor favored in any way by Sampo Group companies.
In locations where employees have decided not to appoint representatives, Sampo Group promotes 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 it is committed to the abolition of such practices.
Sampo Group aims 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, as well as limiting the use of non-regular employment.
All employees will have a written contract of employment with mutually agreed terms and conditions, including notice periods on both sides. All employees are also 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 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 shall 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.
Sampo Group aims to raise awareness, encourage participation, and train employees on 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 its employees and external stakeholders in the Group’s Corporate Responsibility Report, which is published on an annual basis.
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 and monitoring its environmental performance:
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.