Anti-corruption and bribery
The Sampo Group companies can be exposed to corruption and bribery through their investments, customers, and supply chains. Sampo Group can face reputational risks, legal risks, business risks, and potential costs if it fails to effectively combat corruption in all its forms. The risks are mitigated, for example, by screening investments and customers against international norms and standards and by encouraging sustainability in supply chains.
The Sampo Group Code of Conduct sets the overall guiding principles on working against corruption and bribery within Sampo Group. Sampo Group is also a signatory of the UN Global Compact, which supports work against corruption.
The managing director 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 bribery activities, as well as on potential incidents, is organised 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 organisation is informed of all relevant incidents. Sampo plc’s Risk Management organisation is responsible for organising the reporting of relevant incidents to Sampo plc’s Audit Committee and Board of Directors.
Group goals and ambitions
Sampo Group has zero tolerance towards corruption and bribery, and it expects its employees, customers, suppliers, and other business partners to share the same view.
Reported corruption and bribery incidents
Work against corruption and bribery in Group companies
At If, the work against corruption and bribery derives from the company’s Ethics Policy, and the policy itself is based on the Swedish Anti-Corruption Institute’s code against bribery. The Ethics Policy is updated annually, and it contains rules on gifts, participation in events, and hospitality. In addition, the supplementary policy material includes different practical educational dilemmas. Employees are informed on the intranet when the policy has been revised, and there are voluntary and mandatory learning programmes connected to the policy. Upon employment, all employees sign a statement that they will follow If’s policies and instructions, including the Ethics Policy.
Furthermore, work against corruption and bribery is part of If’s work to prevent money laundering and terrorist financing. If has controls in place by which it checks whether customers are politically exposed persons or on the EU or UN sanctions lists.
Any suspicions of corruption or bribery can be reported through If’s whistleblowing system. Reports can also be made directly to If’s Investigation unit. Any incidents or events connected to corruption or bribery are reported to If’s Ethics Committee, If’s Own Risk and Solvency Assessment (ORSA) Committee, and further to the Board of Directors.
Topdanmark has a formal policy on anti-corruption. The policy describes the company’s objectives and targets related to anti-corruption, expectations regarding employees, and roles and responsibilities. Topdanmark’s decentralised compliance functions monitor compliance with the policy in their respective departments. The compliance functions also work as help desks for employees. Topdanmark Group Compliance carries out controls of compliance with the policy in connection with general compliance inspections. If Group Compliance identifies any breaches of the policy, the normal procedure for non-compliance with policies will be followed. This includes the preparation of a report on the breach, a decision on measures to rectify the breach, and a follow-up on whether the recommendation is implemented within the given timeline. In addition, Topdanmark’s approach to anti-corruption is embedded in the company’s internal Code of Conduct.
Topdanmark has assessed that the biggest risk of corruption and bribery for the company is related to gifts and events relating to customers, suppliers, and other business partners. In general, the risk is considered low.
Hastings’ approach to the prevention of corruption and bribery is embodied in its Anti-Bribery and Corruption Policy, which reflects Hastings’ obligations under various laws and statutes, especially the UK Bribery Act 2010 and Part 24 of the Gibraltar Crimes Act 2011. The policy is reviewed annually.
Upon starting employment at Hastings, all employees sign an undertaking of compliance with all Hastings Group policies. All employees are informed of any policy revisions through the company’s’ intranet, with annual mandatory training on this subject delivered and monitored through the company’s e-learning platform.
Any suspicions of corruption or bribery can be reported via Hastings’ whistleblowing channel or via less formal internal channels. Any incidents or events connected to corruption or bribery, or breaches of the policy, are reported to appropriate management and governing body forums.
Mandatum’s anti-corruption and bribery framework is based on the Sampo Group Code of Conduct and Mandatum’s Conflict of Interest policies, which are supplemented by the Mandatum Way guide and Gifts and Hospitality guidelines. Together, the policies and guidelines set the principles against corruption and bribery and aim to promote ethical and responsible business operations and to safeguard Mandatum’s reputation by preventing inappropriate influence and conflicts of interest.
In addition, the work against corruption and bribery is an integral part of Mandatum’s anti-money laundering (AML) and counter-terrorist financing (CTF) framework. Mandatum has implemented processes for enhanced monitoring of politically exposed persons and the national and international sanctions lists. The AML officers and Mandatum’s Group Legal unit support the management and business units in complying with the company policies.
Anti-corruption and bribery topics are part of all new and existing employees’ mandatory training programmes. Furthermore, all employees must, on a regular basis, complete compliance e-learning programmes, in which employees are reminded of the Sampo Group Code of Conduct and Mandatum’s internal procedures.
Any suspicions of corruption or bribery can be reported through Mandatum’s whistleblowing system or otherwise directly to the Compliance function.
At Sampo plc, the CEO, together with Risk Management, ensures that sufficient resources are allocated to the prevention of corruption and bribery. Sampo plc is also in charge of the annual review and update of the Sampo Group Code of Conduct, which includes group-level guidelines on anti-corruption and bribery. All Sampo plc’s employees are required to familiarise themselves with the Sampo Group Code of Conduct upon employment, and after that every other year.