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Climate Risk Governance

Climate-related risks and opportunities are identified, assessed, and managed primarily in the insurance subsidiaries, where the actual business operations are being carried out. As If, Topdanmark, Hastings and Mandatum 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.

Sampo plc's Board of Directors has the ultimate oversight of sustainability-related matters on group-level, 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.


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, Head of Risk Control and Reporting, 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 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.

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, and actuarial services. 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 defining and implementing 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 monitoring and mitigating risks against this strategy within areas of their functional responsibility. Second line assurance functions are responsible for implementing an effective control framework, and governing body reporting protocol.


At Mandatum, the parent company Mandatum Holding Ltd.’s Board of Directors is responsible for the adequacy of risk management and internal control within Mandatum Group. The Board of Directors annually approves the Risk Management Policy, Balance Sheet Policy, Compliance Policy, and other general policies according to which risk management and internal supervision are organised in the holding company and in the subsidiaries. However, the Board of Directors of the subsidiaries are responsible for setting their own risk management policies, which should comply with Mandatum Group’s policies and principles. Moreover, the risk appetite of each company in Mandatum Group is approved by the company’s Board of Directors. Risk management and risk appetite concern climate-related risks among other risks. 

The Mandatum Group CEO has overall responsibility for the implementation of risk management, which includes assessing and managing all risks, in accordance with the instructions set by the Board of Directors. It is also the Mandatum Group CEO’s responsibility to ensure that the company's risks are regularly reported to the Board. At Mandatum Group, a separate risk committee structure supports the Group CEO in overseeing the risk management process within the Group.   

Updated 7 Feb 2023