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Human Rights and Labor Practices

Sampo Group is committed to complying with applicable human rights, labor, and employment legislation.

The Group strives to ensure that internationally accepted human rights are never infringed in its operations. The group-level guiding principles regarding human rights and labor practices are outlined in the Sampo Group Code of Conduct.

The risk of possible direct human rights violations is relatively low in Sampo Group. In the Group’s own operations, the human rights issues identified to be most relevant are discrimination and equal opportunities. Information on equal opportunities and non-discrimination is available in the section Diversity and Equality.

At Sampo Group, the risk of indirect human rights violations mainly arises from external factors, such as customers, investments, and supply chains. In terms of customers, data breaches and misuse of customer information may result in human rights violations, particularly if sensitive personal information is disclosed. 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. More information is available in the sections Data Privacy and Information Security and Cybersecurity.

Regarding investments, Sampo Group companies screen investments against international norms and standards, including those related to human rights. More on investments can be found in the section Responsible Investment Management and Operations.

Sampo Group expects suppliers and other business partners to respect and comply with human rights and encourages them to adopt the principles of the Sampo Group Code of Conduct. Further, some Group companies have more specific policies on these matters for their own suppliers, for example a Supplier Code of Conduct.

There were no reported human rights incidents in Sampo Group in 2020.

Reported Human Rights Incidents, Sampo Group 2020 2019
If 0 0
Topdanmark 0 0
Mandatum Life 0 0
Sampo plc 0 0
Sampo Group, total* 0 0

*Excluding Hastings


Responsibility for human rights and labor 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 and labor rights 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 chairman of the committee is the Head of HR and members represent corporate functions, 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 labor practices. If’s Ethics Policy, which is based on the 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, labor 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 Global Compact and other material corporate responsibility matters, and it is mandatory for all new and renewed supplier contracts.

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 behavior. The channel is available both for employees on the intranet and externally on If’s website.

If organizes 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 programs on ethics.

Even though If considers the risk of direct human rights violations to be relatively low in the company’s operations, If recognizes 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.


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 recognized human rights. Human rights is also one of Topdanmark’s focus areas regarding corporate responsibility. Topdanmark joined the Global Compact in 2010, and the company is continuously working on integrating the ten principles, including principles on human rights and labor, into its policies and business. Topdanmark has a Policy for Human Rights and Ethical Guidelines for the Use of Artificial Intelligence.

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

Topdanmark also works together with a number of suppliers to ensure 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 Global Compact, is not only incompatible with Topdanmark’s Corporate Social Responsibility (CSR) policy, but it can also damage the company’s reputation and consequently revenue. In order to counter this risk, Topdanmark has a CSR program for suppliers.

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


Hastings Group (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 which falls below the standards it has set.

Hastings 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 which 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 also makes sure that its employment policies, process and practices are compliant with UK law and that its employees and their leaders recognize 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. Where non-compliance is identified Hastings has well established protocols for issues to be escalated and remedied.

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 behavior and compliance.

Hastings will not tolerate slavery and human trafficking within its business and supply chain. Hastings is committed to acting responsibly in business relationships and ensuring that slavery and human trafficking does 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.

Mandatum Life

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

Mandatum Life 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, based on the Global Compact. If violations are detected, Mandatum Life seeks to engage with the involved parties to rectify the issues.

More information on Mandatum Life Investment Management's measures regarding investments

Regarding employee relations, Mandatum Life has HR policies and procedures in place safeguarding human rights-related matters. Mandatum Life emphasizes equality in all its actions and policies and monitors the gender distribution in management positions. Equality issues are part of the Mandatum Life 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 Life 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.

More information in Sampo Group’s Corporate Responsibility report, p. 47.

Updated 28 Oct 2021