Human rights and labour 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, reputational damage, and financial loss. The risk of human rights violations may arise directly from the Group’s own operations or indirectly from customers, suppliers, and/or investments, for example.

Policies and commitments

Sampo Group has policies, internal guidelines, management systems, and initiatives in place to ensure that human and labour rights are respected. 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 Sampo’s Board of Directors. Sampo Group is a participant in the UN Global Compact and respects its principles related to human and labour rights. In addition, each Group company has adopted supplementary policies and guidelines for its own purposes. Examples include responsible investment policies, supplier codes of conduct, policies and guidelines for management of customer relations, and HR policies and management systems for ensuring employee well-being. Sampo Group develops continuously its policies and processes related to human and labour rights.

Identification of human rights impacts

Sampo Group has conducted a human rights impact assessment to identify and prioritise risks on human rights across its value chain, including its own operations, corporate customers, suppliers, and investments. The assessment investigated potential impacts that Sampo Group may directly cause, contribute to, or be linked to through its business relationships. The assessment is reviewed and updated regularly.

Through its corporate customers, suppliers, and investee companies Sampo Group can have an impact on human rights that goes beyond its own operating countries. This can, for example, include a risk of forced labour, unhealthy working conditions, or discrimination and harassment, as these risks exist in industries or regions where the corporate customers, suppliers, and investee companies might operate. The impacts may affect workers in the value chain, local communities, consumers, and vulnerable groups such as migrant workers, women, and children. As these risks materialise further down the value chain, Sampo Group’s possibilities to limit the impacts is limited. In general, these potential impacts within the value chain are more severe in nature in comparison to impacts occurring in Sampo Group’s own operations.

Prevention, mitigation, and grievance measures

Sampo Group has measures in place to respect and protect human rights by preventing and mitigating identified human rights impacts in its own operations and in the value chain. In the case not all negative impacts can be mitigated and/or prevented, the Group prioritises impacts to be mitigated based on scale, irremediability, and scope, for example. Responsibility for human rights at Sampo Group has been divided among different functions, including, for example, Compliance, Risk Management, HR, Sustainability, Investments, Business Areas, and Claims.

Own operations

In Sampo Group’s own operations, issues such as privacy, discrimination, and healthy and safe working conditions have been identified as key human rights risk areas. These risks are mitigated, among others, through human rights and HR policies which all employees have a responsibility to comply with, as well as mandatory and voluntary training on the topic and awareness raising events.

Sampo Group 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. The terms of bargaining agreements apply to most employees (excluding top management) even if they are not formally covered by the agreements.

Sampo Group engages regularly and directly with employees and their representatives to gain insight into employees’ perspectives, gather feedback, and identify development needs. Forums for dialogue include, for example, leader-employee discussions, work environment councils, meetings with union representatives, exit interviews, and employee engagement surveys. In addition, employees can raise concerns through internal reporting and whistleblowing channels.

Customers

Corporate customers

Sampo Group’s downstream value chain includes the workforce and supply chains of its corporate customers, where workers may be exposed to human rights violations and risks outside the Group’s own operating countries. These human rights risks related to forced labour, child labour, unsafe working conditions, or discrimination and harassment may occur in the industries or regions where corporate customers operate.

To manage the above-mentioned risks Sampo Group has integrated sustainability considerations into its underwriting standards and customer due diligence processes for corporate customers. The practices are based on the UN Global Compact principles and cover, for example, human and labour rights. Sampo Group conducts norm-based screening of corporate customers against international norms and standards using external service provider. In addition to norm-based screening, Sampo Group applies sector-based screening.

Sampo Group’s whistleblowing channels are externally available for corporate customers to report possible incidents. In addition, the Group has means to have continuous dialogue with customers, for example, during virtual and face-to-face meetings and events.

All customers

In terms of all customers, data breaches and misuse of customer information may result in human rights violations. 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.

Sampo Group has controls in place to ensure that information provided to customers is accessible, relevant, and timely before a customer commits to any purchase, and that the Group satisfies all regulatory and conduct obligations. These controls are regularly assessed. In addition, Sampo Group reviews its products and services continuously to ensure that they remain appropriate.

To ensure compliance with laws, regulations, and internal policies, Sampo Group has training programmes that develop personal conduct and increase the competence of sales teams and other customer representatives. In addition, the Group offers customer feedback channels (e.g. customer satisfaction surveys, contact centres, consumer ombudsman, chat) to make it easy for customers to provide feedback on the products and services, and to complain if they are dissatisfied.

Suppliers

Through its value chain, Sampo Group can have an impact on supply chain workers. The majority of the Group’s suppliers in claims handling are based in the Nordics, where the general risk for human rights violations is considered lower than in many other regions globally. However, value chains can be long and complex, and certain sectors such as construction, mining, transportation, and electronics are particularly associated with human and labour rights risks. Workers may be exposed to unhealthy or unsafe working conditions, including, for example, long hours and exposure to hazardous substances. Other risks include forced labour, child labour, discrimination, and violations of privacy. These risks can be considered systemic.

Sampo Group expects its suppliers and other business partners to respect and comply with human rights and labour rights within their business and supply chains. This is communicated, for example, in the Sampo Group Code of Conduct, which suppliers and other business partners are encouraged to adopt. In addition to the Code of Conduct, the Group has supplier codes of conduct that set the minimum requirements that suppliers are expected to meet. The policies are supported by other supplier processes and actions, including additional contractual requirements for specific suppliers, risk assessments, audits, supplier self-assessment questionnaires, and meetings with suppliers, for example. Sampo Group employees working with relevant functions (e.g. purchasing departments, premises, group services, legal departments) receive training, for example, on supplier codes of conduct depending on need.

Most of Sampo Group’s whistleblowing channels are externally available to suppliers and their workers, for reporting suspected violations of legislation or unethical conduct. In addition, the majority of Sampo Group’s supplier codes of conduct or related contracts require suppliers to provide channels for reporting grievances. Suppliers are also required to report any breaches of the principles outlined in the codes of conduct to Sampo Group.

Investments

Through its investments, Sampo Group may be exposed to human rights and labour rights risks relating, for example, to forced labour, unsafe working conditions, and privacy. The Group strives to minimise these risks through its responsible investment policies, and conducts norm-based screening of direct investments against international norms and standards using external service providers. In addition, Sampo Group applies sector-based screening to its direct investments and excludes certain sectors from direct investments unless pre-defined criteria are fulfilled. The Group also has processes in place in case of violations against these norms and standards. Most of Sampo Group’s whistleblowing channels are externally available for investee companies and their workers to report incidents.

Monitoring

Sampo Group uses different metrics to monitor human rights issues. The externally disclosed metrics are available in Sampo Group’s quarterly and annual sustainability reporting and/or website.

When evaluating the effectiveness of mitigation efforts, Sampo Group takes relevant stakeholder feedback into account on a case-by-case basis. Examples of stakeholder groups include internal stakeholders (e.g. employees) and external stakeholders (e.g. consultants, regulators, investors, NGOs, rating agencies, corporate customers, suppliers). Feedback is received as part of regular stakeholder engagement and dialogue.

Sampo Group strives for a constructive, trustful, and open dialogue with all stakeholders and their representatives with the purpose of developing the company and safeguarding the correct treatment of all stakeholders. The Group has several forums for dialogue, which may vary by stakeholder group, and reporting channels available for reporting of identified or suspected non-compliance with internal or external rules or inappropriate behaviour.

Reporting and communication

Sampo Group’s key forms of reporting and communication related to human rights are Sampo Group’s annually published sustainability reporting and website. In addition, each Group company produces reporting according to their own legislative requirements. Communication of human rights-related policy commitments to different stakeholders is done, for example, through training, websites/intranets, contractual discussions, questionnaires, audits, and site visits.

Providing remedy

Sampo Group ensures that all outcomes and remedies accord with internationally recognised human rights and local legislation.

Own operations

Where non-compliance is identified, Sampo Group has established protocols for issues to be escalated and remedied. If potential negative impact lies with Sampo Group itself, the company takes corrective action and offers the employees involved a suitable remedy depending on the nature of the breach.

Customers

Corporate customers

In case of a verified violation or unsatisfactory performance, Sampo Group starts a dialogue with the corporate customer. The Group can, for example, insure the customer but set the company under observation; grant conditional approval for insurance cover, but require the company to take action; or decide not to offer insurance for the customer or renew an already existing insurance contract. If the customer does not take any corrective actions, Sampo Group will consider additional steps, including termination of the customer relationship. The Group reviews and develops its sustainable underwriting practices continuously to ensure effective monitoring of human rights impacts and risks among its potential and existing corporate customers.

All customers

Sampo Group aims to clearly inform private customers of their complaint options, as well as to ensure a fair and transparent complaint process. In case of a complaint, the priority is to discuss with the customer to find a solution that is satisfactory to both parties. If a consensus cannot be reached, the customer is entitled to appeal to external complaints boards (ECBs) or similar, according to local practices in each operating country. In addition, as required by law, certain Sampo Group companies have internal customer representative functions that the customer can contact to submit a complaint. Regardless of the outcome of appeal cases, Sampo Group always analyses how it can improve its sales and marketing practices and data privacy processes.

Suppliers

If Sampo Group detects non-compliance with its supplier requirements, the first step to remediate non-compliance is to verify what has happened and investigate the reasons leading to it. Depending on the findings, corrective actions can be, for example, improvement of processes, correction of mistakes, refunds, or audits. If the error or contract breach is major, it may result in the termination of the contract. Set requirements, in combination with close cooperation with suppliers and partners, enable Sampo Group to develop its business while also contributing to more sustainable development.

Investments

If abuses or breaches related to human rights are observed in an investee company, Sampo Group investigates the incident, and takes measures on a case-by-case basis. Depending on the severity, nature, and extent of the breach, portfolio management measures may consist of direct dialogue with the investee company, a collaborative engagement action or, as a measure of last resort, divestment if the investee company does not respond to the engagement efforts and does not take measures to prevent the abuse or breach within a reasonable time frame. Sampo Group reviews and develops its responsible investment practices continuously to ensure effective monitoring of human rights impacts and risks among its potential and existing investee companies.