Climate risk governance

Climate-related risks and opportunities at Sampo Group are identified, assessed, and managed primarily in the insurance subsidiaries, where the actual business operations are being carried out.

Board oversight

Sampo plc's Board of Directors has ultimate oversight over group level sustainability, including environment and climate change. The Board has assigned its Audit Committee to monitor Sampo Group's sustainability reporting and activities. The Audit Committee reports to the Board of Directors quarterly. The Board of Directors approves, for example, the Code of Conduct, Risk Management Principles, and the Group Own Risk and Solvency Assessment (Group ORSA) as well as the Group’s sustainability and risk management reports.

Management role

The Group Chief Financial Officer (CFO), who is a member of the Sampo Group Executive Committee, directs Sampo plc’s Sustainability unit. The CFO ensures that adequate reporting on environmental and climate matters is provided to the Group Chief Executive Officer (CEO). The Sustainability unit of Sampo plc, led by the Head of Sustainability, is responsible for the development and coordination of sustainability at group level. The Group CFO and Sampo plc’s Sustainability unit report to the Board of Directors and the Audit Committee on sustainability matters at least twice a year, and more frequently when deemed necessary.  

Insurance subsidiaries

Climate-related risks and opportunities are identified, assessed, and managed primarily in the insurance subsidiaries, where the actual business operations are being carried out. The Group companies all operate in different geographical areas and in different lines of business, it is consequently the responsibility of the respective company boards and managements to manage climate-related risks and opportunities accordingly. 

Company-level information

If’s Board of Directors’ decision-making powers follow from local legislation in each If Group company’s country of incorporation, as well as the articles of association and any other instructions given directly by the general meeting. The Board of Directors approves If’s policy framework, the Own Risk and Solvency Assessment (ORSA) report and the financial plan. The Board of Directors has oversight of sustainability, including climate-related matters, and approves the sustainability policy and the annual sustainability report.  

The CEOs hold the overall responsibility for the day-to-day business activities of the If companies. They have the possibility to delegate decision-making authority concerning day-to-day business activities to other persons within If but retain the ultimate responsibility for the decisions made.

If’s Sustainability Committee is an advisory and preparatory body to the CEOs on sustainability-related matters and integration of sustainability into operations. The Sustainability Committee is a risk committee which meets quarterly and reports to the ORSA Committee. Members of the Sustainability Committee include the Chief Financial Officer (chair), Head of Human Resources, Head of Brand Marketing & Communication, Chief Legal Counsel, Chief Information Officer, Chief Risk Officer, Head of Sustainability, and representatives from BA Private, BA Commercial, BA Industrial, BA Baltics, and Claims.

The Head of Sustainability coordinates If’s sustainability work and reports on strategy, targets, actions, and follow-up processes to the Sustainability Committee. The Head of Sustainability is supported by the Sustainability Office as well as the Sustainability Core teams, which consist of persons in the line organisation performing sustainability related work. The Sustainability Office provides strategic input on sustainability issues and coordinates the reporting to the Sustainability Committee and the work of the Sustainability Core teams. If’s Sustainability Policy describes If’s position and approach to sustainability. 

The Board of Directors has the overall responsibility for business risks including risks and opportunities linked to weather-related issues and climate change. The Board of Directors approves Topdanmark’s risk policies, risk profile, and risk management. The Board also approves the overall ambition level and sustainability programme, which includes climate change.  

The results of scenario analyses, stress tests, and sensitivity analyses are reported to the Board of Directors annually as a part of the solvency reporting. The Board of Directors reviews the investment policy at least once a year and ensures that Topdanmark’s response to climate risk in investments is relevant and sufficient. The Board of Directors also makes decisions on strategic sustainability actions for Topdanmark as an organisation. Data on GHG emissions and progress towards GHG emission reduction targets are reported to the Board of Directors annually.

The Group Executive Management is responsible for the goals set for the individual business areas and staff functions as well as the risk framework. The Risk Committee is responsible for climate change issues related to the core business. The CFO of Topdanmark acts as chairman of the Risk Committee. In addition to the CFO, the committee consists of representatives from asset management, statistical services, reinsurance, finance, group security, and compliance. The Risk Committee reviews reports on weather-related risks prepared by Topdanmark’s Statistical Services and prepares reports and recommendations to the Board of Directors.

In addition, Topdanmark has a Sustainability Forum, which consists of four executives from the Group Executive Management and five general managers from the staff functions. The forum is chaired by the Head of Group Management Support, Strategy and Sustainability. The Sustainability Forum has the overall responsibility for the action plan and the ambition level, including issues related to climate change, sustainability reporting and evaluation of the results of the year. The Sustainability Forum meets four times a year. 

Oversight of Hastings’ sustainability risks, including climate-related risks and opportunities, is maintained by the respective Board of Directors of each main operating subsidiary of Hastings Group, and overseen at a group-level by the Hastings Group Holdings Limited Board of Directors.

The Chief Operating Officer is accountable for the provision, oversight, and governance framework of Hastings Group’s sustainability strategy, with responsibility delegated to the Director of Business Services. Each Accountable Executive within Hastings Group’s trading operations has responsibility for identifying, monitoring, and mitigating climate-related risks against this strategy within areas of their functional responsibility. The ESG Manager has responsibility for supporting and advising on the Group’s ESG strategy and ESG risk identification process, alongside sharing industry insights and best practice. Second line assurance functions are responsible for implementing an effective control framework, and governing body reporting protocol.