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Anti-Corruption and Bribery

At Sampo Group, corruption is defined as the abuse of entrusted power for private and/or corporate gain. It can take many forms, such as bribery, excessive business entertainment, facilitation payments (i.e. financial payments that may constitute a bribe and are made with the intention of expediting an administrative process), kickbacks, and extortion.

In general, the Nordic countries have the lowest levels of corruption in the world. The Nordic countries are also the main area of business for Sampo Group companies. Therefore, it can be stated that corruption and bribery, as such, are not the most critical risk factors for the Group companies’ own operations. Regardless, Sampo Group can face reputational risks, legal risks, business risks, and potential costs, if it fails to effectively combat corruption in all its forms.

Through investments, Sampo Group companies have a higher exposure to corruption and bribery. These risks are mitigated by screening investments against international norms and standards laid down in international conventions, such as the UN Global Compact. More on investments can be found in the section Responsible Investment Management and Operations.

Sampo Group’s Code of Conduct sets the overall guiding principles on working against corruption and bribery within Sampo Group. Sampo Group does not accept any kind of conduct that could create the appearance of improper influence, and it 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. Further, Sampo Group is a signatory of the UN Global Compact and therefore the entire Group actively works against corruption.

The managing director of each company in Sampo Group has ultimate responsibility to ensure that sufficient resources are allocated to the prevention of corruption and bribery. Each Group company may organize duties and take other measures it deems necessary and appropriate, to be able to comply with the applicable local rules and various sanctions regimes, which may be imposed by the United Nations and/or the European Union.

Reporting on anti-corruption and bribery activities, as well as potential incidents, is organized in each Group company in a manner that ensures that the management and the boards of directors of relevant companies receive all material information without undue delay and that Sampo plc’s Risk Management organization is informed of all relevant incidents in a timely manner. Sampo plc’s Risk Management organization is responsible for organizing the reporting of relevant incidents to Sampo plc’s Audit Committee and Board of Directors.

Reported Corruption and Bribery Incidents, Sampo Group 2019 2018
Number of incidents reported through internal reporting channels 0 0


Further information can be found in the Corporate Responsibility Report (page 27).

Updated 7 May 2020