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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.
Corruption and bribery, as such, are not the most critical risk factors for the Sampo Group companies’ own operations. However, the Group companies can be exposed to corruption and bribery through their investments, customers, and supply chains. Sampo Group can face reputational risks, legal risks, business risks, and potential costs if it fails to effectively combat corruption in all its forms. The risks are mitigated, for example, by screening investments and customers against international norms and standards and by encouraging sustainability in supply chains.
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 UN Global Compact, which supports work against corruption.
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 organises 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 on potential incidents, is organised 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 organisation is informed of all relevant incidents. Sampo plc’s Risk Management organisation is responsible for organising the reporting of relevant incidents to Sampo plc’s Audit Committee and Board of Directors.
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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 programmes connected to the policy. Upon employment, all employees sign a statement that they will follow If’s policies and instructions, including the Ethics Policy.
Furthermore, work against corruption and bribery is part of If’s work 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, for example, 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 can 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’ 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. Employees are informed via the intranet when the policy has been revised, and the Chief Risk Officer issues reminders to all employees about their obligations under the policy. Mandatory training in this subject is undertaken by all employees on an annual basis. Training is delivered and monitored via the company’s e-learning platform.
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's top management has ultimate oversight of anti-corruption and bribery matters at Mandatum. Mandatum’s Conflicts of Interest Policy, together with the Mandatum Way guide, sets the overall requirements for anti-corruption and bribery at Mandatum.
In addition, the work against corruption and bribery is an integral part of Mandatum’s anti-money laundering and counter-terrorist financing framework. Mandatum 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 and existing employees’ mandatory training programmes. Furthermore, all employees must, on a regular basis, complete compliance training programmes, in which employees are reminded of the Sampo Group Code of Conduct and Mandatum’s internal procedures.
Any suspicions of corruption or bribery can be reported anonymously through Mandatum’s whistleblowing system.
At Sampo plc, the CEO, together with Risk Management, ensures that sufficient resources are allocated to the prevention of corruption and bribery. Sampo plc is also in charge of the annual review and update of the Sampo Group Code of Conduct, which includes group-level guidelines on anti-corruption and bribery. All Sampo plc’s employees are required to familiarise themselves with the Sampo Group Code of Conduct upon employment, and after that every other year.
More information in Sampo Group’s Sustainability Report.