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Human Rights and Labor Practices


Managing human rights is not only about doing the right thing, it is also about protecting the bottom line. Failure to identify and respond to human rights issues can lead to, for example, legal action, investor divestment, reputation damage, and financial loss.

Group-level approach

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 the Board of Directors of Sampo plc. Sampo Group is also a signatory of the UN Global Compact, which supports work on human rights. In addition, each Group company has adopted supplementary policies and guidelines for its own purposes.

The risk of human rights violations may arise directly from the Group’s own operations or indirectly from external factors, such as customers, investments, and supply chains. In the Group’s own operations, the human rights violations may arise, for example, in discrimination and equal opportunities. In terms of customers, data breaches and misuse of customer information may result in human rights violations, particularly if sensitive personal information is disclosed. The Sampo Group companies have stringent policies and processes to ensure that all collected data is protected through data privacy and information security measures and adequate employee training. Regarding investments, the Sampo Group companies screen investments against international norms and standards, including those related to human rights.

The Sampo Group companies are also committed to encouraging suppliers and other business partners to respect and comply with human rights. This shows, for example, in the Sampo Group Code of Conduct, which suppliers and other business partners are encouraged to adopt. Furthermore, some Group companies have more specific policies on these matters for their own suppliers (e.g., Supplier Code of Conduct).

Number of Internally Reported Human Rights Incidents 2021 2020 2019
If 0 0 0
Topdanmark 0 0 0
Hastings 0 - -
Mandatum 0 0 0
Sampo plc 0 0 0
Sampo Group, total* 0 0 0

*Excluding Hastings




Responsibility for human rights and labour practices at If has been divided among different functions including, for example, Compliance, Risk Management, and HR. The Risk Management and Compliance functions are responsible for reporting on incidents to the boards of directors and CEOs within If.

If follows local legislation on human rights and labour practices in all its operating countries. If’s Ethics Committee is an advisory and preparatory body to the CEO’s meetings, held at least four times a year. The chair of the committee is the Head of HR, and members represent corporate functions, the second line, and all business areas. The committee discusses and coordinates ethics issues within the company and provides recommendations on related matters, including human rights and labour practices. If’s Ethics Policy, which is based on the UN Global Compact, describes ethical standards, goals, principles, and responsibilities in more detail, including the company’s commitment to respecting human rights. The policy applies to all If employees.

If also expects its suppliers and business partners to conduct their business in a lawful and ethical manner, which includes adopting business practices compliant with human rights, labour rights, and other employment practices within their business and their supply chains. If has a Supplier Code of Conduct, which defines the minimum requirements that If asks suppliers to respect when conducting business with If. The code covers the ten principles of the UN Global Compact, including human rights, and other material sustainability matters, and it is mandatory for all new and renewed supplier contracts.

Even though If considers the risk of direct human rights violations to be relatively low in the company’s operations, If recognises that its actions might have indirect negative impacts on human rights. These concerns mainly arise from external factors, such as supply chains, investments, and customers.

Employee training

If organises courses, seminars, and discussions on ethical matters and dilemmas in the workplace at local offices. All If employees are trained to pay attention to human rights topics. Human rights training is part of If’s e-learning course on Challenging Unconscious Biases and Promoting Inclusion, which all employees take as a part of the onboarding process. All employees in the Nordic and Baltic countries are obliged take part in training and workshop programmes on ethics.

Incident reporting

If assesses and manages its compliance with human rights in its own business operations and supply chains on an ongoing basis. If has a whistleblowing channel for anonymous reporting for any identified or suspected non-compliance with internal or external rules or inappropriate behaviour. The channel is available both for employees on the intranet and externally on If’s website.



As a company, Topdanmark has a responsibility to ensure that human rights are respected in its own operations and in the entire value chain. Topdanmark has devised a materiality assessment, in which a focus on human rights is seen as neither a high risk nor a great business opportunity, but it is seen as an area that demands focus and responsibility throughout the company.

Topdanmark follows and complies with Danish legislation, which incorporates internationally recognised human rights. In addition, Topdanmark has a Policy for Human Rights, and human rights is also one of the company’s focus areas regarding sustainability. Topdanmark joined the UN Global Compact in 2010, and the company is continuously working on integrating the ten principles, including principles on human and labour rights, into its policies and business.

Topdanmark closely monitors human rights issues that the company might face in connection with its various business activities. Topdanmark has policies, initiatives, and management systems in place when it comes to safeguarding human rights-related issues. These include, for example, investment activities, for which procedures and policies are in place; protection of personal data, where procedures and policies have been established; and employee relations and non-discrimination, where a range of HR policies, a management system, and initiatives have been established.

Topdanmark also works with several suppliers to ensure the best possible service for the company’s customers and to get access to supplies for its own use. Topdanmark wants to establish trusting and professional collaboration with its suppliers, with a focus on quality and sustainability. Irresponsible conduct in the supply chain, such as non-compliance with the principles of the UN Global Compact, is not only incompatible with Topdanmark’s policies, but it can also damage the company’s reputation and consequently revenue. To counter this risk, Topdanmark has an ESG programme for suppliers, including a supplier Code of Conduct.

Incident reporting

At Topdanmark, human rights violations are reported either directly to HR or via the whistleblowing system.



Hastings understands its responsibilities to protect and respect internationally accepted human rights, specifically those defined within the UK’s Human Rights Act of 1998. Hastings also has the appropriate mechanisms to both identify and remedy any conduct or situation that falls below the standards it has set.

Hastings maintains systems and practices to safeguard against slavery and related human trafficking within both the company and its supply chain. Hastings is committed to acting responsibly in business relationships and ensuring that slavery and human trafficking do not occur anywhere in its business operations. Hastings also requires its suppliers and business partners to take the necessary steps to avoid and/or tackle slavery and human trafficking.

Hastings applies these same principles and standards of conduct to the way it treats its customers, third party partners, and suppliers, seeking to protect their human and statutory rights as it does for its employees. Hastings also conducts appropriate due diligence to ensure that suppliers adhere to and adopt the appropriate standards of behaviour and compliance. 

Hastings complies with applicable human rights and employment legislation and strives to ensure that all its employment policies, processes, and practices support its commitment to value and uphold the human rights of its employees. By adopting this integrated approach, Hastings supports the articles of the UK Human Rights Act that it believes have the greatest impact on the employment relationship, being:

  • Article 6: right to a fair and public hearing
  • Article 7: right to respect for private and family life
  • Article 9: freedom of thought, conscience, and religion
  • Article 10: freedom of expression
  • Article 11: freedom of assembly and association
  • Article 14: prohibition of discrimination

Hastings reviews and refreshes its policies and guidelines regularly.

Employee training

Hastings ensures that its employment policies, processes, and practices are compliant with UK law and that its employees and their leaders recognise their individual responsibility to understand and adhere to agreed practices and standards of conduct and governance. The company provides appropriate and ongoing training to all employees to support this.

Incident reporting

Where non-compliance is identified, Hastings has established protocols for issues to be escalated and remedied. 


Mandatum respects internationally recognised human rights and is committed to ensuring that human rights are never infringed in its operations. Human rights are considered throughout Mandatum’s operations and value chain, ranging from investment decisions to employment issues.

Mandatum’s investment management is committed to responsible investing, and ESG issues form a key part of the investment risk management process. The company’s portfolio holdings are regularly monitored for human rights violations as a part of norms-based screening. If violations are detected, Mandatum seeks to engage with the involved parties to rectify the issues.

Regarding employee relations, Mandatum has HR policies and procedures in place safeguarding human rights-related matters. Mandatum emphasises equality in all its actions and policies and monitors the gender distribution in management positions. Equality issues are part of the Mandatum Way guide given to all new employees as part of onboarding. Discrimination issues are monitored, for example, through the Great Place to Work survey, which is sent to all employees annually.

Mandatum has implemented policies and procedures to protect the personal data of its customers, and it arranges regular data privacy and information security training for employees.

Mandatum also expects its suppliers to conduct their business lawfully and ethically. To ensure this, Mandatum conducts a check against the Sampo Group Code of Conduct as part of their supplier assessment prior to agreeing on cooperation and during the cooperation. The key areas included in the check are commitment to human rights and ensuring equal treatment, environmental objectives, data protection and information security, and governance-related issues such as conflicts of interests, bribery, and corruption.

Sampo plc

Every other year, all Sampo plc’s employees are required to familiarise themselves with the Sampo Group Code of Conduct, which includes guidance on human rights and labour practices.

More information in Sampo Group’s Sustainability Report.

Updated 25 Apr 2022