Anti-corruption and bribery

Sampo Group can face reputational risks, legal risks, business risks, and potential costs if it fails to combat financial crime, corruption, and bribery in all their forms. The Group can be exposed to corruption and bribery especially through its customer support functions (e.g. sales, claims handling), investments, as well as suppliers and business partners (e.g. procurement, claims handling, IT). Customer support functions are at risk of corruption, for example due to financial transactions and the handling of personal data, whereas investment operations can be vulnerable, for example, due to exposure to industries and markets with varying levels of corruption risk. Suppliers and business partners, in turn, may face risks associated with the dependency on third-party partnerships and intricate procurement operations.

The risks of corruption and bribery within Sampo Group are mitigated through a range of internal control systems, including commitments to international initiatives and the Group’s own principles and policies. The Group is, among other things, a participant of the UN Global Compact, which promotes anti-corruption efforts, and the Sampo Group Code of Conduct sets the overall guiding principles for preventing corruption and bribery across the organisation. The Group also maintains supplementary policies and guidelines for more specific purposes. These annually updated guidance documents outline, for example, rules regarding gifts, participation in events, and hospitality. They also clarify expectations for employees as well as roles and responsibilities. Furthermore, allegations or incidents of corruption and bribery can be identified through reporting and control mechanisms.  hese include whistleblowing channels, customer and direct investment screening, and supplier selection and risk assessment processes.

Sampo Group provides training (e.g. e-learning and during contract discussions) on business conduct matters to mitigate risks and to ensure that employees, suppliers, and other business partners have sufficient knowledge of these topics. For example, all Sampo Group employees are offered training (e.g. e-learning) on anti-corruption and anti-bribery at least biennially. Related and relevant policies are available to all Group employees on intranet pages and to other stakeholders on the Group’s websites.

The CEO of each company in Sampo Group has the ultimate responsibility to ensure that sufficient resources are allocated to the prevention of corruption and bribery. Each Group company organises duties and takes other necessary and appropriate measures to comply with the applicable local rules and various sanctions regimes, which may be imposed by the UN and/or the European Union (EU).

Reporting on anti-corruption and anti-bribery activities, as well as on potential incidents, is organised in a manner that ensures that the applicable management and board of directors within Sampo Group receive all material information without undue delay. All valid whistleblowing notifications received through the whistleblowing channels are reported to the parent company, Sampo plc, as part of regular compliance reporting. Sampo’s Risk Management organisation is responsible for overseeing the reporting of relevant incidents to Sampo’s Audit Committee and the Board of Directors.