Sampo plc and its subsidiaries have their own whistleblowing channels through which employees and external stakeholders can raise concerns if they have reasonable grounds to suspect that someone employed by Sampo or any of the Group companies has breached the law or rules and regulations applicable to the financial services industry.

All Group companies have defined structures for processing whistleblowing notifications and all notifications are investigated promptly in a confidential manner, while protecting the identity of the whistleblower. The number of whistleblowing notifications reported through the subsidiaries’ whistleblowing channels are reported to the parent company, Sampo plc, as a part of regular compliance and sustainability reporting to ensure group-level monitoring of these matters.

In addition to the whistleblowing channels, the Sampo Group companies have reporting procedures for grievances and other incidents. The Group companies also encourage a culture of open discussion in which grievances can be aired and addressed proactively. Employees are encouraged to report unethical practices or possible violations of laws, regulations, or internal policies directly, for example, to their leader, HR contact person, or the Compliance unit.  

Information about the whistleblowing channels as well as the grievance and other incident reporting procedures is proactively communicated to the employees in the respective companies.

Characteristics of the whistleblowing systems
Sampo Group

  If Topdanmark Hastings Sampo plc
Available 24/7 Yes Yes Yes Yes
Available in local languages Yes* Yes Yes Yes
Available on the company's intranet Yes Yes Yes Yes
Available on the company's external website Yes Yes No No
Anonymous reporting and protection of the whistleblower Yes Yes Yes Yes
Non-retaliation policy Yes Yes Yes Yes
Hosted/managed by a third party Yes No Yes Yes
Certified/audited/verified by a third party ISO 27001 and CSA Star certified Approved by the Danish Data Protection Agency SOC 2 certified ISO 27001 certified

* Available in English in the Baltic countries

Number of whistleblowing notifications
Sampo Group

  2023 2022 2021
If 7 3 0
Topdanmark 2 0 0
Hastings 7 3 5
Mandatum*  - 0 1
Sampo plc 0 0 0
Total 16 6 6

* Mandatum was part of Sampo Group until and including 30 September 2023.

The reported incidents have been related to conflicts of interest and inappropriate behaviour, for example. All incidents have been investigated and concluded by appropriate means. The increase in reported incidents is mainly due to increased attention to the whistleblowing systems in general (e.g. due to policy updates, training, and communication).