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Sustainable Sales and Marketing

For an insurance company, it is important to gain the trust of customers by ensuring that the products and services offered are clearly explained and transparently marketed. The trust that customers have in Sampo Group companies’ integrity is the foundation of the companies’ positive reputation.

Paying attention to the risks associated with sales and marketing is important to the Sampo Group companies. Such risks include, for example, inappropriate customer advice and product sales; lack of clarity in terms, prices, and fees; errors in claims handling; and errors in the complaint process. To minimise the risks and increase value for the customer, the Group companies continuously work to develop and improve customer service, and sales and marketing practices.

Group-level Approach

The Sampo Group Code of Conduct sets the group-level requirements for responsible sales and marketing practices. In addition, each Group company has adopted supplementary and more detailed policies, guidelines, and processes for their own purposes.

According to the Code of Conduct, the Group companies must take appropriate care to ensure that customers are given transparent and easily accessible and understandable information about the costs, risks, and conditions relating to the product or service in question, as well as the reasons leading to a decision regarding an application. The Group companies also need to ensure that suitable products are sold to each individual customer. Sales, marketing, and product information must be professional, comprehensive, accurate, balanced, and never misleading.

To ensure compliance with laws, regulations, and internal policies, the Sampo Group companies have continuous training programmes that develop personal conduct and increase the competence of the companies’ sales teams and other customer representatives. Customer feedback channels are also offered to make it easy for customers to provide feedback on the products and services and complain if they are dissatisfied with the handling of their claim.

Group Goals and Ambitions

The Sampo Group companies’ common goal is to act in the best interests of the customers using sustainable sales and marketing practices.



If’s sales and marketing practices focus on meeting the demands and needs of customers and providing customers with the information necessary to make well-informed decisions. If's Distribution Policy includes instructions on responsible sales and marketing practices. According to the policy, If and its distributors shall always act honestly, fairly, and professionally, with due care, and in accordance with the best interests of customers.

Employee training

The sales staff involved in the distribution of insurance contracts continuously undergo comprehensive training in this area. Training is given according to annual plans on various topics such as insurance products, evaluation of risks and customer needs, legislation and guidelines, business ethics, and conflicts of interest. The training varies depending on the country and business area in question. If also provides training to its external distributors.

If is continuously developing and improving the control mechanisms and follow-up routines regarding insurance product and service information, as well as marketing communications. If monitors that training requirements are fulfilled by external distributors and that products are sold to the right target group, in accordance with the company’s instructions.


In If’s remuneration structure, fixed compensation represents a sufficiently high proportion of the total remuneration to avoid employees being overly dependent on variable compensation and to ensure that they act in the best interests of the customers. If does not remunerate or assess the performance of its employees in a way that conflicts with the duty to act in the best interests of the customers. For example, there are no sales targets that could provide an incentive to recommend a particular insurance product to a customer when a different insurance product would better meet the customer’s demands and needs. In addition, variable compensation programmes include a clause that gives the company the right to cancel, in whole or in part, the payment of variable compensation, if material, non-acceptable risk-taking or breaches of internal or external business rules have materialised.

Feedback and complaint process

If’s aim is to focus on service quality throughout the customer journey and to continuously strive to improve the company’s sales and marketing practices. This also means giving the customer a chance to leave feedback. The feedback is carefully analysed, and both positive and negative feedback is used to develop and improve products and services. As required by law, If also has an internal customer representative function that the customer can contact in order to submit a complaint. The customer is also entitled to appeal to external complaints boards (ECBs) in each country.



Topdanmark wants its customers to have the right coverage to match their needs and wishes. The company is aware that this requires good and correct customer advice in sales and consulting situations, from competent employees.

Topdanmark has one central and several local compliance departments, ensuring that sales personnel meet quality requirements and follow agreed business procedures and applicable laws and regulations. There is a reporting system in place, which ensures that inappropriate situations are evaluated to improve customer service and avoid errors in the future.

Topdanmark provides customers with easily accessible information on products, price, and coverage. Therefore, customers can get an overview of what can be expected from the insurance policy. Furthermore, all text is always checked to ensure that the content is understandable to the average customer. All information on the insurance is stated in the terms, and small print is not used. Topdanmark improves product information continuously, based on customer feedback.

Topdanmark is obliged to state the full price of its insurance policies, including all charges and fees. The information appears in the terms. Fees that are not directly related to the insurance price, such as an early termination fee, are stated on the company’s website. Changes to fees are communicated according to legislation.

Employee training

Topdanmark ensures the competence of employees by providing employees with adequate training. All salespeople are trained at the Insurance Academy, and new employees are thoroughly trained in Topdanmark's business and sales procedures. In addition, employees continuously receive training in professional and interpersonal skills.

Feedback and complaint process

Topdanmark emphasises the importance of clearly informing customers of their complaint options, as well as ensuring a fair and transparent complaint process. In private customers’ insurance cases, if the customer disagrees with Topdanmark’s decision on a claim, the customer is entitled to appeal to the Danish Insurance Complaints Board. The number of customer complaints that are passed on to the Insurance Complaints Board is less than one per thousand claims received.

Topdanmark’s foremost objective is to reduce the number of claims in the first place, but as claims always occur, the goal of the company is to succeed in appeal cases brought before the Insurance Complaints Board. Regardless of the outcome of the appeal cases, Topdanmark always analyses how the company can improve communication with its customers.



Treating customers fairly and acting in their best interests is important to Hastings. This includes supporting all customers, including customers in vulnerable circumstances, to ensure they receive the same fair outcomes and value from the products. Hastings’ policies and processes are designed in a way that enables employees and leaders to be flexible and to provide additional support for customers when needed.

It is essential that Hastings’ customers fully understand the cover options available and that they purchase products that meet their demands and needs. Customers can purchase their products digitally or via the contact centre and, regardless of the chosen channel, Hastings believes it is essential for customers to be clear so they can make an informed choice.

At Hastings, Treating Customers Fairly (TCF) and Customer Best Interest (CBI) are integrated within the conduct framework. The conduct framework is anchored in the Financial Conduct Authority’s (FCA) six outcomes, which encompass CBI as well as other Insurance Distribution Directive requirements. The six consumer outcomes are available at the FCA website (

The associated controls and measures are regularly assessed and reported to Hastings at executive and board level. In reporting, Hastings focuses on customer conduct, including outcomes, experience, and value measures, with a specific lens on vulnerability.

As part of the IDD, Hastings provides customers with clear and transparent information prior to purchasing a policy, with full disclosure provided on product coverage, cover limitations, excess levels, and any fees connected to the ongoing management of their insurance policy. The company has controls in place to ensure that information is clearly accessible before a customer commits to any purchase, and it satisfies all regulatory and conduct obligations. 

Hastings ensures that any product offered is of suitable quality and provides the customer with value and utility, and each product is assessed annually to ensure it remains appropriate.

Digital design

Hastings focuses on meeting level AA of the Web Content Accessibility Guidelines (WCAG 2.1). For those customers in vulnerable circumstances, Hastings is increasing design considerations and relevant signposting. In terms of user experience and interface design, Hastings is deliberately avoiding dark patterns (a digital term whereby designs are used on websites and in apps that make users do things they did not mean to, like buying or signing up for something). This eliminates any risk or intent to deceive customers.



In accordance with the Sampo Group Code of Conduct and the company’s internal guidelines, Mandatum is committed to transparent, understandable, and not-misleading communication in both sales and marketing. The company is also committed to offering customers comprehensive, accurate, and transparent product information, as well as information on costs and conditions, and on product risks in sales, marketing, and product materials and practices. Mandatum has internal instructions for marketing and customer communications, and specified groups of customers to whom certain products or campaigns may not be marketed.

Mandatum has an extensive permission structure to handle individual permissions related to marketing and customer communications, and the GDPR processes embedded into marketing processes (e.g., personal data deletion). Mandatum’s marketing and customer communications follow regulations and key principles and are reviewed by the company’s Legal department before publication.

When offering investment products, Mandatum always evaluates the customer’s risk profile. The risk profile is based on answers given in the investor profile survey. The survey gathers information on the customer’s investment experience, risk tolerance, and grounds and goals for investing. The offered investment product is always related to the customer’s risk profile, so it is certain that the product suits the customer’s needs.

The customers are classified either as professional or non-professional investors. The customer can be a professional investor based on law, or they can apply to be accepted as a professional investor after meeting certain criteria. The classification affects how comprehensively the customer’s insurance need has to be determined before offering an investment product: an investor profile survey must be completed for a non-professional investor, whereas a professional investor does not need to complete one.

Employee training

The basis for responsible sales practices is identifying customers’ needs and determining suitable services to meet those needs. At Mandatum, this approach to sales is implemented through mandatory training (minimum 15 hours/year/person) offered to all customer-facing employees. The mandatory training at Mandatum includes training on the needs-based sales model and sales process, new products and services, regulatory demands such as anti-money laundering and the IDD, tools and systems used in sales, and customer data documentation. In addition, all customer-facing employees must complete certain product and policy training courses to gain a sales license. To secure the know-how of employees involved with sales, leaders take part in customer meetings during the year.


Responsible sales practices include annual sales commission negotiations. Mandatum’s sales commissions follow IDD demands to avoid any conflict of interests between the customer and a salesperson. To secure ethical sales, sales agreements also include ethical objectives, such as internally defined levels of customer satisfaction. In addition, Mandatum does not pay sales commissions before the demands set by the regulation have been met.

Feedback and complaint process

In the case of a complaint, Mandatum’s first priority is to negotiate with the customer in order to find a solution that is satisfactory to both parties. If a consensus cannot be achieved, the customer can bring the matter before an alternative dispute resolutions (ADR) body, which is either the Insurance Complaints Board or the Consumer Disputes Board, or ultimately the matter can be submitted to the local district court.

Updated 25 Apr 2022