Internal control

Internal control means all activities, which ensure that Sampo Group’s businesses are carried out towards desired targets in accordance with desired policies and practices and in compliance with applicable legal and regulatory requirements. Accordingly, the tasks of internal control are performed by different actors starting from the top of the organization.

The organization of internal control and safeguarding its functioning and viability play a key role in the activities of the Board of Directors of Sampo plc. In order to ensure the proper running of operations, Sampo’s Board has approved Group-level policies and guidelines concern­ing corporate governance, financial target setting, risk management, remuneration, compliance, reporting and internal audit in conformity with and supplementing the existing legal and regulatory framework. With the policies and guidelines Sampo’s Board directs Group’s activities towards desired practices and, with appropriate control mechanisms provided by the policies, ensures that poten­tial deviations are discovered without undue delay.

Sampo Group's financial reporting process aims to ensure that Sampo’s Board of Directors and executive management have timely and reliable information supporting their decision-making, and that external stakeholders can also rely on the financial information provided to them.


Sampo Group's financial reporting process

Sampo Group’s financial reporting is organised under Group Control and Planning and Group Accounting units and it operates under the Group Chief Financial Officer. Group Control and Planning prepares and follows Group-level and parent company’s financial targets and forecasts, takes care of monthly reporting of profit development as well as solvency calculations. It also produces different types of market analyses and reviews. Group control is also responsible for the Group’s annual and quarterly Solvency II reporting to the supervisory authorities.

Sampo plc is committed to developing sustainability activities and targets of the Group’s operations, as well as related performance measurement and reporting. This is in the interests of and expected by the Group’s various internal and external stakeholders.

Sampo plc’s Board of Directors is responsible for and has the ultimate oversight of group-level sustainability, covering the entire range of environmental (including climate change), social, and governance issues. The Board has assigned its Audit Committee to monitor Sampo Group’s sustainability reporting and activities.

The Group Chief Financial Officer (CFO), who is a member of the Sampo Group Executive Committee, directs Sampo plc’s Sustainability unit. The CFO also ensures that adequate reporting on sustainability matters is provided to the Group CEO.

The Sustainability unit of Sampo plc, led by the Head of Sustainability, is responsible for the development and coordination of sustainability at group level. The unit prepares the group level sustainability reporting and the sustainability programme, which sets the direction for the Group’s sustainability work. In addition, the unit sets schedules and requests, provides group-level guidance to the subsidiaries, and organises regular sustainability meetings.

At each subsidiary, various business areas, operational departments, and units are actively involved in the Group’s sustainability endeavours and reporting. Group-level sustainability reporting is largely based on information provided by the subsidiary companies according to formats and schedules defined by Sampo plc’s Sustainability unit. Each subsidiary is responsible for its respective reporting to the parent company to ensure correctness of information. In addition to group-level sustainability governance, each Group company has its own internal governance structures.

Non-financial disclosures according to the Non-Financial Reporting Directive (NFRD) are published annually in Sampo Group’s Sustainability Reports.

The Board of Directors of Sampo plc is responsible for ensuring that the Group’s risks are properly managed and controlled. The Board establishes both the risk manage­ment principles and closely connected remuneration principles and provides guidance on the risk management governance structure and internal control in the business areas. Working within the framework of these principles and guidelines, the subsidiaries tailor their risk manage­ment practices to take account of the special features of their respective business activities. The Board makes decisions on strategy, return targets and the general levels of risk and capitalisation of the subsidiaries.

More detailed information on Sampo’s risk management is available in Sampo’s Risk Management Report.


Risk management governance framework in Sampo Group

In Sampo Group, compliance is an activity supporting business activities while being independently admin­istered, and it aims at securing the compatibility with applicable norms of all Group activities.

In Sampo Group Compliance Principles the starting point is that compliance with norms is an established part of Sampo’s corporate culture, and the principles ensure that compliance activities are properly organized in Group companies, and that the business organization is capable to respond to the changing requirements of business envi­ronment. The guidance contains the perceived common denominators of successful compliance activity – a set of general principles that describe essential features of effective compliance activities within the context of the business environment Sampo Group companies are oper­ating. The principles do not, however, limit the flexibility of each subsidiary company when addressing its own specific needs in relation to compliance.

Further information is available in Sampo Group Compliance Principles.


Sampo Group's compliance organisation and reporting structure


Insider administration

Sampo plc's Board of Directors has approved Sampo Group's Guidelines for Insiders. These comply with the Guidelines for Insiders issued by Nasdaq Helsinki ( Sampo Group's Guidelines for Insiders are stricter than the above-mentioned norms on matters that concern the Group Executive Committee, all Sampo plc’s employees and other Group’s employees working with interim statements and other financial announcements and persons having access to such documents before publication thereof, as these persons must request a separate written permission in advance for each share related securities transaction they make with the securities of Sampo plc or any of Sampo’s publicly listed subsidiary or associated company. Further information is available in Sampo Group's Guidelines for Insiders.

As Nasdaq Copenhagen listed entity, Sampo's subsidiary Topdanmark A/S has its own insider procedure applicable to Topdanmark's financial instruments, as is required by Danish regulations.

Notifications under Article 19 of the Market Abuse Regulation can be found in the Releases section of the Media section.