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Anti-Corruption and Bribery

Sampo Group has zero tolerance towards corruption in all its forms, and it expects its employees, customers, suppliers, and other business partners to share the same view.

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 Global Compact, which supports work against corruption.

Corruption and bribery, as such, are not the most critical risk factors for the Group companies’ own operations. However, the Group companies are exposed to corruption and bribery through their investments and supply chains. These risks are mitigated, for example, by screening investments against international norms and standards laid down in international conventions and encouraging sustainability in supply chains.

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 organizes 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 potential incidents, is organized 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 organization is informed of all relevant incidents. Sampo plc’s Risk Management organization is responsible for organizing the reporting of relevant incidents to Sampo plc’s Audit Committee and Board of Directors.

In 2020, no incidents related to corruption or bribery were reported at Sampo Group.

Reported Corruption and Bribery Incidents, Sampo Group 2020 2019 2018
If 0 0 0
Topdanmark 0 0 0
Mandatum Life 0 0 0
Sampo plc 0 0 0
Sampo Group* 0 0 0

*excluding Hastings


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 various voluntary and mandatory training programs connected to the policy. Upon employment, all employees sign a statement that they will follow If’s policies and instructions, including the Ethics Policy.

The work against corruption and bribery is part of If’s efforts 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 anonymously 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 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.

In accordance with the principles of the Global Compact, Topdanmark works against corruption in all its forms. To support its employees, Topdanmark has a policy in place that states when employees may give and receive gifts, and when they are allowed to hold or participate in events. The purpose of the policy is, among other things, to prevent and avoid business decisions being influenced by personal or non-business-related considerations and interests.


Hastings Group’s (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, such as the UK Bribery Act 2010 and Part 24 of the Gibraltar Crimes Act 2011. The policy is reviewed annually and frames Hasting’s approach to matters such as inducements, unethical practices, abuse of power, and other improper activity.

Hastings strives to maintain the highest standards of governance, personal and corporate ethics, and compliance with laws and regulations. It also seeks to ensure that its employees understand what is required of them in terms of appropriate and responsible conduct and the ethical standards they are expected to uphold.

Employees are informed via the intranet when the policy has been revised, and at least twice a year the Chief Risk Officer issues reminders to all employees about their obligations under the policy. Upon employment, all employees sign an undertaking of compliance with all Hastings Group policies. Regular mandatory training is also undertaking by all employees via e-learning modules.

Any suspicions of corruption or bribery can be reported anonymously via Hastings’ externally hosted whistleblowing platform 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 Life

Mandatum Life's top management has ultimate oversight of anti-corruption and bribery matters at Mandatum Life. The Sampo Group Code of Conduct and Mandatum Life’s internal Code of Conduct, Mandatum Life Way, set the overall requirements for anti-corruption and bribery at Mandatum Life. In addition, the work against corruption and bribery is an integrated part of Mandatum Life’s anti-money laundering and counter-terrorist financing (AML and CTF) framework. Mandatum Life has implemented processes for enhanced monitoring of politically exposed persons and the national and international sanctions lists. The Legal Affairs and Compliance function supports the management and business units in complying with the company policies.

Anti-corruption and bribery topics are part of all new employees’ and existing employees’ mandatory training programs. Furthermore, all employees must, on a regular basis, complete compliance training programs, in which employees are reminded of the Group’s Code of Conduct and Mandatum Life’s internal procedures.

Any suspicions of corruption or bribery can be reported anonymously through Mandatum Life’s whistleblowing system.

More information in Sampo Group’s Corporate Responsibility report, p. 27.

Updated 29 Jul 2021