Human rights and labor practices
For Sampo Group, managing human rights is not only about doing the right thing and obeying the law, but also about protecting the bottom line. Failure to identify and respond to human rights issues can lead to, for example, legal action, investor divestment, reputation damage, and financial loss.
The group-level guidance document regarding human rights and labour practices is the Sampo Group Code of Conduct, which is reviewed annually and approved by the Board of Directors of Sampo plc. Sampo Group is also a participant of the UN Global Compact, which supports work on human rights. In addition, each Group company has adopted supplementary policies and guidelines for its own purposes. Sampo Group is committed to continuous development of their policies and processes related to human rights, including conducting human rights due diligence, applying precautionary principle, and taking remedy.
The risk of human rights violations may arise directly from Sampo Group’s own operations or indirectly from external factors, such as customers, investments, and supply chains. In own operations, human rights violations may arise, for example, in discrimination and from lack of equal opportunities. In terms of customers, data breaches and misuse of customer information may result in human rights violations, particularly if sensitive personal information is disclosed. Sampo Group has stringent policies and processes to ensure that all collected data is protected through data privacy and information security measures and adequate employee training. Regarding investments and corporate customers, Sampo Group screens investments against international norms and standards, including those related to human rights.
Sampo Group is also committed to encouraging suppliers and other business partners to respect and comply with human rights. This is communicated, for example, in the Sampo Group Code of Conduct, which suppliers and other business partners are encouraged to adopt. Furthermore, the Group companies have more specific policies on these matters for their own suppliers (e.g. supplier code of conduct).
Communication of human rights-related policy commitments to different stakeholders is done, for example, through training, the intranet, contractual discussions, questionnaires, audits, and site visits.
Group goals and ambitions
Sampo Group aims to respect and protect human rights throughout its operations.
Human rights and labor practices in Group companies
Responsibility for human rights and labour practices at If has been divided among different functions, including Compliance, Risk Management, and HR. In addition, If has an Ethics Committee, which is an advisory and preparatory body to the CEO. The committee meets at least four times a year. The chair of the committee is the Head of HR, and members represent corporate functions, business areas, claims, and the unions, for example. The committee discusses, assesses, and coordinates ethics issues within If and provides recommendations on related matters, including human rights and labour practices.
All If’s policies relating to human rights and labour practices are approved by If’s Board of Directors.
If’s Ethics Policy, which is based on the UN Global Compact, describes ethical standards, goals, principles, and responsibilities, including the company’s commitment to respecting human rights. The policy applies to all If employees and states that no kind of discrimination, harassment, or bullying is tolerated. In addition, If has a Diversity, Equity, and Inclusion Instruction. If strives for a constructive and trustful dialogue with employees and their elected representatives, such as unions, with the purpose of developing If and safeguarding the correct treatment of all employees. If respects employees’ freedom of association, and the company’s business processes are designed to ensure equal treatment regardless of unionisation, based on employees’ constitutional rights. All employment conditions, whether they are covered by a collective agreement or not, are largely regulated by local labour legislation and apply to all employees. Upon changes in the organisation, union members are informed and/or consulted accordingly.
If has integrated sustainability directly into its underwriting standards and into the existing customer due diligence process for corporate clients. The framework is based on the UN Global Compact principles and covers, for example, human and labour rights. To assess whether corporate clients are respecting the Global Compact, If utilises research and grading by an external service provider. If the grading does not meet If’s internally set threshold, a referral is made to If’s internal ESG assessment team for further action.
Suppliers and other business partners
If expects its suppliers and other business partners to adopt business practices compliant with human rights, labour rights, and other employment practices within their business and supply chains. If has a Supplier Code of Conduct, which defines the minimum requirements If expects suppliers to respect when conducting business with the company. Through the Supplier Code of Conduct, If ensures it does not engage suppliers or other counterparties that have substantially neglected their obligations to their business partners, employees, or the general public. Therefore, If also respects the rights of contingent workers in its operations.
If has a responsible investment policy, which guides responsible investment at the company. Information on how human rights are considered in the context of If’s investments is available in the section Investment management and operations.
If organises courses, seminars, and discussions on ethical matters and dilemmas at local offices. All If employees are trained to pay attention to human rights topics as part of the One Responsible If learning programme, which is a mandatory introduction to If’s responsible corporate culture and business practices. The programme includes a module on ethics that reflects the content of If’s Ethics Policy. The programme is part of new employees’ onboarding, and it is an annual activity for all existing employees.
If has several incident and accident reporting tools available, as well as a whistleblowing channel for anonymous reporting for any identified or suspected non-compliance with internal or external rules or inappropriate behaviour. The tools are developed in line with If’s policies and assessed through annual surveys to ensure the reporting tools are fit for purpose. The Risk Management and Compliance functions are responsible for reporting on incidents to the boards of directors and CEOs within If.
Topdanmark has policies, internal guidelines, management systems, and initiatives in place to ensure that human rights are respected. Examples include responsible investment practices and policies for investment management; a supplier programme for sustainable supply chain management; ESG screening of customers for sustainable underwriting; processes, policies, and guidelines for management of customer relations; and HR policies and management systems for ensuring employee well-being.
In addition, Topdanmark has a due diligence process in which the company can identify potential negative impacts on human rights, either by the company directly or by suppliers or partners. If potential negative impact lies with the company, Topdanmark offers the people involved a suitable remedy depending on the nature of the breach. If the negative impact is identified with the partners or suppliers, Topdanmark starts a dialogue with the partner in question. If this dialogue does not lead to a change and a remedy for the persons affected, Topdanmark can end the cooperation. The due diligence process is part of the general processes for monitoring risks under the auspices of Topdanmark’s Risk Committee. The process also includes monitoring potential and actual ESG risks, including the risk of a negative impact on human rights.
Topdanmark’s employees have a responsibility to comply with the company’s human rights policy. In addition, it is mandatory for all employees to take and pass the Code of Conduct e-learning, which includes a module on human rights.
At Topdanmark, human rights violations are reported either directly to HR or via the whistleblowing system.
Hastings understands and delivers its responsibilities to protect and respect internationally accepted human rights, specifically those defined within the UK’s Human Rights Act of 1998. Hastings also has mechanisms to both identify and remedy any conduct or situation that falls below the standards it has set.
Hastings is committed to acting responsibly in business relationships and ensuring that slavery and human trafficking does not occur anywhere in its business operations. Hastings also requires its suppliers and business partners to take the necessary steps to avoid slavery and human trafficking. The company has a statement in place, available and accessible to all parties who do business with Hastings, which is approved by the Board, the Company Secretary and the Company Executive Committee.
Hastings applies these same principles and standards of conduct to the way it treats its customers, third-party partners, and suppliers, seeking to protect their human and statutory rights as it does for its employees. Hastings also conducts appropriate due diligence to ensure that suppliers adhere to and adopt the appropriate standards of behaviour and compliance.
Hastings complies with applicable human rights and employment legislation and strives to ensure that all its employment policies, processes, and practices support its commitment to value and uphold the human rights of its employees. By adopting this integrated approach, Hastings supports the articles of the UK Human Rights Act that it believes have the greatest impact on the employment relationship, being:
- Article 6: right to a fair and public hearing
- Article 7: right to respect for private and family life
- Article 9: freedom of thought, conscience, and religion
- Article 10: freedom of expression
- Article 11: freedom of assembly and association
- Article 14: prohibition of discrimination
Hastings has an employee consultation group, the Hastings Colleague Forum (HCF). The company recognises the HCF for the purposes of statutory collective consultation and also recognises the trade union membership of its employees in the context of individual formal processes (e.g. conduct, grievance, performance, sickness absence management). The HCF is made up of democratically elected members acting as representatives, who engage with their business areas to represent the general views of Hastings employees, discussing collective issues and feedback in addition to the consultation process.
Hastings ensures that its employment policies, processes, and practices are compliant with UK law and that its employees and their leaders recognise their individual responsibility to understand and adhere to agreed practices and standards of conduct and governance. The company provides appropriate and ongoing training to all employees to support this. In addition, all of Hastings’ leaders have access to three online learning modules that provide them with the information and guidance they need to effectively address and resolve colleague complaints.
Hastings provides mechanisms for its employees to report any concerns that they may have in relation to their employment. This includes a grievance policy and procedure and a whistleblowing service. The whistleblowing service is accessible through an online portal and via a telephone number. Hastings’ grievance process provides a route by which timely and informal resolution is attempted before the formal mechanism is invoked. Where non-compliance is identified, Hastings has established protocols for issues to be escalated and remedied. Hastings tracks formal grievances and whistleblowing on a monthly and annual basis to monitor volumes and causation trends.
Hastings’ suppliers are obligated under contract to notify the company if they become aware of any human rights (and other) violations within their business or supply chain. As part of Hastings’ due diligence process, suppliers are required to provide a copy of their whistleblowing policy.
Mandatum respects internationally recognised human rights and is committed to ensuring that human rights are not infringed in its operations. Human rights are considered throughout Mandatum’s operations and value chain, ranging from investment decisions to employment issues.
Mandatum’s investment management operations are committed to responsible investing, and ESG issues form a key part of the investment risk management process. The company’s portfolio holdings are regularly monitored for human rights violations as a part of norms-based screening. If violations are detected, Mandatum seeks to engage with the involved parties to rectify the issues.
Regarding employee relations, Mandatum has HR policies and procedures in place safeguarding human rights-related matters. All the policy commitments are approved at the most senior level in the company. Mandatum emphasises equality in all its actions and policies and monitors the gender distribution in management positions. Equality issues are part of the Mandatum Way guide given to all new employees as part of onboarding.
Mandatum also expects its suppliers to conduct their business lawfully and ethically. To ensure this, Mandatum conducts a check against the Sampo Group Code of Conduct as part of their supplier assessment prior to agreeing on cooperation and during the cooperation. The key areas included in the check are commitment to human rights and ensuring equal treatment, environmental objectives, data protection and information security, and governance-related issues, such as bribery and corruption.
Sampo plc is responsible for the annual review and update of the Sampo Group Code of Conduct, which includes group level guidelines on human rights. All Sampo plc’s employees are required to familiarise themselves with the Sampo Group Code of Conduct upon employment and, after that, to take part in an internal training every other year.