Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Contents
Introduction ................................................................

3

Sustainable corporate culture .............................

40

2023 highlights ..........................................................
Preface ..........................................................................
Sampo Group in brief...............................................
Sustainability governance ......................................
Risk management ......................................................

4
5
7
11
14

Empowering work environment ..........................
Diversity, equity, and inclusion .............................
Health and well-being ..............................................
Competence development ...................................
Remuneration .............................................................

41
53
62
69
73

Sustainable business management andpractices.......................................................................

17

Sustainable investment management andoperations ...................................................................

78

Anti-corruption and bribery ..................................

18

Investment management at Sampo Group ......
Investment management at If ...............................
Investment management at Topdanmark ........
Investment management at Hastings ................
Climate impact of investments.............................

79
80
84
86
88

Sustainable products and services ....................

92

Sustainable product and service offering.........
Sustainable supply chain management .............
Sustainable sales and marketing practices ......
Customer satisfaction ..............................................

93
96
101
105

Anti-money laundering and counter-terrorist
financing .......................................................................
Data privacy ................................................................
Information security and cybersecurity ............
Human rights and labour practices.....................
Environmental impacts of group operations...
Compliance with laws and regulations ..............

20
22
25
27
30
39

About the report
This is Sampo Group’s Sustainability Report 2023, published on 27 March 2024. The reporting scope covers Sampo plc
and its subsidiaries If P&C Insurance Holding Ltd (publ) (If), Topdanmark A/S (Topdanmark), and Hastings Group(Consolidated) Ltd (Hastings). The report gives an overview of a wide array of topics regarding how Sampo Group
ensures sustainable business operations, integrates sustainability into investments and insurance activities, supports
personnel, and engages in communities. The key stakeholder groups considered in the report are investors, customers,
and employees of Sampo Group, as well as suppliers and other business partners, regulators and authorities, thegeneral public, and the media. The information in this report is aimed at a specialist sustainability audience.
More information on the report in general is available in Appendix 1: Calculation principles.

SUSTAINABILITY REPORT 2023

2

Sustainable communities ...................................... 108
Stakeholder engagement and dialogue ............
Donations and other humanitarian efforts .......
Tax footprint ...............................................................

109
114
118

Appendices .................................................................

122

Appendix 1: Calculation principles.......................
Appendix 2: GHG emissions ..................................
Appendix 3: GRI content index ............................
Appendix 4: TCFD content index ........................
Appendix 5: SASB content index ........................

123
127
132
138
139

Appendix 6: The UN Sustainable
Development Goals ..................................................
Independent practitioner’s assurance report ..
Signatures to the Sustainability Report ............
Contacts .......................................................................

REPORTS FOR THE YEAR 2023
WWW.SAMPO.COM/YEAR2023

ADDITIONAL SUSTAINABILITY DISCLOSURES
WWW.SAMPO.COM/SUSTAINABILITY

140
142
144
145

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Introduction
2023 highlights .........................................................
Preface ..........................................................................
Sampo Group in brief..............................................
Sustainability governance.....................................
Risk management .....................................................

SUSTAINABILITY REPORT 2023

4
5
7
11
14

3

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡2023 highlights• Employed approximately 13,500 employees.
• Updated the Sampo Group Code of Conduct.
• Committed to the Science Based Targets initiative(SBTi) and to setting group level science-based
climate targets accordingly.

• Received validation and approval for its sciencebased climate targets from the SBTi.
• Exceeded the employee engagement (eNPS) targetof above 50.
• Developed a due diligence process for suppliers andbusiness partners.

SUSTAINABILITY REPORT 2023

• Improved customer satisfaction (tNPS) compared tothe previous year.
• Integrated a Supplier Code of Conduct into 76 percent of new contracts.
• Launched Leadership Principles, focusing on hybrid
workplace, well-being, and employee engagement.

4• Ranked 4th in the Inclusive Top 50 UK Employers
list.
• Implemented a formal set of supplier policies, which
suppliers must agree to before cooperation.
• Switched to biogas and runs its headquarters in
Bexhill on 100 per cent renewable energy.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Preface
In 2023, we continued to work on sustainability in linewith the Group’s sustainability programme and strategic
sustainability themes. Sustainability is an importantfocus area for Sampo Group, and our many initiatives
and development projects supported this journey
throughout the year.

Actions to combat climatechangeActive development related to climate and theenvironment remained a priority for us during 2023.
Sampo made a commitment to the Science Based
Targets initiative (SBTi) and we started to develop
group level science-based climate targets (SBTs) for
our own operations and investments according to the
SBTi’s methodology. The targets have a designatedwindow for submission to the SBTi for validation, no
later than October 2025, but we aim to be ready tosubmit ours well ahead of that deadline.
In addition, the individual Group companies continued
to work on their company-specific SBTs according toschedule. If’s targets were validated during the year andare already publicly available. Hastings and Topdanmark
will submit their targets to the SBTi for validation within
2024.

SUSTAINABILITY REPORT 2023

5

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Sustainable development
throughout operations

Well-being of our customers
and employees

Adherence to applicable laws, regulations, and internal
policies is an established part of Sampo Group’s culture.
In 2023, we conducted an update of the Group’s Codeof Conduct and strengthened the guidance on humanrights and labour practices, for example. We also
maintained our focus on responsible investment by
updating our investment policies. Further instructions
on how to take environmental, social, and governance(ESG) issues into account in investment processes wereadded. In addition, the environment and climate-related
considerations were highlighted as internal
development areas going forward. We also took steps
toward harmonising responsible investment practices
and reporting throughout the Group, a developmentthat will continue in 2024.

As always, our employees were focused on putting ourcustomers first and serving them in the best possible
way throughout the year. To support our employees,
we advanced sustainable corporate culture. This
included, for example, policy and training updates,
employee surveys as well as new employee initiatives.
The results of our efforts are visible, as If, Topdanmark,and Hastings were all able to exceed the employee
engagement targets they set for the year.

During 2023, we also paid attention to the sustainabilityof our supply chains. Supply chains are a crucialcomponent of the sustainability of our products andservices, and Sampo Group emphasises sustainability
factors when working with suppliers. Both If andTopdanmark worked on setting voluntary SBTs for their
supply chains during the year, while at the same time
focusing on the companies’ existing supply chainrelated goals. Hastings, on the other hand, completed
an ESG due diligence assessment on all its criticalsuppliers and is committed to developing a suppliercode of conduct during 2024.

SUSTAINABILITY REPORT 2023

We also consider it important that all our employees
can be themselves at work. Therefore, in 2023, we
emphasized diversity, equity, and inclusion (DEI) among
our employees, and development could be seen related
to recruitment practices, awareness raising, and overall
acknowledgment of DEI work.

Continuous development andclear focus on the future
Going forward, Sampo will be subject to newsustainability reporting requirements laid down by theEuropean Union. We began preparing for the
implementation of the Corporate Sustainability
Reporting Directive (CSRD) and the related European
Sustainability Reporting Standards (ESRS) already in
2023 and the work will continue in 2024. Due to the

6

Appendices≡legislative changes, this Sampo Group Sustainability
Report 2023 will be our last sustainability reportfollowing the current reporting structure. In accordancewith the CSRD, the Group’s sustainability reporting will
be part of the Board of Directors’ report from 2024
onwards.
The sustainability field continues to move ahead andchange at a fast pace. But as we look forward, ourobjective is clear. Our sustainability strategy is and willcontinue to be linked to the Group’s overall strategy,
which focuses on high-quality P&C insurance
operations. Sustainability is an integral part of ourbusiness, and we are also committed to strengthening
our sustainability endeavours further in close
cooperation with our broad group of stakeholders in
the years ahead.
Torbjörn Magnusson
Group CEO

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Sampo Group in brief
Sampo Group is the leading property and casualty(P&C) insurance group in the Nordic region and a major
operator in the growing digital P&C insurance market in
the United Kingdom (UK). Sampo plc is the parent
company of the Group, and the insurance brands are If,
Topdanmark, and Hastings.
Sampo Group has over seven million customers and it
employs approximately 13,500 people. The Group’s
annual gross written premiums totalled EUR 8.9 billion
in 2023 of which the Nordic market accounted forapproximately 77 per cent.
Sampo Group’s operations are diversified bygeography, line of business, and customer group. The
Group’s main operating countries are Finland, Sweden,
Norway, Denmark, the UK, and the Baltic countries. In
addition, the company has operations or offices in
Spain, Gibraltar, France, Germany, the Netherlands, andthe United States (US). Sampo Group’s largest
customer group is private customers, which accounts
for 64 per cent of the annual premiums. The Group isalso a leading provider of P&C insurance in Nordic
commercial and industrial business.

SUSTAINABILITY REPORT 2023

Sampo plc
Sampo plc is the parent company of Sampo Group andlisted on Nasdaq Helsinki and Nasdaq Stockholm.
Sampo plc controls the Group’s strategy, capital
allocation, investment policy, risk management, groupaccounts, investor relations, and sustainability, as wellas legal and tax matters. The company employs
approximately 60 people, and the headquarters is in
Helsinki, Finland.

If

Topdanmark
Topdanmark is a leading Danish non-life insurer. The
company focuses on the private, agricultural, and SME
markets. Topdanmark’s headquarters is in Ballerup,
Denmark, and the company has approximately 2,200
employees. Topdanmark’s shares are listed on Nasdaq
Copenhagen. As of 31 December 2023, Sampo plc
owned 48.9 per cent of the company’s shares.

Hastings

If provides insurance solutions for individuals,
businesses, and international industrial enterprises. The
company has approximately four million customers in
the Nordic and Baltic countries, and it is the largest P&C
insurer in the Nordic region. If also has offices in Spain,
France, Germany, the Netherlands, and the United
Kingdom. If’s operations are divided into four businessareas: Private, Commercial, Industrial, and Baltic. If has
approximately 7,900 employees, and is a wholly owned
subsidiary of Sampo plc. If’s headquarters is located in
Stockholm, Sweden.

7

Hastings is one of the leading insurers of cars, vans,
bikes, and homes in the UK. The company has over 3.2
million customers and approximately 3,300 employees.
Hastings’ headquarters is located in Bexhill, United
Kingdom, with additional sites in Leicester, Gibraltar,
and London. Hastings is a wholly owned subsidiary of
Sampo plc.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Shareholder structureGroup structure

Sampo plc, 31 December 2023

Sampo Group, 31 December 2023

Communities

Appendices* Solidium Oy is entirely owned by the Finnish state.

The official legal structure of the Group on 31 December 2023 is available in the Board of Directors Report 2023.

SUSTAINABILITY REPORT 2023

8≡

Introduction

Business management
and practices

Corporate
cultureStrategy
Sampo Group’s strategy focuses on P&C insurance;
investing in and developing its P&C insurance
subsidiaries across the Nordic countries, the UK, and theBaltics. Sampo Group's purpose statement asserts‘Safety and value through understanding risks’, amission underpinned by its values of Trust, Integrity,and Excellence. Sampo Group creates value andprovides safety to its stakeholders through high-quality
P&C insurance solutions, which are developed byunderstanding risks and managing them responsibly.
Sampo Group’s key stakeholder groups are its
customers, investors, employees, suppliers and otherbusiness partners, and society at large. The Group’sbusiness model is primarily based on the interests of its
customers. Sampo Group’s employees who develop anddeliver P&C insurance products and related services areconstantly monitoring and taking the Group customers’interests into consideration. These interests arecomplemented by the views and expectations of
Sampo Group’s employees and suppliers and otherbusiness partners in shaping the Group businessmodel(s) and strategy. Finally, the interests andperspectives of investors in securities issued by Sampo
plc, such as the interests of shareholders, similarly
influence Sampo Group’s strategy and business modelthrough discussions with the Group’s management andInvestor Relations function. Sampo Group takes all
stakeholder groups into consideration in theformulation of the Group strategy and businessmodel(s). This includes society at large, as Sampo
Group is an active member of local communities.
Further information on stakeholder engagement during2023 is available in the section Stakeholder
engagement and dialogue.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Strategy:www.sampo.com/group/strategy
Market overview:www.sampo.com/group/market-overview
Business model:
www.sampo.com/group/business-model
Principles and policies:
www.sampo.com/governance/principlespolicies-and-statements

Appendicesmanagement. They constitute three of the six board
members elected by the annual general meeting (AGM).
The subsidiaries have their own infrastructure andmanagement, as well as operative processes. In
compliance with the group-wide framework, eachsubsidiary designs and implements supplementarycompany-specific policies, and governance and risk
management frameworks, which steer, limit, and control
all operations. Each individual Group company is
responsible for following up and monitoring compliancewith the policies.

Normative framework
Sampo Group

Group business model
If, Topdanmark, and Hastings organise their businessactivities to implement the strategic decisions made by
the parent company Sampo plc. Sampo’s main
management tool is the work conducted on thesubsidiaries’ boards of directors. The boards of If andHastings mainly consist of Sampo Group’s management.
Regarding the wholly owned subsidiaries, Sampo
provides a group-wide framework of general principles
and policies (e.g. Code of Conduct, Risk Management
Principles, Remuneration Principles, and Compliance
Principles) within which the company expects its
subsidiaries to independently conduct their business,with frequent communication with Sampo on major
operational matters. In addition, Sampo monitors
performance, risks, and capitalisation at a detailed level.
Topdanmark has also adopted Sampo Group’s groupwide principles and policies. The dialogue between
Sampo and Topdanmark focuses primarily on
performance, risk, and capitalisation reporting, and isless detailed than the discussions between Sampo andits wholly owned subsidiaries. At Topdanmark, the chair
and two other board members are from Sampo Group’s
9≡Introduction

Business management
and practices

Corporate
cultureValue creation and thedescription of the value chain
Sampo Group creates value by providing safety tocustomers through high-quality P&C insurance
products. Safety, and thus value, is enabled by adetailed understanding of various risks that Sampo
Group underwrites. By pooling risks, Sampo Groupbalances the various risks of the customer base andprovides insurance coverage for events that can becomplex for customers to prepare for without P&C
insurance products.
Sampo Group accomplishes the safety and value
creation through teams of employed professionals andthrough cooperation with suppliers and other business
partners. The value created for customers flows to faircompensation to Sampo Group's employees andsuppliers, and to Sampo plc’s shareholders. This safety
also benefits society at large, enabling other sectors to

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

continue creating value through their value chains,which are insured for perils with Sampo Group’s P&C
insurance solutions.
Sampo Group’s largest customer group is private
individuals. The largest product segments for private
individuals are motor and home insurance, but Sampo
Group also offers other insurance covers, such as travel
insurance and other personal accident covers. Sampo
Group’s second largest business area is commercial
insurance. While property and motor insurance risks
dominate in the commercial business area, certain
liability covers are also prominent. In addition, Sampo
Group is a leading provider of industrial lines P&C
insurance in the Nordic region through If. The industrial
lines business area serves companies with an annual
turnover above EUR 50 million and more than 500
employees. In the UK P&C insurance market, Sampo
Group operates through the digital insurer Hastings.
Hastings is one of the major motor insurance providers
in the UK.

10

Appendices≡

Sampo Group has large networks of suppliers andpartners, in which vehicle and property partners andpartners in health and travel services play a big role. In
addition, suppliers in ICT and external data providers,for example, support the running of the business.
There were no significant changes in the P&C insurance
sector, value chain, and business relationships during
the year or compared to the previous reporting period.
Sampo plc successfully completed its partial demerger
during the reporting period, where Mandatum wasseparated from Sampo Group to be its own listed
entity. This strategic development enables Sampo
Group to deepen its focus on P&C insurance, whileproviding Mandatum flexibility to pursue growth
opportunities within asset management and life
insurance.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Sustainability governance
Sustainability organisation
and reporting
Sampo plc’s Board of Directors has ultimate oversightover group level sustainability, covering the entire range
of environmental (including climate change), social, andgovernance (ESG) matters. The board has assigned its
Audit Committee to monitor Sampo Group’s
sustainability activities and reporting. The Audit
Committee reviews and approves the sustainability
programme, including the material sustainability topics.
In addition, the annually published sustainability report
and the annually updated Sampo Group Code of
Conduct are reviewed and approved by both the Audit
Committee and the Board.
The Group Chief Financial Officer (CFO), who is amember of the Sampo Group Executive Committee,
directs Sampo plc’s Sustainability unit. The CFO also
ensures that adequate reporting on sustainability
matters is provided to the Group Chief Executive
Officer (CEO). The Sustainability unit of Sampo plc, led
by the Head of Sustainability, is responsible for thedevelopment and coordination of sustainability atGroup level. The unit prepares sustainability reporting
and the sustainability programme, which sets the
direction for the sustainability work. In addition, the unit
sets schedules, requests, and group level guidance forthe subsidiaries, and organises regular sustainability
meetings.

SUSTAINABILITY REPORT 2023

11

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureThe Group CFO and Sampo plc’s Sustainability unit
report to the Board of Directors and the Audit
Committee on sustainability matters at least twice ayear, and more frequently when deemed necessary.
During 2023, sustainability as a standalone topic was on
the agenda at Board and Audit Committee meetings a
total of four times. In addition to the Sustainability unit,
other units, such as Compliance, Risk Management,
Investment Management and Operations, and HR,
provide reporting to the Board and/or its committees
and the Group Executive Committee regularly. This
reporting can also include sustainability matters, assustainability is an integral part of operations. The
Board and its committees receive meeting materials
before each Board and/or committee meeting and havetime to provide feedback. During a meeting, apresentation on the topic in question is provided before
a decision is made.
According to Sampo plc’s Board Diversity Policy, theBoard of Directors shall possess the requisiteknowledge and experience in the social, business, andcultural conditions of the regions and markets in which
the main activities of the Group are carried out. The
policy states that when electing the Board of Directors,
a broad set of qualities and competencies are sought.
Training can be provided for the Board when it isconsidered necessary. For example, in February 2024,
the Board received training on the Corporate
Sustainability Reporting Directive (CSRD) and therelated European Sustainability Reporting Standards(ESRS).
At each subsidiary, various business areas, operational
departments, and units are actively involved in theGroup’s sustainability endeavours and reporting. GroupSUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

level sustainability reporting is largely based on
information provided by the subsidiaries, according toformats and schedules defined by Sampo plc. Eachsubsidiary is responsible for its respective reporting to
the parent company, to ensure correctness of
information. Information on If, Topdanmark, andHastings’ sustainability governance can be found intheir respective reporting.

Sustainability programme
and materiality analysis
Sampo Group has a sustainability programme, which
drives group level sustainability work. The programme
consists of five strategic sustainability themes: Business
management and practices, Corporate culture,
Investment management and operations, Products andservices, and Communities. Under each theme, the mostmaterial sustainability topics have been identified usingmateriality analysis. The selected material topics include
areas that are especially important to a company
operating in the insurance industry. In addition, they link
to Sampo Group’s overall business and are seen as
important by the Group’s various stakeholders.
Representatives from all the Sampo Group companies
have been involved in drafting the programme andanalysing the material topics. In addition, regulatory
requirements regarding current and future sustainability
reporting, feedback from investors and personnel,
industry best practices, relevant reporting frameworks(e.g. the GRI Standards, the TCFD), and the views ofvarious ESG rating agencies have been taken into
account. The sustainability programme also links theGroup’s sustainability work to the UN Sustainable
Development Goals (SDGs).

12

Appendices≡

Board of Directors:
www.sampo.com/governance/board-ofdirectors
Sustainability reports of the Sampo Group
companies:
www.sampo.com/year2023

In this Sustainability Report, the most material
sustainability topics at Sampo Group are presented
under individual sections. In each section, the major
actions taken to manage the topic and its impacts,
progress against targets, and developments related topolicies, processes, and/or working methods during thereporting year are covered. The significance in terms ofreporting is viewed from Sampo Group and its
stakeholders’ perspective, meaning that the reporting
focuses on the impacts most material to the Group andits stakeholders.
The latest sustainability programme, including material
sustainability topics, was approved by the Group CFO
in December 2021 and by Sampo plc’s Audit Committee
in February 2022. In 2023, Sampo Group conducted adouble materiality analysis to meet the requirements of
the CSRD and the ESRS. The analysis will be finalised in
2024 and published as part of the Sampo Group Boardof Directors’ Report 2024. Based on the results of the
double materiality analysis, Sampo Group’s
sustainability programme will also be updated during2024.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Sustainability programme
Sampo GroupSUSTAINABILITY REPORT 2023

13

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Risk management
Sustainability-related risks, including climate change,
are a part of Sampo Group’s overall risk management.
Sampo plc’s Board of Directors is responsible for
ensuring that the Group’s risks are properly managed
and controlled. The Board defines financial targets for
the Group and for the wholly owned subsidiaries, andapproves group level principles that steer thesubsidiaries’ activities. The Audit Committee is
responsible, on behalf of the Board, for the preparationof Sampo Group’s risk management principles andother related guidelines. The committee ensures thatthe operations follow these guidelines, controls Sampo
Group’s risks and risk concentrations, and controls thequality and scope of risk management in the Group
companies.

Risk management governance framework
Sampo Group, 31 December 2023

Risk Management Report 2023:
www.sampo.com/year2023
Risk Management Principles:
www.sampo.com/governance/principlespolicies-and-statements

The Sampo Group CFO chairs the Group Risk
Committee, which ensures communication andcooperation in supporting risk management, includinginternal control, and risk reporting in Sampo Group. The
committee assists both the Board of Directors and theGroup CEO in the effective operation of the risk
management system.

SUSTAINABILITY REPORT 2023

14

Appendices≡Introduction

Business management
and practices

Corporate
cultureThe Group Chief Risk Officer (CRO) is responsible for
ensuring appropriate risk management at Group level.
The CRO’s responsibility is to monitor Sampo Group’s
aggregated risk exposures, and to control and monitor
company-specific and group level risk management.
The boards of directors of If, Topdanmark, and Hastings
are the ultimate decision-making bodies of therespective companies and have overall responsibility forthe risk management processes. The Boards of
Directors of the Group companies appoint the relevantrisk committees and are responsible for identifying any
need to change the policies, principles and instructions
related to risk management.

Sustainability as a businessrisk driver
The key sustainability-related business risk drivers for
Sampo Group can be divided into five main categories:
Sustainable business management and practices arefundamental to Sampo Group’s operations. In Sampo
Group, good governance means effective policies,
management practices, and training that provide
assurance that the Group companies and theirpersonnel, suppliers, and other business partners
comply with laws, regulations, and generally accepted
principles on human rights, labour rights, theenvironment and climate, anti-money laundering,counter-terrorist financing, and anti-corruption andbribery. Furthermore, they include comprehensive
information security and cybersecurity governancesystems, and data privacy activities.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Sustainable corporate culture includes factors relating
to the work environment, diversity, equity and inclusion,
employee health and well-being, competencedevelopment, remuneration, and talent attraction andretention. Sampo Group wants to provide customers
with the best service in all situations. Here, skilled andmotivated employees are an essential success factor.
Losing talent or being perceived as an unattractive
employer would pose large risks for the businesses.
Therefore, Sampo Group strives to ensure a sound work
environment, not only because it is stipulated by law,
but also because it lays the foundation for sustainablebusiness performance. Diversity and inclusion are key
focus areas for Sampo Group, which is committed toproviding a non-discriminatory, open, and agreeable
work environment where everyone is treated fairly andequally. Risks related to these themes are managed, forexample, by having strong internal policies andgovernance structures, conducting organisational
development programmes, and offering employees
training, interesting career opportunities, and attractive
remuneration packages.
Sustainable investment management and operations
are important in managing investment risks and in
mitigating potential adverse impacts on Sampo Group’s
reputation. Therefore, Sampo Group takes ESG issues
into account when assessing the security, quality,
liquidity, and profitability of investments. Investment
opportunities are carefully analysed before any
investments are made, and ESG issues are consideredalong with other factors that might affect the risk-return
ratio of individual investments. Sampo Group uses
different ESG strategies to ensure the effective
consideration and management of investment risks
arising from ESG issues. These strategies include, forexample, ESG integration, sector-based screening,norms-based screening, and engagement with investee
companies.

15

Appendices≡Sustainable product and service offerings areimportant in meeting the evolving needs of all
customers and in mitigating potential adverse impacts
on Sampo Group’s reputation. Therefore, Sampo Groupaims to take ESG issues into account in product andservice development, underwriting, and supply chain
management. Additionally, a sustainable product andservice offering requires being attentive to the risks
relating to inappropriate customer advice and productsales, errors in claims handling and complaint processes,
and a lack of clarity on conditions, prices and fees. The
focus in sales and marketing practices is on meeting thedemands and needs of the customer, and providing thecustomer with the information necessary for them tomake well-informed decisions on their insurance
coverage. Sampo Group manages risks related to these
themes, for example, by having effective internal
policies and governance structures, and offering
employees training.
Environmental issues and climate change are factorsthat are expected to have a mid- and long-term effecton Sampo Group’s businesses. Climate-related risks canbe categorised into physical risks and transition risks.
The strength of the risks depends on the trajectory of
global warming. A scenario in line with the Paris Climate
Agreement, limiting the temperature rise to 1.5°C, would
have moderate consequences, whereas 3–5°C scenarios
would have severe consequences for industry,
infrastructure, and public health.
Physical risks are risk factors affecting, in particular, thefinancial position and results of Sampo Group. The
increasing likelihood of extreme weather conditions andnatural disasters is included in internal risk models.
Climate-related risks are also managed effectively with
re-insurance programmes and price assessments. Since
climate change could increase the frequency and/or
severity of physical risks, Sampo Group conducts
sensitivity analyses using scenarios in which the severity

Introduction

Business management
and practices

Corporate
cultureof natural catastrophes is assumed to increase. Sampo
Group also helps its corporate and private customers tomanage climate-related risks. Extreme weather events
can, for example, damage properties and lead to crop
failure and business interruption. Loss prevention is an
essential part of insurance services, as it helps
customers to reduce economic losses and mitigates theimpacts of climate change.
Sampo Group’s investments can be exposed to both
physical risks and transition risks, depending on theinvestment in question. Investments are particularly
exposed to physical risks in the form of losses incurredfrom extreme weather events. The transition to a lowcarbon society, with potentially increasing
environmental and climate regulation, more stringent
emission requirements, and changes in market
preferences, could in turn cause transition risks for theGroup’s investments, and a possible revaluation ofassets as operating models in carbon-intense sectors
change. To manage physical risks and transition risks,
investment opportunities are carefully analysed before
any investments are made, and climate-related risks are
considered along with other factors affecting the riskreturn ratio of individual investments. The methods
used by Sampo Group include annual analysis of the
carbon footprint and climate impact of investments,
sector-based screening and ESG integration, monitoring
the geographical distribution of investments,
engagement with investee companies, and climate
targets for investments.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities≡

AppendicesSustainability factors as risk drivers
Sampo Group
Sustainability factors

Examples of risk management
practices

Risks and effects

Sustainable business management
Reputationand practices(e.g., anti-corruption andbribery, anti-money launderingand counter-terrorist financing,
Quality of operations
data privacy, information
security and cybersecurity,
human rights and labour
practices, environmental
Penalty fees
impacts of group operations)• Underwriting volumes• Well-performing staff• Underwriting results

Sustainable corporate culture(e.g., empowering work
environment, diversity, equity,and inclusion, health and wellbeing, competencedevelopment, remuneration)

Reputation• Underwriting volumes• Well-performing staff• Underwriting results

Quality of operations• Operational risks• Costs

Reputation• Underwriting volumes• Underwriting results

Quality of operations• Operational risks• Costs

Performance ofinvestee companies• Market risks• Investment returns

Sustainable investment
management and operations

Sustainable products and services(e.g., sustainable product and
Reputation
service offering, sustainablesupply chain management,sustainable sales and marketing
practices)
Claims frequency andseverity

Environmental issues and climatechange16• Operational risks• Costs• Strong policies and guidelines• Effective governance structures• Topical training and competencedevelopment programmes• Operational risks• Costs• Underwriting volumes• Underwriting results• Underwriting risks• Underwriting results

Reputation• Underwriting volumes• Well-performing staff• Underwriting results

Claims frequency andseverity• Underwriting risks• Underwriting results

Performance ofinvestee companies• Market risks• Investment returns• Strong policies and guidelines• Effective governance structures• Topical training and competencedevelopment programmes• Attractive remuneration
packages• Strong policies and guidelines• Effective governance structures• Topical training and competencedevelopment programmes• Competent employees• Strong policies and guidelines• Effective governance structures• Loss prevention• Integrating ESG into repairs,
replacements, and other claims
services• Topical training and competencedevelopment programmes• Competent employees• Strong policies and guidelines• Effective governance structures• Internal risk modelling andsensitivity analysis• Reinsurance programmes andprice assessments• Loss prevention• ESG strategies and analysis tools

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Sustainable business management and practices
Anti-corruption and bribery ..........................................................
Anti-money laundering and counter-terrorist financing ....
Data privacy .........................................................................................
Information security and cybersecurity ....................................
Human rights and labour practices .............................................
Environmental impacts of group operations ..........................
Compliance with laws and regulations......................................

SUSTAINABILITY REPORT 2023

18
20
22
25
27
30
39

17

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesAnti-corruption and bribery
Sampo Group can be exposed to corruption and bribery
especially through its investments, customers, andsupply chains. Sampo Group can face reputational risks,
legal risks, business risks, and potential costs if it fails tocombat corruption in all its forms. The risks are
mitigated, for example, by screening investments andcustomers against international norms and standards
and by encouraging sustainability in supply chains.

Approach
Sampo Group is a signatory of the UN Global Compact,which supports work against corruption. The Sampo
Group Code of Conduct sets the overall guiding
principles on working against corruption and bribery
within Sampo Group. In addition, each Group company
has adopted supplementary policies and guidelines for
its own purposes. These annually updated guidance
documents contain, for example, rules on gifts,
participation in events, and hospitality, as well as
information on expectations regarding employees, androles and responsibilities. Employees are informed, forexample, on the intranet, when policies have beenrevised, and the Group companies offer mandatory andvoluntary training for their employees regarding the
topics.

sufficient resources are allocated to the prevention ofcorruption and bribery. Each Group company organises
duties and takes other necessary and appropriate
measures to comply with the applicable local rules andvarious sanctions regimes, which may be imposed by
the UN and/or the European Union (EU).

Group goals and ambitions

Reporting on anti-corruption and bribery activities, aswell as on potential incidents, is organised in a mannerthat ensures that the management and the boards of
directors of relevant Group companies receive allmaterial information without undue delay, and that
Sampo plc’s Risk Management organisation is informedof all relevant incidents. Sampo plc’s Risk Management
organisation is responsible for reporting relevant
incidents to Sampo plc’s Audit Committee and Board of
Directors.

Actions and results

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Additional information:www.sampo.com/sustainability/sustainablebusiness-management-and-practices/anticorruption-and-bribery

The managing director of each company in Sampo
Group has the ultimate responsibility to ensure thatSUSTAINABILITY REPORT 2023

18

Sampo Group has zero tolerance towards corruption
and bribery, and it expects its employees, customers,
suppliers, and other business partners to share the sameview.

In 2023, no incidents related to corruption or bribery
were reported at Sampo Group.

Reported corruption and bribery incidents
Sampo Group
2023

2022

2021

If

0

0

0

Topdanmark

0

0

0

Hastings000

Mandatum-00Sampo plc

000

Sampo Group, total

0

0

0

Introduction

Business management
and practices

Corporate
cultureIf
If’s One Responsible If learning programme includes an
e-course on ethics. The course reflects the content of
If’s Ethics policy and includes reading exercises, as wellas training on managing ethical dilemmas. The One
Responsible If learning programme is mandatory for all
If employees, and it is completed annually. In 2023,
approximately 94 per cent of all If employees, excluding
contingent workers and non-guaranteed hours
employees, completed the programme.

Topdanmark
In 2023, Topdanmark updated the company’s internal
guidelines for receiving gifts. In addition, the anticorruption policy was updated to adhere to the UN
Convention against Corruption. At Topdanmark, it ismandatory for all employees to pass a Code of Conduct
e-learning every second year. In 2023, 96 per cent of
Topdanmark’s employees passed the e-learning module
on anti-corruption.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

In 2024, Topdanmark will focus on communicating thecompany’s anti-corruption policy internally. In addition,
the company will evaluate if the current control
procedures stay in the divisional compliancedepartments or are moved to a centralised department.
Topdanmark will also update the module on anticorruption in the company’s Code of Conduct elearning.

Hastings
In 2023, Hastings conducted an annual review of its
Anti-Bribery and Corruption Policy. The Hastings Group
Conduct Policy, which carries a high-level commitment
to preventing and/or detecting bribery, corruption, andother forms of financial crime, was also refreshed during
the year.
In 2023, Hastings developed a new series of videos for
its employees. The videos include case studies,interviews with partnership agencies, and other content,

19

Appendices≡designed to create awareness of fraud, highlighting
what to look for across policies and claims, and to help
employees know what to do if they believe something isunusual. The series of videos will continue into 2024 aspart of a continuous effort against fraud.

Sampo plc
In 2023, Sampo plc updated the Sampo Group Code of
Conduct, which includes group level guidelines on anticorruption and bribery. All Sampo plc’s employees are
required to familiarise themselves with the Code of
Conduct upon employment, and after that, to take partin internal training every other year. The next internal
training is scheduled to be held in 2024. In 2022, 98 percent of the company’s employees participated in the
Code of Conduct training.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesAnti-money laundering and counter-terrorist financing
Sampo Group recognises that money laundering andterrorist financing are serious problems for society ingeneral, and financial institutions tend to be favoured
channels through which illicit money is laundered.
Robust and well-resourced operations to countermoney laundering and terrorist financing are criticalfactors in Sampo Group’s success.
A defence against money laundering is required by law,
but it also goes hand-in-hand with the insurance
business, in the sense of good risk selection. For P&C
insurance companies, being able to evaluate risks is at
the core of their business. For Sampo Group, the risk ofmoney-laundering and terrorist financing is considered
low overall.

Approach
The Sampo Group Code of Conduct and the Sampo
Group Guideline for Required Internal Procedures toPrevent Money Laundering and Terrorist Financing set
out the group level principles for anti-money launderingand counter-terrorist financing (AML and CTF) efforts.
In addition, Sampo Group has locally required controls
and procedures in place, and both mandatory andvoluntary training is offered annually to prevent the useof the company’s products and services for money
laundering and terrorist financing purposes. When
providing insurance services, Sampo Group follows theauthorities’ regulations and required due diligence toprevent money laundering and terrorist financing.

SUSTAINABILITY REPORT 2023

Customer databases are screened and updated
regularly to ensure accuracy of data and appropriate
record-keeping. In addition, Sampo Group’s appointed
specialists assess high-risk decisions and business
relationships separately.
In some countries, Sampo Group has a legal obligation
to know its customers (Know Your Customers, KYC),
which means that additional processes are necessary
when working with customers. These obligations are
based on legislation on the prevention of money
laundering, terrorist financing, and financial crime.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Sampo Group guideline to prevent money
laundering and terrorist financing and otheradditional information:www.sampo.com/sustainability/sustainablebusiness-management-and-practices/antimoney-laundering-and-counter-terroristfinancing

Group goals and ambitions
Sampo Group has zero tolerance towards money
laundering and terrorist financing, and it expects its
employees, customers, suppliers, and other business
partners to share the same view.

Actions and results
During 2023, Sampo Group reported to the authorities
a total of 271 suspicions of money-laundering or
terrorist financing related to customer transactions. All
suspicions were reported by If. This is due to the size ofthe company compared to the other Sampo Group
companies and the legislation in its operating countries.
In Finland and Norway, AML and CTF legislation applies
both to life and non-life insurance, whereas for example
in Denmark (Topdanmark’s market) and the UK(Hastings’ market), legislation is limited to life insurance.

Money laundering and terrorist financing
suspicions reported to the authorities
Sampo Group
2023

2022

2021

271

410

248

Topdanmark

0

3

3

Hastings0

10

Mandatum-

123

Sampo plc

0

0

0

271

426

254

If

Sampo Group, total

20

Introduction

Business management
and practices

Corporate
cultureIf
If’s One Responsible If learning programme includes an
e-course on AML and CTF. In 2023, approximately 94
per cent of all If employees completed the learning
programme. In addition, targeted employee groups are
required to undergo supplementary training related to
AML and CTF.

Topdanmark
According to Danish legislation, Topdanmark’s own
non-life insurance products and services are not subject
to the AML and CTF regulation. Therefore, the risk of
Topdanmark being misused for the purpose of money
laundering and/or terrorist financing is assessed aslimited.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Following the divestment of Topdanmark Liv Holding
A/S in 2022, Topdanmark promotes life insurance andpension products for Nordea Life Holding AB via a
distribution agreement, and is thus subject to the AML
and CTF regulation. During 2023, Topdanmark focusedon complying with the regulation, and having required
controls and processes in place to prevent money
laundering and terrorist financing related to the
distribution agreement. Topdanmark, for example,
provides mandatory training on AML and CTF to
employees who handle these products and services. In
2023, 99 per cent of those employees completed thetraining.

Hastings
During 2023, Hastings conducted an annual review of
its Anti-Money Laundering and Counter Terrorist
Financing Policy. The Hastings Group Conduct Policy,
which carries a high-level commitment to preventing
and/or detecting money laundering and other forms offinancial crime, was also refreshed during the year.

21

Appendices≡Hastings maintains ongoing monitoring andmanagement of appropriate controls for money
laundering and financial crime. In 2023, examples ofthese controls included mandatory annual AML training
for all employees, completion of the annual Financial
Crime Risk Assessment, and an external audit on the
Sanctions and Financial Crime Risk & Control
Framework.

Sampo plc
In 2023, Sampo plc updated the Sampo Group Code of
Conduct, which includes group level guidelines on antimoney laundering and terrorist financing. All Sampo
plc’s employees are required to familiarise themselveswith the Code of Conduct upon employment, and after
that, to take part in internal training every other year.
The next internal training is scheduled to be held in
2024. In 2022, 98 per cent of the company’s employees
participated in the Code of Conduct training.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Data privacy
Protecting customers and other stakeholders’ personal
data is of utmost importance for Sampo Group. The
insurance sector, which is a highly regulated industry, ischaracterised by a high amount of personal dataprocessing. Sampo Group can face business risks,
operational risks, and reputational risks if it fails tocomply with data privacy regulations and guidelines.

Approach
At Sampo Group, the guidance documents regarding
data privacy are the Sampo Group Code of Conduct
and the Sampo Group Data Privacy Statement, which
are both reviewed annually, and approved by the Boardof Directors of Sampo plc. In addition, each Group
company has adopted supplementary policies andguidelines for its own purposes, and has data privacy
frameworks or similar procedures that help create aculture of commitment to data protection. The
procedures include, for example, awareness-raising,reporting structures, screenings, impact assessments,
security measures, and data processing agreements.
At Sampo Group personal data is processed in a lawful,
fair, and transparent manner. The aim is to ensure thatthe privacy of the employer, employees, customers, andother stakeholders is not breached. Reporting on data
privacy is provided regularly to the CEOs and Board of
Directors of respective Sampo Group companies.
Sampo Group also has incident investigation andprocesses for corrective actions in place.
Sampo Group uses awareness-raising activities offeredto employees and contingent workers to prevent andmitigate user risk. Such activities include mandatory
data privacy training, refresher courses, data protection

SUSTAINABILITY REPORT 2023

impact assessment (DPIA) courses, and privacy bydesign and default courses. These activities help
employees and contingent workers understandappropriate data protection, and the risks associatedwith their actions. In addition, the intranet is a source of
information for all employees and contingent workers,
offering practical help, contacts, training, guidelines,
and information on data privacy processes andmethods.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Sampo Group Data Privacy Statement and otheradditional information:www.sampo.com/sustainability/sustainablebusiness-management-and-practices/dataprivacy
If Data Privacy Policy:
www.if-insurance.com/about-the-website/
handling-of-personal-data
Topdanmark Data Privacy Policy:
www.topdanmark.com/en/privacy-policy
Hastings Data Privacy Policy:
www.hastingsdirect.com/legal/privacynotice.shtml

When third parties handle personal data on Sampo
Group’s behalf, it is done in accordance with applicabledata protection laws, and Sampo Group enters into a
data processing agreement (or similar). The agreement
22

states how suppliers and, if applicable, sub-suppliers
shall handle Sampo Group’s data. Third-party dataprocessors are assessed regularly.

Group goals and ambitions
The goal of Sampo Group’s data privacy operations isto protect employees, customers, and otherstakeholders’ personal data.

Actions and results
During 2023, Sampo Group received a total of 4,131
requests from data subjects. During the year, six
complaints were received from data protection
authorities and 197 from data subjects. The complaints
from data protection authorities were mainly customer
complaints filed directly with the authorities or
responses to requests for clarification. The increase incomplaints from data subjects is primarily due to thedata subjects’ overall greater awareness and knowledgeof their rights.
In 2023, human and technical errors were identified asroot causes for the majority of the 167 data breaches
reported to the authorities. Data subjects and dataprotection authorities were notified accordingly, andappropriate measures were taken to resolve theincidents, such as a change in procedures or a reminderof due care. Even though there is a great focus on dataprotection and related management systems, humanand technical errors can be difficult to avoid completely.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Requests from data subjects
Sampo Group
Right of access

2023

2022

2021

3,550

2,433

1,975

Right to rectification

11

3

12

465

583

508

Right to restrict processing

0

59

0

Right to data portability

0

1

0

105

32

79

Right of erasure

Right to object*
Right not to be subject to a decision based solely on automated processing

0

0

0

4,131

3,111

2,574

2023

2022

2021

197

119

60

6

9

18

2023

2022

2021

167

175

175

Number of requests from data subjects, total
Mandatum is included in 2021 and 2022 figures.
* Topdanmark is not included in 2021–2023 figures, as data was not available.

Complaints from data subjects and data protection authorities
Sampo Group
Number of complaints from data subjects
Number of complaints from data protection authorities
Mandatum is included in 2021 and 2022 figures.

Data breaches reported to local data protection authorities
Sampo Group
Number of data breaches reported to local data protection authorities
Mandatum is included in 2021 and 2022 figures.

SUSTAINABILITY REPORT 2023

23

Appendices≡Introduction

Business management
and practices

Corporate
cultureIf
In 2023, If’s Data Protection Office continued toenhance data protection within the company by raisingawareness, providing training, giving advice on DPIA,and monitoring compliance with data protection rules
and principles. If’s data privacy e-course, which is partof the One Responsible If learning programme, was also
updated based on feedback and identified needs fordeveloping employee awareness.
During the year, the Data Protection Office monitored
all processing activities relating to personal data, andensured they were transparent, duly documented, andrespected the rights and privacy of customers andemployees. Other activities included advising andsupporting functions and projects on the principles ofprocessing personal data, as well as ensuring theinterpretation or application of the processing
principles. In addition, the Data Protection Officecontinued to ensure that, when necessary, personal
data breaches are reported without delay to the
Swedish Data Protection Authority, as well as ensuringthat If takes appropriate measures to resolve any such
incidents.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Topdanmark
In 2023, Topdanmark updated the company’s Principles
for Data Ethics, and combined the updated principles
with the Principles for Ethical Artificial Intelligence (AI).
Topdanmark wants to ensure that AI is reliable, basedon facts, and represents a diverse group of customers.
During the year, Topdanmark improved its data
handling processes. The company uses automatedprocesses and machine learning when serving
customers and, therefore, securing data is a top priority.

Appendices≡In 2023, subject access requests at Hastings reached an
all-time high, driven by increased awareness of dataprotection rights, and challenging economic conditions.
Despite this, Hastings responded to all requests within
the regulatory deadline. Internal breach reporting has
also risen, attributed to increased awareness rather thanan increase in security incidents.
As at 31 December 2023, 96 per cent of Hastings’
employees had completed the mandatory training ondata privacy.

Sampo plc

Hastings
During 2023, Hastings continued to embed dataprotection within the business, exceeding its
Information Commissioner’s Office (ICO) Accountability
Framework target set for 2023. The frameworkprovided a basis for internal assessments of the key
data protection processes, highlighting any areas for
improvement, and ensuring continued compliance in all
operations.

24

During 2023, Sampo plc monitored the erasure of
unnecessary personal data, and focused on updating
and improving documentation related to data privacy.
Moreover, employee awareness of the company’s data
privacy obligations was further increased by training
personnel. Going forward, Sampo plc will continue toraise employee awareness of data privacy matters bysystematic communication and training.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesInformation security and cybersecurity
It is of paramount importance to Sampo Group that thelevel of information and cybersecurity is adequate forthe nature and scope of the business and the generallevel of technical development, and that it corresponds
to the level generally expected from a financial
company. Sampo Group is exposed to information
security and cybersecurity risks due to the high quantityof sensitive data the companies handle, and due tooperations in countries with strict data protection
regulations. It is important to address these risks toensure that customers and other stakeholders’ data isalways protected, and that operations can continue
without disruption.

Approach
The group level guidance documents regarding
information security and cybersecurity are the Sampo
Group Code of Conduct and the Sampo Group
Information Security Principles, which are both
reviewed annually and approved by the Board of
Directors of Sampo plc. In addition, each Group
company has adopted supplementary policies andguidelines for its own purposes.
Sampo Group performs regular risk analyses, conducts
continuity planning, and has effective internal
processes, high-quality systems, and infrastructure to

SUSTAINABILITY REPORT 2023

ensure information security and cybersecurity
preparedness. Sampo Group measures theirperformance regularly and is committed to continuous
development. At Sampo Group, the requirements inrelation to information security and cybersecurity areset, and expected to be met by both internal andexternal stakeholders (e.g. third-party data processors).
All Sampo Group employees must adhere to theapplicable information security and cybersecurity
standards by following internal rules and guidelines,
using appropriate tools, and acting responsibly. Sampo
Group provides both mandatory and voluntary training
to all employees and contingent workers. This includes,for example, e-learning, in-person sessions, simulations,and intranet articles.

Group goals and ambitions
Sampo Group’s goal is to protect all types and forms of
information according to its sensitivity and importanceto Sampo Group, and in compliance with applicable
rules and regulations.

Actions and results
Sampo Group is required to report major information
security incidents to the local authorities annually andon an ad-hoc basis. During 2023, no incidents werereported.

Information security and cybersecurity
incidents reported to the authorities
Sampo Group

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Sampo Group Information Security Principles
and other additional information:www.sampo.com/sustainability/sustainablebusiness-management-and-practices/
information-security-and-cybersecurity

25

2023

2022

If

0

1

2021
1

Topdanmark

0

0

0

Hastings000

Mandatum-00Sampo plc

000

Sampo Group, total

0

1

1

Introduction

Business management
and practices

Corporate
cultureIf
In 2023, If’s focus area regarding information security
was the EU’s new Digital Operational Resilience Act(DORA). If strengthened the company’s digital security
and resilience, particularly in the areas of workstationand server security, identity and access management,
security anomaly detection and threat intelligence
security testing, and IT continuity planning. If ran
several crisis simulations with various parts of thebusiness organisation, and disaster recovery tests with
the IT organisation. This has further strengthened If’s
capability to detect, mitigate, and respond to cyberthreats.

Topdanmark
In 2023, Topdanmark began to prepare for the
implementation of the DORA, which the company mustcomply with starting January 2025.
In October 2023, Topdanmark had its first-evercybersecurity month, which included games andquizzes for all employees to raise awareness on
cybercrime. In addition, 90 per cent of the company’s
employees completed a mandatory training on
information security. During the year, Topdanmark also
launched a security awareness programme, which trains
employees in detecting phishing emails and othermalware.
In 2024, Topdanmark will continue to strengthen its
processes and management related to information
security and cybersecurity. This includes, for example,

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

the implementation of the requirements brought on by
the DORA, and the focus on increasing company-wideawareness on cybersecurity using the new tools andprocesses.

Hastings
Throughout 2023, Hastings continued to invest in its
programme for information security and cybersecurity
resilience. This included enhancements to cyber
resiliency awareness and training platforms, and theintroduction of a crisis simulation platform. Hastings
also updated its information security management
system based on assessed control maturity against the
ISO 27002:2022 standard.
Hastings information security controls and programme
are audited annually by an external audit partner. The
most recent audit was focused on the alignment ofHastings’ controls to the UK National Cyber Security
Centre (NCSC) guidance on Malware and Ransomware
protection. No critical or major findings were found as aresult of this audit.
In 2023, in context of the cyber threat landscape andevolving geopolitical situations, Hastings maintained aheightened state of security awareness in line with the
UK National Cyber Security Centre (NCSC) guidance.
The company also continued to play an active part in
UK regulator sponsored cyber co-ordination bodies,such as the FCA sponsored Insurance Sector Cyber Coordination Group (ISCCG), and the Bank of Englandsponsored Cross Market Operational Resilience Group(CMORG).

26

Appendices≡

Sampo plc
In 2023, Sampo plc focused on the continuity of
information systems and business, as well as the data
security of applications, as geopolitical instability
continued. Several improvements were made to theprotection of servers and workstations, identity andaccess management, detection and response to cyberattacks, and resilience to large-scale cyber-attacks.
Sampo plc also increased its efforts in information
security testing.
During the year, Sampo plc updated its employee
onboarding materials related to information security
and cybersecurity. Advanced phishing email simulations
targeting all employees were also continued as part ofthe company's cybersecurity training programme.
In 2023, Sampo plc strengthened the existing incident
monitoring measures, including the monitoring of
network traffic, privileged access rights, businesscritical services, and system redundancies. In addition,
the process for responding to information security andcybersecurity incidents was improved by acquiring newservices that support the process.
During 2023, Sampo plc migrated to a modern and amore energy-efficient data centre as part of IT
infrastructure lifecycle updates.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Human rights and labour practices
For Sampo Group, managing human rights is not only
about doing the right thing and obeying the law, butalso about protecting the bottom line. Failure to identify
and respond to human rights issues can lead to, forexample, legal action, investor divestment, reputation
damage, and financial loss. The risk of human rights
violations may arise directly from the Group’s own
operations or indirectly from customers, investments,
and/or supply chains, for example.

Approach
The group level guidance document regarding humanrights 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 isalso a signatory of the UN Global Compact, which
supports work on human rights. In addition, each Group
company has adopted supplementary policies andguidelines for its own purposes. Sampo Group iscommitted to continuous development of policies andprocesses related to human rights, including conducting
human rights due diligence, applying the precautionary
principle, and taking remedy. In addition to employees,
communication of human rights-related policy
commitments to different stakeholders is done, forexample, through training, the intranet, contractual
discussions, questionnaires, audits, and site visits.

Employees
In Sampo Group’s own operations, human rights
violations may arise, for example, in discrimination andfrom lack of equal opportunities. Sampo GroupSUSTAINABILITY REPORT 2023

employees have a responsibility to comply with thecompany’s human rights policies, and take part inmandatory and voluntary training that include humanrights topics and/or modules.
Sampo Group strives for a constructive and trustfuldialogue with employees and their elected
representatives, such as unions, with the purpose ofdeveloping the company and safeguarding the correct
treatment of all employees. Sampo Group respects
employees’ freedom of association, and the company’sbusiness processes are designed to ensure equal
treatment regardless of unionisation, based on
employees’ constitutional rights. All employment
conditions, whether they are covered by a collective
agreement or not, are largely regulated by local labour
legislation and apply to all employees. Upon changes in
the organisation, union members are informed and/or
consulted accordingly.

Customers
Sampo Group has integrated ESG considerations into
underwriting standards and customer due diligenceprocess for corporate clients. The frameworks are
based on the UN Global Compact principles and cover,for example, human and labour rights. To assess
whether corporate clients respect the principles of the
Global Compact, Sampo Group utilises research byexternal service providers.
In terms of all customers, data breaches and misuse ofcustomer information may result in human rights
violations. Sampo Group has stringent policies and27

processes to ensure that all collected data is protected
through data privacy and information security
measures, and adequate employee training.

Suppliers and other business
partners
Sampo Group is committed to encouraging suppliers
and other business partners to respect and comply withhuman rights. This is communicated, for example, in the
Sampo Group Code of Conduct, which suppliers andother business partners are encouraged to adopt.
Furthermore, the Group companies have more specificpolicies on these matters for their own suppliers (e.g.
supplier codes of conduct).

Investments
Sampo Group has responsible investment policies,
which guide responsible investment. Sampo Group
screens investments against international norms andstandards, including those related to human rights.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Additional information:www.sampo.com/sustainability/sustainablebusiness-management-and-practices/humanrights-and-labor-practices

Introduction

Business management
and practices

Corporate
cultureGroup goals and ambitions
Sampo Group aims to respect and protect human rights
throughout its operations.

Actions and results
During 2023, there were no reported human rights
incidents at Sampo Group. This refers to any severe
violations of human rights and labour rights legislation.
In 2023, there were eight reported incidents of
discrimination and harassment at Sampo Group. All
incidents were investigated, with necessary corrective
actions initiated already during the reporting year (e.g.
verbal warning). The majority of cases were solved in
2023.
As at 31 December 2023, 66.1 per cent of Sampo
Group’s employees were covered by collective
bargaining agreements. The figures include only
employees who are fully covered by collective
agreements. In addition, at If, Topdanmark, and Sampo
plc, the agreement applies to most employees’ (e.g.
excluding top management) terms of employment,even if they are not covered by the agreement. Hastings
does not formally recognise a trade union, preferring tocommunicate and engage with employees directly,
either through the Hastings Colleague Forum (HCF),
through the YourVoice employee survey, by email andintranet, and/or directly with individual employees, as
appropriate. Trade union membership is not, however,prohibited, and the company does not restrict union
representation at a grievance or disciplinary meeting,should any employee request it. The company also
compares the terms of employment to market practices
at regular intervals.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Number of internally reported humanrights incidents≡

Appendices

Employees covered by collective
bargaining agreements by company

2023

2022

2021

If

0

0

0

Topdanmark

0

0

0

Hastings000

Mandatum-00Sampo plc

000

Sampo Group, total

0

0

0

%

31 Dec.
2023

31 Dec.
2022

31 Dec.
2021

If

85.5

85.5

86.4

Topdanmark

96.3

96.9

96.5

Hastings

0.0

0.0

0.0

48.7

48.9

Mandatum-

Sampo plc
Sampo Group

66.1

66.1

Employees covered by collective
bargaining agreements by country

Number of internally reported incidents
of discrimination and harassment

Sampo Group

2023

2022

2021

If

4

5

0

Topdanmark

3

2

0

Hastings

100

Mandatum-00Sampo plc

000

Sampo Group, total

8

7

0

In 2022, the reporting was broadened to include reported casesof harassment.

%

31 Dec.
2023

31 Dec.
2022

31 Dec.
2021

Sweden

99.4

99.5

99.6

Denmark

96.2

96.9

96.6

Norway

99.8

96.0

96.3

Finland

89.1

79.5

81.8

Baltic countries

17.3

18.7

18.7

United Kingdom

0.0

0.0

0.0

Other countries

87.8

83.4

78.3

Mandatum is included in 2021 and 2022 figures.

28

66.5

Introduction

Business management
and practices

Corporate
cultureIf
If’s One Responsible If learning programme includes an
e-course on ethics, which reflects the content of If’s
Ethics policy, and includes topics on human rights andlabour practices. The learning programme is mandatory
for all If employees and completed annually. In 2023,
approximately 94 per cent of If employees completed
the programme.
If has integrated the principles of the UN Global
Compact into its underwriting standards. This meansthat the company assesses its corporate clients toensure they comply with these principles. During 2023,
If assessed 772 corporate clients. In total, 12 cases werereferred to If’s ESG assessment team for further
assessment. During the year, three clients improved
their rating and, therefore, are no longer referral cases.
If developed a due diligence process for its suppliers inaccordance with the OECD Guidelines for Multinational
Enterprises in 2022. During 2023, If continued tointegrate the process into its purchasing processes. In
addition, If developed and implemented more detailed
instructions for the due diligence process. In 2023, If
also started the implementation of a digital tool that will
support the due diligence process. The tool is already in
use and will gradually be implemented in all units thatpurchase products or services.
If has a self-assessment questionnaire (SAQ) in place, aspart of the due diligence process for suppliers andbusiness partners, for assessing suppliers’ compliancewith If’s Supplier Code of Conduct. More information on
the SAQ and the due diligence process can be found in
this report’s section Sustainable supply chain
management.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Topdanmark
In 2023, Topdanmark’s focus was especially ontransgressive behaviour. The company prepared a new
set of guidelines on transgressive behaviour that outline
the different aspects of such behaviour (e.g.
discrimination, bullying, unwanted sexual attention, andharassment), and underline Topdanmark’s zerotolerance stand on it. In addition, Topdanmark added a
new module on transgressive behaviour in the
mandatory e-learning on the Code of Conduct. Allexisting employees must pass the e-learning every
second year, and new employees within the first threemonths of employment.
In 2023, Topdanmark started to prepare for the EU’s
Corporate Sustainability Due Diligence Directive(CSDDD), even though it is not clear how financial
institutions will be impacted by it. The implementationof the CSDDD builds on Topdanmark’s existing
framework and current due diligence processes.

Hastings
Hastings listens to and engages with its employees
through its intranet, bi-annual employee engagement
survey, roadshow events, and day-to-day performance
conversations. The company takes employee feedback
seriously, responding to and acting on points raised
throughout the year, with a summarised ‘you said, we
did’ communication published at the end of the year.
Changes made as a result of employee feedback in
2023 include the continuation of the Leading for
Growth leadership programme for the wider leadershipcommunity, and increased funds for the colleague
hardship fund, including a partial advance on the 2024
annual bonus award for employees beneath a specified
earnings threshold.

29

Appendices≡

During 2023, the HCF Representatives continued to
advocate on matters they know are important toemployees. This includes issues relating to site facilities.
During 2023, HCF was also closely involved in the full
review of Hastings’ employee policy suite.
In 2023, Hastings prepared for the increasing legislation(e.g. CSRD) related to human rights and labour
practices, by conducting a current state analysis, forexample.
Hastings has a sustainable supply chain strategy andthe company intends to implement a Supplier Code of
Conduct in 2024.

Sampo plc
In 2023, Sampo plc conducted a group-wide humanrights impact assessment to prepare for future
legislative requirements, and to further strengthen
human rights-related governance and processes (e.g.
due diligence). The work will be finalised in early 2024.
In November 2023, Sampo plc updated the Sampo
Group Code of Conduct, which includes group levelguidelines on human rights. All Sampo plc’s employees
are required to familiarise themselves with the Sampo
Group Code of Conduct upon employment, and to takepart in internal training every other year. The next
internal training is scheduled to be held in 2024. In
2022, 98 per cent of the company’s employees
participated in the Code of Conduct training.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Environmental impacts of group operations
Sampo Group is committed to protecting theenvironment and combatting climate change. Sampo
Group can face reputational risks, legal risks, businessrisks, and potential costs if it fails to take climate,environmental, and biodiversity considerations into
account in its operations.
As an insurance group, Sampo Group does not cause
large amounts of GHG emissions directly. However, thecompany can face the consequences of climate change
in the form of unpredictable and extreme weather,which can impact business as an increased risk and apotential rise in claims costs. By reducing direct GHG
emissions, Sampo Group contributes to the goal of
limiting global warming.

Approach
Sampo Group supports the Paris Climate Agreement
and has set targets to reduce its direct GHG emissions.
Furthermore, Sampo Group wants to promote a green
workplace in which all employees can participate andtake responsibility.
The group level guidance document regarding climate,environment, and biodiversity is the Sampo Group Codeof Conduct, which is reviewed annually and approvedby the Board of Directors of Sampo plc. In addition,
each Group company has adopted supplementarypolicies and guidelines for its own purposes. The work isalso driven by the commitments to the SBTi andinvolvement in various initiatives (e.g. UN Global
Compact) and reporting requirements (e.g. TCFD), as
well as stakeholder demand.

SUSTAINABILITY REPORT 2023

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Sampo Group TCFD reporting:www.sampo.com/sustainability/climate-andenvironment
If TCFD reporting:www.sampo.com/year2023
Topdanmark TCFD reporting:
www.topdanmark.com/en/sustainability/
sustainability-in-topdanmark/reports/?
category=TCFD-reports

Group goals and ambitions
Sampo Group is committed to reducing theenvironmental and climate impacts of its own
operations. Sampo joined the SBTi in October 2023.
Group level SBTs are being developed in 2024 and will
be submitted to the SBTi for validation by October
2025 at the latest.

Actions and results
In 2023, Sampo Group’s total GHG emissions from its
own operations were 23,411.3 tonnes, which equals 1.8
tonnes per employee. Scope 1 emissions were 4.5 percent (6.0), Scope 2 emissions were 15.3 per cent (21.6),
and Scope 3 emissions were 80.2 per cent (72.3) of thetotal. Most of the emissions originated from employee
commuting and remote working, business travel, andelectricity.
30

Overall, Sampo Group’s GHG emissions increased by 8.7
per cent in 2023. The increase was due to higher Scope
3 emissions compared to the previous year. The main
reasons for higher Scope 3 emissions were a change inthe methodology for calculating emissions for remote
working in UK locations, and improved data collection
for purchased goods and services. Both Scope 1 and 2
emissions decreased during the year, as a result ofemissions reduction efforts related to company cars
and the use of renewable energy. The demerger of
Mandatum also impacted the results.
During the year, Sampo Group continued to improvedata collection and align group level reporting. For
example, Topdanmark included two new Scope 3
categories in its reporting, If increased its operationalboundary, and Hastings developed reporting in thepurchased goods and services category. In addition,
reporting on IT equipment was aligned, with all Group
companies now reporting under capital goods, insteadof purchased goods and services.
In 2023, data for 2022 was amended for all Group
companies due to errors in data collection, and arecalculation of If’s emissions to align with SBTi
requirements. In total, the changes amounted to a 3.4
per cent increase in Sampo Group’s GHG emissions forthe year 2022.
A complete set of environmental data is available inAppendix 2: GHG emissions.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices

GHG emissions by scope

Source of GHG emissions

Sampo Group

Sampo Group, 2023

tCO2e

2023

2022

2021

Change2023/2022, %-18.3

Scope 1: Direct GHG emissions

1,059.8

1,297.9

1,867.9

Scope 2: Indirect GHG emissions

3,585.3

4,663.5

2,458.5-23.1

Scope 3: Other indirect GHG emissions

18,766.3

15,581.2

6,314.9

20.4

Scope 1–3 GHG emissions, total

23,411.3

21,542.6

10,641.3

8.7

1.8

1.6

0.9

9.0

2022

2021

Change2023/2022, %-2.6

GHG emissions per employee

2022 figures were updated due to errors in reporting and a recalculation of If’s GHG emissions toalign with SBTi requirements. The changes increased Sampo Group’s total emissions by 702.5
tCO2e in 2022.
2022 figures include Topdanmark Liv Holding A/S, which was divested in December, 2022.
Mandatum is included in 2021 and 2022 figures.

GHG emissions by company
tCO2e

2023

If

10,856.4

11,151.2

3,638.0

Topdanmark

7,807.6

7,612.7

5,471.5

2.6

Hastings

4,472.1

1,762.0

943.8

153.8

Mandatum

-

848.7

508.7

-

Sampo plc

275.2

168.1

79.2

63.7

23,411.3

21,542.6

10,641.3

8.7

Sampo Group, total

2022 figures were updated due to errors in reporting and a recalculation of If’s GHG emissions toalign with SBTi requirements. The changes increased Sampo Group’s total emissions by 702.5
tCO2e.
2022 figures include Topdanmark Liv Holding A/S, which was divested in December, 2022.

SUSTAINABILITY REPORT 2023

31≡

Introduction

Business management
and practices

Corporate
cultureIf
Goals and ambitions
If committed to the SBTi in October 2021 andprogressed to develop SBTs in accordance with the
SBTi sector-specific guidelines for the financial sector.
The guidelines require If to set targets for directemissions from owned or controlled sources (Scope 1),
indirect emissions from the generation of purchased
electricity, heating, steam, and cooling (Scope 2), andinvestment activities (Scope 3). In addition, If decided
to set a voluntary climate target for its supply chain.
Following the commitment, If had 24 months todevelop targets, and submit them to the SBTi forvalidation. The validation process started in August
2023, and If’s targets were approved by the SBTi in
December 2023.
Regarding its own operations, If commits to reduce
absolute Scope 1 and Scope 2 GHG emissions 42.5 percent by 2030 from a 2020 base year. Information on
targets related to investment activities is in this report’s
section Investment management and operations, andinformation on the voluntary target for the supply chain
in the section Sustainable supply chain management.

Investment management
and operations

Products
and services

Communities

In 2023, If had a business travel target of reducing thetotal number of flights by 50 per cent compared to the2019 level. For 2024, If will have the same target, i.e. toreduce the number of flights by 50 per cent compared
to 2019.

Actions and results
GHG emissions
In 2023, total GHG emissions from If’s own operations
were 10,856.4 tonnes. Scope 1 emissions were 1.3 percent (1.6), Scope 2 emissions were 9.5 per cent (17.1),
and Scope 3 emissions were 89.2 per cent (81.4) of thetotal. In 2023, most of If’s GHG emissions arose frombusiness travel, employee commuting, and IT
equipment, with 37.6 per cent (32.6), 32.9 per cent(31.0), and 12.8 per cent (11.2), respectively.
In 2023, If’s Scope 1 emissions decreased by 22.3 percent and Scope 2 emissions by 45.7 per cent. The Scope
1 and Scope 2 emissions are linked to the company
vehicles and energy use in the offices in the Nordics andBaltics, including subsidiaries.

GHG Emissions
If
tCO2e

2023

2022

2021

Change2023/2022, %Scope 1: Direct GHG emissions

136.6

175.8

77.2

-22.3

Scope 2: Indirect GHG emissions

1,033.8

1,903.2

281.9

-45.7

Scope 3: Other indirect GHG emissions
Scope 1–3 GHG emissions, total
GHG emissions per employee

9,686.1

9,072.3

3,278.9

6.8

10,856.4

11,151.2

3,638.0

-2.6

1.4

1.5

0.6

-10.1

2022 figures were updated due to errors in calculations and a recalculation of GHG emissions toalign with SBTi requirements. The changes increased If’s total emissions by 841.2 tCO2e andemissions per employee by 0.1 tCO2e in 2022.

SUSTAINABILITY REPORT 2023

32

Appendices≡

If’s facility management strategy and company vehicles
instruction already include several features, which willcontribute to meeting the company’s new SBTs. For
example:• In 2023, solar panels were installed at If’s office inVækerø, Norway. In 2024, solar panels will be
installed at If’s headquarters in Stockholm, Sweden.
• As of 2023, all district heating purchased for the If
office in Espoo, Finland is produced from renewablesources.
• The share of company vehicles in the Nordics, which
are plug-in hybrids or electric vehicles (EV), increased
from 39 per cent in 2020 to 77 per cent in 2023.
In 2024, If will further develop its approach and strategy
for reaching its Scope 1 and Scope 2 targets.

Introduction

Business management
and practices

Corporate
cultureIf’s business travel target for 2023 was to reduce thetotal number of flights (excluding Baltic operations) by
50 per cent compared to the 2019 level, which was thelast ordinary travel year before the COVID-19 pandemic.
The total number of flights taken in 2023 was 11,191. The
target was not achieved as the number of flights was
34.5 percent lower than the 2019 level. This was mainly
due to 2023 being the first full year of travelling since2019 without COVID-19 restrictions, and a backlog
regarding physical meetings. Improving the possibilities
for digital meetings is seen as an important factor insupporting the company’s travel policy. At the end of2023, If had more than 350 Teams-compatible rooms in
the Nordic countries. In 2023, more than 38,000 Teams
meetings were organised every month.
Employee training
One of the topics covered by the One Responsible If
learning programme is sustainability, including climate

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

and environmental matters. As at December 2023,
approximately 94 per cent of all employees hadcompleted the programme.
Sustainable offices
If does not own any of its office buildings (except for If
Security Centre’s office and the training building in
Hobøl, Norway), but it is in continuous dialogue with its
landlords on how to improve the offices’ environmental
performance and work environment. Examples of
discussion topics and measures used include optimising
office space, upgrading ventilation systems,
thermostatic control, installing LED lighting, andreducing waste.
Since 2019, If has had minimum environmental
requirements for its major offices (i.e. offices with morethan 100 employees) in the Nordic countries. In 2023, If
raised the ambition level and created a new

33

Appendices≡environmental standard for all its offices. The standard
defines concrete measures, targets, and guidance on
topics such as office supplies, canteen operations,energy efficiency, greening of rental agreements, andreducing waste. If is currently mapping the present
status, and the new standard will serve as a baseline forsecuring environmentally friendly operations.
In 2023, If also focused on the sustainability of its Baltic
offices, with the renovation of the office in Riga as ahighlight. As a result of a cooperation with the landlord,
the Riga office increased the share of green energy
used, introduced recycling stations, redesigned old
furniture, and installed intelligent lighting, for example.

Introduction

Business management
and practices

Corporate
cultureTopdanmark
Goals and ambitions
In 2019, Topdanmark set a goal to become carbon
neutral in 2030. This includes the operations of thecompany locations (Scope 1 and Scope 2), company
driving in privately owned cars, air travel, water, andwaste (Scope 3).
In June 2022, Topdanmark joined the SBTi and its NetZero Standard. This means that it is mandatory for thecompany to set SBTs targets for the direct emissions
arising from the company’s own operations (Scope 1
and Scope 2), as well as for the company’s investments(Scope 3). Topdanmark will submit its targets to theInvestment management
and operations

Products
and services

Communities

SBTi for validation no later than the end of May 2024.
Topdanmark will use 2022 as the baseline year fortarget setting, which means that GHG emissions will berecalculated to exclude the sold Topdanmark life andpension business.

Actions and results
GHG emissions
In 2023, the GHG emissions of Topdanmark’s own
operations were 7,807.6 tonnes. Scope 1 emissions were
9.6 per cent (11.6), Scope 2 emissions were 29.4 percent (33.3), and Scope 3 emissions were 60.9 per cent(55.0) of the total. Most of Topdanmark’s GHG
emissions arose from electricity and business travel,with 29.4 per cent (33.3) and 21.9 per cent (22.0),
respectively.

GHG Emissions
Topdanmark
tCO2e

2023

2022

2021

Change2023/2022, %Scope 1: Direct GHG emissions

752.8

886.5

1,458.3-15.1

Scope 2: Indirect GHG emissions

2,297.5

2,538.0

2,019.8-9.5

Scope 3: Other indirect GHG emissions

4,757.3

4,188.2

1,993.4

13.6

Scope 1–3 GHG emissions, total

7,807.6

7,612.7

5,471.5

2.6

3.6

3.2

2.3

13.0

GHG emissions per employee

Scope 2 figure for 2022 was updated due to an error in emission factors. The change reduced Topdanmark’s
GHG emissions by 99.5 tCO2e and GHG emissions per employee by 0.04 tCO2e in 2022.
2022 figures include Topdanmark Liv Holding A/S, which was divested in December, 2022.

SUSTAINABILITY REPORT 2023

34

Appendices≡2023 saw some reductions in Scope 1 and 2 emissions, a
result of increasing the share of electric vehicles in the
car fleet, and optimising ventilation and lighting
settings. Scope 3 emissions increased due to theinclusion of two new emission sources, remote working
and downstream leased assets, as well as an increase inpurchased IT equipment. In addition, Topdanmark
included purchased plastic items in the inventory for thepurchased goods and services category, and travel bytrain and ferry in the business travel category.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Topdanmark
Action plan

Operation of the company’s buildings• A step-by-step plan for 2021–2025: Includes
phasing out natural gas, concrete optimisation
actions, and a shift to carbon-neutral electricity.
• Optimisation of the cooling system: Expected tolead to a GHG emission reduction of
approximately 110 metric tonnes.
• Shift to LED lighting: All light bulbs changed to
LED bulbs on an ongoing basis.

Appendices≡Sustainable offices
Topdanmark has two main goals when it comes to sustainable offices: reduction of
single-use plastic items and paper consumption. In addition, the company has otherenvironmental considerations that it monitors closely.

• Reduction of driving: Hybrid workplace and useof digital collaboration tools.
Use of company cars (Topdanmark has • Transition to low-emission cars: A gradualleased approximately 100 cars)transition to hybrid or electric vehicles.

In 2023, the amount of single-use plastic items was more than 133,000 items. Thismeans that Topdanmark was not able to reduce its plastic consumption. The reason isthat during 2018–2021, which was the period for which Topdanmark first set its target,
the company reduced consumption with more than 90 per cent. In 2021, the company
set a new baseline based on the 2021 result. However, this baseline has proven to bedifficult to surpass. Certain single-use plastic items cannot be avoided, and may evenbe required by legislation in the canteens, bathrooms, and waste-sorting, for example.

• Reduction of driving: Hybrid workplace andcontinued use of digital customer meetings, andintroduction of digital tools for inspections ofproperties and buildings in connection withmaking an insurance contract or after a claim.
• Shift to low-emission cars: Yet to find a model
Use of private cars for business travel
for the transition to low-emission cars for(primarily business-related driving inprivately owned cars, because the company has
privately owned cars by the company’s little influence on the choice of cars. The work
salespeople and claims adjusters)
continues in the years to come.
Air travel (primarily external IT
developers employed by Topdanmarkin connection with different projects,
travel to investor meetings, otherbusiness meetings and conferences,
etc.)

Communities

Carbon neutrality
In 2023, Topdanmark continued to work on concrete actions to become carbon
neutral by 2030. The planned actions so far are listed in the table Actions leading tocarbon neutrality.

Actions leading to carbon neutrality
Focus area

Products
and services

However, the long-lasting focus on reducing plastic items has evolved into a wish to
reduce all single-use items, regardless of the material. As an example, since 2020, thewelcoming gift for new employees has been a cup and a reusable water bottle. As aresult, Topdanmark saw a 67 per cent reduction in single-use cups from 2019 to 2021,
and today the company does not have single-use coffee cups in any of its offices.

• Reduction of air travel: Hybrid workplace anduse of digital platforms.

In 2023, paper consumption also increased by 27 per cent from 2022. The primarycause for the increase is the use of envelopes and standard printing paper. The digital
workplace is becoming a natural way of working, and Topdanmark emphasises digitalsolutions, however, there is still a need for physical mail.

SUSTAINABILITY REPORT 2023

35

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Topdanmark
Baseline 2023

70 per cent reduction insingle-use plastic items by
2025

2022

2021

133,395
77,52675,188purchased units purchased units purchased units

50 per cent reduction in
paper consumption by
2025

2021

11.7 tonnes

9.2 tonnes

2021

12.7 tonnes

Other environmental considerations

Waste

IT equipment (sold forrecycling or responsible
scrap)

2022

2021

37 per cent of all
waste wasrecycled.

38 per cent of all
waste wasrecycled.*

33 per cent of all
waste wasrecycled.

58 per cent of all
waste from theheadquarters wasrecycled.

41 per cent of all
waste from theheadquarters wasrecycled.

38 per cent of all
waste from theheadquarters wasrecycled.

9,161 kg

7,924 kg

2,227 kg

Bicycles (donated for reuse) 149 pcs

109 pcs

133 pcs

Disposable paper cups
(reduction compared to2019)

70 per cent67 per cent-* Figure has been corrected in this report, as there was an error in the 2022 report (39 per cent).

SUSTAINABILITY REPORT 2023

Appendices≡In 2022, WorkGreener saw that 91 per cent of employees felt important that
Topdanmark works to support the climate and the environment, however, only 45 percent felt capable of making climate or environmentally friendly choices at work. This
result spun a line of activities during 2023. Examples included setting up a
WorkGreener email address where all employees can send suggestions or wishes,organising a Green Week, where sustainable life hacks and steps to reduce the carbon
footprint were in focus, and creating a new setup for carpooling.

Topdanmark
2023

Communities

WorkGreener community
Topdanmark has an internal community for a green workplace called WorkGreener.
The community consists of nine representatives, one from each organisational division.
WorkGreener is responsible for developing new internal initiatives and solutions that
support the targets Topdanmark has set for the workplace, such as reducing energy
consumption and GHG emissions, as well as paper consumption and single-use plastic
items. The representatives of WorkGreener communicate the work and initiatives fromWorkGreener to their organisational division, and ensure that the solutions take root in
the organisation. In addition, they gather ideas from colleagues and bring them back to
the community.

Sustainable procurement of office supplies
Goal

Products
and services

36

Introduction

Business management
and practices

Corporate
cultureHastings
Goals and ambitions
Hastings’ goal is to be a net-zero organisation by 2050,
demonstrated by the company’s commitment to the
SBTi in August 2022. Whilst Hastings develops its
targets in line with the SBTi, an interim target has been
set to reduce the carbon footprint of own operations by
10 per cent year on year from its 2022 baseline.

Actions and results
GHG emissions
In 2023, Hastings’ overall GHG emissions were 4,472.1
tonnes. Scope 1 emissions were 3.7 (10.6) per cent,Scope 2 emissions were 5.5 (5.8) per cent, and Scope 3
emissions were 90.8 (83.6) per cent of the total. Most of
Hastings’ total GHG emissions arose from remote

Investment management
and operations

Products
and services

Communities

working and purchased goods and services, with 38.3
per cent (23.8) and 30.7 per cent (34.7), respectively.
Emissions from remote working increased significantly
due to a change in methodology to align calculations
for UK locations with the Streamlined Energy andCarbon Reporting (SECR) regulation.
During 2023, Hastings introduced new renewableenergy contracts for its head office with a move tobiogas, resulting in the Bexhill site now being poweredby 100 per cent renewable energy. Alongside this,Hastings continued to implement energy efficiencies
through installing an energy use monitoring system,
replacing lighting in the Leicester office to LED fittings,
and further mothballing of underutilised office areas.
Hastings’ Scope 2 emissions increased in 2023 due toone office using grid electricity for the majority of theyear. All UK sites had renewable electricity providers by
the end of 2023.

GHG Emissions
Hastings
tCO2e

2023

2022

2021

Change2023/2022, %Scope 1: Direct GHG emissions

165.4

185.9

253.8

-11.0

Scope 2: Indirect GHG emissions

244.5

102.4

25.1

138.9

Scope 3: Other indirect GHG emissions

4,062.1

1,473.7

664.9

175.6

Scope 1–3 GHG emissions, total

4,472.1

1,762.0

943.8

153.8

1.4

0.6

0.3

139.6

GHG emissions per employee

An error in electricity consumption in 2022 was corrected. The change reduced Hastings’ GHG
emissions by 20.6 tCO2e, and emissions per employee by 0.01 tCO2e in 2022.

SUSTAINABILITY REPORT 2023

37

Appendices≡In 2023, Hastings’ business travel increased by 30.4 percent. Hastings recruits talent from across the UK,
requiring some employees to travel further for events.
During the year, Hastings developed data collection on
Scope 3 categories purchased goods and services, andcapital goods, and reported emissions arising fromthese categories for the first time. In 2024, Hastings
intends to develop reporting through increased internalreporting at a more granular level, and addressing any
remaining gaps in Scope 3 data in line with the SBTi
methodology.

Introduction

Business management
and practices

Corporate
cultureSustainable offices
During 2023, Hastings furthered its commitment tosustainable onsite catering by working with its suppliers
to remove all plastic drink bottles from sale. This action
prevented approximately 178,000 plastic products fromentering the waste stream during the year.
Hastings’ Leicester site also had all its fluorescent lamps
replaced with energy efficient LED equivalents in 2023.
This will generate an annual GHG emission reduction of
approximately 48 tCO2e.
Hastings’ Green Ambassador employee network,
comprised of employees acting as sustainability
champions, continued to drive the sustainability agenda

Investment management
and operations

Products
and services

Communities

amongst their peers, and supported with activities tohighlight positive change habits. During 2023, these
activities included a Go Green month, New 2 Meswapping events, Veganuary challenges, andsupporting the national initiative of Plastic free July.

Sampo plc
In 2023, the GHG emissions of Sampo plc’s own
operations were 275.2 tonnes. Scope 1 emissions were
1.8 per cent (4.3), Scope 2 emissions were 3.4 per cent(6.1), and Scope 3 emissions were 94.8 per cent (89.6)of the total. Most of the emissions derived frombusiness travel, upstream transportation anddistribution, and purchased goods and services, with

GHG emissions
Sampo plc
tCO2e

2023

2022

2021

Change2023/2022, %Scope 1: Direct GHG emissions

5.0

7.3

8.2

-31.7

Scope 2: Indirect GHG emissions

9.5

10.2

6.9

-7.2

Scope 3: Other indirect GHG emissions

260.8

150.6

64.2

73.1

Scope 1–3 GHG emissions, total

275.2

168.1

79.2

63.7

5.1

3.4

1.3

51.6

GHG emissions per employee

An error in Sampo plc’s heating, cooling and water consumption in 2022 was corrected. Thechange reduced Sampo plc’s GHG emissions by 18.6 tCO2e and emissions per employee by 0.4
tCO2e in 2022.

SUSTAINABILITY REPORT 2023

38

Appendices≡the shares being 45.8 per cent (48.6), 19.0 per cent (-),
and 13.2 per cent (18.9), respectively.
In 2023, Scope 3 emissions increased significantly due
to increased business travel. However, it seems that
digital meeting practices adopted during COVID-19
have, to some extent, become permanent, as businesstravel has not reached its pre-COVID-19 level.
In 2023, 22.5 per cent of Sampo plc’s GHG emissions
derived from the printing and mailing of invitations to
the AGM. This was a one-time occurrence due to theBoard’s proposal on the demerger of Mandatum.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesCompliance with laws and regulations
Compliance with laws and regulations gives insight into
the ability of management to ensure that Sampo Group
conforms to certain performance parameters.

Approach
Sampo Group reports the total number and themonetary value of fines for instances of non-compliancewith laws and regulations that were paid during thereporting period, and a breakdown of this total by finesthat occurred during the current reporting period, andfines that occurred during previous reporting periods.
This is to ensure transparency and meet the voluntary
reporting requirements.

Group goals and ambitions
Sampo Group complies with applicable laws andregulations.

Actions and results
In 2023, there were no cases of non-complianceresulting in fines within Sampo Group. However, If
reported two significant non-monetary sanctions during
the reporting year. One of the cases concerned a

Number of cases of non-compliance

Fines paid

Sampo Group

Sampo Group

Numbercriticism received from the Danish Natural Hazards
Council regarding the handling of a specific floodingrelated case, and the other a reprimand from theEstonian Data Protection Inspectorate for violation ofcertain principles relating to processing of personal
data.

2023

2022

Number of cases resulting in fines

0

4

Fines for instances during the reporting year00

Number of significant cases resulting in non-monetary sanctions

2

1

Fines for instances in previous reporting periods

0

160,000

SUSTAINABILITY REPORT 2023

EUR

39

2023

2022

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Sustainable corporate culture
Empowering work environment .........................
Diversity, equity, and inclusion...........................
Health and well-being.............................................
Competence development ..................................
Remuneration.............................................................

SUSTAINABILITY REPORT 2023

41
53
62
69
73

40

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Empowering work environment
Employees are the most important resource for
ensuring that Sampo Group’s customers receive thebest service in every situation. Dedicated employees
create results by delivering first-class customer
experiences daily. For this reason investing in personnel
practices and an empowering work environment not
only reflects Sampo Group’s values but also makes
good business sense.
Employees and their contributions are also Sampo
Group’s most important source of competitive
advantage. Insurance products can be copied, but
duplicating the company culture and the attitude,competence, and engagement of great employees ismuch harder.
Engaged and motivated workforce lays the ground forvalue creation. Employee engagement depends on thecompany’s ability to create an empowering work
environment and on the employees’ motivation tocontribute to the company’s goals. It is important to
attract and retain talent, as a lack of competentemployees can pose a business risk for Sampo Group.

Approach
The Sampo Group Code of Conduct, together withcompany-specific policies, addresses the relationshipthat Sampo Group aims to uphold with its employees.
The Group aims to offer a work environment that
supports the commitment of all employees to thecompany and its operations.
At Sampo Group, employee engagement is measured
by employee turnover and employee engagement
surveys. When possible, the Group companies compare

SUSTAINABILITY REPORT 2023

turnover rates to industry averages within theiroperating countries, to evaluate the level of theturnover rates. Employee engagement surveys are
conducted at company level instead of group level toensure the suitability of the surveys for each Group
company and its individual needs and characteristics.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Additional information:www.sampo.com/sustainability/sustainablecorporate-culture/empowering-workingenvironment

Group goals and ambitions
Sampo Group aims to retain employee turnover rate ata healthy level. This means that the employee turnovershould present more opportunities than hindrances.
Each individual Group company has a target for
employee engagement.

Actions and results
In 2023, the number of Sampo Group employees (fulltime equivalent, FTE) decreased slightly compared tothe previous year due to the Mandatum demerger. The
total number of employees working at If saw anincrease of 4.2 per cent compared to 2022, mainly due
to If’s strategy to invest in recruitment in Finland andthe Baltics. The increase in specific business areas isconnected to meeting customer needs, improving
large-scale sales capacity in certain markets, and41

refining existing IT solutions. During 2023, If’s Danish
organisation was restructured to ensure increased
efficiency and cost control.
Hastings saw a 8.1 per cent increase in the number of
employees in 2023 compared to the previous year. This
was largely driven by a rebalancing of the UK based
employed resource and offshored contractor services.
The number of employees working at Topdanmark
remained stable in 2023.
The majority of Sampo Group’s employees were
employed full-time on permanent contracts at the endof the year. No large-scale redundancies or significant
job cuts have been made at Sampo Group during thepast three years. Contingent workers are not employeesof Sampo Group, and work for the company on atemporary or project basis (e.g. consultants, freelancers,
other independent contractors, and employees
employed by a staffing company).
In 2023, If and Topdanmark had some employees
working on non-guaranteed hours contracts. The nonguaranteed hours employees can be, for example,
students working occasional hours while studying, andare not included in headcount and FTE numbers.
In 2023, the employee turnover (external turnover,including monthly paid permanent employees andemployees leaving on pension) decreased at If,
Topdanmark, and Hastings. The reasons behind thisdevelopment are described in the company-specificsections. At Sampo plc, the employee turnoverincreased, which is mainly explained by the Mandatum
demerger and the relatively low total number of
employees working at the company. In addition toIntroduction

Business management
and practices

Corporate
cultureexternal employee turnover, Sampo Group reports
separately voluntary and involuntary turnover bycompany and country. Voluntary turnover means that

Investment management
and operations

Products
and services

Communities

an employee chooses to leave the organisation by
resigning or retiring, and involuntary turnover meansthat the employment is terminated by the employer or≡Appendicesthe employment ends, for example, due to healthrelated reasons, e.g. disability pension.

Number of employees (FTE) by company
31 Dec. 2023

% of the total

31 Dec. 2022

% of the total

If

7,948

59.1

7,630

Topdanmark

2,161

16.1

2,143

Hastings

3,283

24.4

Change2023/2022, %31 Dec. 2021

% of the total

56.6

7,287

54.6

4.2

15.9

2,374

17.8

0.8

3,037

22.5

2,995

22.5

8.1

629

4.7

638

4.8

-

Mandatum-

Sampo plc

58

0.4

51

0.4

45

0.3

13.3

13,450100.0

13,490100.0

13,340

100.0

-0.3

% of the total

31 Dec. 2022

% of the total

31 Dec. 2021

% of the total

Sampo Group-

Number of employees (FTE) by country
31 Dec. 2023

Change2023/2022, %United Kingdom

3,260

24.2

3,015

22.3

2,967

22.2

8.1

Denmark

2,743

20.4

2,739

20.3

2,946

22.1

0.1

Sweden

2,466

18.3

2,409

17.9

2,344

17.6

2.4

Finland

1,947

14.5

2,486

18.4

2,320

17.4

-21.7

Norway

1,642

12.2

1,592

11.8

1,549

11.6

3.1

Latvia

518

3.9

492

3.6

443

3.3

5.3

Estonia

462

3.4

418

3.1

414

3.1

10.5

Spain

188

1.4

128

0.9

118

0.9

46.9

Lithuania

176

1.3

161

1.2

183

1.4

9.7

Gibraltar

28

0.2

27

0.2

33

0.2

3.7

France

7

0.1

6

0.0

6

0.0

16.7

Germany

6

0.0

6

0.0

5

0.0

0.0

Netherlands

5

0.0

6

0.0

5

0.0

-10.3

United States

1

0.0

1

0.0

1

0.0

0.0

Luxembourg

0

0.0

4

0.0

5

0.0

-100.0Sampo Group

13,450100.0

13,490100.0

13,340

100.0

-0.3

Mandatum is included in 2021 and 2022 figures..

SUSTAINABILITY REPORT 2023

42

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesFull-time and part-time employees (FTE) by company and binary gender
31 Dec. 2023
Women

31 Dec. 2022
Men

Women

31 Dec. 2021
Men

Women

Men

Full-timePart-time

Full-timePart-time

Full-timePart-time

Full-timePart-time

Full-timePart-time

Full-timePart-time

3,945

294

3,603

105

3,785

274

3,488

83

3,604

292

3,300

90

Topdanmark

775

97

1,275

13

771

105

1,248

19

862

135

1,360

18

Hastings

1,323

287

1,602

71

1,183

288

1,491

76

1,131

316

1,448

100

Mandatum

-

-

-

-

265

21

332

11

280

29

313

16

Sampo plc

29

1

28

0

26

0

25

0

24

0

21

0

6,072

680

6,508

189

6,030

687

6,584

189

5,901

773

6,442

224

If

Sampo Group

Full-time and part-time employees (FTE) by country and binary gender
31 Dec. 2023
Women

31 Dec. 2022
Men

Women

Men

Full-timePart-time

Full-timePart-time

Full-timePart-time

Full-timePart-time

United Kingdom

1,313

285

1,591

71

1,174

286

1,480

75

Denmark

1,004

134

1,573

32

1,008

142

1,563

27

Sweden

1,173

93

1,161

39

1,111

105

1,161

32

Finland

1,047

115

769

16

1,301

106

1,054

26

Norway

724

32

860

26

701

35

831

25

Latvia

222

3

290

3

209

2

279

2

Estonia

360

11

91

0

325

6

87

0

Lithuania

124

3

49

1

120

1

39

1

Other countries

106

4

124

2

82

4

90

3

Sampo Group

6,072

680

6,508

189

6,030

687

6,584

189

Year 2022 includes Mandatum.

SUSTAINABILITY REPORT 2023

43

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Employees on permanent and temporary contracts (FTE) by company and binary gender
31 Dec. 2023
Women

31 Dec. 2022
Men

Women

Men

Permanent

Temporary

Permanent

Temporary

Permanent

Temporary

Permanent

If

4,170

69

3,674

34

3,986

73

3,546

25

Topdanmark

854

19

1,263

25

855

21

1,244

23

Hastings

1,594

16

1,660

13

1,464

6

1,559

8

-

-

-

-

270

16

327

16

Mandatum
Sampo plc
Sampo Group

Temporary

30

0

26

2

26

0

25

0

6,648

104

6,623

74

6,600

116

6,701

72

Employees on permanent and temporary contracts (FTE) by country and binary gender
31 Dec. 2023
Women

31 Dec. 2022
Men

Women

Men

Permanent

Temporary

Permanent

Temporary

Permanent

Temporary

Permanent

United Kingdom

1,582

16

1,649

13

1,454

6

1,547

8

Denmark

1,113

25

1,567

38

1,125

24

1,566

24

Sweden

1,257

9

1,194

7

1,209

7

1,189

4

Finland

1,153

9

776

10

1,372

34

1,055

24

Norway

737

19

884

2

716

20

845

11

Latvia

217

8

292

1

203

8

281

0

Estonia

365

6

89

2

328

3

87

0

Lithuania

115

12

49

1

107

14

39

1

Other countries

110

0

125

1

86

0

93

0

6,648

104

6,623

74

6,600

116

6,701

72

Sampo GroupYear 2022 includes Mandatum.

SUSTAINABILITY REPORT 2023

44

TemporaryIntroduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesContingent workers by company
31 Dec. 2023
If

31 Dec. 2022--

Topdanmark

660

689

Hastings

272

415

Mandatum-81

Sampo plc

8

8

940

1,193

Sampo GroupIf was not able to report the number of contingent workers in 2022 and 2023 due toa lack of system support. If will be included in the reporting in 2024.

Non-guaranteed hours employees by company and binary gender
31 Dec. 2023

31 Dec. 2022

Women

Men

Total

Women

Men

Total

If

88

48

136

85

58

143

Topdanmark

56

61

117

54

62

116

Hastings

0

0

0

0

0

0

Mandatum

-

-

-

0

0

0

Sampo plc

0

0

0

0

1

1

144

109

253

139

121

260

Sampo GroupNon-guaranteed hours employees by country and binary gender
31 Dec. 2023

31 Dec. 2022

Women

Men

Total

Women

Men

Total

Denmark

56

61

117

55

71

126

Sweden

65

24

89

62

24

86

Norway

23

24

47

22

25

47

Finland

0

0

0

0

1

1

Estonia

0

0

0

0

0

0

Latvia

0

0

0

0

0

0

Lithuania

0

0

0

0

0

0

United Kingdom

0

0

0

0

0

0

Other countries

0

0

0

0

0

0

Sampo Group

144

109

253

139

121

260

Year 2022 includes Mandatum.

SUSTAINABILITY REPORT 2023

45

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesCompany-specific employee turnover (external) by binary gender and age group
2023

2022
30–50
years

>50
years

Total

Women

2021

%

Women

Men

<30
years

Men

<30
years

30–50
years

>50
years

Total

Women

Men

<30
years

30–50
years

>50
years

If

10.3

12.0

23.6

9.5

6.7

11.1

12.5

13.6

24.6

11.0

9.5

13.0

10.0

12.2

20.5

8.9

8.8

11.0

Topdanmark

12.0

11.4

11.0

11.8

11.8

11.7

10.7

15.5

22.2

14.4

8.8

13.5

15.0

17.9

22.1

16.2

15.1

16.7

Hastings

Total

20.7

21.7

34.5

14.1

16.9

21.2

27.4

27.6

44.9

19.3

18.3

27.5

31.5

26.7

45.8

18.6

20.1

29.2

Mandatum

-

-

-

-

-

-

7.8

12.8

19.0

11.1

4.4

10.4

8.5

12.7

20.5

9.8

6.8

10.6

Sampo plc

6.8

11.5

0.0

6.5

14.5

9.0

0.0

8.6

0.0

4.1

5.0

4.0

0.0

3.3

0.0

3.1

0.0

1.6

Sampo Group

13.0

14.3

26.2

11.0

9.0

13.6

15.4

17.2

31.7

13.4

10.1

16.3

15.5

16.7

30.8

12.3

11.3

16.1

30–50
years

>50
years

Total

29.4

Country-specific employee turnover (external) by binary gender and age group
Sampo Group
2023

2022

Women

Men

United Kingdom

21.2

20.7

34.6

14.2

16.6

21.2

27.3

27.5

45.0

19.1

18.1

27.4

31.7

26.9

46.0

18.9

19.7

Sweden

12.7

15.5

28.0

11.8

7.6

14.0

15.9

16.4

32.6

12.4

9.2

16.1

11.1

14.1

26.4

8.8

6.2

12.5

Denmark

13.0

12.4

15.4

12.7

11.1

12.7

11.9

15.4

21.4

14.7

9.5

13.9

14.7

17.5

22.8

15.9

14.3

16.3

Norway

8.8

8.9

17.5

7.8

7.2

8.8

11.2

10.9

21.6

9.6

9.0

11.0

9.0

10.4

18.6

8.3

8.2

9.7

Latvia

7.1

9.2

12.0

7.5

4.7

8.3

7.1

10.9

12.7

8.6

0.0

9.2

7.4

9.3

11.1

7.9

5.0

8.5

Lithuania

10.1

2.2

3.1

9.8

4.9

8.0

6.6

15.4

7.0

9.0

10.2

8.8

8.4

13.4

6.3

10.8

8.2

9.8

Estonia

6.3

9.0

18.5

6.2

2.7

6.8

10.8

10.5

17.0

10.7

7.1

10.8

9.6

10.0

11.7

11.2

4.1

9.7

Finland

6.7

5.3

10.3

6.4

4.3

6.2

8.6

9.7

14.1

8.4

8.1

9.1

8.0

10.0

13.7

6.8

10.1

8.8

Other countries

39.8

40.5

72.1

27.7

22.6

40.2

41.6

44.6

60.0

42.8

25.1

43.2

22.3

19.9

25.3

16.5

26.1

21.1

%

30–50
years

>50
years

Total

Women

2021

<30
years

Men

<30
years

30–50
years

>50
years

Total

Women

Men

<30
years

Mandatum is included in 2021 and 2022 figures.

SUSTAINABILITY REPORT 2023

46

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Voluntary and involuntary turnover by company
2023%

Voluntary
turnoverIf
Topdanmark
Hastings

2022
Involuntary
turnoverVoluntary
turnover

Involuntary
turnover

9.2

1.9

11.8

1.2

8.1

3.6

9.4

4.1

17.6

3.6

23.7

3.8

Mandatum

-

-

10.3

0.2

Sampo plc

9.0

0.0

4.0

0.0

Sampo Group

11.1

2.5

14.1

2.2

Voluntary
turnover

Involuntary
turnoverVoluntary
turnoverUnited Kingdom

17.6

3.7

23.6

3.8

Sweden

11.9

2.2

15.2

0.9

Denmark

8.4

4.3

9.8

4.1

Norway

8.7

0.1

11.0

0.1

Estonia

4.3

2.6

8.9

1.9

Latvia

6.6

1.7

8.2

1.0

Lithuania

7.4

0.6

7.5

1.3

Finland

5.5

0.7

8.6

0.5

33.0

7.2

34.3

9.0

Voluntary and involuntary turnover by country
Sampo Group
2023%

Other countries

2022
Involuntary
turnoverYear 2022 includes Mandatum.

SUSTAINABILITY REPORT 2023

47

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureIf
Goals and ambitions
If’s goals are to keep employee turnover below 12 percent and eNPS (employee Net Promoter Score) at 50 orabove.

Actions and results
Employee turnover
Employee turnover at If is monitored monthly both bycountry and by business area, and it is part ofmanagement reporting. In 2023, the employee turnovertarget was met, as the turnover was 11.1 per cent. The
decrease is partly explained by the general tendencies
noted across If’s markets, indicating that employees
value secure employment. If has also focused on
employee retention.
If performs exit interviews and analyses the employee
turnover results to understand the reasons behindvoluntary employee turnover and to identify
development areas (e.g. regarding recruitment
processes, onboarding, internal mobility opportunities,
and performance and follow-up processes). One
example has been a cultural transformation journey,

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

which If embarked on in its Swedish customer centres.
This means that If identified and addressed root causes
behind high turnover by establishing relevant initiatives,contributing to a decrease in turnover in recent years.
During 2023, If continued ensuring visibility among all
main target groups and conducted several employer
branding campaigns. If defined an updated employer
value proposition along with a new communication
concept. Further initiatives to structure and strengthen
recruiting included internal education, improving thetools used for background checks, investing in more
inclusive test tools, updating the recruitment processaccording to new legal requirements, strengthening thetalent pipeline, developing new trainee programmes,
offering in-house recruitment support within IT, andhandling all volume recruitment in the customer andclaims centres. In 2023, as a response to the increased
recruitment needs, the Talent Acquisition team
expanded its scope to offer specialized support to thebusiness, which in turn decreased recruitment costs

48

Appendices≡

If continually invests in the sourcing of new talentthrough trainee programmes. In 2023, If increased thenumber of available positions from the previous year byrecruiting 16 new trainees within Analytics, Controlling,
IT and Underwriting, and 19 new summer interns.
Employee engagement
If measures employee engagement through the biannual survey called HeartBeat. In the spring 2023
survey, If exceeded its eNPS target, and the score also
remained above target in the autumn survey. The
results have increased in previous years due toinvestments in employee engagement initiatives.
Leaders at If are trained on the purpose of the survey,
and they discuss and share the results with their teammembers to take relevant action. Furthermore, data on
an aggregated level is used by management teams as
input into the organisational development processes.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Number of employees (FTE) by country
If
31 Dec. 2023

% of the total

31 Dec. 2022

% of the total

31 Dec. 2021

2,457
1,898
1,642
582
518
462
188
176
6
7
6
5
7,948

30.9
23.9
20.7
7.3
6.5
5.8
2.4
2.2
0.1
0.1
0.1
0.1
100.0

2,402
1,817
1,592
596
492
418
128
161
6
6
6
6
7,630

31.5
23.8
20.9
7.8
6.4
5.5
1.7
2.1
0.1
0.1
0.1
0.1
100.0

2,340
1,721
1,549
574
429
386
118
149
6
6
5
5
7,287

SwedenFinland
NorwayDenmark
LatviaEstonia
Spain
Lithuania
United Kingdom
FranceGermany
Netherlands
If

Employee turnover by country
If
%

2023

2022

2021

Denmark

16.1

15.3

14.8

Sweden

14.1

16.2

12.5

Norway

8.8

11.0

9.7

Latvia

8.3

9.2

8.5

Lithuania

8.0

8.8

11.8

Estonia

6.8

10.8

9.1

Finland

6.1

8.7

8.4

Other countries

42.9

43.9

24.6

If

11.1

13.0

11.0

2023
SpringAutumn2022
SpringAutumn2021
SpringAutumnEmployee engagement
If
SurveyTargetScale

HeartBeat (eNPS)

50-100–100SUSTAINABILITY REPORT 2023

56

51

51

53

49

54

51

% of the total Change 2023/2022, %
32.1
23.6
21.3
7.9
5.9
5.3
1.6
2.0
0.1
0.1
0.1
0.1
100.0

2.3
4.5
3.1
-2.4
5.3
10.5
46.9
9.7
0.0
16.7
0.0
-10.3
4.2

Introduction

Business management
and practices

Corporate
cultureTopdanmark
Goals and ambitions
Topdanmark’s goals are to maintain employee turnoverat industry level or below, and employee engagement
at a minimum of 79 points until 2025.

Actions and results
Employee turnoverTopdanmark sees employee turnover as an indicator ofwhether the company has succeeded in its well-being
efforts. In 2023, employee turnover at Topdanmark
decreased slightly to 11.7, and the target was met. The
industry average in 2023 was 12.1.

Investment management
and operations

Products
and services

Communities

Employee engagement
In 2023, Topdanmark launched new Leadership
Principles. They were created on the ground of theengagement surveys conducted in 2022, whichhighlighted psychological well-being. The principles
focus on attentive management to support a hybrid
workplace and psychological well-being, and to keep
employee turnover at a low level.

≡

AppendicesThis shows that the mandatory team talks, which areheld with an HR business partner after engagement
surveys, have a positive effect on the well-being ofteams.
In 2023, Topdanmark added two new questions on
diversity, equity, and inclusion (DEI) in the engagement
survey. This was to set a benchmark on the experienceof DEI in the workplace, but also to gain insights onwhat is relevant to employees in this area. The
questions related to equal opportunities and inclusion in
the workplace, and the results were positive in both.

During 2023, Topdanmark conducted its bi-annual
engagement surveys with positive results. Both thespring and autumn surveys showed high scores, whichindicates that the company’s employees thrive at theworkplace. The response rate was 95 per cent. The
teams with the lowest scores in the 2022 engagement
surveys had raised their scores by 7–14 points in 2023.

Number of employees (FTE) by country
Topdanmark
Denmark

31 Dec. 2023

% of the total

31 Dec. 2022

% of the total

31 Dec. 2021

% of the total

Change2023/2022, %
0.8

2,161

100.0

2,143

100.0

2,372

99.9

Luxembourg

0

0.0

0

0.0

2

0.1

-

Topdanmark

2,161

100.0

2,143

100.0

2,374

100.0

0.8

Employee turnover by country

Employee engagement

Topdanmark

Topdanmark

%

2023

2022

2021

Denmark

11.7

13.5

16.7

SurveyTopdanmark, including all
countries

11.7

13.5

16.7

Group
engagement
survey2025: 79

SUSTAINABILITY REPORT 2023

50

Target

Scale
0–100

2023

2022

2021

Spring Autumn

Spring Autumn

Spring Autumn

82

81

80

81

79

80

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

also maintained the right culture, by connecting morecolleagues through work, development, andcommunity-based events, and supported leaders to
optimise and lead hybrid teams.

Hastings
Goals and ambitions
Hastings’ goal is to secure full-year employee
engagement at 72 per cent.

Actions and results
Employee turnover
Despite a competitive labour market, voluntary
employee turnover at Hastings reduced in 2023
compared to 2022. This can be attributed to improving
and increasing opportunities for employees to develop
and progress their careers at Hastings, with high levels
of internal movement and progression, and anincreased number of internal promotions compared to2022. In addition, a focus on financial well-being,
including supporting employees during a high cost ofliving environment, likely impacted the results. Hastings≡

Appendicesagenda. In 2023, Hastings also continued to support
employees during the cost-of-living crisis throughseveral initiatives. Employee sentiment and comments
were positive in response to this and resulted in an
uplift in scores in all associated questions in the Your
Voice survey.

Employee engagement
Hastings measures employee engagement bi-annuallyusing the Your Voice survey. The spring (mid-year)
survey is shorter, and the autumn (full-year) survey
features the complete set of questions for all
employees.

During the summer 2023, Hastings ran a well-being andemployee benefits services -focused survey. The survey
was validated by colleague focus groups, which gavefurther insight into employee satisfaction and where
improvements could be made. As a result, Hastings
made a series of changes, including better informationand messaging about well-being and reward services,
as well as sourcing new service providers. Hastings willcontinue this work in 2024, with new benefit options
being explored for employees.

Hastings’ autumn 2023 employee survey reported asustained high level of employee engagement at 75 percent. The survey had a response rate of 82 per cent.
The results were driven by Hastings’ continued
investments in initiatives, such as training and careerdevelopment, development of operational leaders, andactive management of the diversity and inclusion

Number of employees (FTE) by country
Hastings

United Kingdom
Gibraltar
United States
Hastings% of the total

31 Dec. 2022

% of the total

31 Dec. 2021

% of the total

3,254

99.1

3,009

99.1

2,961

98.9

8.1

28

0.9

27

0.9

33

1.1

3.7

1

0.0

1

0.0

1

0.0

0.0

3,283

100.0

3,037

100.0

2,995

100.0

8.1

Employee turnover by country

Employee engagement

Hastings

Hastings%

Change2023/2022, %31 Dec. 2023

2023

2022

2021

Spring Autumn

Spring Autumn

Spring Autumn

2023

2022

2021

United Kingdom

21.3

27.4

29.4

SurveyTargetScale

Gibraltar

26.3

36.6

6.6

Your Voice72

0–100%

Hastings, including all
countries

21.2

27.5

29.2

2022 figures have been adjusted to allow comparison between 2022 and 2023, as Hastings has
transitioned to a new employer engagement platform. Therefore, 2021 figures are not comparable.

SUSTAINABILITY REPORT 2023

51

76

75

73

77

70

74

Introduction

Business management
and practices

Corporate
cultureSampo plc
Sampo plc renewed its employee engagement survey in2022. In 2023, the same survey was conducted, and theresults indicated that the employees trust in the support
from their colleagues and believe in Sampo's future

Investment management
and operations

Products
and services

Communities

success. Sampo plc was also perceived as a stable andreliable employer. The survey’s response rate was 82
per cent.

≡

Appendicesplans were created based on the discussions. Sampo plc
also publishes a company-wide summary on theintranet with overall results and breakdown by genderand age group.

The survey results were discussed within theorganisation on a team basis and team-specific action

Number of employees (FTE) by country
Sampo plc
Change2023/2022, %31 Dec. 2023

% of the total

31 Dec. 2022

% of the total

31 Dec. 2021

% of the total

Finland

49

84.4

46

90.2

41

91.1

6.1

Sweden

9

15.6

5

9.8

4

8.9

80.0

Sampo plc

58

100.0

51

100.0

45

100.0

13.3

Employee turnover by country

Employee engagement

Sampo plc

Sampo plc

%

2023

2022

2021

Survey

Scale

2023

2022

Finland

10.6

4.4

1.7

eNPS

-100–10047

46

Sampo plc, including all
countries

9.0

4.0

1.6

SUSTAINABILITY REPORT 2023

52

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Diversity, equity and inclusion
Sampo Group’s organisation and business activities
should reflect the customers and markets in which theGroup companies operate. At Sampo Group, it isbelieved that companies performing well in diversity,
equity, and inclusion (DEI) also tend to be moreinnovative and profitable.

Approach
The Group level guidance document regarding DEI is
the Sampo Group Code of Conduct, which is reviewed
annually and approved by the Board of Directors ofSampo plc. In addition, each Group company has
adopted supplementary policies and guidelines for theirown purposes.
Sampo Group focuses on creating an inclusive culture,building a diverse workforce for the future, andenhancing the company’s reputation internally andexternally. At Sampo Group, all employees must betreated fairly and equally. Discrimination, bullying,harassment, or any other type of abusive behaviour is
prohibited. Discriminatory practices regarding
recruitment, job assignment, training and development,
promotion, remuneration and other benefits, or general
conduct in the workplace are not tolerated. At thegroup level, DEI is measured, for example, by age and

SUSTAINABILITY REPORT 2023

gender distribution. In addition, the Group companies
have company-specific measures and targets in place.
Sampo Group aims to listen to its stakeholders, such as
employees and customers, and wants to act on their
feedback, as well as bring in external expertise whenneeded. Sampo Group is working to regularly review its
policies and practices in line with its ambitions to be an
inclusive employer.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Information about the Board of Directors:
www.sampo.com/governance/board-ofdirectors
Information about the management:www.sampo.com/governance/management
Additional information:www.sampo.com/sustainability/sustainablecorporate-culture/diversity-equity-inclusion

53

Group goals and ambitions
Sampo Group seeks diversity and inclusion among
employees and management.

Actions and results
On 31 December 2023, both the binary gender
distribution of all employees and the binary gender
distribution of all leaders were at a good level at Sampo
Group. Binary gender distribution at the four highest
management levels shows that there is still room fordiversity at the very top. However, at the levels
immediately below top management, the balance ismore equal. Certain functions are also dominated bymen or women, such as IT and customer centres,
respectively.
In 2023, the results show that diversity in terms ofbinary gender is at a good level in recruitment. In
addition, the age distribution within the Group has
historically been steady, and it stayed on track in 2023.
The share of employees at different organisational
levels remained stable compared to the previous years.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Binary gender distribution of all employees (FTE)
31 Dec. 2023

31 Dec. 2022

Women

Men

31 Dec. 2021

Women

Men

Women

Men

4,240

53.3%

3,708

46.7%

4,059

53.2%

3,571

46.8%

3,897

53.5%

3,390

46.5%

Topdanmark

872

40.4%

1,288

59.6%

876

40.9%

1,267

59.1%

997

42.0%

1,378

58.0%

Hastings

1,610

49.1%

1,673

50.9%

1,471

48.4%

1,567

51.6%

1,447

48.3%

1,548

51.7%

-

-

-

-

286

45.4%

343

54.6%

309

48.5%

329

51.5%

If

Mandatum
Sampo plc
Sampo Group

30

51.6%

28

48.4%

26

51.0%

25

49.0%

24

53.3%

21

46.7%

6,752

50.2%

6,697

49.8%

6,717

49.8%

6,773

50.2%

6,674

50.0%

6,665

50.0%

Binary gender distribution of leaders (all levels) (FTE)
31 Dec. 2023
Women

31 Dec. 2022
Men

Women

31 Dec. 2021
Men

Women

Men

If

487

49.1%

504

50.9%

462

47.9%

501

52.1%

445

48.4%

475

51.6%

Topdanmark

75

39.4%

115

60.6%

69

36.4%

120

63.6%

87

40.3%

129

59.7%

Hastings

275

44.9%

338

55.1%

232

42.1%

320

57.9%

210

41.5%

296

58.5%

Mandatum

-

-

-

-

34

35.8%

61

64.2%

29

32.2%

61

67.8%

3

30.0%

7

70.0%

3

27.3%

8

72.7%

3

27.3%

8

72.7%

840

46.5%

964

53.5%

800

44.2%

1,011

55.8%

774

44.4%

969

55.6%

Sampo plc
Sampo Group

Binary gender (FTE) by country
31 Dec. 2023
Women

Men

31 Dec. 2022
Total

Women

Men

Total

United Kingdom

1,598

1,662

3,260

1,460

1,555

3,015

Denmark

1,138

1,605

2,743

1,150

1,590

2,739

Sweden

1,266

1,200

2,466

1,216

1,193

2,409

Finland

1,162

785

1,947

1,407

1,080

2,486

Norway

756

886

1,642

736

856

1,592

Latvia

225

293

518

211

281

492

Estonia

371

91

462

331

87

418

Lithuania

127

50

176

121

40

161

Other countries

110

126

236

86

93

178

Sampo Group

6,752

6,697

13,450

6,717

6,773

13,490Year 2022 includes Mandatum.

SUSTAINABILITY REPORT 2023

54

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Share of women leaders at the highest management levels
Level 1 (the Group CEO)Level 2 (the CEOs of Sampo
plc’s subsidiaries)

Level 3 (reporting to any of theCEOs)

31 Dec.
2023

31 Dec.
2022

31 Dec.
2021

31 Dec.
2023

31 Dec.
2022

31 Dec.
2021

31 Dec.
2023

31 Dec.
2022

If

-

-

-

0.0%

0.0%

0.0%

25.0%

25.0%

25.0%

Topdanmark

-

-

-

0.0%

0.0%

0.0%

28.6%

28.6%

50.0%

Hastings

-

-

-

0.0%

0.0%

0.0%

31.2%

18.9%

9.1%

Mandatum

-

-

-

-

0.0%

0.0%

-

45.5%

31 Dec.
2021

Level 4 (reporting to level 3)
31 Dec.
2023

31 Dec.
2022

31 Dec.
2021

47.4%

45.2%

34.0%

30.7%

36.5%

44.4%

-

Total (levels 1–4)
31 Dec.
2023

31 Dec.
2022

31 Dec.
2021

46.3%

44.1%

42.3%

43.2%

29.2%

32.7%

29.8%

32.2%

38.8%

37.2%

35.1%

34.5%

31.4%

27.8%

26.5%

-

31.3%

29.5%

Sampo plc

0.0%

0.0%

0.0%

-

-

-

25.0%

25.0%

25.0%

40.0%

33.3%

33.3%

30.0%

27.3%

27.3%

Sampo Group

0.0%

0.0%

0.0%

0.0%

0.0%

0.0%

27.6%

29.1%

30.4%

40.7%

37.7%

37.1%

37.9%

35.5%

35.3%

Age distribution of employees (FTE)
31 Dec. 2023

31 Dec. 2022

31 Dec. 2021

<30 years

30–50 years>50 years<30 years

30–50 years

If

1,253

15.8%

4,539

57.1%

2,156

27.1%

1,239

16.2%

4,341

56.9%

2,050

Topdanmark

362

16.7%

1,154

53.4%

644

29.8%

320

14.9%

1,121

52.3%

702

1,064

32.4%

1,802

54.9%

417

12.7%

1,009

33.2%

1,645

54.2%

-

-

-

-

-

-

127

20.1%

353

56.0%

Hastings
Mandatum
Sampo plc
Sampo Group>50 years<30 years

30–50 years>50 years

26.9%

1,220

16.7%

4,076

55.9%

1,991

27.3%

32.8%

340

14.3%

1,233

51.9%

802

33.8%

383

12.6%

1,071

35.7%

1,544

51.6%

380

12.7%

150

23.9%

118

18.5%

359

56.2%

161

25.3%

7

12.1%

31

53.3%

20

34.6%

5

9.8%

26

51.0%

20

39.2%

6

13.3%

20

44.4%

19

42.2%

2,685

20.0%

7,527

56.0%

3,238

24.1%

2,699

20.0%

7,486

55.5%

3,305

24.5%

2,755

20.7%

7,231

54.2%

3,353

25.1%

SUSTAINABILITY REPORT 2023

55

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

New employees by binary gender
2023

2022

Women

Men

2021

Women

Men

Women

Men

If

651

52.8%

581

47.2%

677

49.8%

683

50.2%

574

52.2%

525

Topdanmark

103

33.6%

204

66.4%

124

35.5%

225

64.5%

106

37.1%

180

47.8%
62.9%

Hastings

489

50.9%

471

49.1%

423

48.3%

453

51.7%

467

51.4%

441

48.6%

Mandatum

-

-

-

-

42

36.5%

73

63.5%

38

35.5%

69

64.5%

Sampo plc

2

33.3%

4

66.7%

2

33.3%

4

66.7%

3

50.0%

3

50.0%

1,245

49.7%

1,260

50.3%

1,268

46.9%

1,438

53.1%

1,188

49.4%

1,218

50.6%

Sampo Group

Number of new employees hired during the year. Only externally hired, monthly paid employees.

New employees by age group2023<30 years2022

30–50 years>50 years<30 years2021

30–50 years>50 years<30 years

30–50 years>50 years

If

540

43.8%

581

47.2%

111

9.0%

596

43.8%

642

47.2%

122

9.0%

513

46.7%

505

46.0%

81

7.4%

Topdanmark

120

39.1%

151

49.2%

36

11.7%

110

31.5%

196

56.2%

43

12.3%

68

23.8%

167

58.4%

51

17.8%

Hastings

558

58.1%

335

34.9%

67

7.0%

474

54.1%

362

41.3%

40

4.6%

484

53.3%

368

40.5%

56

6.2%

-

-

-

-

-

-

58

50.4%

50

43.5%

7

6.1%

53

49.5%

44

41.1%

10

9.3%

3

50.0%

2

33.3%

1

16.7%

2

33.3%

4

66.7%

0

0.0%

2

33.3%

3

50.0%

1

16.7%

1,221

48.7%

1,069

42.7%

215

8.6%

1,240

45.8%

1,254

46.3%

212

7.8%

1,120

46.6%

1,087

45.2%

199

8.3%

Mandatum
Sampo plc
Sampo Group

Number of new employees hired during the year. Only externally hired, monthly paid employees.

Share of employees at different organisational levels (FTE)
31 Dec. 2023
Senior level

31 Dec. 2022

Mid-level

%

Women

If

0.7

0.7

Topdanmark

1.2

Hastings
Mandatum

Senior level

Mid-level

Men Women

Men Women

22.8

29.1

29.9

16.9

0.7

0.9

2.1

19.1

39.2

20.0

18.3

1.6

0.9

1.2

21.1

28.7

27.0

21.1

-

-

-

-

-

-

Sampo plc

10.4

13.8

41.2

29.4

0.0

Sampo Group

0.9

1.1

21.9

30.6

27.5

SUSTAINABILITY REPORT 2023

Men WomenFirst level

Men Women

31 Dec. 2021
First level

Senior level

Mid-level

Men Women

22.1

28.5

30.4

17.4

0.7

0.9

21.5

28.3

31.3

17.3

2.7

17.9

39.1

21.4

17.3

1.3

1.8

17.6

40.0

23.1

16.2

0.9

1.5

19.3

27.7

28.3

22.4

0.9

1.4

18.2

27.1

29.2

23.2

1.4

5.7

31.7

42.5

12.3

6.3

4.1

6.3

30.7

38.6

13.7

6.7

5.2

11.8

17.6

39.2

27.5

0.0

3.9

20.0

22.2

26.7

22.2

2.2

6.7

18.1

1.0

1.6

21.3

30.7

27.5

17.9

1.1

1.5

20.5

30.6

28.4

17.9

56

Men WomenFirst level

Men Women

Men Women

Men

Introduction

Business management
and practices

Corporate
cultureIf
Goals and ambitions
If has set the following goals to guide its DEI work.
• Reach an outstanding perceived sense of inclusion,
defined as at least 85 per cent of employees agreeing
or strongly agreeing with the statements related toinclusion in the autumn employee survey HeartBeat.
• Have equal binary gender representation, meaningthat the ratio of men/women should be 50/50 (+/- 5
percentage points), for both employees and leaders.
• Increase diversity in management teams (i.e. Business
Management Group (BMG) or the level below BMG)
by 30 per cent by 2026 (baseline 2022), defined as
selected under-represented groups, including peopleof colour and non-binary gender.

Actions and results
In autumn 2023, the perceived sense of inclusion
among If employees was 87 per cent, which exceeded
the target. The results were also examined according todemographic groups, such as gender and If Specifically
Underrepresented Group (ISURG), encompassing
employees who consider themselves to be a person ofcolour, a refugee and/or LGBTQIA+. In 2023, another
ISURG for employees with neurodiversity or disability
was introduced at If. Of the demographic groups in theautumn engagement survey, men and women reported
the highest average scores, 87 and 86 per cent,respectively, whereas the two ISURG groups reported
the lowest average scores, both 77 per cent. The two
ISURG groups generally reported the lowest results
among the demographic groups.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

In 2023, If had relatively equal binary gender
representation, with 47 per cent men and 53 per cent
women. The distribution of men and women leaders
was 51 and 49, respectively. In If’s management teams,
women accounted for 17 per cent of the positions.
In 2023, If’s Employee Resource Groups Women@If andQueer@If continued to spread awareness and promote
an open discussion among If’s employees. The Queer@If
group welcomes those who specifically identify asqueer and operates in a closed Teams group to create asafe space and build a sense of community. Certain
events are open to all interested employees. During2023, the Baltics appointed a resource to integrate DEI
topics across the Baltic region, initially focusing on
neurodiversity and disability.
Following a linguistic research study conducted among
If employees in 2022, one concrete action was thedevelopment of an advisory forum in 2023. The forum
works towards establishing principles for when to use
English and when to use the local language. One
initiative in 2023 was the introduction of local language
courses to equip non-native speakers with relevant skills
in support of the cultural and societal integration into
their new country.
If acknowledges the importance of DEI in policies andhas initiated an expansion of the company’s Ethics
policy in line with this. In 2023, If increased equity in thepeople processes and policies through, for instance,
enabling holiday swapping to support employees tocelebrate in line with their culture and religion. During
the 2024 pilot, employees will be allowed to swap
Ascension Day, Good Friday, and Easter Monday.

57

Appendices≡

If works towards incorporating DEI into recruitment
efforts, through building a more diverse talent pool andoffering trainee and internship programmes. During2023, If included in recruiting processes assessments,
such as personality tests and case presentations,structured interview guidelines, references, and a foureye-principle, to avoid decisions being influenced byunconscious bias and discrimination. One example of
how this was successfully applied, was in an IT
management team recruitment process where thecandidate’s case presentations were anonymized tolimit the influence of unconscious bias. If has integrated
DEI into its trainee programme and trainees may freely
select DEI challenges to analyse. During 2023, trainees
assessed the diversity of the product and service
offering in the Private business area.

Introduction

Business management
and practices

Corporate
cultureTopdanmark
Goals and ambitions
Topdanmark has set the following goals to guide its DEI
work:• At least two of each gender among the AGM-elected
members of the Board of Directors.
• Maximum 60 per cent of one gender at managementlevels 1 and 2.
• Maximum 60 per cent of one gender (on average) at
all levels of management.
• Maximum 60 per cent of one gender in the succession
planning for levels 1 and 2.

Actions and results
In 2022, Topdanmark launched a new employee
community for DEI. The group consists of 15 employees

Investment management
and operations

Products
and services

from different parts of the organisation, and withdifferent approaches to working with DEI. During 2023,
the employee group focused on clarifying
Topdanmark’s DEI agenda. This resulted in the inclusionof an additional focus area to the term DEI: belonging(diversity, equity, inclusion, and belonging, DEI&B).
Belonging means that all employees feel that they
belong, are accepted, and are valued for who they are
and what they bring to the workplace. Going forward,
Topdanmark works with the DEI&B concept.
Topdanmark’s target of maximum 60 per cent of one
gender in the succession planning requires a deeper
look at the leadership pipeline, which feeds into thesuccession planning. During 2023, Topdanmark
digitised its people review process, making it more
efficient. People review is a working method, where thecompany assesses leadership potential among its

Diversity in management
Topdanmark
Goal

2023

2022

2021

At least two of each gender among the AGM-elected
members of the Board of Directors

2 women

2 women

4 men

4 men

4 women on
the board

Maximum 60 per cent of one gender at managementlevels 1 and 2

28% women--

72% men--Maximum 60 per cent of one gender (on average) at
all levels of management

39% women

36% women

40% women

61% men

64% men

60% menMaximum 60 per cent of one gender in the
succession planning for level 1 and 2 management
positions

30% women

50% women

47% women

70% men

50% men

53% menCalculated using company-specific calculation methods. Cannot be compared to other Group companies or group level figures.

SUSTAINABILITY REPORT 2023

Communities

58

Appendices≡employees, making sure that it always has the best
candidates to step into a leader position. Topdanmark
expanded the review process to include all fourmanagement levels, which enabled the company toreview more leaders in 2023 compared to the previous
year. When assessing leaders, Topdanmark considers
management skills, professional skills, and whether the
person in question could carry a larger responsibility
within the organisation.
The share of women at management levels 1 and 2 andin the succession planning shows that the efforts
regarding gender diversity have not yet accumulated
into better results . However, when looking at gender
diversity across all management levels the company has
seen a small increase in the number of women leaders.

Introduction

Business management
and practices

Corporate
cultureHastings
Goals and ambitions
Hastings has set the following goals to guide its DEI
work:• Focus on ethnic minority leadership and disability in2024.
• Achieve Disability Confident Accreditation to be able
to attract, hire, and retain talent who have either
visible or non-visible disabilities.
• Participate in the 30% Club and Women in Data
Network, providing external mentoring and network
events for women.
• Maintain the company’s support of the advancementof women in senior roles in the financial services
sector by being an ongoing signatory of the Womenin Finance Charter.
• Benchmark Hastings against other leading employers
by participating in the Inclusive Top 50 UK Employers
survey.

Actions and results
In 2023, Hastings’ Inclusion Council piloted a paid
Carers Leave policy in preparation for new UK
legislation expected to be implemented in 2024. In

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

addition, the council worked towards achieving
Disability Confident Accreditation, by challenging
attitudes and increasing the understanding of disability.
The council also reviewed Hastings’ new Baby Loss
Policy, launched in 2023 for employees who experience
any type of baby loss.
Hastings was ranked 4th among the Top 50 UK
Inclusive Employers list for 2023, an improvement of 5places from 2022. Hastings is also a signatory to the
Women in Finance Charter, meeting the target ofachieving 30 per cent female representation in senior
roles. The company is aiming to achieve at least 35 percent of women in senior roles by 2025.
During 2023, Hastings continued its partnership with
Generation, an organisation that specialises in training
skilled yet underemployed candidates from diverse
backgrounds in data and analytics. The Generation
programme assists Hastings’ goals of providing early
career opportunities and has led to 13 hires since thepartnership began in 2022. Hastings’ commitment to
attract a wide pool of graduates onto its graduate
programmes remains. 50 per cent of successful
candidates during 2023 were women and 55 per centwere from ethnic minority backgrounds.

59

Appendices≡

During the year, Hastings’ partnership with the 30%
Club, an external mentoring programme aimed at
women and people from ethnic minority backgrounds,
also continued. Over the last three years, there havebeen 14 promotions or new roles from the mentee
population. During 2023, a record number of 30
employees and 30 leaders enrolled onto the mentoring
programme.
In 2023, Hastings continued to raise awareness on awide range of topics related to diversity during, forinstance, Black History Month, Pride, Neurodiversity
Week, National Inclusion Week, and Interfaith Week.
Throughout the year, different religious events wererecognised and celebrated, and it was ensured that
employees, who require flexibility during times offasting, are supported.
In 2024 Hastings intends to focus on ethnicity inleadership, social mobility, disability, and inclusive
leadership, starting with the company’s operational
leaders.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Actions and results

Sampo plc
Goals and ambitions
Sampo plc’s target is that the Board of Directors should
always include at least 37.5 per cent of both men andwomen.

On 31 December 2023, the Board of Directors of Sampo
plc consisted of three women and six men. The share ofwomen was 33.3 per cent and, thus, temporarily below
the target. The average tenure of board members wasfour years.

Members of the Group Executive Committee (GEC) areappointed by the Sampo plc Board of Directors. On 31
December 2023, the GEC consisted of seven members,
and the share of women was 14.3 per cent. The average
tenure of the members in 2023 was 9 years.

Binary gender distribution of the Board of Directors

Average tenure of board members

Sampo plc

Sampo plc

Share of women, %31 Dec. 2023

31 Dec. 2022

31 Dec. 2021

33.3

33.3

37.5

Years

Length of tenure of board members

Country of origin of board members

Sampo plc, 31 December 2023

Sampo plc, 31 December 2023≡

Appendices

31 Dec. 2023

31 Dec. 2022

31 Dec. 2021

4

6

6

Educational background of board
members
Sampo plc, 31 December 2023

SUSTAINABILITY REPORT 2023

60

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Binary gender distribution of the Group Executive Committee

Average tenure of Group Executive Committee members

Sampo plc

Sampo plc
31 Dec. 2023

31 Dec. 2022

31 Dec. 2021

14.3

14.3

14.3

Share of women, %Years

31 Dec. 2023

31 Dec. 2022

31 Dec. 2021

9

15

14

Length of tenure of GEC members

Country of origin of GEC members

Educational background of GEC members

Sampo plc, 31 December 2023

Sampo plc, 31 December 2023

Sampo plc, 31 December 2023

SUSTAINABILITY REPORT 2023

61

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Health and well-being
For Sampo Group, it is important to have employees
who are healthy and happy. Placing an emphasis on
employee health and well-being can improve generalemployee engagement and motivation, result in fewer
absences due to illness, and eventually contribute to thebottom line.

Approach
The group level guidance document on health and wellbeing is the Sampo Group Code of Conduct. In addition,
each Group company has adopted supplementarypolicies and guidelines for their own purposes. The
Sampo Group companies have work environment
committees (or similar) set up according to local
legislation. These committees have responsibilities,
including monitoring the work environment, developing
health and safety procedures, and ensuring a highquality of physical and psychosocial well-being. The
duties of the work environment committees depend on
the Group company in question and follow national andlocal legislation.
At Sampo Group, the mental and physical well-being of
employees is managed, by implementing preventative
measures (e.g. stress counselling, preventative
occupational healthcare, good design of offices, andwell-being-related webinars), focusing on work–lifebalance (e.g. workplace flexibility, working time
reduction, dependent care, and special leave), offering
employees meaningful work assignments, education,and organising team activities and sports programmes(e.g. yoga, and sports clubs). In addition, focus is placed

SUSTAINABILITY REPORT 2023

on employment security and responsible workforce
restructuring according to local legal and factual
standards.
Sampo Group investigates health and well-being risks
regularly and takes preventive action to mitigate
potential risks. Risk assessments are performed by all
Sampo Group companies, and any incidents and risks
detected are handled accordingly and reported in therelevant incident reporting tool. Along with employee
surveys, the risk assessments and incident reports
provide valuable indications to further develop thebusiness processes and work environment.
Sampo Group recognises the role that leaders play increating a safe space for employees to be open about
their well-being. By providing leaders with training andtools, Sampo Group wants to establish an engaged andsupportive leadership team that can help employeeswith managing their well-being.
Sampo Group measures health and well-being byabsence due to illness. Sampo Group follows up on
absence due to illness closely in all business areas andoperating countries. Trends and possible actions are
regularly discussed by management teams, leaders,
unions, and work environment committees/steeringgroups, where applicable. The goal is to maintain aproactive approach to reduce absence due to illness.
Sampo Group continuously evaluates the many
initiatives and their contribution to employee health andwell-being.

62

The Group companies measure employee engagement
using company-specific measures. More information on
employee engagement is available in the section
Empowering work environment.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Additional information:www.sampo.com/sustainability/sustainablecorporate-culture/health-and-well-being

Group goals and ambitions
Sampo Group aims to achieve a low level of absence
due to illness.

Actions and results
In 2023, absence due to illness at Sampo Groupdecreased slightly. The decrease was driven by the
positive development in absence due to illness at If andTopdanmark.
During 2023, the number of work-related injuries
remained stable and occupational healthcare coverage
was high. There have been no deaths caused by workrelated injuries at Sampo Group during 2021–2023.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Absence due to illness by company

Products
and services

Communities≡

Appendices

Number of work-related injuries by company

%

2023

2022

2021

2023

2022

If

3.1

3.5

3.2

If

53

47

Topdanmark

2.9

3.2

2.4

Topdanmark

11

3

Hastings

3.0

2.1

3.4

Hastings

14

10

Mandatum

-

2.0

1.1

Mandatum-

7

Sampo plc

0.6

0.7

0.5

Sampo plc

02

Sampo Group

3.0

3.1

3.0

Sampo Group78

69% of FTE average

0.6

0.5

Absence due to illness by country

Number of work-related injuries by country

Sampo Group

Sampo Group

%

2023

2022

2021

2023

2022

Norway

3.8

4.7

3.8

Finland33

33

Sweden

3.5

3.8

3.7

Sweden15

11

United Kingdom

3.0

2.2

3.4

United Kingdom

14

10

Finland

2.9

2.9

2.5

Denmark

13

7

Denmark

2.7

2.9

2.5

Baltic countries2

2

Estonia

1.8

2.0

1.5

Norway1

2

Latvia

1.4

1.4

1.3

Other countries

04

Lithuania

0.6

0.8

0.7

Year 2022 includes Mandatum.

Other countries

4.9

6.3

4.9

Mandatum is included in 2021 and 2022 figures.

SUSTAINABILITY REPORT 2023

63

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Occupational healthcare coverage by company

%

2023

2022

2021

Employees covered by Employees covered by aan occupational
supplementary
healthcare system
healthcare system

Employees covered by Employees covered by aan occupational
supplementary
healthcare system
healthcare system

Employees covered by Employees covered by aan occupational
supplementary
healthcare system
healthcare system

If

100.0

95.8

100.0

98.9

100.0

Topdanmark

100.0

0.0

99.3

0.0

100.0

0.0

Hastings

100.0

100.0

100.0

100.0

100.0

100.0

98.3

Mandatum

-

-

99.0

99.0

99.5

94.0

Sampo plc

100.0

100.0

100.0

100.0

100.0

100.0

Sampo Group

100.0

81.4

99.9

83.5

100.0

81.0

Occupational healthcare coverage by country
Sampo Group

%

2023

2022

2021

Employees covered by Employees covered by aan occupational
supplementary
healthcare system occupational healthcare

Employees covered by Employees covered by aan occupational
supplementary
healthcare system occupational healthcare

Employees covered by Employees covered by aan occupational
supplementary
healthcare system occupational healthcare

Finland

100.0

100.0

100.0

100.0

100.0

100.0

United Kingdom

100.0

100.0

100.0

100.0

100.0

100.0

Baltic countries

100.0

100.0

100.0

100.0

100.0

96.6

Sweden

100.0

98.1

99.9

96.9

100.0

94.8

Norway

100.0

94.1

100.0

100.0

100.0

100.0

Denmark

100.0

20.7

99.5

21.8

100.0

19.5

Other countries

100.0

23.8

97.8

94.0

98.2

98.2

Mandatum is included in 2021 and 2022 figures.

SUSTAINABILITY REPORT 2023

64

Introduction

Business management
and practices

Corporate
cultureIf
Goals and ambitions
If’s goal is that absence due to illness should not exceed
three per cent.

Actions and results
In 2023, If saw a decrease in absence due to illness, andthe goal was nearly met. If has worked proactively toaddress the work environment factors, such as work
autonomy and social support, which tend to be linked
to illness. In 2023, one action was to further improvereporting and analytics to HR and leaders, enabling
more detailed statistics and a historical perspective
regarding absence due to illness.
In the Nordic countries, dedicated health partners work
systematically to develop and communicate tools

Investment management
and operations

Products
and services

Communities

related to well-being for both employees and leaders. In
2023, If arranged well-being weeks in all countries.
During these occasions, employees could listen toexpert guest speakers, meet different health providers
at If offices, and challenge themselves with new healthy
habits and routines. In addition, If celebrated the UN’s
World Health Day, Bicycle Day, and Mental Health Day
in each country during the year.
The New Leader in If training includes information on
how to detect and act on early signs of health issues.
During 2023, If’s health partners updated the training
materials to ensure they support leaders inunderstanding and acting on potential work
environment issues.
Since 2022, questions on psychological safety havebeen part of If’s employee engagement survey
HeartBeat to better understand which factors might

Absence due to illness by country
If
%

2023

2022

2021

Norway

3.8

4.7

3.8

Sweden

3.5

3.8

3.7

Finland

2.9

3.3

2.9
2.5

Denmark

2.1

1.9

Estonia

1.8

2.0

1.5

Latvia

1.4

1.4

1.3

Lithuania

0.6

0.8

0.7

Other countries

5.5

7.1

5.4

If, including all countries

3.1

3.5

3.2

SUSTAINABILITY REPORT 2023

65

Appendices≡contribute to an employee’s ability to take interpersonalrisks without fear of consequences for their self-image,career, or status within the workplace. The results of the2023 survey indicate that while the sense of inclusion ishigh among all If employees, significant differences
emerge when examining the data by demographic
groups. Specifically, there are differences among
employees identifying as one of the two ISURG (IfSpecifically Underrepresented Group) in comparison toemployees who do not consider themselves as part of
the ISURG. It was also noted that despite employees
reporting a high sense of psychological safety,
responses for some themes, such as job demand andcontrol, remain lower. Based on the results, If continues
to develop health and well-being and other related
practices.

Introduction

Business management
and practices

Corporate
cultureTopdanmark
Goals and ambitions
Topdanmark’s goal is that absence due to illness should
be below the average for the entire insurance industry,
as calculated by the Danish Employer’s Association for
the Financial Sector.

Actions and results
In 2023, absence due to illness calculated according to
Sampo Group’s calculation principles was 2.9 per cent(3.2 in 2022), and according to Topdanmark’s

Investment management
and operations

Products
and services

Communities

company-specific calculation method, corresponding to
the Danish Employer’s Association, 3.1 per cent (3.2).
The industry figure for 2023 was not available at thetime this report was completed, but for the year 2022, it
was 3.2 per cent. Overall, the results remain at a goodlevel, and are below industry average. Topdanmark
monitors changes in absence due to illness closely
because the company considers it to be an indicator ofboth physical and mental well-being of its employees.
Topdanmark’s Well-being Committee evaluates theactivities on health and well-being constantly and willcontinue this during 2024.

Absence due to illness by country
Topdanmark
%

2023

2022

Denmark

2.9

3.2

2.4

Topdanmark, including all countries

2.9

3.2

2.4

SUSTAINABILITY REPORT 2023

66

2021

Appendices≡In 2023, Topdanmark should have conducted its biannual health screening, which is used to remediate
negative impacts on physical and mental health for
employees. However, due to the acquisition of Oona
Health in 2023, the health screening was pushed to thebeginning of 2024.

Introduction

Business management
and practices

Corporate
cultureHastings
Goals and ambitions
The goal of Hastings’ well-being programme is to focus
on embedding wellness into Hastings’ culture andcontinuing to raise awareness and deliver educational
health and well-being initiatives. In addition, thecompany invests in the cohort of well-being champions
and mental health first aiders to help deliver key wellbeing objectives.

Actions and results
During 2023, Hastings continued to embed well-being
into all induction journeys, giving all new employees anopportunity to understand what health and well-being
benefits they are entitled to.
In 2023, Hastings’ well-being champions were
supported with a well-being champion development
programme. The programme contains five well-being
modules covering menopause, mental health first aid,

Investment management
and operations

Products
and services

Communities

hybrid working, soft skills training, and financial wellbeing. Upon completing the programme, the well-being
champions receive an internal accreditation. The wellbeing champion community is an essential part of thewell-being programme as it can influence peer-to-peer
communication and promote preventative healthcare.
During 2023, Hastings organised new, mandatory
workshops and refresher training for mental health firstaiders. Once completed, all mental health first aiders
have the opportunity to apply for the internationallyrecognised level 3 Royal Society of Public Healthqualification.
Hastings also continued to deliver its 1-day mental
health workshop for leaders during the year, with 110
leaders attending. The workshop aims to provide
leaders with the skills and confidence to proactively
support employees’ mental well-being, while also
covering boundary setting and self-care.

Absence due to illness by country
Hastings
%

2023

2022

2021

United Kingdom

3.0

2.2

3.4

Gibraltar

0.9

0.9

1.0

Hastings, including all countries

3.0

2.1

3.4

SUSTAINABILITY REPORT 2023

67

Appendices≡Throughout the year, Hastings’ well-being programme
focused on awareness campaigns, which were
supported by various external providers. These included
the Bexhill NHS primary health care offering employees
blood pressure checks, Leicester NHS Diabetes
department offering employees the opportunity to havea diabetes assessment, as well as Leicestershire’s
leading mental health charity, LAMP, visiting to talkabout the support there is within the local community.
2023 also saw other well-being initiatives being
launched, which included a therapy app, providing a
confidential live chat therapy service, menopause
consultations, and a men’s talking and listening group.

Introduction

Business management
and practices

Corporate
cultureSampo plc
At Sampo plc, the key indicators of health and wellbeing are the results of the employee engagement
survey and the absence due to illness rate. The
occupational healthcare partner supports employees
and leaders in well-being matters, and the early care

Investment management
and operations

Products
and services

Communities

principle is followed in everyday leadership work. The
occupational healthcare plan was updated in 2023.

and greener commuting. Since 2022, Sampo plc alsooffers a bike benefit.

In 2023, Sampo plc’s recreational team organised
several cultural, social, and sports events and activities
for the employees. In addition, a new employee
commuter benefit was launched to encourage healthierAbsence due to illness at Sampo plc remained low in2023.

Absence due to illness by country
Sampo plc
%

2023

2022

Finland

0.7

0.8

0.5

Sampo plc, including all countries

0.6

0.7

0.5

SUSTAINABILITY REPORT 2023

Appendices

68

2021

≡

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Competence development
The development of the competencies and professional
skills of all employees is a fundamental part of Sampo
Group’s corporate culture. Sampo Group prioritises
competence and professional development of
employees, both to ensure employee engagement andskill set in the organisation. Providing employees with
opportunities for learning and an understanding ofcustomers’ needs are prerequisite for continued
competitiveness.

Approach
At Sampo Group, the group level guidance document
regarding competence development is the Sampo
Group Code of Conduct, which is reviewed annually andapproved by the Board of Directors of Sampo plc.
Together with supplementary company-specificpolicies, the Code of Conduct outlines how Sampo
Group supports and promotes the professional
development of its employees and develops leadership
practices.
Sampo Group has a comprehensive learning offering
available to all employees, starting from onboarding
processes. Sampo Group offers mandatory training (e.g.
the training requirements of the Insurance Distribution
Directive), voluntary training (e.g. digital skills, language
studies), and training in collaboration with external
suppliers. The type of training programmes used
depends on the part of the organisation in which theemployee is working. Some trainings are mandatory for
all employees (e.g. Code of Conduct training,
compliance training, information security and data
privacy training), and others are part of annual training

SUSTAINABILITY REPORT 2023

cycles. Participation and completion of the mandatory
training is monitored.
Over the years, Sampo Group has seen a growth ofcommunity-driven competence development
opportunities. Employees have engaged in specialist
academies, where they create their own learning paths
according to their interests and professional
competence needs. In some countries, Sampo Groupalso provides on-the-job training, as well as graduate
and internship programmes, some through third-party
relationships, to build the pipeline of its future talent.
These are increasingly being utilised across the businessalongside apprenticeship programmes to bolster
capability and develop future leaders.
At Sampo Group, leadership development is offered,encouraged, and provided in a variety of ways. As
leaders join the company, or are promoted, thecompany ensures there is a leadership induction
covering foundation skills such as performance
management and an introduction to coaching. This
creates consistent principles, tools, and frameworks,
enabling leaders to lead and manage their teams
effectively. In addition, several other management
trainings are offered depending on the role and theGroup company in question. These can include
extensive leadership programmes or briefings on
specific topics, for example. Training for the membersof the boards of directors is organised when necessary.
Sampo Group encourages leaders and employees to
use the competence development tools and supporting
materials available on the company intranets and69

learning platforms. Sampo Group fosters competencedevelopment by offering paid and unpaid study leave.
The form of the leave depends on the purpose, thelength of the leave, and national regulations.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Additional information:www.sampo.com/sustainability/sustainablecorporate-culture/competence-development

Group goals and ambitions
Sampo Group’s aim is that employees’ skills andworking methods are in line with the company’s goals
and provide a competitive advantage.

Actions and results
In 2023, training costs per employee remained stable at
Sampo Group, with some variations between the Group
companies. All companies continued to develop theirtraining, e.g. for customer-facing employees andleaders. Internal training and other initiatives provided
by Sampo Group form a significant part of employees’
competence development. More information on theinternal training provided is available in the companyspecific sections.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Average training costs per employee by company
EUR

Communities≡

Appendices

Average training costs per employee by country

2023

2022

2021

If

895

942

435

Topdanmark

1,498

1,187

1,090

319

318

454

Mandatum

-

1,074

669

Sampo plc

547

901

577

Sampo Group

853

852

568

Hastings

Products
and services

Sampo Group

Hastings’ figure includes costs for both internal and external training investments. For the otherGroup companies, the figures include mainly costs for external training.

EUR

2023

2022

Sweden

1,803

1,919

2021
618

Denmark

1,381

1,140

1,018

Lithuania

796

463

226

United Kingdom

542

316

454

Norway

442

514

357

Finland

437

548

379

Estonia

363

428

278

Latvia

330

440

304

Other countries

309

267

233

Mandatum is included in 2021 and 2022 figures.

If
In 2023, If continued to establish processes tostrengthen customer-centred skills development
relating, for example, to sales techniques, customer
communication, claims handling, and legal knowledge.
In addition, If recruited an additional Competence
Development Lead and established a new team for IT
learning and growth.
If secures growth opportunities for existing employees
by posting job openings internally prior to any external
advertisement. In 2023, a pilot was launched in the IT
organisation to explore internal mobility challenges andopportunities within If. During 2023, close to 700
employees transferred between positions internally.
During 2023, If established an initiative focusing on
digital employee experience. The initiative will establish
common ways for communicating and collaborating at
If, as well as exploring common learning and growthsolutions.

SUSTAINABILITY REPORT 2023

Educational programmes

Leadership development

During 2023, If offered over 1,900 training programmes
through Workday Learning, and approximately 93,000
hours were spent on these trainings. 9,000 individual
employees used Workday Learning during the year. In
2023, If’s employees who are subject to the training
requirements of the Insurance Distribution Directive(IDD) were trained in accordance with the local legal
requirements. On Workday Learning, approximately 50
per cent of the education is related to the IDD.

The Leader Onboarding programme equips new andexisting leaders with the relevant tools and knowledge
they require throughout their leadership lifecycle, andcomplements all other leadership training within If. It
consists of several modules and seminars within
leadership practices, culture, compliance, legal
requirements, and people processes, which are offeredin their first year of employment, and made available toall existing leaders. During 2023, If reviewed thelearning materials to signify a clearer ownership of each
module and to offer appropriate educational formats,depending on the leader’s previous leadershipexperience. The new materials were first introduced in
the Nordics, and certain parts can be integrated into theBaltic training concepts later. As part of the
programme, six New Leader in If onboarding seminars
were arranged in Sweden, Norway, Finland, andDenmark in 2023.

In 2023, If organised monthly seminars as part of its
Coming Together onboarding programme. Seminars
were organised both at the office and virtually to all
new employees. The onboarding includes summer
workers and offers seminars in English to ensure nonnative-speaking employees are given the opportunity toparticipate. During 2023, the structure, scope andcontent of the onboarding programme was reviewed toensure a relevant introduction to If’s business and core
processes.

70

If’s HR organisation, consisting of approximately 130
employees, partake in regular skills development andIntroduction

Business management
and practices

Corporate
cultureknowledge sharing on HR topics to adequately support
the organisation in navigating change. Leaders areoffered support through the New Leader Forums.
During 2023, topics included salary setting in uncertain
times and employer branding.
All leaders are obliged to partake in If’s Leadership
Compass programme, which was launched in 2022. The
programme enables leaders to support and motivate
their teams in a way that contributes to If’s vision andstrategy. During 2023, all participants together spentapproximately 40,000 hours on the programme andreceived over 4,000 hours of individual coaching froman external professional coach. During 2023, thelearning materials were reviewed based on feedback
collected from the first year’s participants. The mostrecent Leadership Compass programme was offered to
new leaders in January 2024. Those who completed theprogramme in 2023 had access to the Leadership
Library in order to keep developing their leadershipskills, and they are invited to two Leader Forums during
2024.
A majority of 2023 was dedicated to the Leadership
Compass programme. However, investments are also
made towards targeted leadership development
programmes in the business areas each year. For
instance, the Claims organisation conducted a leader
programme consisting of modules relating tooperational excellence, value creation, and digitalvisualisation. The agile transformation thatencompasses both the Private and Commercial
business areas, as well as IT and Marketing, has created
new roles and new requirements for leadership skills
and people processes. Two important initiatives
towards building future technical skills were delivered
through the Tech that Matters event and the AI days,
which were arranged during the second half of 2023.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Appendices≡

Educational programmes

Topdanmark
In 2023, Topdanmark focused on the digital workplace.
The company has a hybrid workplace model, which
underscores the importance of reinforcing employees’skills and knowledge of digital tools. In particular, digitalmeans of cooperation are crucial for all employees tomaster and, in response, Topdanmark developed
training on Microsoft 365 for employees during theyear.
At the end of 2023, Topdanmark launched a newlearning and competence development strategy, toensure a coherent concept for learning across theorganisation. Previously, competence development washandled in a decentralised manner in the respective
divisions. Going forward, the company will focus on
ensuring equal access to learning across theorganisation.
Objectives of Topdanmark’s learning and competencedevelopment strategy (by the end of 2025) are:• Annual training hours per employee at minimum 40
hours.
• A satisfaction score of 4 out of 5 from attendees onlearning sessions.
• Gender learning gap <10 per cent (in both hours and
DKK spent).
• When a training need is identified, it must take nolonger than 30 days until training materials or learning
opportunities are available.
• Training should be held digitally (exceptions may
apply).

71

There are several mandatory e-learning courses that all
employees of Topdanmark will have to take and pass.
These include, for example, e-learning on the Code of
Conduct. In 2023, 96 per cent of Topdanmark’s
employees participated in the Code of Conduct elearning.

Leadership development
Topdanmark organises specific training for leaders.
Examples include Introduction to Management offered
to all new leaders, and the Introduction to leadershippipeline offered to all leaders. In 2023, Topdanmark
offered also other management training, such as
General Management for Personnel Managers andIntroduction to Management, the latter being offered to
newly hired leaders to understand the management
principles at Topdanmark.

Introduction

Business management
and practices

Corporate
cultureHastings
In 2023, Hastings made investments in ensuring all its
learning material supports good customer outcomes, inline with the FCA’s new Consumer Duty principles. This
involved a comprehensive review of all material andensuring Hastings Learning and Development assurance
model and curriculum has the appropriate controls inplace.
Hastings focused on supporting customer
understanding by delivering an interactive session toapproximately 1,300 customer-facing employees toensure customers receive simple and straightforward
written communications. The next stage is to progress
the rollout of conversation skills across key customer
facing roles. This intervention is supported throughleader upskilling, quality assurance, and consistent callcalibrations.
In 2023, Hastings invested in strategic learning
partnerships. These include, for example, an AI
questioning tool supporting competency in key teams
across the business and partnerships to increase
learning effectiveness. In addition, Hastings invested in
the claims system to support the company’s ambition of
being the best-in-class claims operation. Activities haveincluded the creation of dedicated new roles to support
route to competency and the journey of new starters
and upskill of existing employees and leaders.
In 2024, Hastings will focus on developing talentinternally to support some of its critical capabilities
including digital, pricing, data, and analytics. Hastings
will also be working towards uplifting its internallearning and development capability alongside theappropriate use of strategic partnerships.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Educational programmes
Hastings has a suite of mandatory learning interventions
that are completed by all employees. At the end of2023, Hastings’ regulatory and mandatory training
completion rate was 98 per cent, and the IDD
adherence rate was 99 per cent.
During the year, Hastings continued to hold several
strategic partnerships to support the development of
employees and create a pipeline of talent bothinternally and externally. As a member of Women in
Data, Hastings supports women who are currently
working in or have ambitions to work in data. Hastings
will continue this partnership in 2024, aiming to increase
gender diversity in senior data roles.
In 2023, Hastings supported 30 women employees andemployees from an ethnic minority background toparticipate in the Moving Ahead 30% Club externalcross-company mentoring programme. Hastings also
continued its partnership with Generation, a non-profit
organisation that specialises in training skilled yet
underemployed candidates from diverse backgrounds
in data and analytics. During 2023, a further 9
individuals were hired.
Throughout 2023, Hastings’ employees continued toenrol onto structured apprenticeship programmes. In
2023, 59 employees started an apprenticeshipprogramme.

Leadership development
In 2023, Hastings continued the Leading for Growthdevelopment programme, which is designed to build,develop, and align the leadership community. It alsoseeks to build leadership capability, enabling leaders torealise the potential employees hold, and maximise thecapacity Hastings has to drive and deliver growthambitions. 458 leaders attended an in-person module in72

Appendices≡

Leicester, with a further 789 leaders attending a virtual
session during the year. Hastings expects the
programme to continue into 2024.
In 2024, Hastings will be launching a new training
programme called Operational Leadership Excellence(OLE). The programme has been specifically designed
for customer-facing leaders aiming to deliver greatcustomer, colleague and company outcomes throughthe development of leadership skills, behaviours, andconfidence.

Sampo plc
In 2023, Sampo plc actively recruited new employees,
largely due to the reorganisation of responsibilities inconnection with the demerger of Mandatum. The new
employees participated in general introduction training
and more specific onboarding related to theirrespective unit. In addition, Sampo plc offeredsupplementary training to existing employees based on
the company’s training programme.
The annual development discussions were held at theend of 2023. Sampo adjusted the discussion guidelines
slightly during the year to better cater to newly hired
employees and employees with long careers at Sampo
plc.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Remuneration
Sampo Group wants to offer attractive total
remuneration packages to both current and potential
employees in order to recruit and retain the best talent.
Motivating remuneration can affect employees’
productivity and work performance and lead toemployee engagement.

Approach
At Sampo Group, the group level guidance principles
regarding remuneration and general conditions of work
are the Sampo Group Remuneration Principles and the
Sampo Group Code of Conduct, respectively. In
addition, each Group company has adopted
supplementary policies for their own purposes.
The different forms of remuneration used are fixed andvariable compensation, as well as pensions and otherbenefits. Fixed compensation is the basis of every
employee’s remuneration package. Variable
compensation is used to ensure the competitiveness ofthe total remuneration package and can be either shortterm (short-term incentives, STI) or long-term (longterm incentives, LTI).
At Sampo Group, most employees, including all senior
executives, who participate in variable compensation
programmes have ESG criteria linked to their variable
compensation, thereby supporting the sustainable
development of the business. Both quantitative andqualitative criteria are used for assessing performance.
Customer satisfaction metrics are widely used for all

SUSTAINABILITY REPORT 2023

employees, and employee satisfaction is often includedin the annual goals of leaders and senior executives. In
addition, individual Group companies’ result criteria canbe linked to their strategic sustainability initiatives,
which derive from their sustainability programmes. ESG
targets have also been integrated into the Group CEO
and the Group Executive Committee members’ STI
programmes.
The ESG targets are updated every year as part of theannual planning process. In general, to be eligible forpayment from a variable compensation programme,
participants must also have acted in compliance withinternal and external rules for the business. Board
members are independent of the companies and do notparticipate in variable compensation programmes.
At Sampo Group, remuneration depends on objective
criteria, such as work experience, competence, position,and responsibilities. Pay and additional benefits are notbased on or affected by gender or any other nonprofessional aspect. The Group companies have, forexample, job title and job position structures to ensurethat employees in the same position are employed
under the same conditions, and internal and externalbenchmarks are used in setting the salary ranges. To
ensure fair and objective remuneration for employees,
all decisions concerning individual remuneration madeby a leader must also be approved by the leader’sleader (grandparent principle).

73

The Group companies conduct annual equal pay
analyses in accordance with local legislation and theircompany-specific needs. The purpose of these analyses
is to identify, handle and prevent unwarranted pay
differences that may be derived from gender.
Sampo Group mainly uses external remuneration
consultants for remuneration benchmarking purposes,
and remuneration consultants are always independentof the organisation, its governing bodies, and senior
executives. The Board of Directors of the respective
Group company oversees the remuneration area andrelated policies and processes. In major Group
companies, a remuneration committee has been
appointed to support the Board.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Sampo Group Remuneration Principles:
www.sampo.com/governance/remuneration
Sampo Group Remuneration Report for
Governing Bodies 2023:
www.sampo.com/year2023
Additional information:www.sampo.com/governance/remuneration

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Group goals and ambitions

Remuneration structure
Sampo Group, 2023

All remuneration systems at Sampo Group shouldsafeguard the long-term financial stability and value
creation of the Group and comply with regulatory andethical standards. They must also be aligned with therisk management framework. Remuneration
mechanisms should encourage and stimulate
employees to do their best and surpass their targets,and they should be designed to reward fairly forprudent and successful performance. At the same time,
to safeguard the interests of other stakeholders,remuneration mechanisms must not generate conflictsof interest, or entice employees to engage in excessive
or unwanted risk-taking.

Actions and results
At Sampo Group, the main reasons for the gender pay
gap are the lack of women at the highest levels ofmanagement and the predominance of women at thelower organisational levels. In addition, certain
functions, such as IT and customer centre roles, aredominated by men and women, respectively. For thesefunctions and for the lower organisational levels, themain goal is to make sure that the available talent pool,when recruiting, becomes more diverse. Other
initiatives to close the pay gap include encouraging
more women to apply for top-level positions andincorporating more women in succession planning.
The Group CEO pay ratio is followed up on a regularbasis to compare the development of CEO
remuneration with the average remuneration of Sampo
Group employees. The variation in the CEO pay ratio is
mainly a result of fluctuations in the variable
compensation paid to the Group CEO, as short-termand long-term incentives form a significant share of theGroup CEO's total remuneration. In 2023, the partial

SUSTAINABILITY REPORT 2023

74

Introduction

Business management
and practices

Corporate
culturedemerger of Sampo Group and fluctuating currency
rates affected the CEO pay ratio.

Investment management
and operations

Products
and services

Communities

Appendices

Remuneration

Average employee remuneration

Sampo Group

Sampo GroupThe average employee remuneration is reported bycountry. Changes from one year to another are mainly
explained by salary raises and variations in variable
compensation pay-out levels. The average employee
remuneration varies between countries due todifferences in the general market salary levels,
occupational pension systems, and social security
structures, for example. In addition, currency rate
fluctuations impacted the reported numbers in 2023.
The highest average remuneration of employees, interms of both fixed and total remuneration, is in
Denmark and Norway, while the lowest is in the Baltic
countries and the UK. The figure for Other countries isvolatile due to the relatively small number of
employees.
Mandatum is included in 2021 and 2022 figures.

SUSTAINABILITY REPORT 2023

75

Mandatum is included in 2021 and 2022 figures.

≡

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Average remuneration by binary gender
Sampo Group
2023

2022

Women

Men

Pay gap(ratio)Fixed remuneration

53,726

68,229Fixed and variable remuneration

57,67478,545

EUR

2021

Pay gap
(%)

Women

Men

Pay gap(ratio)Pay gap
(%)

Women

Men

Pay gap(ratio)

0.79

21.3

54,352

69,8600.73

26.6

58,53581,316

Pay gap
(%)

0.78

22.2

52,73567,755

0.78

22.2

0.72

28.0

56,361

77,5130.73

27.3

Mandatum is included in 2021 and 2022 figures.
Excluding the remuneration of the Group CEO and President.

Average employee remuneration vs. Group CEO remuneration
Sampo Group
Average employee remuneration, EUR
Group CEO remuneration, EUR

2023

2022

2021

68,442

69,941

66,915

3,138,705

3,327,858

2,511,459

46:1

48:1

38:1

Pay ratio
All figures include Mandatum.

Average employee remuneration by country
Sampo Group
2023

2022

2021

Fixed remuneration

Fixed and variable
remuneration

Fixed remuneration

Fixed and variable
remuneration

Denmark

97,963

107,596

95,649Norway67,532

74,207

71,692Finland60,70667,449EUR

Fixed remuneration

Fixed and variable
remuneration

104,286

91,826

100,327

78,61768,306

74,69160,82070,85459,93968,916

Sweden55,401

63,57756,001

62,96856,08061,327

United Kingdom

41,09747,49240,514

48,29339,21644,813

Baltic countries

35,801

39,16932,42636,02730,48333,932Other countries

37,68448,02950,37858,81543,25048,555Mandatum is included in 2021 and 2022 figures.

SUSTAINABILITY REPORT 2023

76

Introduction

Business management
and practices

Corporate
cultureIf
At If, all employees, including top management, whoparticipate in variable compensation programmes, have
ESG criteria linked to their remuneration criteria. In
2023, one common ESG metric used was customer
retention.
In 2023, If’s joint ESG metric for managers and key
specialists (variable compensation programme formanagers and key specialists, VCPM) was to continue
strengthening the One If Strategy Framework bydelivering on the strategic foundations - Customer, Risk,
People & Culture, and Sustainability. A significant
portion of leaders and key specialists participating in
VCPM also had eNPS and leadership metrics as a part oftheir annual goals.
Since 2020, If has conducted an annual Nordic Equal
Pay Analysis. In 2023, If made preparations to include
its Baltic operations as part of the process from 2024
onwards.

Topdanmark
Topdanmark has sustainability metrics in its cash andshare based STI programme for the executive
management and other key personnel in senior

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

management. This means that the result criteria for the
STI programme include sustainability initiatives that
support either the company’s sustainability aspiration in
general and/or the sustainability programme. The
sustainability initiatives are assessed based on theirlevel of impact on the company’s sustainability targets,and the extent to which they have been implemented.
The relative weighting of the sustainability metrics isfive per cent of the STI bonus.
In 2023, a total of 29 sustainability initiatives wererewarded, including initiatives related to GHG emission
reductions and health care, for example. In 2024,
Topdanmark will investigate the possibility of an evenstronger connection between the STI programme andthe company’s sustainability targets.

Hastings
Hastings’ variable compensation takes into accountannual performance against the organisation’s 4Cs(colleague, customer, company and community) goals,
which include measures on employee engagement,
customer experience, progress on Hastings’ ESG anddiversity and inclusion agendas, and the embedding ofstrong governance. Performance across these goals has
a direct impact on the size of the short-term incentive

77

Appendices≡pool available during the annual pay review process
and, therefore, influences the individual earnings
opportunities of colleagues at all levels of theorganisation.
The UK cost of living pressures continued throughout
2023, driven predominantly by high inflation andinterest rate increases. Whilst anticipating a return tonormal in 2024, Hastings decided to continue the costof-living support implemented in 2022, specifically:• Employees earning up to and including GBP 47,250
per year benefited from a GBP 500 bonus advanceincluded in their October 2023 pay.
• A commitment for all frontline employees within
Hastings’ step pay framework to receive a minimum 5
per cent pay increase in March 2024.
• Hastings continued support to the Colleague
Hardship Fund for employees experiencing financial
difficulties.
• A new mortgage advice service was launched, free toall employees, plus friends and family.
Hastings’ latest Gender Pay Gap Report is available on
the company website.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Sustainable investment management and operations
Investment management at Sampo Group ....
Investment management at If .............................
Investment management at Topdanmark.......
Investment management at Hastings ...............
Climate impact of investments ...........................

SUSTAINABILITY REPORT 2023

79
80
84
86
88

78

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Investment management at Sampo GroupAt Sampo Group, responsible investment is defined as
an approach to managing assets so that ESG issues areincorporated into investment analysis, decision-making,and reporting. Responsible investment also includes
active ownership related to ESG issues. Responsible
investment complements traditional financial analysis
and, therefore, ESG issues are considered in parallelwith other factors affecting the risk-return ratio ofinvestments. The Sampo Group companies manage
their investments according to their own responsible
investment policies and provide data for group level
reporting regularly. The investment policies are updated
annually and approved by the boards of directors ofeach Group company.
Sampo Group has been a signatory of the UN Principles
for Responsible Investment (PRI) since 2019. In October
2023, Sampo joined the SBTi, which means that thecompany will define group level science-based climate
targets for its investments. The targets will be
submitted to the SBTi for validation as soon as possible,
but no later than October 2025.

Responsible investment policies:
www.sampo.com/sustainability/investmentmanagement-and-operationsSUSTAINABILITY REPORT 2023

Investments by company

Investments by asset class

Sampo Group, 31 December 2023

Sampo Group, 31 December 2023

Investment allocation by company and asset class
Sampo Group, 31 December 2023
Asset class

If

Topdanmark

Hastings

Public sector

9.8%

4.1%

2.8%

Sampo plc
0.0%

Money market

1.0%

0.0%

26.5%

57.9%

Other fixed income

57.8%

1.4%

68.9%

4.2%

Covered bonds

20.0%

81.5%

0.0%

0.0%

Equities

11.4%

3.8%

0.0%

0.0%

Private equity

0.0%

1.4%

0.0%

37.9%

Real estate

0.0%

4.6%

0.0%

0.0%

Other

0.0%

3.4%

1.9%

0.0%

Total, EUR billion

10.9

2.2

1.7

2.3

79

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Investment management at If
Commitment to responsible
investment

Science-based climate targets forinvestments

If’s responsible investment practices reflect Sampo
Group’s commitment to the UN PRI and the UN Global
Compact. If also supports the Paris Climate Agreement
and has set science-based climate targets for its
investments. The portfolio managers at If areresponsible for managing investments in accordancewith If’s Responsible Investment Policy.

In December 2023, If’s climate targets were validated
and approved by the SBTi. If developed targets inaccordance with the sector-specific guidelines for thefinancial sector.
If uses the Temperature Rating Approach for corporateloans, listed equity, corporate bonds, funds, and ETFs.
These represent more than 90 per cent of If’s total
investment portfolio. The Sectoral Decarbonisation
Approach (SDA), meaning emissions-based physicalintensity targets, is used for commercial real estateloans, since the Temperature Rating Approach cannot
be used for this asset class.

Approved SBTs for investments
If
Asset class

SBT• If commits to align its Scope 1 + 2 portfolio temperature score by invested value of its listed
equity, corporate bond, fund, and ETFs portfolio from 2.52°C in 2020 to 2.04°C by 2027.
Listed equity, corporate • If commits to align its Scope 1 + 2 + 3 portfolio temperature score by invested value of its listedbonds, funds, and ETFs
equity, corporate bond, fund, and ETFs portfolio from 2.7°C in 2020 to 2.14°C by 2027.

Corporate loans• If commits to align its Scope 1 + 2 portfolio temperature score by invested value of its corporateloan portfolio from 2.91°C in 2020 to 2.25°C by 2027.
• If commits to align its Scope 1 + 2 + 3 portfolio temperature score by invested value of its
corporate loan portfolio from 2.84°C in 2020 to 2.21°C by 2027.

Corporate loans:
Commercial real estate• If commits to reduce GHG emissions from the commercial real estate sector within its corporateloan portfolio 57.2 per cent per square meter by 2028 from 2020 base year.

SUSTAINABILITY REPORT 2023

80

Currently, If’s responsible investment approach includes
several features which will contribute to meeting theportfolio targets (e.g. active ownership, sector-based
screening). In 2024, If will further develop its approachfor reaching the investment targets and update its
Responsible Investment Policy.

ESG integration
If integrates ESG criteria systematically into investment
decision-making and analysis. Risks arising from ESG
criteria are evaluated using an internal ESG traffic-lightmodel, which is based on ESG risk ratings provided by
an external data provider. The risk ratings measurecompanies’ exposure to ESG-related risks, including
climate change, and management of material ESG
issues. Based on the risk ratings, issuers are classified
into internally defined risk categories: low risk, medium
risk, high risk, and severe risk. Possible actions dependon the risk category and a thorough analysis of the ESG
risks and their consequences for the investee company.

Introduction

Business management
and practices

Corporate
cultureActions and results
On 31 December 2023, 0.2 per cent of If’s investments
included in the traffic-light model were invested incompanies in the severe ESG risk category. Thisconsisted of investments in two companies.

Investment allocation according to the
ESG risk categories
If, 31 December 2023

Investment management
and operations

Products
and services

Communities

carefully evaluated based on an internal set of criteria.
The criteria include, for example, the target company’s
energy mix and proportion of renewable energy
sources, plans to grow the renewable energy business,and emissions reduction targets.
Investments in the sensitive sectors are monitored
closely, both for direct and indirect involvement. Sector
involvement information is based on data provided by
an external data provider. If’s Responsible Investment
Policy is reviewed annually, which means that the list ofsensitive sectors and the internally defined tolerance
thresholds can change and develop over time. In some
sectors (e.g. coal, oil), exemptions to the tolerance
thresholds can be made for companies that have acredible plan for transitioning to a more sustainablebusiness model.

≡

Appendices

Actions and results
On 31 December 2023, 1.3 per cent of If’s total
investments were in sensitive sectors. This means that in
total, including both direct and indirect involvement, If
had invested in four companies operating in sensitive
sectors that exceeded the sectors’ tolerance thresholds.

Sensitive sectors
Calculated according to market value. Includes direct
investments with a risk rating provided by an external data
provider.

Sector-based screening
If sees that certain industry sectors are considered tocarry more ESG-related risks (e.g. reputational risk,
regulatory risks, human rights risks, labour rights risks,technology risks, and transition risks) than others.
According to If, these so-called sensitive sectors arecontroversial weapons (including biological, chemical,
nuclear, and cluster weapons), adult entertainment,
coal, gambling, military equipment, oil, and tobacco.
The coal and oil screenings enable If to better monitor
and manage risks arising from fossil fuels during thetransition to a low-carbon economy, as companies
exceeding the limits established for sensitive sectors are

SUSTAINABILITY REPORT 2023

If
Number of companies
invested in on 31 Dec. 2023

SectorThresholdControversial weapons

Direct business (production): 0%
Indirect business (distribution/services): 0%0

Adult entertainment

Direct business: 0%
Indirect business: 50%

0

Coal

Direct business: 5%
Indirect business: 5%

1

Gambling

Direct business: 50%
Indirect business: 50%

0

Military equipment

Direct business: 50%
Indirect business: 50%

1

Oil

Direct business: 30%
Indirect business: 30%

2

TobaccoDirect business: 0%
Indirect business: 50%

081

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Norms-based screening

Actions and results

Active ownershipIf screens its current and potential investments forpossible violations of international norms and standards
using research provided by an external data provider.
The international conventions considered in this context
include the UN Global Compact, the OECD Guidelines
for Multinational Enterprises, the ILO Tripartite
Declaration of Principles concerning Multinational
Enterprises and Social Policy, the Guiding Principles on
Business and Human Rights, and the Paris Climate
Agreement. If a violation is detected among the current
holdings, depending on the severity, nature, and extent
of the breach, portfolio management measures may
consist of direct dialogue with the company’s executive
management or an engagement action. As a measure oflast resort, the investment can be sold if the investee
company does not take corrective action within areasonable timeframe.

On 31 December 2023, If had no investments incompanies with confirmed norms violations.

As an active owner, If strives to ensure that its investee
companies take sustainability aspects into account intheir operations. The key issues on which If engages
with investees include international standards,
governance and compliance-related matters,sustainable business operations, environmental aspects
and climate change.

Norms-based screeningIf, 31 December 2023

Active ownership practices include internal staff
engagement, voting at AGMs, and pooled engagementwith other investors. In general, If only engages withcompanies in which it has invested. Additional criteria
considered before engaging are, for example, themateriality of the ESG issue, the size of the investment,
actions already taken by the investee company, andgeographical location.

Actions and results
During 2023, If took part in nine pooled engagements
and attended nine AGMs. If did not abstain from voting
in any AGMs during 2023.

Participation in AGMs

Pooled engagement

If

If
2023

2022

2021

Number of AGMs attended

9

9

10

Voting for the Board’s proposal

9

9

10

Year

Number of pooled
engagements
participated in

Reasons for theengagement

Status ofthe engagementon 31 Dec. 2023

2023

9

Environment, labour rights,
human rights, corruption

4 suspended, 5 active

All pooled engagement cases are signed by Sampo Group and included those that also Mandatum
had investments in.

SUSTAINABILITY REPORT 2023

82

Introduction

Business management
and practices

Corporate
cultureExternal investment manager
selection
If has investments in funds (e.g. equity, fixed income,exchange-traded, and alternative), bank accounts, andderivatives. All fund investments are managed byexternal fund managers. If encourages external fundmanagers to support initiatives such as the UN PRI and
UN Global Compact, and to adopt responsible

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

investment policies. During the due diligence process
when selecting new external fund managers, theportfolio managers establish relevant ESG aspects suchas the extent of sustainability reporting, identified
sustainability risks and opportunities, as well as the fundmanager’s commitment to responsible investment.

83

Appendices≡

Actions and results
On 31 December 2023, all of If’s fund investments weremanaged by asset managers who had signed the UN
PRI. In addition, 87 per cent of the funds were managed
by asset managers who had signed the UN Global
Compact.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Investment management at Topdanmark
Commitment to responsible
investing
All Topdanmark’s investment practises are inaccordance with the company’s Policy for Responsible
Investment, which is based on the ten principles of the
UN Global Compact. Topdanmark’s Board of Directors
bears the ultimate responsibility for this policy, while
Topdanmark Forsikring A/S and the Investment
department of Topdanmark Forsikring A/S are in
charge of the implementation of the policy, andensuring that the investments continue to meet thepolicy requirements. The policy applies to all asset
classes. However, Topdanmark has a proportional
approach to analysing different asset classes to ensurethat the attention is directed to the areas where theperceived ESG risk is most significant.

Science-based climate targets forinvestments
Topdanmark has joined the SBTi and its Net-Zero
Standard. This means that the company will definescience-based climate targets for investments tobecome carbon neutral by 2050. These targets will be
submitted to the SBTi for external validation no later
than end of May 2024.

SUSTAINABILITY REPORT 2023

ESG integration

Actions and results

Topdanmark conducts annual ESG risk analysis of thecompany’s holdings, based on ESG data from anexternal service provider. Besides the annual analysis,
investments are regularly evaluated according to their
ESG risk, both at company level and an aggregate level
through the service provider. While Topdanmark does
not have a stated goal for the ESG risk rating, it ismonitored to avoid unnecessary risk and to understandcompany exposure to ESG risks.

On 31 December 2023, Topdanmark’s investments did
not violate the set threshold.

Actions and results
On 31 December 2023, Topdanmark’s total ESG risk
rating for the investment portfolio was 16.9 (including
covered bonds, fixed income, and equities), against abenchmark (MSCI ACWI) rating of 21.3. The result
indicates that Topdanmark’s investments had a lower
ESG risk than the benchmark.

Sector-based screening
Certain sectors are controversial by nature andassociated with excessive costs for society and/or
negative impact on the climate and the environment.
According to Topdanmark’s sustainability principles,
this applies to the production of tar sands, thermal coal,smoking tobacco, and controversial weapons.
Regarding Topdanmark’s investment activities, thismeans that its investment portfolio is screened annuallyfor these sectors. Topdanmark does not exclude
companies that are exposed to sensitive sectors but has
set a threshold for the share of investee companies’
revenue on a maximum of 5 per cent arising fromcontroversial business activities.
84

According to a sector-based screening conducted in
December 2023, a company in one of the funds
Topdanmark had invested in, had one per cent ofrevenue coming from controversial weapons. In 2023,
Topdanmark reached out to the external investment
partner to have the company removed from the fund at
the next rebalancing and will follow up with the external
investment partner later in 2024.

Sensitive sectors
Topdanmark

SectorNumber of companies
invested inon 31 Dec. 2023

Fuel based on tar sands0

Thermal coal0

Smoking tobacco0

Controversial weapons0Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Norms-based screening

Active ownershipTo ensure that Topdanmark’s current and potential
investments do not violate international norms andstandards, all investment assets are screened annually
against the UN Global Compact, the OECD Guidelines
for Multinational Enterprises, the ILO Tripartite
Declaration of Principles concerning Multinational
Enterprises and Social Policy, the Guiding Principles on
Business and Human Rights, the Universal Declarationof Human Rights, the UN SDGs, and the Paris Climate
Agreement. If, based on the screening, Topdanmark
believes that an investment is in violation ofinternational norms and standards, Topdanmark willtake action either through dialogue with the external
investment managers, or possibly by divesting theposition.

Topdanmark conducts active ownership through its
external asset managers, who exercise both directcompany and collaborative engagement with investee
companies while attending and voting at investee
companies’ AGMs and engage with investees in theevent of a verified or potential breach of the UN Global
Compact principles. If the dialogue does not lead to achange in conduct, it can result in divestment. For
Topdanmark to ensure that the external investment
managers exercise the desired ESG engagement, thecompany receives bi-annual investor engagement andvoting reports on how active ownership has been
conducted.

Actions and results

In 2023, the active ownership of Topdanmark was
conducted on its global ETFs invested through anexternal partner. The partner voted in 826 AGMs out ofa possible 835 AGMs. Moreover, the external partner
was involved in direct engagement with 399 individualcompanies out of the 1,350 companies represented in
the ETFs. Notably, 20 per cent of these engagements
were dedicated to addressing environmental issues,
such as climate risk management and biodiversity
conservation.

On 31 December 2023, Topdanmark had no investments
in companies with confirmed norms violations.

SUSTAINABILITY REPORT 2023

Appendices≡External investment manager
selection
When selecting new investment managers, Topdanmark
prioritises managers who endorse the principles set
forth by the UN PRI and the UN Global Compact, whileemphasising ESG screening criteria for the investment
funds to be, at minimum, equally restrictive as
Topdanmark’s own set criteria in the policy for
responsible investment. Moreover, Topdanmark only
enters into business with external investment managers
who have the size and integrity that enable them toenter into dialogue with companies to promote more
ESG friendly conduct and influence through active
participation and voting at the underlying companies’
AGMs.

Actions and results

85

Actions and results
On 31 December 2023, all of Topdanmark’s investments
in ETFs were managed by external investment
managers who are PRI and Global Compact signatories.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Investment management at Hastings
Commitment to responsible
investment
At Hastings, investment management is undertaken by
Advantage Insurance Company Limited (Advantage),the insurance subsidiary of Hastings. Quarterly
reporting to the insurance subsidiary’s Investment
Committee includes ESG ratings and any exposure to
excluded or sensitive sectors. The committee also
facilitates reviews of guidelines and may report toHastings’ Board of Directors when changes to the ESG
framework have been recommended or any breaches
arise.
Hastings views responsible investment as a process ofcontinuous development. Advantage is a signatory of
the UN PRI, which further supports integration of ESG
considerations into investment processes.

Science-based climate targets forinvestments
Hastings committed to the SBTi and its Net-Zero
Standard in August 2022. This means that the company
will define science-based climate targets for its
investments that will be submitted to the SBTi forvalidation no later than August 2024.
Hastings’ current climate targets for investments are to
reduce carbon intensity in the core investment portfolio
by 50 per cent by 2030 and to be net-zero by 2050.

SUSTAINABILITY REPORT 2023

The company’s Investment Committee oversees
progress against the targets on a regular basis. During2023, the carbon intensity of Hastings’ portfolio
exceeded the targeted 6 per cent annual reduction inline with the company’s 2030 target of 50 per centreduction. Hastings’ current climate targets forinvestments are being reviewed as part of the process
for setting SBTs according to the SBTi’s methodology.

ESG integration
Hastings works with external investment managers tointegrate ESG criteria into its investment process
without negatively impacting returns, diversification, or
the overall quality of the portfolio. Hastings iscommitted to maintaining an average ESG rating of “A”
on its fixed income portfolio, based on MSCI ratings(scale CCC–AAA).

Actions and results
On 31 December 2023, Hastings’ fixed income
portfolio’s average MSCI ESG rating was maintained
above target at “AA”.

Sector-based screening
At Hastings, sector-based screening covers thermal
coal extraction, thermal coal generation, tobacco, andcontroversial weapons. These sectors have been
excluded from the investment portfolio. In addition,

86

Hastings undertakes regular reviews to identify
exposure to other sensitive sectors, including nuclear
power, fossil-based energy, adult entertainment, andgambling.

Actions and results
In 2023, no new investments were made in the excluded
sectors. The current portfolio exposure to these sectors
is due to investments made prior to implementing thecompany’s ESG strategy. On 31 December 2023,
Hastings’ portfolio retained exposure to two companies
that produce tobacco, one company that derives lessthan three per cent of its revenue from tobacco, andtwo companies that derive some revenue from thermal
coal extraction. Hastings will not make further
investments in these industries when the positions
mature. The current positions will all have matured by
2026.

Sensitive sectors
Hastings
SectorNumber of companies invested inon 31 Dec. 2023

Thermal coal extraction

2

Thermal coal generation0

Tobacco3

Controversial weapons0Introduction

Business management
and practices

Corporate
cultureNorms-based screening
Hastings conducts norms-based screening, withquarterly reporting to the Investment Committee oncompanies that do not meet the principles of the UN
Global Compact. The Investment Committee thenmakes decisions on further actions, together withinvestment managers.

Actions and results
On 31 December 2023, Hastings had 0.7 per centportfolio exposure, through two holdings, to companies

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Appendiceswith the UN Global Compact Fail status. Engagementwith these companies is undertaken by Hastings’
external investment managers.

investment, active ownership, and their resourcing,monitoring, and reporting of ESG and sustainability
factors.

External investment manager
selection

Actions and results

Hastings has included the UN PRI status and ESG
practices as part of external investment manager
selection. This includes due diligence on the company’s
general policies and practices, as well as consideration
towards the fund manager’s commitment to responsible

87≡

All of Hastings’ external investment managers are
signatories to the UN PRI and have responsible
investment policies, and active ownership policies and/or practices in place.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Climate impact of investments
Sampo Group measures the climate impact of its
investments annually. Therefore, Sampo Group
conducted a carbon footprint analysis and a climate
impact assessment of its direct equity and fixed income
investments again in 2023. The calculations included If,
Topdanmark, Hastings and Sampo plc’s investments as
at 31 December 2023, and they represented
approximately 75 per cent of Sampo Group’s total
direct equity and fixed income investments.

The equity and fixed income portfolios included in thecalculations had a market value of EUR 10,620 million.
That means that the carbon footprint analysis and theclimate impact assessment covered approximately 62
per cent of Sampo Group’s total investments at the endof 2023. The 2022 and 2021 calculations included
Mandatum’s investments and, therefore, the 2023
results are not entirely comparable to those of previous
years.

Carbon footprint of direct equity and direct fixed income investments
Sampo Group
31 Dec. 2023

31 Dec. 2022

Financed Scope 1 and 2 emissions (tCO2e)

300,199

470,899

31 Dec. 2021
601,270

Financed emissions incl. Scope 3 (tCO2e)6,513,044

7,024,855

6,289,198

Relative carbon footprint (tCO2e/invested)

28

39

40

Carbon intensity (tCO2e/EURm revenue)

87

128

152

Weighted average carbon intensity (tCO2e/EURm revenue)

29

56

63

Mandatum is included in 2021 and 2022 figures.

SUSTAINABILITY REPORT 2023

88

Carbon footprint analysis
The carbon footprint (Scopes 1 and 2) of Sampo
Group’s direct equity and direct fixed income
investments was 300,199 tCO2e at the end of 2023. This
corresponds to a weighted average carbon intensity of
29 tCO2e for each million euros of revenue. The results
were impacted by the Mandatum demerger.

Introduction

Business management
and practices

Corporate
cultureDirect equity and direct fixed income
investments, sector contribution toemissions

Investment management
and operations

Communities

Direct equity and direct fixed income investments,
weighted average carbon intensity per sector
Sampo Group, 31 December 2023

Sampo Group

Mandatum is included in 2021 and 2022 figures.
Emission contribution for all other portfolio sectors is less than
one per cent for each sector.

SUSTAINABILITY REPORT 2023

Products
and services

89

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices

Climate impact assessment
Climate scenario analysis
Part of the climate impact assessment was an analysisof whether Sampo Group’s direct equity and fixedincome investments are aligned with the International
Energy Agency’s (IEA) scenarios. The scenarioalignment analysis compares current and future
portfolio GHG emissions with the carbon budgets for
the IEA Sustainable Development Scenario (SDS),

Announced Pledges Scenario (APS), and Stated Policies
Scenario (STEPS). Performance is shown as thepercentage of the assigned budget used by the
portfolio.
According to the service provider’s analysis, Sampo
Group’s direct equity and fixed income investments intheir current state are misaligned with the SDS scenario,
i.e. the 1.5°C scenario, by 2050. The portfolio exceeds its
SDS budget in 2043, and it is associated with aPortfolio comparison to Sustainable Development Scenario (SDS) budget
Sampo Group
Sampo Group's portfolio

2023

2030

2040

2050

-67.4%-59.7%-17.1%

106.7%A positive figure equals overshoot.

Portfolio emissions vs. climate scenarios
Sampo Group, 31 December 2023

SUSTAINABILITY REPORT 2023

90

potential temperature increase of 1.8°C by 2050. In asimilar analysis conducted in 2022, the portfolio
exceeded the SDS budget in 2040, and it was
associated with a potential temperature increase of
1.9°C by 2050. Regardless, the Sampo Group
companies’ investments are still aligned with the
trajectory to below 2.0°C.

≡

Introduction

Business management
and practices

Corporate
cultureClimate targets analysis
In order to transition to a low-carbon world, investee
companies need to commit to alignment withinternational climate goals and demonstrate future
progress. According to a climate targets analysis
conducted as a part of the climate impact assessment,
73 per cent of Sampo Group’s direct equity and fixedincome investment value as at 31 December 2023 wascommitted to such a goal. This includes ambitious
targets set by the investee companies, as well as
committed and approved science-based targets. Thereis a clear improvement of the results compared to asimilar analysis completed in 2022, when the figure was
59 per cent. The Sampo Group companies continue tofollow the climate actions taken by their investee
companies to manage climate risk.

Investment management
and operations

Products
and services

Climate target assessment (% of portfolio
weight)Sampo GroupYears 2021 and 2022 include Mandatum.

SUSTAINABILITY REPORT 2023

Communities

91

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Sustainable products and services
Sustainable product and service offering....... 93
Sustainable supply chain management ........... 96
Sustainable sales and marketing practices .... 101
Customer satisfaction ............................................. 105

SUSTAINABILITY REPORT 2023

92

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Sustainable product and service offering
To be able to offer products and services that
customers need and want, ESG considerations,
including climate change, need to be taken into
account. These matters can also create opportunities
for Sampo Group in the form of new products andservices.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Additional information:www.sampo.com/sustainability/products-andservices/sustainable-underwriting

Sampo Group aims both to offer products and services
that customers need and want, and to take ESG
considerations into account in the product and service
offering and insurance underwriting.

If’s risk experts and loss prevention managers visit theSME clients, and give them concrete safety advice andactionable risk reports. If also financially supports theclients’ investments in fire safety, and has piloted a newfire safety training and inspection concept in Sweden.
Smaller clients in very fire-prone segments are either
physically inspected by experienced sales managers orotherwise receive extra attention and support.

Actions and results

Integration of ESG considerations into
underwriting

Approach
The Sampo Group Code of Conduct sets the group levelguidelines for a sustainable product and service offering
at Sampo Group. The Code of Conduct states that ESG
considerations should be taken into account in productand service development, and insurance underwriting.
In addition to the Code of Conduct, each Group
company has adopted supplementary and moredetailed policies, guidelines, and processes for their own
purposes.
Sustainability is an integral part of Sampo Group’sbusiness. In terms of insurance products and services
this means, for example, that Sampo Group• Provides loss prevention services (e.g. risk
management services).
• Handles claims in a sustainable way.
• Integrates ESG considerations into insurance
underwriting.
• Develops products and services in accordance with
relevant legal requirements (e.g. the EU Taxonomy).

Group goals and ambitions

If
Loss prevention services
Together with its partner Anticimex, If offers houseassessments to private customers who own their houseand have insurance policies with top coverage. Since
2012, more than 210,000 house assessments have been
completed in the Nordic countries. In 2023 alone,around 30,000 houses were inspected. The same
number of assessments is planned for 2024.
In 2022, based on the positive experiences with thehouse assessments, If started offering the If Building
Check for small and medium-sized (SME) clients thatown residential buildings in Norway. By the end of2023, more than 400 building checks for SME clients
have been conducted. Following a physical inspection,

SUSTAINABILITY REPORT 2023

the clients get help to identify where maintenance andfire safety measures are most needed. Clients receiving
the If Building Check receive hands-on advice thatmakes them aware of risks, including climate-relatedrisks, and suggestions for mitigating actions. The If
Building Check is offered once every fifth year.

93

If has integrated the principles of the UN Global
Compact into its underwriting standards. This meansthat If assesses its corporate clients to ensure they
comply with these principles. During 2023, If assessed
772 corporate clients. In total, 12 cases were referred to
If’s ESG assessment team for further assessment. All
clients that were assessed by the ESG assessment team
were contacted and informed that If has been notifiedof the alleged breaches, and therefore will monitor theactions taken in response to them. During the year,
three clients improved their rating and are, therefore, nolonger referral cases.
Among the referral cases, If has had cases in which
additional actions have been taken. One potential client,which was accused of several breaches, was given a
conditional approval, which means that If required
additional information and action from the client inIntroduction

Business management
and practices

Corporate
cultureorder to offer them insurance. Another case concerned
two clients with global ultimate parent companies
involved in the same joint venture, which have yet toadequately rectify past environmental damage. Basedon the confirmed inaction from the companies, If
decided not to renew these clients.

Development of sustainable products andservices
In 2023, If analysed to what extent its underwriting andinvestment activities are Taxonomy-eligible andTaxonomy-aligned according to the the EU Taxonomy
Regulation. This information is reported in If’s
Sustainability Report 2023 and Sampo Group’s Board of
Directors Report 2023.

Investment management
and operations

Products
and services

Communities≡

Topdanmark

Integration of ESG considerations into
underwriting

Loss prevention services

Topdanmark screens its existing commercial andagricultural customers (i.e. companies with at least two
employees) for compliance with the principles of the
UN Global Compact using an external service provider.
In addition to these principles, Topdanmark monitors
issues related to work environment, animal abuse,sexual harassment, and illegal marketing practices, forexample. In case of a verified violation, Topdanmark
begins a dialogue with the customer.

In 2023, Topdanmark focused on prevention of fires inelectric vehicles and all kinds of electric tools or
machines that use lithium batteries (e.g. trucks,
scooters, bicycles, and handheld tools). During the year,
Topdanmark had dialogue with both suppliers of lithium
batteries to understand how to prevent overheating
and with suppliers of charging devices to learn about
the best and most fire-safe products on the market. The
work will continue in 2024. The aim is to finalise
prevention requirements for Topdanmark’s customers,
regarding installation of certified charging devices andtraining in fire prevention, for example.
In 2023, Topdanmark inspected (e.g. though site visits)
the largest non-residential properties the company has
insured, 4,676 in total. The objective was to assess fire
safety preparedness of the properties and require
improvements in case of any weak points, thus
preventing fire damage. Through dialogue, Topdanmark
has not only helped preventing fire damages but also
water damage, which can result from a damaged water
pipe, for example.
In Q4/2022 and 2023, Topdanmark intensified its
efforts related to thermal imaging. In 2023, thermal
imagining was completed at 961 farms, and 522 will becompleted in 2024. In addition, Topdanmark performed
systematical follow up on all errors and omissions foundon the thermal imaging and ensured that these wererectified. These efforts prevent fires to the benefit of thecustomers and improve Topdanmark’s business risk
management.
In 2024, Topdanmark will continue its efforts related tolithium batteries and thermal imaging. Furthermore, thecompany will investigate how to improve fire safety inmulti-storey car parks.

SUSTAINABILITY REPORT 2023

Appendices94

During 2023, 40,000 commercial and agricultural
customers were screened twice by the external service
provider. Customer contracts were terminated due toverified cases of animal abuse, illegal marketing
practices, and non-compliance with safety standards.
Going forward, Topdanmark will investigate how toinclude the ESG screening in the sale and renewal of
insurance policies. This is especially relevant for sectors
where the potential negative impact on the UN Global
Compact principles is assessed to be high.
Topdanmark excludes the same industries in its
insurance underwriting as in its investment activities,
namely, the production of coal, tar sands, controversial
weapons, and tobacco. This means that the company
does not insure companies in these industries. In 2023,
there were no underwriting activities related to the
excluded industries.

Introduction

Business management
and practices

Corporate
cultureProducts
and services

Communities

Hastings

ESG screening of commercial andagricultural customers

Loss prevention services

Topdanmark
Topic

Investment management
and operations

31 Dec. 2023

Customers on internal watchlist

9

Customers that Topdanmark currently
has or has had dialogue with1

Customers terminated based on ESG
issues3

In 2023, Hastings developed its customer
communication strategy by creating a newsletter
campaign. The campaign offers supportive information
for customers in preparation for events when damages,
incidents, and ultimately claims can occur.

Sustainable claims handling
Development of sustainable products andservices
Topdanmark has had a goal to have five new products,
areas of insurance coverage, or services that support
customers in GHG reduction and other sustainablechoices by 2025. The requirements for these products
were based on the Danish consumer ombudsman’s
guidelines on marketing a product as a green product.
The process of developing such products and services
has been a challenge due to organisational changes,
internal system changes, and general market
development, for example. Therefore, Topdanmark
reviewed the company’s target in 2023.
Going forward, Topdanmark will apply the EU
Taxonomy Regulation as a basis for developing
sustainable products and services. The company’s
ambition is to have one to two products aligned with
the EU taxonomy in 2024. More information on
Taxonomy eligibility and Taxonomy alignment of
Topdanmark’s underwriting and investments activities isin Topdanmark’s Sustainability Report 2023 and Sampo
Group’s Board of Directors’ Report 2023.

SUSTAINABILITY REPORT 2023

In February 2023, Hastings released a new customer
digital tool, which allows customers to notify Hastingsof a motor incident online or via the Hastings app. This
ensures that customers have a straightforward start totheir claims journeys.
Hastings started a partnership with a new provider ofinnovative temporary solutions. When a Hastings’
customer is a victim of fire or flood, they will be offereda solution (e.g. temporary kitchen, bathroom, or
bedroom) so that they can continue to use their homeduring the renovation.
During 2023, Hastings updated policy wording for its
home insurance product, enabling lost, damaged, andstolen mobile phones to be replaced with refurbishedrather than new devices. This reduces waste throughrecycling and improving supply chain sustainability.
Hastings also continued its Green Earth scheme, whichallows customers the opportunity to opt out of acourtesy car and have a tree planted on their behalf
instead. Through the scheme, Hastings avoided the useof 1,590 courtesy cars in 2023 and planted trees acrossthe UK and Ireland instead.

95

Appendices≡

As part of Hastings’ Recycled or Green Parts scheme,
recycled parts were fitted on approximately 3.5 percent of all repairs in 2023, saving 30 tCO2e.
Approximately 28 per cent of repairers within Hastings’
network have achieved the BSI PAS 2060 carbon
neutral certification. In 2024, Hastings aims to partnerwith companies, offering sustainable solutions to homecontents replacement and disposal practices.
In 2024, Hastings will introduce a digital vehicle writeoff service, enabling motor customers to go through theentire journey digitally; from notifying Hastings of aclaim, to agreeing to the value of their vehicle, andreceiving payment into their bank account. Further
enhancements to other customer claims journeys arealso planned. Hastings will also investigate technologies
for home claims, which will enable employees tosupport customers virtually, further reducing carbon
emissions and enabling quick settlement of claims.

Development of sustainable products andservices
As part of Sampo Group, Hastings performs analysis on
EU Taxonomy eligibility and alignment and intends toreview opportunities to align products and policies with
the EU taxonomy in the future. More information on
Taxonomy eligibility and Taxonomy alignment of
Sampo Group is in Sampo Group’s Board of Directors’
Report 2023.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesSustainable supply chain management
Supply chains are a crucial part of the sustainability of
products and services, and Sampo Group emphasises
sustainability factors when working with suppliers.
Sustainability issues can carry significant reputational andoperational risks if not managed correctly. Sampo Groupis a major procurer of goods and services, especially inclaims handling, and therefore has an impact on theeconomy, the environment, and people.

Approach
The Sampo Group Code of Conduct provides the grouplevel guidance principles regarding sustainable supply
chain management. Sampo Group expects its suppliers
and other business partners to comply with theprinciples of the Code of Conduct throughout its own
operations and supply chains. Moreover, Sampo Groupshould take ESG considerations, including climatechange, into account in supply chain management. In
addition to the Code of Conduct, each Sampo Group
company has its own supplementary policies,
guidelines, and processes.
The types of activities related to Sampo Group’s
products and services that are carried out by suppliers
include property, vehicle and content repairs, healthand hospital services, and travel services. The Groupalso makes purchases, such as external consultancy,
office supplies, and IT equipment, to secure its own
operations.
The nature of the business relationships with suppliers
varies with respect to the type of product or service
purchased, and can be long-term or short-term,
contractual or non-contractual, project-based or eventbased. Sampo Group can, for example, offer networks

SUSTAINABILITY REPORT 2023

of repair shops that have a long-term contractual
relationship with the company. On the other hand,certain suppliers, such as external consultants, aretypically hired on a project basis, and can be either
long-term or short-term.

Characteristics of sustainablesupply chain management

Sampo Group’s suppliers can have sector-specificcharacteristics, but they vary with respect to the type of
product and service purchased. For example, rebuilding tends to be highly labour intensive. Content
claims are capital intensive when items are replaced,
but labour intensive if items are repaired.

Supplier Code of Conduct(or similar) based on the
UN Global Compact

Yes

Yes

No

Supplier Code of Conduct(or similar) applicable tothird parties, i.e. subsuppliers

Yes

Yes

No

Additional contractual
requirements for specificsuppliers (e.g. based on
ESG risks, sector, size,
geography, businessrelevance)

Yes

Yes

No

Targets (externallydisclosed) related tosupply chain management

Yes

Yes

No

Supplier risk assessments(e.g. audits,
questionnaires)

Yes

Yes

Yes

Collection of feedback
from suppliers (e.g. during
tender processes, contract
negotiations)

Yes

Yes

Yes

Mapping of Tier 1 suppliers(direct suppliers)
according to e.g. service
and/or product category,
expenditure

Yes

Yes

Yes

Sampo Group is committed to encouraging andsupporting the company’s suppliers and partners intheir efforts to use more sustainable methods in theiroperations. By actively requesting innovative solutions,
resource efficiency, transparency, and responsibility
from suppliers, Sampo Group aims to minimise its
negative impact and stimulate sustainable production
and consumption. Set requirements, in combination
with close cooperation with suppliers and partners,
enable Sampo Group to develop its business, while also
contributing to sustainable development.
If non-compliance with requirements is detected, thefirst step to remediate non-compliance is to verify what
has happened and investigate the reasons leading to it.
Depending on the findings, corrective actions taken canbe, for example, improvement of processes, correctionof mistakes (e.g. errors in invoicing), refunds, or audits.
If the error or contract breach is major, it may result intermination of the contract.

96

Sampo Group, 2023
TopIf danmark Hastings

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Additional information:www.sampo.com/sustainability/sustainableinsurance-operations/sustainable-supply-chain

Introduction

Business management
and practices

Corporate
cultureGroup goals and ambitions
Sampo Group aims to drive high standards across
supply chains.

Actions and results
If
Goals and ambitions
If’s suppliers must comply with If’s Supplier Code of
Conduct. In addition, If’s property and vehicle repair
contractors must comply with If’s sector-specific
Additional Environmental Requirements (AER), which
are incorporated into the purchasing agreements. The
additional requirements cover transportation, energy
usage, material usage, water usage, handling ofchemicals and hazardous substances, and waste
handling. If has also set expected levels of plastic
repairs, as well as used parts, for individual contractors.
As part of If’s commitment to the SBTi, If has on a
voluntary basis (i.e. not a requirement for financial
institutions according to the SBTi) set a supplierengagement target for purchased goods and services(Scope 3, category 1), in order to reduce emissions fromclaims operations. Emissions from claims represent a
substantial part of If’s total emissions. Based on
calculations by the IVL Swedish Environmental
Research Institute (life cycle assessment methodology),
the emissions from If’s property and vehicle repairs
were 89,685 tCO2e in the baseline year 2020. The
calculations are based on data from If’s claims
organisation.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

If’s target is that 30 per cent of its suppliers by spend
covering purchased goods and services, will havescience-based targets by 2028. The target wasapproved by the SBTi in December 2023. If’s current
supplier engagement approach and strategy includes
several features that will contribute to meeting thetarget. In 2024, the company will further develop its
approach for reaching the target.

Actions and results
During 2023, If procured products and services as partof claims handling worth more than SEK 17 billion.
Together with its partners and suppliers, If handled
1,018,000 cases of vehicle damage, 519,000 cases ofproperty damage and 526,000 cases of personal injury
claims.
Supplier Code of Conduct
If’s Supplier Code of Conduct specifies the minimum
requirements If expects its suppliers to comply with.
The Code covers environmental issues, including
climate change, and stipulates that suppliers must strive
to minimise GHG emissions by identifying, monitoring,
controlling, and managing the emissions from theiroperations. Furthermore, suppliers must strive to
reduce energy consumption, and prioritise the use ofrenewable energy sources.
If has developed a Self-Assessment Questionnaire(SAQ) to assess suppliers’ compliance with If’s Code of
Conduct. In spring 2022, as a pilot survey, the SAQ wasprovided to 919 property and vehicle repair contractors.
In total, 461 contractors completed the whole survey,
which corresponds to a response rate of 50 per cent.

97≡

Appendices

An additional 115 contractors completed parts of thesurvey. The lessons learned from the pilot survey fed
into the development of If’s due diligence process for
suppliers and business partners, and theimplementation of the Evaluate system in 2023.
At the end of 2023, suppliers responsible for 99 percent of the total volume If procures in claims had signed
the Supplier Code of Conduct. The target is for 100 per
cent of the suppliers in claims to have signed the Codeby the end of 2024.

Suppliers that have signed the Supplier
Code of Conduct
If
Share of suppliers, %

2023

2022

2021

99

97

87

Sector-specific requirements
If is continuously seeking new ways to reduce material
use, increase reuse and recycling, and minimise waste inclaims handling. If has set expected levels of plastic
repairs and used parts, and these are monitored andreported regularly. Consequently, If’s contractors reuse
thousands of tonnes of metal and plastic each year,
instead of using brand new spare parts. 3,776 tonnes ofmetal and plastic were reused in 2023.

Introduction

Business management
and practices

Corporate
cultureIf has used two mobile tools, In4mo and MEPS, to makeit possible for property repair contractors to digitally
report and calculate property damage claims on site.
These tools enable all contractors to comply with If’s
process requirements. They also minimise travelling andallow If to measure how much waste has been
generated. Since November 2023, If has used MEPS as
the common Nordic tool, which can be linked moreclosely to sustainability measuring and reporting.

Investment management
and operations

Reuse of materials in vehicle repairs
If

During 2023, If conducted more than 60,000 photo
inspections in Sweden, instead of inspections at vehicle
repair shops. As a result, an estimated 2.4 million
kilometres of driving was avoided

SUSTAINABILITY REPORT 2023

Products
and services

Communities

Appendices≡

Supplier risk assessments and audits
If has a due diligence process in accordance with theOECD Guidelines for Multinational Enterprises to
identify, avoid, and address possible adverse impacts
on human rights, labour rights, the environment, andanti-corruption commitments associated with If’s
operations, supply chain and business partners. During2023, If incorporated the due diligence process into its
purchasing processes, initially focusing on theprocesses in Norway, in accordance with the NorwegianTransparency Act.
During 2023, the number of agreements being verified
and screened, as part of the due diligence process, was280. In 2023, If also began the implementation of adigital tool that will support the process. Developmentof more detailed instructions for the due diligenceprocess continues in 2024.

98

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Goals and ambitions

independent consultants. Topdanmark did not identify
any breaches related to its Supplier Code of Conduct
during the reporting year.

Topdanmark has set goals for its supply chain
management, and for recycling and repair in claims
handling, as presented in the tables. In 2022,
Topdanmark joined the SBTi and its NetZero Standard,
and has, in 2023, worked on setting voluntary climate
targets for its supply chain. The work continues in 2024.

In 2023, the repairs of windscreens decreased slightly.
Windscreens have become thinner and in new cars they
have more electronics installed. These challenges do
not only apply to Topdanmark, but the decrease of
repaired windscreens is an overall trend.

Topdanmark

Actions and results
Topdanmark integrated its Supplier Code of Conduct or
the supplier’s own Code of Conduct into 76 per cent of
new contracts in 2023. The contracts, for which thecompany has not succeeded in integrating the Code,are typically global IT and software partners, as well as

The repairs of electronics decreased in 2023, compared
to 2022. The decrease was due to an IT system changeof the supplier conducting the repairs, leading to longer
handling times. To mitigate the longer handling times,
Topdanmark accepted an increase in cash settlements
instead of repairs, which impacted the second half of
2023.

≡

AppendicesIn 2023, Topdanmark continued the process ofchanging stock goods to products with recognised
ecolabels (e.g. EU Ecolabel, Rainforest Alliance, Cradle
to Cradle, TCO Certified, or OCS 100). This means thatnew purchases will be ecolabelled to the extent
possible. At the end of 2023, 61 per cent of stock goods
within the scope were ecolabelled.
In 2024, Topdanmark plans to strengthen thesustainability of its supply chain even further. In addition
to the existing goals, the company’s focus will be on
enhancing sustainable procurement, decarbonisationand science-based targets, internal knowledge sharing
and collaboration, supplier engagement and dialogue,
and increasingly data-driven ESG monitoring of
suppliers, for example.

Sustainable supply chain

Recycling and repair in claims handling (cars)

Topdanmark

Topdanmark

Goal 2025
All suppliers in the ESG focus groupwith which Topdanmark signs acontract have been screened for ESG
risks, compliance, and sustainability inthe tender process

Unit Baseline

%

2021

2023

100

2022

100

2021

Goal 2025-

A Code of Conduct is integrated into
all new supplier contracts (either
Topdanmark’s Supplier Code of
Conduct or the supplier’s own Code of
Conduct)*

%

2021

76

66

<5

70 per cent of all stock goods arelabelled with a recognised ecolabel**

%

2021

61

53

-

Unit Baseline

2023

2022

2021

2021

33

32

28

%

2021

39

40

41

%

2021

3

3

2

2023

2022

2021

63

66

72

Increase the percentage of bumper
repairs%

Increase the percentage of windscreen
repairs to 45 per centIncrease the percentage of used spareparts to 4 per cent

Recycling and repair in claims handling (electronics)
Topdanmark* The figure covers contracts made by Topdanmark’s procurement department.
** The calculation is based on spend.

Goal 2025
Maintain the percentage of repairs ofphones, computers, and tablets at 72
per cent*

Unit Baseline%

2021* The percentage of damaged units sent to Topdanmark’s main collaboration partner.

SUSTAINABILITY REPORT 2023

99

Introduction

Business management
and practices

Corporate
cultureHastings
Goals and ambitions
Hastings has a sustainable supply chain strategy, andthe company intends to implement a Supplier Code of
Conduct in 2024.

Actions and results
In 2023, Hastings completed an ESG due diligence on all
critical suppliers. The due diligence questionnaire seeks
to understand the alignment of suppliers with Hastings’
own sustainability ambitions and policies, providing an
overall ESG due diligence rating relative to the supplier.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

The results were encouraging, with the majority ofsuppliers achieving a good ESG rating. Hastings
continues to have discussions with the suppliers on
possible improvements, and supports them by sharing
best practices or guiding on ESG-related topics. Goingforward, Hastings will include the ESG due diligence inall suppliers’ annual due diligence refresh assessments.
During 2023, Hastings implemented a formal set of
supplier policies, which all suppliers are expected toagree to, prior to engaging in cooperation with
Hastings. The policies cover a range of corporate policy
requirements, along with ESG elements relating to100

Appendices≡human rights, the environment, and responsible
investment. In addition, during 2023, Hastings
implemented a procurement platform, which enables
the company to manage ESG-related due diligence inan automated fashion, and provides real-time views of
the supply chain’s commitment to sustainability.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Sustainable sales and marketing practices
For an insurance company, it is important to gain thetrust of customers by ensuring that the products andservices offered are clearly explained and transparently
marketed. The trust that customers have in the Sampo
Group companies’ integrity is the foundation of thecompanies’ positive reputation.
Paying attention to the risks associated with sales andmarketing is important to Sampo Group. Such risks
include inappropriate customer advice and productsales; lack of clarity in terms, prices, and fees; errors inclaims handling; and errors in the complaint process. To
minimise the risks and increase value for the customer,
Sampo Group continuously works to develop andimprove customer service, and sales and marketing
practices.

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.

SUSTAINABILITY REPORT 2023

Sampo Group has controls in place to ensure that
information provided to customers is accessible,
relevant, and timely before a customer commits to any
purchase, and that the company satisfies all regulatory
and conduct obligations. The associated controls andmeasures are regularly assessed. Sampo Group assesses
products regularly to ensure they remain appropriate.

country. In addition, as required by law, certain Sampo
Group companies have internal customer representative
functions that the customer can contact to submit acomplaint. Regardless of the outcome of appeal cases,
Sampo Group always analyses how it can improve its
sales and marketing practices.

To ensure compliance with laws, regulations, andinternal policies, Sampo Group has continuous training
programmes that develop personal conduct, andincrease the competence of sales teams and othercustomer representatives. Customer feedback channels
are also offered to make it easy for customers toprovide feedback on the products and services, and tocomplain if they are dissatisfied.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct

Sampo Group aims to clearly inform customers of theircomplaint options, as well as to ensure a fair andtransparent complaint process. In the case of acomplaint, the priority is to discuss with the customer tofind a solution that is satisfactory to both parties. If aconsensus cannot be achieved, the customer is entitledto appeal to external complaints boards (ECBs) or
similar, according to local practices in each operatingGroup goals and ambitions

101

Additional information:www.sampo.com/sustainability/businessmanagement-and-practises/sustainable-salesand-marketing

Sampo Group’s goal is to act in the best interests of thecustomers using sustainable sales and marketing
practices.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

If

and the percentage of cases concerning If that wereruled in If’s favour remained fairly stable during thereporting year. All 2023 data for Norway, Finland, andDenmark was not available when the report was written.

In 2023, If continued to proactively contact customers
to ensure that they are correctly insured. In Sweden, thethe number of cases concerning If handled at the ECBs

In Norway and Denmark, there is only one public
external board in each country, and in Sweden andActions and results≡

AppendicesFinland, there are several public external boards, eachwith a somewhat different status. Therefore, comparing
the numbers and trends in each respective country ismore relevant than comparing one country to another.

Number of complaints to internal customer ombudsman
If
Country

2023

2022

Sweden

1,368

1,444

2021
1,301

Norway

1,425

1,053

1,022

Finland

1,136

1,067

878

Denmark

339

217

178

The number of cases
concerning If handled
at the ECBs, 2023

The number of cases
concerning If handled
at the ECBs, 2022

Cases at external complaint boards
If

Country

The number of cases
The percentage of
The percentage of
The percentage ofconcerning If handled cases that were ruled in cases that were ruled in cases that were ruled inat the ECBs, 2021
If’s favour, 2023
If’s favour, 2022
If’s favour, 2021

Sweden89

94

58

Norway

467

420

414

-

81%

82%

Finland

-

102

124

-

76%

85%

Denmark

-

29

30

-

62%

80%

100%

96%

98%

Source: The Finnish Financial Ombudsman Bureau; the Norwegian Financial Services Complaints Board; the Insurance Complaints Board in Denmark; the Swedish figures are based on internal statistics.
2021 data for If, Sweden was corrected in this report, as the liability cases where If represents their policyholder, were mistakenly included in the statistics.

SUSTAINABILITY REPORT 2023

102

Introduction

Business management
and practices

Corporate
cultureTopdanmark
In 2023, Topdanmark focused on proactive and relevant
customer communication. The company made morethan 293,000 outbound calls to customers toproactively check their insurance coverage. This is anincrease of 27 per cent from 2022.

Investment management
and operations

Products
and services

Communities

Topdanmark aims to continuously improve the qualityof service both in its digital and analogue channels. In
2023, the company experimented with new digitaltechnologies, such as voice bots, to increase efficiency
and improve self-service ratio.

Cases at the external complaints board
Topdanmark
2023

2022

The number of cases concerning Topdanmark handled at the ECB

104

108

111

The percentage of cases that were ruled in Topdanmark’s favour

83%

86%

86%

Source: This data is based on all complaints and rulings on non-life insurance from the Danish
Complaint Board statistics and Topdanmark’s internal statistics. The data corresponds to thestatistics published by the Complaints Board in Denmark every May.

SUSTAINABILITY REPORT 2023

103

2021

Appendices≡

The number of cases concerning Topdanmark handled
at the complaints board, and the percentage of cases
ruled in the company’s favour, remained stable in 2023.

Introduction

Business management
and practices

Corporate
cultureHastings
In 2023, Hastings completed the implementation of its
new customer marketing platform. The platform
facilitates automated marketing and communications
campaigns, and drives deeper customer engagement.
During 2023, Hastings’ focus was on optimising thecompany’s streamlined Quote and Buy customer
journeys for car and home customers. The improvementin the home sales journey resulted in an increase above
30 per cent in home customer policies. Customer
feedback received from car journeys remained positive,
with customers rating the car insurance buying
experience 4.3 out of 5 for ease of use.

Investment management
and operations

Products
and services

Communities≡

Hastings focuses on meeting level AA of the Web
Content Accessibility Guidelines (WCAG 2.1). To
maintain high standards, in 2023, Hastings conductedannual accessibility audits across all customer-facing
digital platforms. This ensures the company stays up todate with the latest WCAG guidelines and identifies any
potential accessibility risks.

which yielded positive results indicating a good level ofunderstanding. Nonetheless, during 2023, Hastings
continued to improve communications, particularly inthe critical journeys of renewals and claims. The work
will continue in 2024. During 2023, Hastings alsoaligned its sales and marketing conduct framework to
the FCA’s Consumer Duty.

In July 2023, the FCA’s Consumer Duty became
effective in the UK. The Consumer Duty regulation aims
to ensure that companies prioritise the interest of theircustomers, treat them fairly, and provide clear andtransparent information. Before the legislation cameinto force, Hastings carried out extensive testing of all
critical customer communications and digital journeys,

In 2023, the number of Hastings’ cases referred to the
Financial Ombudsman Service (FOS) increased due tohigher claims volumes and the impact of the pandemic
and Ukraine conflict on the repair networks andcourtesy car availability.

Cases at the Financial Ombudsman Service (FOS)
Hastings
2023

2022

The number of Hastings’ cases referred to the FOS

1,875

1,305

778

The percentage of cases that were ruled in Hastings’ favour

60%

69%

73%

Source: Financial Ombudsman Service

SUSTAINABILITY REPORT 2023

Appendices

104

2021

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Customer satisfaction
Satisfied customers are the cornerstone of Sampo
Group’s business, as they are more loyal and prone torecommend products and services. Through systematic
measurement of customer satisfaction, Sampo Groupwants to both identify the factors that are valued by thecompany’s customers, and recognise the parts of thecustomer journey that should be improved.

Approach
In accordance with the Sampo Group Code of Conduct,
Sampo Group strives to act in the best interests of its
customers. The aim is to provide products and services
that are fair, comprehensible, and designed to help
meet the evolving needs of customers. To track how
well Sampo Group accomplishes this and to identify
areas for improvement, customer satisfaction ismeasured continuously. Both positive and negative
feedback is carefully analysed and used to further
develop products and services.
The Sampo Group companies have customer
experience programmes (or similar) that are spread
across the organisations, and the different customer
touchpoints. The programmes enable the companies toboth collect data and follow the results. The datacollected and the results received are used to improvethe customer experience.
Equally important is quality assurance, which follows
customer feedback. Sampo Group follows up thecustomer’s journey to look for root causes of feedback,and to repair the customer relationship, if needed. The
insight gained is utilised in training and in improving
products, processes, and the overall customer journey.

SUSTAINABILITY REPORT 2023

Sampo Group uses the Net Promoter Score (NPS) tomeasure customer satisfaction. The NPS is an index
ranging from -100 to 100 that measures the willingnessof customers to recommend a company’s products orservices to others. It is used as a proxy for gauging thecustomer’s overall satisfaction with a company’s
product or service, and the customer’s loyalty to thebrand. The transactional NPS (tNPS) assesses thecustomer’s opinion on a certain business transaction.
The score shows whether customers want torecommend the company to others after they havebeen in contact with the company. It is calculated as the
net result of the share of promoters (who replied 9–10)
minus the share of detractors (who replied 0–6) on thequestion of to what extent they would recommend thecompany to others. In addition to the NPS and tNPS,
the Sampo Group companies use other supplementarymeasurements of customer satisfaction.

Group goals and ambitions

Goal

2023

2022

2021

Sampo Group uses external benchmarking tocomplement the internal data and feedback. This assists
in assessing performance against peers andcompetitors.

If – tNPS, Business
Area Private

2023: 62

60

62

61

Topdanmark – tNPS

2027: 70

57

56

56

Hastings – tNPS

2024: 58

52

55

54

Customer satisfaction results are reported regularly tothe top management and the Board of Directors ofeach Group company. The results are also integrated
into the management compensation structures.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct

105

The key objective for Sampo Group is to deliver an
excellent customer experience.

Actions and results
During 2023, customer satisfaction remained on a fairly
good level across Sampo Group. If and Hastings saw
some decrease in their surveys, and the result of
Topdanmark improved slightly. Results have been
discussed in more detail in the following companyspecific texts.

Customer satisfaction
Sampo Group
Company and survey

Introduction

Business management
and practices

Corporate
cultureIf
If uses the NPS to rate customer experience acrossbusiness areas. Objectives are set on a transactional ora relational level by different business areas, and key
results are followed through the customer experience
programme using the tNPS or rNPS. In addition, If uses
an external, annually published Extended Performance
Satisfaction Index (EPSI) to benchmark the
performance of customer satisfaction against theindustry as a whole in all Nordic countries.

Investment management
and operations

Products
and services

Communities

If has had a positive tNPS development during therecent years in the business area Private, which includes
both feedback from claims handling, and calls to If’s
contact centres. In 2023, the tNPS result waschallenged. However, the Nordic EPSI results confirmed
both in the Commercial and in the Private market that If
performed better than the industry average, andmaintained its strong position in most markets during
the year.

If
Industry
average, 2023

Industry
average, 2022

2021

Industry
average, 2021

71.1

71.2

72.9

73.0

74.5

72.7

73.3

71.4

73.3

72.1

74.5

72.9

76.0

78.1

77.5

76.6

76.4

Industry
average, 2023

2022

Industry
average, 2022

2021

Industry
average, 2021

2023

Sweden73.3

72.8

Norway72.2

72.4

Finland

74.2

72.7

Denmark

77.1

2022

Source: EPSIEPSI results, Commercial (B2B)
If
Country2023

Sweden

68.2

67.8

69.0

68.1

68.8

68.8

Norway

69.4

69.4

72.1

69.7

69.5

69.1

Finland

74.2

73.2

68.2

69.4

69.3

69.1

Denmark

72.1

69.4

72.8

69.5

70.9

70.8

Source: EPSISUSTAINABILITY REPORT 2023

106≡

During 2023, If’s management continued to develop theagile organisational structure to enable quick responses
to changing customer needs, to be the most caring
insurance company, and to have the most satisfied
customers. Going forward, If focuses on customer
orientation through excellent customer experience,organisational culture, and partnerships.

EPSI results, Private (B2C)

Country

AppendicesIntroduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Topdanmark

EPSI results

In 2023, the annual tNPS of Topdanmark increased fromthe previous year. The result is satisfactory, taking theincrease in weather claims into consideration.
Topdanmark still strives for a tNPS of 70. However, in2023 the target year was extended from 2025 to 2027.
To increase internal short-term engagement towards
the target, Topdanmark introduced a model of annual
gradual steps, including initiatives to break down theoverall tNPS target, and build towards 70 in 2027.
Topdanmark monitors the progress of the tNPS and thecorresponding initiatives at quarterly Customer Forummeetings.

Topdanmark

Topdanmark’s EPSI results for both private andcommercial customers decreased in 2023 compared tothe previous year. However, with a raise in tNPS and
Top Promise score, Topdanmark is confident incustomers’ satisfaction towards the company.

Products
and services

Communities≡

AppendicesHastings

Survey

Scale

2023

2022

2021

EPSI, private
customers

0–100

75.0

76.7

74.6

EPSI, commercial
customers

0–100

69.3

70.9

70.8

TrustScore*
Topdanmark
Survey

Scale

2023

2022

2021

1–5

4.2

4.2

4.2

Trustpilot, overall score* TrustScore is a measure of customer satisfaction based on thecustomer reviews collected on Trustpilot.

Hastings uses NPS to internally measure customer
satisfaction, and to rate its performance across most ofits business areas. Objectives are set on a transactional
level and agreed by the company’s Operating
Committee. Key results are followed through to wider
company measures and targets. In addition, for example
Customer Satisfaction (CSAT) scores are gathered tofurther understand its customers’ experiences.
In 2023, the market inflation and price increases
impacted the overall tNPS negatively. Also the CSAT
score decreased, even though the result is still on a highlevel.
In 2024, Hastings will implement a new Voice of the
Customer platform, enabling additional customer
surveying. It will support Hastings in developing all
customer journeys.

CSAT results
Hastings

Top Promise
Topdanmark
Question to thecustomer“Think about
Topdanmark in general– how helpful do you
think we are?”

Channel

Unit

2023

2022

2021

Phone

Share of customers that
1–5
gave top marks, i.e. 5

74%

72%

71%

Digital selfservice

Share of customers that
1–5
gave top marks, i.e. 5

65%

60%

59%

SUSTAINABILITY REPORT 2023

Scale

107

Survey

Scale

2023

2022

2021

CSAT score

0–100

89

92

90

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Sustainable communities
Stakeholder engagement and dialogue .......... 109
Donations and other humanitarian efforts ..... 114
Tax footprint .............................................................. 118

SUSTAINABILITY REPORT 2023

108

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Stakeholder engagement and dialogue
Stakeholder engagement and dialogue help Sampo
Group to proactively consider the needs and wishes of
its stakeholders. By focusing on stakeholder
engagement, Sampo Group can mitigate potential risks,
including uncertainty and dissatisfaction of its key
stakeholder groups. Stakeholder engagement can help
Sampo Group foster its reputation, trust, and buy-in forthe company’s key initiatives.
In addition, Sampo Group considers stakeholder
engagement and dialogue to be a valuable source of
information. The different stakeholders are experts intheir own fields, and can offer knowledge and expertisefor the purposes of the Group. When relevant, Sampo
Group can also offer its time and expertise to support
the stakeholders.

SUSTAINABILITY REPORT 2023

ApproachGroup goals and ambitions

Sampo Group’s primary stakeholder groups areinvestors, customers, employees, suppliers and otherbusiness partners, and local communities. Each primary
stakeholder group has several subcategories.

The purpose of stakeholder engagement is to build
trust between Sampo Group and its stakeholders, andto seek common benefits.

Sampo Group engages with its stakeholders on multiple
topics. The intention is to engage in activities anddialogue that are best aligned with the purposes of
Sampo Group and its stakeholders. Sampo Group seeks
to ensure meaningful engagement with stakeholders,for example, by identifying relevant stakeholders,
ensuring continuous and regular communication, andproviding multiple forums for dialogue.

109

Actions and results
Every year, Sampo Group engages in dialogue with key
stakeholder groups. The table Stakeholder engagementand dialogue lists some of the main forums for dialogue,
as well as some examples of discussion topics during2023. As a result of stakeholder engagement, Sampo
Group aims to develop its operations. Examples ofactions taken during the year include improved external
communications, customer service, and internalreporting.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices

Stakeholder engagement and dialogue
Sampo Group, 2023
Key stakeholder group

Forum for dialogue and approximate frequency

Examples of discussion topics in 2023

Investors (current and potential shareholders and debt
investors)• Annual General Meeting (AGM) (annual)• Capital Markets Day (CMD) (annual or less frequent)• Roadshows (quarterly)• Seminars (quarterly)• Virtual and face-to-face meetings (weekly)• Financial performance and targets• Strategy and Group structure• Regulatory development• Climate targets• Executive remuneration• Sustainability in general

Customers• Regular customer contact points, e.g., website, chat, contact
centre (24/7 or daily)• Customer feedback channels (24/7)• Customer satisfaction surveys (24/7 or daily)• Virtual and face-to-face meetings (daily)• Consumer ombudsman (daily)• Events (varying)• Company publications, e.g., magazines (varying)• Products and services• Loss prevention and claims handling• Sustainability in general• Market situation in general• Responsible business practices

Employees• Employee engagement surveys (bi-annual)• Performance appraisals and dialogue with superiors(varying)• Work environment committees (varying)• Meetings with union and employee representatives(varying)• Employee representation and consultation forums (varying)• Employee roadshows (on a needs basis)• Social events (varying)• Financial performance• Non-discrimination• Diversity and inclusion• Change in Group structure• Personnel surveys• Performance and development plans• Sustainable workplace• Virtual and face-to-face meetings (daily)• Events (varying)• Company publications, e.g., magazines (varying)• Financial performance• Supply chain management (e.g., targets, performance)• Sustainability considerations in supply chains• Change in Group structure• Future plans• Products and services• Virtual and face-to-face meetings (weekly)• Events (varying)• Company publications, e.g., magazines (varying)• Financial performance• Regulatory development• Sustainability in general• Climate change• Responsible investment

Suppliers and other business partners (e.g., analysts, rating
agencies)
Local communities (e.g., regulators, supervisors, industry
associations, educational institutions, NGOs, general public,
the media)

SUSTAINABILITY REPORT 2023

110≡

Introduction

Business management
and practices

Corporate
cultureIf
Some examples of If’s stakeholder engagement work
during 2023 are listed below.

Cooperation with CICERO and IVL Swedish
Environmental Research Institute
In 2023, If initiated and financed a research project toinvestigate how Norwegian municipalities are equipped
to deal with the increasing amount of extreme weather.
The research was conducted for the third time in close
cooperation with CICERO and IVL Swedish
Environmental Research Institute. If’s CEO, Morten
Thorsrud, handed over the final report to the Norwegian
Minister for Climate and Environment in October 2023.

Research project SafeBESS
If is part of a project called SafeBESS (Battery Energy
Storage Systems) driven by the research organisation
SINTEF during 2023–2026. The objective of theresearch is to establish theoretical and practicalknowledge for safe implementation of large-scale Li-ion
battery systems in buildings. During 2023, case studies
of existing battery installations were conducted,
together with a literature review of research material,
international standards, and regulations. Small scale firetests were also executed to prepare for more largescale testing of battery modules and racks in 2024.

Investment management
and operations

Products
and services

Communities

Cooperation with ICEYE
If was part of a one-year pilot investigating how satellite
data from a company called ICEYE can be utilised inclaims situations (e.g. mitigating losses, optimisingclaims handling resources). The aim of the project was
to learn whether If could be more proactive, byimproving abilities to predict potential floods, and tohave more communication and co-operation with its
customers when an event is potentially approaching.
The pilot was completed in September 2023. The
outcome gave an indication that the ICEYE technology
could suit If’s needs.

Cooperation with SAFERIn Sweden, If is a partner of SAFER, which is acompetence centre where partners from the Swedish
automotive industry, academia, and the authorities
cooperate to create a centre of excellence for traffic
safety research and safe mobility.
In a project called MICA2, finalised in 2023, If addressed
the safety of the car-to-cyclist overtaking manoeuvre.
The project focused on developing and testing
prototypical active and passive safety systems. If
analysed insurance claims crash databases to determine
relevant crash scenarios, and crash-causation
mechanisms for different overtaking phases.
In the Child Safety in Cars study, usage and acceptancestudies were performed to support the development ofsafety equipment. The study is an annual, publicly
available, report on Swedish parents’ knowledge andapproach to child safety in vehicles. In 2023, the 13thedition of the study was published. It examines how
child seats and boosters are used by drivers. If prepares
the report, publishes it online, and presents the resultsin different forums.

SUSTAINABILITY REPORT 2023

111

Appendices≡

In Sweden, If is engaged in a national programme called
Action plan for safe road traffic 2022–2025 led by the
Swedish Transport Administration. As part of the
programme, If, for instance, establishes research reports
on specific crash types, and provides consumer
information about safe and environmentally friendly
travelling to school for children.

Cooperation with the Estonian Hunters’
Association
In 2023, If continued its cooperation with the Estonian
Hunters’ Association to investigate whether and to what
extent the installation of light barrier reflectors on roads
could help to prevent and reduce accidents involving
wild animals. During the research, test sections havebeen installed on roads across Estonia, in areas with aparticularly high risk. To investigate the effectiveness of
the reflectors, some parts of the roads have been
covered with reflectors and others without. In 2023, If
participated in two projects: comparing road sections
with the reference sections and analysing the same
sections in different years' contexts. Both projects haveproduced encouraging results, as the presence of lightbarrier reflectors significantly reduces the number ofaccidents in the study areas. The research started in
2021 and will last for three years.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

complete the education with good results, and that they
are well equipped for the requirements of the insurance
industry. The company has a long tradition of trainee
programmes, and many of the company’s current
employees have been trainees themselves.

Topdanmark
Some examples of Topdanmark’s stakeholder
engagement work during 2023 are listed next.

Education in the insurance industry
Topdanmark wants to support education in theinsurance industry. Therefore, the company annuallyemploys finance trainees on a two-year training
programme and offers internships for students pursuingan AP in Financial Management or a Bachelor of
Financial Management and Services degree.
The trainees attend a structured education programme,
including training in theory and practice. The purpose of
the structured programme is to ensure that all trainees

Of all the finance trainees that completed theireducation with Topdanmark in 2023, 12 werepermanently employed upon completion of theireducation.

Research project From injury to prevention
During 2022 and 2023, Topdanmark and another
Danish insurance company participated in a research
project called From injury to prevention, carried out by

Education in the insurance industry
Topdanmark
TargetContribute to education in the insurance industry
by employing a minimum of 20 finance trainees
annually – in addition to finance internships

2023

2022

2021

Finance trainees: 28

Finance trainees: 17

Finance trainees: 16

Financial economists: Financial economists: Financial economists:
17
20
28
Finance Bachelors ininternship: 2

Finance Bachelors ininternship: 3

Finance Bachelors ininternship: 11

In 2023, the calculation method for finance trainees changed. Since the finance trainees are employed for two years, Topdanmark
decided to include in the calculations all employed finance trainees, regardless of the year they began their studies at Topdanmark.

SUSTAINABILITY REPORT 2023

112

Appendices≡

Aalborg University. The objective of the project was tomap where personal injuries occur in public, thus
enabling local governments to learn from experienceand establish a public space that either prevents or
minimises the occurrence of injuries. Topdanmark
contributed to the research by offering anonymised
claims data on places where personal injuries havetaken place. Based on the data, three local governments
in Denmark were selected for testing and they gained
information on areas of infrastructure that are
particularly risky. In Q2/2024, the project will becompleted, and the three local test governments will
receive the final report.

Introduction

Business management
and practices

Corporate
cultureHastings
Some examples of Hastings’ stakeholder engagement
work during 2023 are listed below.

Association of British Insurers sustainability
working group
The Association of British Insurers (ABI) is the voice of
the UK’s insurance and long-term savings industry. The
ABI sustainability working group consists of insurance
and long-term investment companies, that in 2021,
created a climate change roadmap of recommendations
for the industry. Working group members, which from2023 also includes Hastings, meet on a regular basis tocollaborate, share best practices, and discuss challenges
and upcoming changes in legislation. The aim is toensure progress against the recommendations in theroadmap, as well as supporting the wider industry
sector with adoption.

Futuready education programme
Hastings continued with its sponsorship and support of
the Futureready mentoring partnership in 2023.
Delivered across three diverse days, each young person
is guided through the course by a dedicated Hastingscolleague (business mentor) who has received training
to work with young people. The business mentors canshare their own personal journeys, successes, andfailures with the students and groups, and bring the realworld of employment into the lives of the young people.
In 2023, Hastings’ employees mentored 223 year nine(13- to 14-year-old) students.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Cooperation with Women in Data
During 2023, Hastings continued its partnership with
Women in Data. Hastings hosted an in-person
networking event in London which created numerous
new recruitment prospects. As a data driven company,
Hastings is committed to promoting data as a driving
force in the industry, and recognises the value ofworkforce diversity within the sector.

Tech Returners
In 2023, Hastings commenced a new partnership with
Tech Returners. The organisation’s goal is to address
the under-representation of women in tech, and help
individuals that have taken a career break due to caring
responsibilities or otherwise, return to the industry. The
partnership led to one successful hire in 2023.

Earthwatch
Earthwatch is an environmental charity driving thechange needed to live in balance with nature.
Earthwatch delivers community and environmental
support, whilst educating the next generation in
outdoor settings. The partnership contributes to
Hastings’ sustainability goals in supporting education,community sponsorship, and the environment. During2023, Hastings sponsored three Earthwatch
programmes: Teach Earth Programme (an 18-monthprogramme for trainee teachers), Science Leads Trainthe Trainer Sessions (training for 30 educators), andCreation of materials for age 14–16-year-olds to support
green careers.

113

Appendices≡

Sampo plc
During 2023, the focus of Sampo plc’s stakeholder
engagement was on the financial performance andstrategy of the Group, as well as on changes in theGroup structure. From a sustainability point of view,climate targets, executive remuneration, and regulatory
development are examples of discussion topics thatwere in focus during the year.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Donations and other humanitarian efforts
Sampo Group wants to make donations to and takepart in humanitarian efforts to support the communities
that the company and its employees are part of. At thesame time, donations can, for example, offer
reputational benefits for Sampo Group, help attract andretain employees, and provide possibilities to engage
with current or prospective customers.

Approach
Sampo Group has a group level community
engagement framework. The framework has threethemes, which guide donations and other humanitarianefforts. With donations and other humanitarian efforts,

Sampo Group also wants to support the Group’s
selected UN SDGs.
Every year, the Sampo Group companies decide which
initiatives they wish to support, and what types ofhumanitarian efforts they want to engage in. The
collaborations can range from one-off activities (e.g.,
donations, disaster relief) to long-term projects (e.g.,multiyear partnerships). In addition, Sampo Group
offers employee engagement initiatives, such as
matched donations and employee volunteering.
Sampo Group supports a range of charitable and civilsociety organisations both locally and internationally.

Community engagement framework
Sampo GroupSUSTAINABILITY REPORT 2023

114

The monitoring and evaluation of donations and otherhumanitarian efforts is done on a subsidiary level. Eachactivity and partnership is evaluated on a case-by-casebasis, with criteria depending on the nature and scopeof the cooperation.

Additional information:www.sampo.com/sustainability/communities/
donationsIntroduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Group goals and ambitions

If

Sampo Group’s primary aim is to make donations andtake part in humanitarian efforts that aim to make achange in society. Sampo Group is committed to further
improving the work year on year, for example, bydeveloping reporting and measurements, creating new
initiatives, and increasing employee participation.

Some examples of If’s donations and other humanitarianefforts during 2023 are listed next.

Actions and results
During 2023, Sampo Group made donations worth EUR
270,773. In 2021 and 2022, donations were greater due
to enhanced COVID-19 support, donations to Ukraine,and the inclusion of donations made by Mandatum.

Donations by company
EUR

2023

2022

If

99,140298,32765,020Topdanmark

53,947118,061

60,506

Hastings

46,395

114,313

169,400-

126,870

56,789Mandatum
Sampo plc
Sampo Group, total

2021

71,29176,80069,000270,773

734,372

420,715

Long-term commitments and otherpartnerships
Yellow Cap initiative
In Finland, If organises the Yellow Cap initiative, and has
donated reflective yellow caps for all first graders since2006. The aim is to improve children’s traffic safety, andover the course of 18 years, more than a million Finnish
children have received their own yellow cap. In 2023,
55,000 children began their first year of school, andalmost 56,000 yellow caps were sent to schools.
The Swedish Heart-Lung Foundation
In Sweden, If collaborates with the Swedish Heart-Lung
Foundation, to set up a crowdfunding platform toprovide defibrillators in residential areas. Defibrillators
substantially increase the likelihood of surviving cardiac
arrest, but as it is so important to have access to adefibrillator within the first five minutes, and mostcardiac arrests happen at home, the defibrillators need
to be available in residential areas. The platform waslaunched in September 2022, and by the end of 2023
almost SEK 3 million has been raised from 4,200
donors.
Youth organisations
In Sweden, If contributes SEK 360,000 annually
towards organisations or events supporting sports andathletics for children and youth. Each month, three If
employees are selected in a lottery awarding them SEK
10,000 in support of an organisation of their choice.

SUSTAINABILITY REPORT 2023

115

Appendices≡

The Norwegian fire safety organisation
In Norway, If has for many years cooperated with theNorwegian fire safety organisation, concerning fire
safety in private homes. Together, If and theorganisation have educated hundreds of thousands ofNorwegians about fire prevention, and every year If hasorganised a fire safety week. In 2023, the fire safety
week was organised in the autumn, and If sent out press
releases and organised activities targeting thecompany’s customers regarding the topic.
Support for Ukraine
In 2023, If organised a donation matching programme
to support Ukraine. Donation matching means that If
matches the donations made by its employees. If choseto channel help through several humanitarian civilsociety organisations operating in or close to Ukraine.
The programme will continue in 2024.

Employee volunteering
Community day programme
In most operating countries, If’s employees can dovolunteer work during working hours in support of acause of their own choosing. In 2023, employees
supported, for example, the Red Cross, Caritas, Food
Bank, and local organisations aiding Ukraine,
disadvantaged families, and animals.
Other employee volunteering activities
If employees actively contribute to charities, as they
have an option to donate their Christmas or birthday
gift to preferred charities selected by the company
each year. In 2023, contributions went towards
children’s charities, aid to Ukraine, and supporting
animal shelters.

Introduction

Business management
and practices

Corporate
cultureTopdanmark
Some examples of Topdanmark’s donations and otherhumanitarian efforts during 2023 are listed next.

Long-term commitments and otherpartnerships
FitforKids
In 2023, Topdanmark launched a three-year partnershipwith FitforKids. The partnership focuses on two aspects:
financial donations and professional support. All
Topdanmark employees can donate through their salary
to FitforKids and Topdanmark will match these
donations by the end of the year. In addition,
Topdanmark and FitforKids have set up a working
group with employees from both organisations,

Investment management
and operations

Products
and services

Communities

focusing on professional assistance and sharing ofexpertise. The donation of time and knowledge is meant
as a support for FitforKids in their organisational
development. To begin with, the professional assistancewill be communication and marketing support to help
FitforKids increase their brand value and reach.
Danish Cancer Society
In 2023, Topdanmark participated in the Danish Cancer
Society’s annual Fight Cancer campaign for the tenthconsecutive year. Topdanmark and its employees
contribute to the campaign financially, and by
exercising. The employees pay a participation fee andtake part in different exercise activities. Topdanmark
then makes a donation on behalf of the employees,
based on calories burned. In 2023, this resulted inseveral different activities run by the employees

Donations to FitforKids, the Danish Cancer Society, and Doctors Without Borders
Topdanmark, 2023
Donations made by
Topdanmark (DKK)

Donations made by
Topdanmark
employees (DKK)

Number of employees
participating

Expenses foradministration (DKK)

FitforKids

231,075

8,375

25

0

Danish Cancer Society

81,695489,978841

158,086

Doctors Without
Borders

38,56038,56052

0The cooperation with Doctors Without Borders ended in mid-2023 when the new partnership with FitforKids was launched.
The money donated in the first half of 2023 was to Doctors Without Borders, and the money donated in the second half of 2023
was to FitforKids.

SUSTAINABILITY REPORT 2023

116

Appendices≡throughout the campaign week, including dancing,running, yoga, and a 10-hour spinning marathon. 841
employees participated in the activities in 2023.
Topdanmark and its employees raised a total of DKK
571,673.
Danish Blood BankThe employees at Topdanmark’s headquarters candonate blood to the Danish Blood Bank during paid
working hours. Topdanmark has been part of the
donation programme since 1963. Therefore, in 2023,
Topdanmark and the Danish Blood Bank celebrated the60th anniversary of their cooperation. In 2023,
Topdanmark’s employees donated 100 litres of blood toDanish hospitals.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

AppendicesHastings

Employee volunteering

Sampo plc

Some examples of Hastings’ donations and otherhumanitarian efforts during 2023 are listed next.

Community day programme
Hastings employees are encouraged to play an active
part in supporting their communities through thecompany’s paid community day programme, whereby
employees can volunteer their working hours to support
a community activity. In 2023, employees provided
9,828 hours which equates to GBP 182,800. Employees
participated in a wide range of activities, such as beachcleans, helping at homeless centres, book reading, andsupporting school students with mock interviews.

Some examples of Sampo plc’s donations and otherhumanitarian efforts during 2023 are listed next.

Long-term commitments and otherpartnerships
Community grants
Hastings community grants scheme enables community
groups, schools, and charities to apply for one off
assistance either professionally or financially. Grants canbe applied for by anyone from the local community,
including employees who are able to submit
applications on behalf of intended recipients. During2023, Hastings supported 52 requests and provided a
total of GBP 40,100 in donations.
Insure Pink insurance product
The Hastings Insure Pink Insurance product, which
generates a donation to the Pink Ribbon Foundation in
the UK for every policy sold, raised over GBP 92,000 in
2023. The Pink Ribbon foundation provides support andfunding to breast cancer charities in the UK.
Furthermore, Hastings employees raised an additional
GBP 6,800 for the foundation in 2023, by way of acharity golf tournament.

SUSTAINABILITY REPORT 2023

Colleague fundraising
Charitable effort is encouraged at Hastings andemployees can raise funds for charities of theirchoosing. During 2023, employees raised a total of GBP
45,122 via a variety of different methods, ranging fromcake sales to sponsored marathon running. Employees
welcomed the opportunity to support charities close to
their hearts, and to make a difference for causes acrossa wide spectrum.

117

≡

WWF
In 2023, Sampo plc made an annual Christmas donationof EUR 50,000 to WWF Finland for nature
conservation. The donation is allocated to protecting
the Baltic Sea and improving biodiversity throughwetland conservation and river restoration projects.
Sampo Group is committed to protecting theenvironment, and combating climate change in its
sustainability programme. WWF's work to protect theBaltic Sea and river environments support this goal.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡Tax footprint
Sampo Group is a significant and responsible taxpayer,
and tax compliance is viewed as an important part of
the Group’s business and sustainability. The taxes
Sampo Group pays also have a wider economic andsocial impact, and play an important role in thedevelopment of the countries in which the company
operates.
Sampo Group acts transparently and responsibly in all
tax matters, and works closely with the tax authorities
to ensure all tax payments are fair and follow legislation.
Sampo Group can face reputational risks, operationalrisks, and business risks if it fails to pay its taxes
effectively and accurately.

Approach
Sampo Group is committed to compliance with thespirit, as well as the letter of the tax laws andregulations in the countries in which it has operations.
The Sampo Group Code of Conduct provides the grouplevel guidance principles regarding taxes. The Code of
Conduct is reviewed annually, and approved by Sampo
plc’s Board of Directors.
Tax matters are embedded in the finance function andare, therefore, within the responsibility of the Group
CFO. The Group CFO informs the Board of key strategic
tax topics when necessary. The day-to-day
responsibility for tax-related matters is upheld by the

SUSTAINABILITY REPORT 2023

individual Group companies and their finance and tax
specialists. Furthermore, internal governance models,mandatory legal and regulatory requirements, andsupervision carried out by the financial supervisory
authorities ensure that Sampo Group maintains a highlevel of tax compliance.
Sampo Group’s approach to tax risk management is
consistent with and embedded in overall risk
management. Sampo Group actively identifies, assesses,monitors, and manages tax risks to ensure that theyremain in line with the business and strategic objectives,
taking into account the Group’s appetite towards tax
risks.
Sampo Group supports the work at national andinternational level for a better and fairer tax system, toimprove the balance among the various interests ofsociety, politics, and business. The Sampo Group
companies are members of various industry
associations (e.g. Finance Finland, Insurance Sweden,
Finance Norway, Insurance and Pension Denmark, theConfederation of Finnish Industries, and Association of
British Insurers). Sampo Group seeks to influence policy
and legislation, and engage in dialogue, regarding taxes
primarily through active participation in the work ofindustry associations.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct

118

Group goals and ambitions
Sampo Group’s aim is to be a responsible taxpayer.

Actions and results
In 2023, the taxes payable and collected by Sampo
Group totalled EUR 2,058.2 million. If represents 49.6
per cent, Topdanmark 13.5 per cent, and Hastings 26.9
per cent of the total. The parent company Sampo plc’s
share was 10.0 per cent, which is mainly due to taxes
withheld on dividends, as the parent company does not
usually conduct other significant taxable operations.
Hastings’ relatively low effective tax rate is mainly due
to higher investment income in 2023 in the Gibraltar
insurer entity Advantage Insurance Services Ltd.
Investment income is non-taxable under Gibraltar
corporation tax rules and, therefore, higher investment
income reduces the effective tax rate.
During 2023, Sampo Group did not receive any financial
assistance (e.g. grants or tax relief) from governments
of individual countries.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesTaxes payable and collected
Sampo Group
EURm

2023

2022

2021

Corporate income tax

289.0

326.4

365.4

Employment taxes

155.7

172.6

146.1

5.6

6.0

5.2

450.4

505.0

516.7

Taxes paid by the Group

Other taxes
Total
Taxes collected by the Group
VAT

45.7

57.5

54.4

Insurance premium tax

714.4

643.8

594.0

Other taxes and charges

350.0

573.3

832.9

Withholding tax

497.7

382.5

181.1

Total

1,607.8

1,657.0

1,662.3

Total tax contribution

2,058.2

2,162.1

2,179.1

Mandatum is included in 2021 and 2022 figures.

Taxes payable and collected by company
If
EURm

Topdanmark

Hastings

2023

2022

2021

2023

2022

2021

2023

Corporate income tax

223.6

267.1

214.3

49.9

32.6

81.2

15.1

Employment taxes

100.4

114.0

90.3

35.3

38.2

39.0

17.7

4.1

3.7

3.1

0.8

0.0

0.0

0.7

328.1

384.8

307.7

86.0

70.7

120.2

33.6

2022

Sampo plc
2021

2023

2022

2021

7.6

15.8

0.4

0.3

1.2

17.5

13.9

2.4

2.2

1.7

0.8

0.7

0.0

0.0

0.0

25.8

30.5

2.7

2.5

2.9

Taxes paid

Other taxes
Total
Taxes collected
VAT

33.4

39.7

39.0

1.9

4.8

5.3

7.2

6.0

5.0

3.3

3.2

3.7

Insurance premium tax

451.7

464.6

438.2

50.3

12.6

12.6

212.4

166.6

143.1

0.0

0.0

0.0

Other taxes and charges

207.3

207.9

198.2

95.8

183.7

460.3

40.2

39.4

31.7

6.7

8.2

6.3

0.0

0.0

0.0

44.2

48.5

27.2

259.8

0.0

0.0

193.8

334.0

153.9

Withholding tax
Total
Total tax contribution

SUSTAINABILITY REPORT 2023

692.3

712.2

675.3

192.2

249.6

505.5

519.5

212.0

179.9

203.8

345.4

163.9

1,020.4

1,097.0

983.0

278.2

320.4

625.7

553.1

237.8

210.3

206.5

348.0

166.8

119

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

AppendicesTaxes payable and collected by country
Sampo Group
Finland
EURm

Denmark

2023

2022

2021

2023

2022

Corporate income tax

67.6

139.5

97.4

64.3

32.1

Employment taxes

2.0

2.3

2.4

44.6

47.3

Other taxes

3.3

4.5

4.1

0.9

0.1

72.9

146.2

103.9

109.8

79.5

Norway2021

Sweden

2023

2022

2021

92.3

56.4

57.0

48.4

28.0

27.5

-0.1

0.1

0.1

140.7

84.5

84.6

United Kingdom

2023

2022

2021

2023

71.3

72.1

84.4

83.9

9.4

26.5

51.8

68.3

45.9

17.7

0.0

0.0

0.0

0.0

0.8

97.8

123.9

152.8

129.9

27.9

2022

Other countries

2021

2023

2022

2021

-1.3

4.7

19.2

14.8

15.7

17.5

13.9

11.7

9.7

8.9

0.8

0.8

0.5

0.4

0.3

17.0

19.5

31.5

24.9

25.0

Taxes paid

Total
Taxes collected
VAT
Insurance premium tax

11.9

17.3

14.7

2.4

8.8

9.1

5.4

6.1

5.5

18.1

18.4

18.8

7.3

6.2

5.2

0.6

0.6

1.2

200.9

185.7

178.1

73.4

39.2

36.4

172.4

193.1

177.7

44.1

49.6

50.4

214.4

168.2

144.5

9.3

7.9

6.9

Other taxes and charges

74.4

207.5

205.6

123.4

210.7

486.4

39.2

41.5

39.2

59.1

62.7

59.0

39.2

38.5

31.1

14.6

12.4

11.6

Withholding tax

193.8

334.0

153.9

44.2

48.5

27.2

0.0

0.0

0.0

0.0

0.0

0.0

258.6

0.0

0.0

1.2

0.0

0.0

Total

481.0

744.5

552.3

243.4

307.3

559.1

217.0

240.7

222.5

121.3

130.8

128.2

519.4

212.9

180.7

25.7

20.9

19.6

Total tax contribution

553.9

890.8

656.1

353.2

386.8

699.8

301.5

325.3

320.4

245.2

283.5

258.1

547.3

229.9

200.2

57.1

45.7

44.6

Mandatum is included in 2021 and 2022 figures.

Effective tax rate%

Corporate tax rate in the largest operating countries
2023

2022

If

21.0

21.0

21.0

Topdanmark

26.5

10.0

27.9

Hastings

8.6

14.1

29.5

-

21.3

20.6

22.5

17.0

23.7

Mandatum
Sampo Group

Sampo Group

2021

%

2023

2022

Denmark*

25.2/22.0

22.0

2021
22.0

Norway*25.0/22.0

25.0/22.0

25.0/22.0

Sweden

20.6

20.6

20.6

Finland

20.0

20.0

20.0

25.0/19.0

19.0

19.0

United Kingdom*** Employers in the insurance industry are subject to a higher tax rate.
** 19 per cent from 1 January 2023 to 31 March 2023 and 25 per cent from 1 April 2023 onwards.

SUSTAINABILITY REPORT 2023

120

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

AppendicesDistribution of corporate income tax by company

Distribution of corporate income tax by country

Sampo Group, 2023

Sampo Group, 2023

SUSTAINABILITY REPORT 2023

121≡

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Appendices
Appendix 1: Calculation principles ...........................................................................
Appendix 2: GHG emissions ........................................................................................
Appendix 3: GRI content index .................................................................................
Appendix 4: TCFD content index .............................................................................
Appendix 5: SASB content index..............................................................................
Appendix 6: The UN Sustainable Development Goals .....................................
Independent practitioner’s assurance report ......................................................
Signatures to the Sustainability Report .................................................................
Contacts ..............................................................................................................................

SUSTAINABILITY REPORT 2023

123
127
132
138
139
140
142
144
145

122

Products
and services

Communities

Appendices≡Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Appendix 1: Calculation principles
Scope and structure of thereportApproach used forconsolidation

The report refers to the period from 1 January to 31
December 2023, unless otherwise stated. The report isonly available in digital format.

The consolidation principles used in sustainability
reporting follow those used in Sampo Group’s financial
reporting. The consolidated sustainability report
combines sustainability information from Sampo plc
and all its subsidiaries. The definition of a subsidiaryderives from the Group’s financial reporting.

The reporting scope covers the entire Sampo Group,
meaning the parent company Sampo plc and its
subsidiaries If, Topdanmark, and Hastings. Mandatum
was separated from Sampo Group by partial demerger
on 1 October 2023. Therefore, the company is not partof this report. The report provides group level
information, with some exceptions depending on theavailability of comparable data between the Group
companies or the nature of the Group and the Group
companies.
The report is structured around Sampo Group’s five
strategic sustainability themes: Sustainable business
management and practices, Sustainable corporate
culture, Sustainable investment management andoperations, Sustainable products and services, andSustainable communities. Under each theme, theGroup’s most material sustainability topics are
discussed.
There are no changes to material topics or topic
boundaries compared to the previous reporting year.
There was no need for significant restatements of
information from previous reporting periods. Someminor corrections were made, which have been statedin connection with each specific data point (e.g. GHG
emissions from own operations).

SUSTAINABILITY REPORT 2023

Group level calculation principles have been applied to
calculate most of the key figures and, therefore, thestatistics may deviate from locally published companyspecific figures.
In financial reporting, investments in associates aretreated using the equity method of accounting. In
Sampo Group’s sustainability reporting, associates are
excluded from the scope.
No adjustments to information for minority interests
have been made in 2023.
When it comes to mergers, acquisitions, and thedisposal of entities or parts of entities, the approach isconsidered on a case-by-case basis. It depends, forexample, on timing, size, and the impact of thetransaction in question. Mandatum was separated from
Sampo Group by partial demerger on 1 October 2023.
In 2023, Mandatum is excluded from the reporting, if
not stated otherwise. On 1 December 2023,
Topdanmark acquired Oona Health A/S. This report
does not include Oona Health, as it was not integrated
into Topdanmark’s reporting when this report was
prepared.

123

To enable comparison, figures from previous years areprovided, when available and considered material. Dueto rounding, numbers presented throughout this report
may not add up precisely to the totals indicated, andpercentages may not precisely reflect the absolute
figures for the same reason. Exchange rates used insustainability reporting are the same as those used in
Sampo Group’s financial reporting.
If the consolidation approach differs from the one
presented here, this has been mentioned in thecalculation principles and/or in the context of eachmaterial topic and its related indicators.
A summary of Sampo Group’s significant accounting
policies is available in the Board of Directors’ Report
and Financial Statements.

Reporting frameworks
The report has been prepared to meet the regulatory
requirements for non-financial information, in
accordance with Chapter 3a, Section 5 of the Finnish
Accounting Act. According to the regulation, Sampo plc
publishes the sustainability report of the Group on anannual basis, as soon as possible, after the publicationof the Board of Directors’ Report and Financial
Statements, but no later than 30 June.
The report has been prepared in accordance with the
GRI Standards. The GRI content index is presented inAppendix 3. The report also references the Task Forceon Climate-related Financial Disclosures (TCFD) andSustainability Accounting Standards Board (SASB)
frameworks. TCFD and SASB content indices areavailable in Appendix 4 and Appendix 5, respectively. In

Introduction

Business management
and practices

Corporate
cultureaddition, the report meets the requirements of the UN
Global Compact, and communicates Sampo Group’s
performance regarding the UN Sustainable
Development Goals.
Sampo plc will integrate the Group’s sustainability
reporting into the Board of Directors’ report, according
to the requirements of the Corporate Sustainability
Reporting Directive in 2025, covering the reporting year
2024. Disclosures related to the EU Taxonomy arereported as part of the Board of Directors’ report
already for the reporting year 2023.

Assurance
The Sustainability Report 2023 was assured by anindependent third-party assurance provider with a levelof limited assurance.

Sustainable business
management and practices
Anti-corruption and bribery
Reported corruption and bribery incidents are severe
incidents that are reported to Sampo plc by the Group
companies as part of sustainability and complianceand/or risk reporting.

Anti-money laundering andcounter terrorist financing
Money laundering and terrorist financing suspicions
reported to the authorities are suspicions related tocustomer transactions.

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Human rights and labour practices
The number of internally reported human rights
incidents includes any severe violations of human rights
and labour rights legislation. The number of incidents of
discrimination and harassment includes incidents of
discrimination as defined in the Sampo Group Code of
Conduct and incidents of harassment that have led toformal consequences (e.g. warning or dismissal).

Appendices≡by train, bus, taxi, and rental car, and accommodation),
paper and water consumption, cloud services, ITequipment, employee commuting, waste, and fuel andenergy-related activities. Calculations on employee
commuting are based on a survey conducted by
Deedster in 2021. For If’s subsidiary Viking, only scope 1
and 2 are included in the reporting. The total figure formobile combustion includes Viking’s unspecified fossil
fuel consumption.

The GHG accounting and reporting procedure is basedon the Greenhouse Gas Protocol. Under the GHG
Protocol, emissions are divided into direct and indirectemissions. The direct and indirect emissions are further
divided into three scopes: Scope 1 (direct emissions),
Scope 2 (indirect emissions), and Scope 3 (otherindirect emissions). The marked-based approach is used
for electricity.

Topdanmark reported Scope 1 and 2 data on purchased
electricity and heat for all its offices, self-generated
electricity as well as fuels for stationary and mobile
combustion. Electricity, heating, waste, and water
consumption for the smaller offices (Herning, Odense,
Vejle, Næstved, Ringsted, and Aalborg) were based on
average consumption per FTE or square metre officearea. For the Ballerup office, which is shared withanother company, the consumption was split based on
the respective office surface areas. Scope 3 data
sources include business travel (flights, staff car
reimbursements, travel by train, ferry, taxi and rental
car, and accommodation), paper and water
consumption, cloud services, other purchased goods
and services, IT equipment, employee commuting andremote working, waste, fuel and energy-related
activities, and downstream leased assets. Data on
employee commuting was based on a survey
conducted in 2022. The survey had a 39 per centresponse rate and the results were extrapolated torepresent all employees. For remote working, it was
assumed that employees work from home 40 per centof their time, which is according to company policy.

If reported Scope 1 data on fuel consumption incompany-owned and leased vehicles, and Scope 2 dataon electricity, heating, and cooling. All electricity used in
If’s major offices in the Nordic countries comes fromrenewable sources. Scope 3 data sources include
business travel (flights, staff car reimbursements, travel

Hastings reported Scope 1 data on fuel consumption in
stationary machinery and refrigerants, and Scope 2 dataon electricity consumption. Scope 3 data sources
included business travel (flights, staff car
reimbursements, travel by taxi and train, andaccommodation), paper and water consumption, cloudEnvironmental impacts of group
operations
The GHG emission calculations include If (Nordic andBaltic offices, including subsidiaries), Topdanmark (alloffices), Hastings (all offices), and Sampo plc (Finnish
office). Oona Health, acquired by Topdanmark in
December 2023, was excluded from the 2023
calculations due to its small size and the recent
acquisition. The GHG emissions and related data arereported at both Group and company level. Group levelcalculation principles are used, and an external data
provider, South Pole, conducted the calculations basedon data provided by the Group companies.

124

Introduction

Business management
and practices

Corporate
cultureservices, other purchased goods and services, ITequipment, remote working, waste, and fuel andenergy-related activities. No data was available for theSunderland office, so emissions are based on thenumber of employees and average from other locations.
Sampo plc reported Scope 1 data on fuel consumption
by company-owned and leased vehicles, and Scope 2
data on electricity, heating, and cooling. Scope 3 data
sources include business travel (flights, staff car
reimbursements, taxi rides, and accommodation), paper
and water consumption, food services, cloud services,other purchased goods and services, IT equipment,
employee commuting and remote working, waste, fueland energy-related activities, and upstream
transportation and distribution. Data on employee
commuting and remote working was collected througha survey. The response rate was 48 per cent and theresults were extrapolated to represent all employees.
Overall, the data inventory, emission factors, andassumptions were based on the GHG Protocol. The
selection of assumptions and emission factors followed
a conservative approach. Where activity data for theinventory was lacking, extrapolations and estimations
were made. Further information on consumption dataand emissions is available in Appendix 2: GHG
emissions.

Compliance with laws andregulations
In the context of sustainability reporting, the instancesof non-compliance are considered significant if they forexample, result in fines or relate to restrictions imposedby governments, regulatory authorities, or publicagencies on the Group companies’ activities oroperations (e.g. withdrawal of trading licences or
licences to operate). They can also include the

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Appendices≡corrective powers of supervisory authorities anddirectives to cease or remediate an unlawful activity.

only the healthcare services that the employer offers
voluntarily without any statutory requirement.

Sustainable corporate culture

The gender pay gap describes the difference in actual
paid out compensation between men and women. The
difference in pay can be explained by factors such as
position in the company, job tasks, responsibilities, andleave of absence.

Full-time equivalents (FTE) are used to report personnel
figures, except for contingent workers, non-guaranteed
hours employees, employee turnover (external,
voluntary and involuntary turnover), new employees,
and employees on collective bargaining agreements
figures, which are calculated according to headcount.
Mostly, year-end figures are used, except for employee
turnover (external, voluntary and involuntary turnover),absence due to illness, new employees, work-related
injuries and deaths, and training costs, which arecalculated using averages. Remuneration-related figures
are also calculated using the FTE average. Exchange
rates have an impact on the remuneration figures
presented in the report.
Most Sampo Group employees work in Finland,
Sweden, Norway, Denmark, the UK, Estonia, Latvia, andLithuania. In addition, a small number of employees
work in what is called in Group reporting ‘Other
countries’. These countries have been combined inreporting due to the size of operations in thesecountries and the number of Sampo Group employees
working there. These other countries include Spain,
Gibraltar, France, Germany, the Netherlands, and theUnited States.
Employee engagement is measured and reported using
company-specific metrics. Therefore, the figures are notcomparable.
The occupational healthcare system refers to healthcare
services that the employer offers to employees. It canbe either statutory or voluntarily offered.
Supplementary occupational healthcare, in turn, covers

125

Sustainable investment
management and operations
Investment management at Sampo
Group and If
If and Sampo plc have a common infrastructure forinvestment management. Sampo plc prepares externalreporting on If’s ESG integration, sector-based
screening, norms-based screening, active ownership,
and assets managed by external investment managers.
The reporting is based on data obtained from external
data providers and investment managers. Sampo plc is
also responsible for group level reporting regarding
investments.

Investment management at
Topdanmark and Hastings
Topdanmark and Hastings manage their investments
independently of the other Group companies. The data
presented in these sections of the report are preparedbased on information received from Topdanmark andHastings.

Climate impact of investments
The carbon footprint analysis and climate impact
assessment of investments includes the direct equity
and direct fixed income investments of If, Topdanmark,Introduction

Business management
and practices

Corporate
cultureHastings, and Sampo plc. Sovereign investments were
excluded. The calculations were conducted by ISS ESG.

Carbon footprint analysis
The methodology of ISS ESG is based on two pillars: 1)
ISS ESG collects self-reported GHG data from allavailable sources, including sustainability reports, theCDP, Bloomberg, investor relations and other company
communications. Once self-reported emissions datafrom all available sources is collected, the data is thentested for trustworthiness. 2) For all non-reporting
companies, ISS ESG has developed an approach formodelling such data.
The financed emissions measure the carbon footprint of
a portfolio taking Scope 1, 2 and 3 emissions into
account. The relative carbon footprint is a normalised
measure, defined as the total carbon emissions of theportfolio for each million euros invested. Carbon
intensity is a metric that applies the ownershipapproach to also determine an investor’s share ofrevenue, subsequently dividing one by the other. By
linking to revenue, the metric is intended to describe
the carbon efficiency of the underlying holdings. The
weighted average carbon intensity is derived directlyfrom the TCFD recommendations, in which GHG
emissions are allocated based on portfolio weights
rather than the ownership approach.

Climate impact assessment
Climate scenario analysis
The report presents three climate scenarios provided by
the International Energy Agency (IEA) in their report
World Energy Outlook 2021. These are the Sustainable

SUSTAINABILITY REPORT 2023

Investment management
and operations

Products
and services

Communities

Development Scenario (SDS), the Announced Pledges
Scenario (APS), and the Stated Policy Scenario(STEPS). Each scenario expects a certain level oftemperature increase by 2100 and is thus tied to acarbon budget.
A carbon budget specifies the cumulative amount ofcarbon dioxide emissions permitted if the temperature
is to remain within a certain limit by the end of the
century. For example, to remain within the limits of the
SDS, less carbon can be combusted compared to thescenarios that expect a significant temperature
increase, that is, the STEPS.
The ISS ESG scenario analysis combines the IEA
scenarios with the Sectoral Decarbonization Approach(SDA) by allocating a carbon budget to a company
based on its market share and the expected emissions
trajectory associated with that sector. For most sectors,
this analysis is based on direct and indirect emission
intensity in relation to revenue. For certain sectors, suchas utilities and fossil fuel producers, sector-specificapproaches are implemented.
The Portfolio emissions vs. climate scenarios graphplots the alignment on a portfolio level per year, while
the shaded areas illustrate the emission budgets per
year according to the respective scenarios. The slope of
the portfolio line is influenced by the portfolio
composition and the ownership ratio in each company.
Emission reduction targets are also taken into
consideration, and the expected trajectories ofcompanies are adjusted downwards if companies set
either ambitious targets, or committed or approved
science-based targets.

126

Appendices≡

Climate targets analysis
The climate targets analysis gives an indication of how
well companies are aligning with international climate
goals. Issuers are grouped into five categories,
distinguishing between No target, Non-ambitious
target, Ambitious target, Committed science-basedtarget, and Approved science-based target. Nonambitious and ambitious targets are analysed as part of
the ISS ESG ratings factor GHG emission reduction
targets and action plans. This factor identifies
companies that have set climate targets outside the
SBTi.

Sustainable products andservices
Information on products and services, supply chain
management, sales and marketing practices, andcustomer satisfaction is reported at a company level.
Metrics and calculation methods used in these sectionsof the report are not comparable from one Group
company to another. The reporting is adjusted for eachsubsidiary and its specific needs.

Sustainability in communities
Tax footprint and donations are reported at Group andcompany levels using common group-wide calculation
principles. The tax figures are unaudited and based on
advance information. Effective tax rate is groupeffective tax rate, excluding the share of associates.

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Appendix 2: GHG emissions
GHG emissions
Sampo Group

Scope 1: Direct GHG emissions
Stationary combustion
Natural gas
BiogasGas oil
Mobile combustion
DieselPetrolRefrigerants
Scope 2: Indirect GHG emissions
Electricity
Renewable
Grid
Heating and coolingDistrict heating
District coolingDistrict heating/cooling
Scope 3: Other indirect emissions
Purchased goods and services
Water supply and treatment
Paper
Food services
Cloud services
Other purchased goods and services
IT equipment
Capital goods
IT equipment
Other
Fuel and energy-related activities
Natural gas
BiogasGas oil
DieselSUSTAINABILITY REPORT 2023

2023
emissions(tCO2e)1,059.8
696.0
695.5
0.0
0.5
348.1
185.6
132.1
15.7
3,585.3
3,345.6
0.0
3,345.6
239.7
217.4
7.2
15.2
18,766.3
1,652.1
19.8
71.1
18.9
150.7
1,391.7
2,246.9
1,954.0
293.0
1,296.0
117.7
5.7
0.1
36.1

2022
emissions(tCO2e)1,297.9
801.4
800.1
1.3
493.7
281.9
186.1
2.7
4,663.5
3,746.8
0.0
3,746.8
916.7
826.5
10.6
79.7
15,581.2
2,102.3
23.7
80.0
74.6
102.0
28.5
1,793.6
248.5
204.5
44.0
1,483.0
136.3
0.3
54.7

Change2022–2023
(%)
-18.3
-13.2
-13.1
-64.8
-29.5
-34.2
-29.0
476.6
-23.1
-10.7
-10.7
-73.9
-73.7
-32.0
-81.0
20.4
-21.4
-16.4
-11.1
-74.7
47.8
4783.5-100.0
804.2
855.6
565.3
-12.6
-13.6
-64.8
-34.0

PetrolRenewable electricity
Grid electricity
District heating
District coolingDistrict heating/cooling
Upstream transportation and distribution
Waste generated in operations
Business travel
Flights
Staff carRental car
Taxi
Train
Bus
Ferry
Accommodation
Employee commuting and remote working
Commuting
Walk or bike
E-bike, moped or motorcycle
Public transport
Car
Plane
Remote working
End-of-life treatment of sold products
Downstream leased assets
Total

127

2023
emissions(tCO2e)
14.1
273.0
678.4
148.4
7.8
14.6
52.3
231.6
6,306.4
3,817.8
2,017.5
21.9
57.9
81.0
2.1
5.2
303.0
6,842.4
4,819.9
0.0
8.3
414.4
4,385.1
12.0
2,022.5
0.0
138.6
23,411.3

2022
emissions(tCO2e)
19.9
291.2
759.7
196.5
8.3
16.0
281.0
5,945.1
3,437.7
2,187.0
20.5
63.8
46.4
1.9
187.8
5,521.1
5,024.0
0.0
8.3
456.3
4,547.4
12.0
497.1
0.1
21,542.6

Change2022–2023
(%)
-29.3
-6.2
-10.7
-24.5
-5.9
-8.8
-17.6
6.1
11.1
-7.8
6.8
-9.2
74.5
11.8
61.3
23.9
-4.1
1.1
-9.2
-3.6
0.0
306.8
-100.08.7

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

GHG emissions
Sampo Group, 2023

3,808
201
167
173,211
99,38560,02814MWhMWhlitreslitreslitreslitreskg

22,66715,457
7,210
11,610
9,328
1,814
468

MWh
MWh
MWh
MWh
MWh
MWh
MWh

3,585.3
3,345.6
0.0
3,345.6
239.7
217.4
7.2
15.2

15.3
14.3
0.0
14.3
1.0
0.9
0.0
0.1

m3
tonnesEUR

18,766.3
1,652.1
19.8
71.1
18.9

80.2
7.1
0.1
0.3
0.1

several

150.7

0.6

several1,391.7
2,246.95.9
9.6

Consumption
Scope 1: Direct GHG emissions
Stationary combustion
Natural gas
BiogasGas oil
Mobile combustion
DieselPetrolRefrigerants
Scope 2: Indirect GHG
emissionsElectricity
Renewable
Grid
Heating and coolingDistrict heating
District coolingDistrict heating/cooling
Scope 3: Other indirectemissionsPurchased goods and services
Water supply and treatment
Paper
Food services

47,532
181
122,333

Cloud services
Other purchased goods andservices
Capital goods
IT equipment
Other
Fuel and energy-related
activities
Natural gas
BiogasGas oil
DieselSUSTAINABILITY REPORT 2023

Share of total
emissions
(%)
4.5
3.0
3.0
0.0
0.0
1.5
0.8
0.6
0.1

Emissions(tCO2e)1,059.8
696.0
695.5
0.0
0.5
348.1
185.6
132.1
15.7

Unit

18,142
1,150,769

Number ofdevicesEUR

1,954.0
293.0

8.3
1.3

3,808
201
167
99,385MWhMWhlitreslitres1,296.0
117.7
5.7
0.1
36.1

5.5
0.5
0.0
0.0
0.2

PetrolRenewable electricity
Grid electricity
District heating
District coolingDistrict heating/cooling
Upstream transportation anddistribution
Waste generated in operations
Business travel
Flights
Staff carRental car
Rental car
Taxi
Taxi
Train
Bus
Ferry
Accommodation
Employee commuting andremote working
Commuting
Walk or bike
E-bike, moped or
motorcycle
Public transport
Car
Plane
Remote working
End-of-life treatment of soldproducts
Downstream leased assets
Total

128

Share of total
emissions(%)
0.1

Consumption
60,028Unit
litresEmissions(tCO2e)14.1

15,457
5,060
8,900
1,643
468

MWh
MWh
MWh
MWh
MWh

273.0
678.4
148.4
7.8
14.6

1.2
2.9
0.6
0.0
0.1

311,442994
32,818,712
16,518,490
11,551,353
151,960
5,860
351,538
41,0704,188,919
24,96331,489EUR
tonnes
pkm
pkm
pkm
pkm
DKK
pkm
EUR
pkm
pkm
pkm

52.3
231.6
6,306.4
3,817.8
2,017.5
21.8
0.1
47.2
10.7
81.0
2.1
5.2

0.2
1.0
26.9
16.3
8.6
0.1
0.0
0.2
0.0
0.3
0.0
0.0

23,987

Number ofnights303.0

1.3

43,810,858
2,454,358

pkm
pkm

6,842.4
4,819.9
0.0

29.2
20.6
0.0

419,297
12,004,409
28,888,794
44,000820,072

pkm
pkm
pkm
pkm
Days WFH

8.3
414.4
4,385.1
12.0
2,022.5

0.0
1.8
18.7
0.1
8.6

0

tonnesseveral0.0
138.6
23,411.3

0.0
0.6
100.0

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Sampo Group

If

Topdanmark≡

Appendices

GHG emissions by company
Sampo GrouptCO2e

Hastings

Sampo plc

2023

2022

2023

2022

2023

2022

2023

2022

2023

2022

Scope 1: Direct GHG emissions

1,059.8

1,297.9

136.6

175.8

752.8

886.5

165.4

185.9

5.0

7.3

Stationary combustion

696.0

801.4

-

-

546.3

618.3

149.8

183.2

-

-

695.5

800.1

-

-

546.3

618.3

149.3

181.9

-

-

Biogas

0.0

-

-

-

-

-

0.0

-

-

-

Gas oil

0.5

1.3

-

-

-

-

0.5

1.3

-

-

348.1

493.7

136.6

175.8

206.5

268.2

-

-

5.0

7.3

Diesel

185.6

281.9

13.0

24.4

171.6

240.7

-

-

1.0

2.0

Petrol

132.1

186.1

93.2

125.8

34.9

27.5

-

-

4.0

5.3

Refrigerants

15.7

2.7

-

-

-

-

15.7

2.7

-

-

Scope 2: Indirect GHG emissions

3,585.3

4,663.5

1,033.8

1,903.2

2,297.5

2,538.0

244.5

102.4

9.5

10.2

Electricity

3,345.6

3,746.8

807.6

1,101.2

2,293.3

2,533.5

244.5

102.4

0.1

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

3,345.6

3,746.8

807.6

1,101.2

2,293.3

2,533.5

244.5

102.4

0.1

-

Heating and cooling

239.7

916.7

226.2

801.9

4.2

4.5

-

-

9.3

10.2

District heating

217.4

826.5

204.0

712.0

4.2

4.5

-

-

9.2

10.0

District cooling

7.2

10.6

7.0

10.3

-

-

-

-

0.2

0.2

District heating/cooling

15.2

79.7

15.2

79.7

-

-

-

-

-

-

18,766.3

15,581.2

9,686.1

9,072.3

4,757.3

4,188.2

4,062.1

1,473.7

260.8

150.6

Purchased goods and services

1,652.1

2,102.3

104.7

1,362.4

137.5

14.0

1,373.6

610.7

36.3

31.8

Water supply and treatment

19.8

23.7

12.8

16.5

4.5

4.0

2.4

2.4

0.1

0.1

Paper

71.1

80.0

59.9

64.4

10.8

8.5

0.1

0.5

0.3

0.2
17.1

Natural gas

Mobile combustion

Renewable
Grid

Scope 3: Other indirect emissions

Food services

18.9

74.6

-

-

-

-

-

-

18.9

Cloud services

150.7

102.0

31.9

33.2

115.7

1.5

1.8

62.5

1.3

2.8

Other purchased goods and services

1,391.7

28.5

-

-

6.5

-

1,369.4

-

15.7

11.7

IT equipment-

1,793.6-

1,248.3

-

-

-

545.3

-

-

2,246.9248.5

1,386.0

-

407.5

110.7

434.0

-

19.4

13.3

IT equipment

1,954.0

204.5

1,386.0

-

407.5

110.7

142.1

-

18.4

13.0

Other

293.0

44.0

-

-

-

-

291.9

-

1.0

0.3

1,296.0

1,483.0

356.5

425.8

780.7

874.3

153.6

129.4

5.3

5.8

Natural gas

117.7

136.3

-

-

93.1

105.3

24.6

31.0

-

-

Biogas

5.7

-

-

-

-

-

5.7

-

-

-

Gas oil

0.1

0.3

-

-

-

-

0.1

0.3

-

-

Diesel

36.1

54.7

2.5

4.6

33.4

46.8

-

-

0.2

0.4

Capital goods

Fuel and energy-related activities

SUSTAINABILITY REPORT 2023

129

Introduction

Business management
and practices

tCO2e

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Sampo Group

If

Topdanmark≡

AppendicesHastings

Sampo plc

2023

2022

2023

2022

2023

2022

2023

2022

2023

2022

14.1

19.9

9.9

13.5

3.7

2.9

-

-

0.4

0.6

Renewable electricity

273.0

291.2

183.5

155.1

43.3

48.8

43.3

64.6

2.9

2.9

Grid electricity

678.4

759.7

7.3

70.3

591.3

653.2

79.8

33.5

0.0

-

District heating

148.4

196.5

130.8

158.0

15.9

17.3

-

-

1.8

1.9

PetrolDistrict cooling

7.8

8.3

7.8

8.3

-

-

-

-

0.0

0.0

District heating/cooling

14.6

16.0

14.6

16.0

-

-

-

-

-

-

Upstream transportation and distribution

52.3

-

-

-

-

-

-

-

52.3

-

Waste generated in operations

231.6

281.0

182.3

193.9

43.5

66.1

2.3

20.1

3.6

1.0

Business travel

6,306.4

5,945.1

4,087.1

3,635.6

1,708.6

1,677.7

384.5

294.8

126.1

81.7

Flights

3,817.8

3,437.7

3,219.0

2,748.3

346.3

321.5

140.6

113.1

111.9

78.3

Staff car0.0

2,017.5

2,187.0

581.3

676.8

1,313.9

1,349.9

121.5

104.8

0.8

Rental car

21.9

20.5

21.8

20.5

0.1

-

-

-

-

-

Taxi

57.9

63.8

45.8

42.7

0.6

0.7

0.8

-

10.7

1.8

Train

81.0

46.4

26.5

20.5

0.3

-

54.3

25.5

-

-

Bus

2.1

1.9

2.1

1.9

-

-

-

-

-

-

Ferry

5.2

-

-

-

5.2

-

-

-

-

-

303.0

187.8

190.7

125.0

42.3

5.5

67.3

51.5

2.7

1.6

6,842.4

5,521.1

3,569.6

3,454.6

1,540.9

1,445.3

1,714.1

418.7

17.8

17.1

4,819.9

5,024.0

3,569.6

3,454.6

1,240.7

1,445.3

-

-

9.6

12.1

0.0

0.0

0.0

0.0

0.0

0.0

-

-

0.0

0.0

Accommodation
Employee commuting and remote working
Commuting
Walk or bike
E-bike, moped or motorcycle
Public transport
Car
Plane
Remote working
End-of-life treatment of sold products
Downstream leased assets
Total

8.3

8.3

8.0

7.8

0.4

0.4

-

-

-

0.0

414.4

456.3

385.7

374.2

25.2

40.6

-

-

3.5

4.3

4,385.1

4,547.4

3,175.9

3,072.6

1,203.0

1,392.3

-

-

6.2

7.8

12.0

12.0

-

-

12.0

12.0

-

-

-

-

2,022.5

497.1

-

-

300.2

-

1,714.1

418.7

8.1

4.9
-

-

0.1

-

-

-

0.1

-

-

-

138.6

-

-

-

138.6

-

-

-

-

-

23,411.3

21,542.6

10,856.4

11,151.2

7,807.6

7,612.7

4,472.1

1,762.0

275.2

168.1

Mandatum is included in 2022 Sampo Group figures.

SUSTAINABILITY REPORT 2023

130

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Offices included in the GHG emission accounting

Emission factors

Sampo Group, 2023

Sampo Group, 2023

Location

Country

Group company

Stockholm

SwedenIf

Göteborg

SwedenIf

Sundsvall

SwedenIf

Other offices

SwedenIf

Turku

FinlandIf

Espoo

Finland

If

Other offices

Finland

If

Stamholmen

Denmark

If

Other offices

Denmark

IfVækerø

NorwayIf

Other offices

NorwayIf

All offices

Estonia

If

All offices

LatviaIf

All offices

Lithuania

If

All offices

Spain

If

Ballerup

Denmark

Topdanmark

Viby

Denmark

Topdanmark

Herning

Denmark

Topdanmark

Vejle

Denmark

Topdanmark

OdenseDenmark

TopdanmarkNæstvedDenmark

Topdanmark

Ringsted

Denmark

Topdanmark

Aalborg

Denmark

Topdanmark

Employees not connected to alocation-

Topdanmark

Leicester

United Kingdom

Hastings

Bexhill-on-Sea

United Kingdom

Hastings

Gibraltar

United Kingdom

Hastings

LondonUnited Kingdom

Hastings

Cardiff

United Kingdom

Hastings

Sunderland

United Kingdom

Hastings-

Hastings

Finland

Sampo plc

Employees not connected to alocation
Helsinki

SUSTAINABILITY REPORT 2023

Appendices

Activity

Emission factor reference

Stationary
combustion

UK Department for Energy Security and Net Zero (DESNZ), 2022–2023

Mobilecombustion

Drivmedel, 2021; Swedish Environmental Protection Agency (EPA), 2022

Refrigerants

DESNZ, 2023≡

ADEME, 2022; Association of Issuing Bodies, 2022; Bilan Carbone (BC)Electricity,
v.8.8; Ecoinvent v.3.9.1; Energimarknadsinspektionen (EI), 2022;
market-based International Energy Agency (IEA), 2022; IPCC, 2014
Districtheating

DESNZ, 2022; Euroheat & Power, 2017; Finnish Energy Statistics, 2021;
IPCC, 2014; Paikallisvoima, 2023; Swedenergy, 2021, Swedish EPA, 2022;
Turku Energia

Districtcooling

Helen, 2018, 2020 & 2021; Swedish district cooling suppliers; Turku Energia,
2017

Districtheating/cooling

DESNZ; Euroheat & Power, 2017; IEA; IPCC, 2014; Swedish EPA

Purchased
goods andservices

Amazon, 2021; Cloud Carbon Footprint, 2021; Comprehensive
Environmental Data Archive (CEDA), 2022; DESNZ, 2022–2023; Ecoinvent
v.3.3.8 & v.3.9.1; EI, 2022, Google, 2012 & 2021; IPCC, 2014; Microsoft, 2021;
Salesforce, 2021; SCA Ortviken, 2012; Simapro 2.0

ADEME, 2022; Apple, 2020–2022; DESNZ, 2022-2023; BC v.8.8.; BC
ADEME 2.1; CarbonCatalogue, 2014–2016; CEDA, 2022; Dell 2014 & 2018–
2021; DESNZ, 2022; Ecoinvent v3.9.1; HP, 2022; Konica Minolta, 2018;
Lenovo, 2021; Lexmark, 2020; Microsoft, 2019; Samsung, 2020; Seagate,
Capital goods 2013–2020; South Pole, 2024

131

Fuel andenergyrelated
activities

ADEME, 2022; Association of Issuing Bodies, 2022; BC v.8.8; DESNZ, 2022–
2023; Ecoinvent v.3.9.1; EI, 2022; Euroheat & Power, 2017; Finnish Energy
Statistics, 2021; IEA, 2022; IPCC, 2014; Swedenergy, 2021; Swedish Energy
Agency, 2022; Swedish district cooling suppliers; Swedish EPA, 2022;
Värmeforsk, 2011

Upstreamtransportation anddistribution

CEDA, 2022

Waste

DESNZ, 2022–2023; Ecoinvent v.3.9; World Bank waste statistics, 2019

BusinesstravelCEDA, 2022–2023; DESNZ, 2022–2023; Ecoinvent v3.9.1; EI, 2022; Hotel
Sustainability Benchmarking Index, 2021; NTM Method, 2015; Swedish EPA,
2021; Swedish Transport Administration, 2019

Employeecommutingandteleworking

Anthesis, 2020; DESNZ, 2022–2023; Ecoinvent v.3.9.1; EI, 2022; EU e-bikeassessment; IEA, 2022; Mobitool, 2020; South Pole, 2022; Swedish EPA,
2021; Swedish Transport Administration, 2019 & 2022

Downstream
leased assets

DESNZ, 2022; Ecoinvent v3.9.1; EI, 2022; IEA, 2022; IPCC, 2014

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Appendix 3: GRI content index
Statement of use

Sampo Group has reported in accordance with the GRI Standards for the period 1.1.2023–31.12.2023.

GRI 1 used

GRI 1: Foundation 2021

Applicable GRI Sector Standard(s)N/AOmission
GRI standard/
other source

Disclosure

Requirement(s)omittedLocation

ReasonExplanation

Not applicable

Sampo Group does
not collect data on
racial or ethnic
identities.

General disclosures
2-1 Organisational details

pp. 7–8

2-2 Entities included in the organisation’ssustainability reportingp. 1232-3 Reporting period, frequency and contact
point

The report was published on 27 March 2024, andit refers to the period from 1 January to 31
December 2023, unless otherwise stated. Sampo
Group publishes the sustainability report on anannual basis.
p. 1452-4 Restatements of information

No major restatements of information fromprevious reporting periods, p. 123.

2-5 External assurance

External assurance has been performed (limited
assurance). pp. 142–143
pp. 7–10, 18, 27–29, 96–100

GRI 2: General
Disclosures2021

2-6 Activities, value chain and other business
relationships

pp. 41, 49–50 in Sampo Group’s Board of
Directors’ Report and Financial Statements:
www.sampo.com/year2023

2-7 Employees

pp. 41–47

2-8 Workers who are not employees

pp. 41, 45
pp. 11–13, 53, 60–61

2-9 Governance structure and composition

pp. 3–4, 7–12 in Sampo Group’s Corporate
Governance Statement: www.sampo.com/
year2023
pp. 53, 60–61
p. 8 in Sampo Group’s Corporate GovernanceStatement: www.sampo.com/year2023

2-10 Nomination and selection of the highest
governance body

Sampo plc board diversity: www.sampo.com/
governance/board-of-directors

2-11 Chair of the highest governance body

pp. 7–12 in Sampo Group’s Corporate GovernanceStatement: www.sampo.com/year2023

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Parts of 2-9-c

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and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Omission
GRI standard/
other source

Disclosure

Location

2-12 Role of the highest governance body inoverseeing the management of impacts

pp. 11–16, 109–110

2-13 Delegation of responsibility for managing
impacts

pp. 11–13, 109–110

2-14 Role of the highest governance body insustainability reporting

pp. 11–13

Requirement(s)omittedReasonExplanation

Parts of 2-19-a

Confidentiality
constraints

Staff remuneration
policy is not public.

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
2-15 Conflicts of interest

Sampo Group’s Managers’ transactions:www.sampo.com/media/releases-and-news
pp. 18, 20, 22–23, 25, 27–28
Grievance procedures:www.sampo.com/sustainability/businessmanagement-and-practises/grievanceprocedures

2-16 Communication of critical concerns
GRI 2: General
Disclosures
2021

Whistleblowing:www.sampo.com/governance/whistleblowing
pp. 11–13

2-17 Collective knowledge of the highest
governance body

Board skills matrix: www.sampo.com/
governance/board-of-directors
p. 11

2-18 Evaluation of the performance of the highest pp. 7–14 in Sampo Group’s Corporate Governancegovernance bodyStatement: www.sampo.com/year2023
pp. 73–77
Sampo Group Remuneration principles:
www.sampo.com/governance/remuneration
Sampo Group Remuneration Report for
Governing Bodies: www.sampo.com/year2023

2-19 Remuneration policies

Group CEO and Group Executive Committee:
www.sampo.com/governance/remuneration/other-remuneration-information
pp. 73–75
p. 15 in Sampo Group’s Corporate GovernanceStatement: www.sampo.com/year2023

2-20 Process to determine remuneration

Remuneration: www.sampo.com/governance/
remuneration

2-21 Annual total compensation ratio

p. 76

2-22 Statement on sustainable development
strategy

pp. 5–6

SUSTAINABILITY REPORT 2023

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and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Omission
GRI standard/
other source

Disclosure

Location

Requirement(s)omittedReason201-3

Not applicablep. 92-23 Policy commitments

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
pp. 18, 20, 22, 25, 27, 30

2-24 Embedding policy commitments

GRI 2: General
Disclosures
2021

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct
Grievance procedures:www.sampo.com/sustainability/businessmanagement-and-practises/grievanceprocedures

2-25 Processes to remediate negative impacts

Whistleblowing:www.sampo.com/governance/whistleblowing

2-26 Mechanisms for seeking advice and raisingconcerns

pp. 18–21

2-27 Compliance with laws and regulations

p. 39

2-28 Membership associations

Sampo Group political involvement and lobbying:www.sampo.com/sustainability/businessmanagement-and-practises/political-involvement

2-29 Approach to stakeholder engagement

pp. 11–13, 109–110

2-30 Collective bargaining agreements

pp. 27–28

3-1 Process to determine material topics

pp. 11–13

3-2 List of material topics

p. 13

Material topics
GRI 3: Material
Topics 2021

Economic performancepp. 11–13
GRI 3: Material
Topics 2021

GRI 201:
Economic
Performance2016

3-3 Management of material topics

Sampo Group Board’s of Directors’ Report and
Financial Statements: www.sampo.com/year2023

201-1 Direct economic value generated anddistributed

p. 48 in Sampo Group’s Board of Directors’
Report and Financial Statements 2023:
www.sampo.com/year2023

201-2 Financial implications and other risks andopportunities due to climate change

pp. 14–16, 30–38, 79–91

201-3 Defined benefit plan obligations and otherretirement plans
201-4 Financial assistance received fromgovernment

SUSTAINABILITY REPORT 2023

Sampo Group did not receive any financial
assistance from any government in 2023.

134

Explanation

Introduction

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and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Omission
GRI standard/
other source

Disclosure

Location

3-3 Management of material topics

pp. 11–13, 18

205-1 Operations assessed for risks related tocorruption

pp. 14–16, 18–19

Requirement(s)omittedReasonExplanation

205-2 d-e

Information
unavailable/
incomplete

The aim is to improvedisclosure on
employees who havereceived training on
anti-corruption.

305-6 Emissions of ozone-depleting substances
(ODS)

305-6

Not applicable

305-7 Nitrogen oxides (NOx), sulfur oxides (SOx),
and other significant air emissions

305-7

Not applicable

Anti-corruption
GRI 3: Material
Topics 2021

GRI 205: Anticorruption 2016205-2 Communication and training about anticorruption policies and procedures

pp. 18–19

205-3 Confirmed incidents of corruption andactions taken

p. 18, no confirmed incidents

Anti-competitive behaviour
pp. 11–13
GRI 3: Material
Topics 2021

3-3 Management of material topics

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct

GRI 206: Anticompetitive
Behaviour 2016

206-1 Legal actions for anti-competitive
behaviour, anti-trust, and monopoly practices

No legal actions during the reporting year

3-3 Management of material topics

pp. 11–13, 30–31 , 79–80, 84, 86

305-1 Direct (Scope 1) GHG emissions

pp. 30–38, 88–89, 124–131

305-2 Energy indirect (Scope 2) GHG emissions

pp. 30–38, 88–89, 124–131

305-3 Other indirect (Scope 3) GHG emissions

pp. 30–38, 88–89, 124–131

305-4 GHG emissions intensity

pp. 88–89

305-5 Reduction of GHG emissions

pp. 30–38

Emissions
GRI 3: Material
Topics 2021

GRI 305:
Emissions 2016SUSTAINABILITY REPORT 2023

135

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and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Omission
GRI standard/
other source

Disclosure

Requirement(s)omittedLocation

ReasonExplanation

Information
unavailable/
incomplete

Information on
workers who are not
employees iscurrently notavailable.

403-9-b

Information
unavailable/
incomplete

Information on
workers who are not
employees iscurrently notavailable.

403-10Not applicable

Occupational health and safety
GRI 3: Material
Topics 2021

3-3 Management of material topics

pp. 11–13, 62

403-1 Occupational health and safety
management system

pp. 62–68

403-2 Hazard identification, risk assessment, andincident investigation

pp. 14–16, 62–68

403-3 Occupational health services

pp. 14–16, 62–68

403-4 Worker participation, consultation, andcommunication on occupational health and safety pp. 62–68

GRI 403:
Occupational
Health and
Safety 2018403-5 Worker training on occupational healthand safety

pp. 62–68

403-6 Promotion of worker healthpp. 62–68

403-7 Prevention and mitigation of occupational
health and safety impacts directly linked bybusiness relationships

pp. 62–68

403-8 Workers covered by an occupational
health and safety management system403-9 Work-related injuries

p. 64

Parts of 403-8-a

pp. 62–63

403-10 Work-related ill healthTraining and education
GRI 3: Material
Topics 2021

GRI 404:
Training and
Education 2016

3-3 Management of material topics

404-1 Average hours of training per year per
employee

pp. 11–13, 69

p. 70

404-1

Information
unavailable/
incomplete

Information on
training hours per
year per employee iscurrently notcollected. Training
costs per employee
are reported instead.

404-3

Information
unavailable/
incomplete

Information iscurrently notcollected.

404-2 Programmes for upgrading employee skills
and transition assistance programmes
pp. 69–72, no transition assistance programmes
404-3 Percentage of employees receiving regularperformance and career development reviews

SUSTAINABILITY REPORT 2023

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Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities≡

Appendices

Omission
GRI standard/
other source

Disclosure

Requirement(s)omittedLocation

Diversity and equal opportunity
GRI 3: Material
Topics 2021
GRI 405:
Diversity and
Equal
Opportunity
2016

3-3 Management of material topics

pp. 11–13, 53

405-1 Diversity of governance bodies andemployees

pp. 53–61

405-2 Ratio of basic salary and remuneration of
women to men

pp. 74–76

Non-discrimination
GRI 3: Material
Topics 2021

3-3 Management of material topics

pp. 11–13, 27

GRI 406: Nondiscrimination
2016406-1 Incidents of discrimination and corrective
actions taken

pp. 27–28

Freedom of association and collective bargaining
GRI 3: Material
Topics 2021

3-3 Management of material topics

GRI 407:
Freedom of
Association and 407-1 Operations and suppliers in which the rightCollective
to freedom of association and collective
Bargaining 2016 bargaining may be at risk

pp. 11–13, 27
pp. 27–29
Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct

Child labor
GRI 3: Material
Topics 2021

3-3 Management of material topics

pp. 11–13, 27
pp. 27–29

GRI 408: Child
Labor 2016408-1 Operations and suppliers at significant risk
for incidents of child labor

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct

Forced or compulsory labor
GRI 3: Material
Topics 2021
GRI 409:
Forced orCompulsory
Labor 2016

3-3 Management of material topics

pp. 11–13, 27
pp. 27–29

409-1 Operations and suppliers at significant risk
for incidents of forced or compulsory labor

Sampo Group Code of Conduct:www.sampo.com/governance/code-of-conduct

Customer privacy
GRI 3: Material
Topics 2021

3-3 Management of material topics

pp. 11–13, 22, 25

GRI 418:
CustomerPrivacy 2016418-1 Substantiated complaints concerning
breaches of customer privacy and losses ofcustomer data

pp. 23, 25

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137

ReasonExplanation

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices

Appendix 4: TCFD content index
The following table presents page and URL references in this report and the website where group level disclosures aligned with the recommendations of the Task Force on
Climate-related Financial Disclosures (TCFD) are presented. Additional information on individual Group companies’ TCFD disclosures is available in the companies’ respective
reporting.

TCFD disclosure focus area
Governance
Disclose the organisation's
governance around climaterelated risks andopportunities.
Strategy
Disclose the actual andpotential impacts of climaterelated risks andopportunities on theorganisation's businesses,
strategy, and financial
planning where suchinformation is material.

Risk management
Disclose how theorganisation identifies,
assesses, and manages
climate-related risks.

Metrics and targets
Disclose the metrics andtargets used to assess andmanage relevant climaterelated risks andopportunities where suchinformation is material.

SUSTAINABILITY REPORT 2023

TCFD recommended disclosuresa) Describe the board's oversight of climate-relatedrisks and opportunities.

Location for Sampo
Group level disclosurein this report

Location for Sampo Group level
disclosure on the website

pp. 11–12, 14–15

www.sampo.com/sustainability/
climate-and-environment/climate-risk- Sampo Group Risk Management
governance
Report: www.sampo.com/year2023

Other relevant Sampo Group level
reportingpp. 11–16

www.sampo.com/sustainability/
climate-and-environment/climate-risk- Sampo Group Risk Management
governance
Report: www.sampo.com/year2023a) Describe the climate-related risks andopportunities the organisation has identified overthe short, medium, and long term.

pp. 14–16

www.sampo.com/sustainability/
climate-and-environment/climatestrategy

Sampo Group Risk Management
Report: www.sampo.com/year2023b) Describe the impact of climate related risks andopportunities on the organisation's businesses,
strategy, and financial planning.

pp. 13, 15–16, 79–91, 93–
95, 96–100, 109–113, 141

www.sampo.com/sustainability/
climate-and-environment/climatestrategy

Sampo Group Risk Management
Report: www.sampo.com/year2023c) Describe the resilience of the organisation's
strategy, taking into consideration different climaterelated scenarios, including a 2°C or lower scenario. pp. 15–16, 88–91

www.sampo.com/sustainability/
climate-and-environment/climatestrategy

Sampo Group Risk Management
Report: www.sampo.com/year2023a) Describe the organisation's processes for
identifying and assessing climate-related risks.

pp. 14–16

www.sampo.com/sustainability/
climate-and-environment/climate-risk- Sampo Group Risk Management
management
Report: www.sampo.com/year2023b) Describe the organisation's processes for
managing climate-related risks.

www.sampo.com/sustainability/
climate-and-environment/climate-risk- Sampo Group Risk Management
pp. 14–16, 79–91, 96–100 management
Report: www.sampo.com/year2023b) Describe management's role in assessing andmanaging climate-related risks and opportunities.

c) Describe how processes for identifying,assessing, and managing climate-related risks areintegrated into the organisation's overall risk
management.

pp. 14–16

www.sampo.com/sustainability/
climate-and-environment/climate-risk- Sampo Group Risk Management
management
Report: www.sampo.com/year2023

a) Disclose the metrics used by the organisation toassess climate-related risks and opportunities in line pp. 30–38, 88–91, 97–
with its strategy and risk management process.
99, 127–131

www.sampo.com/sustainability/
climate-and-environment/climaterelated-metrics-and-targets-b) Disclose Scope 1, Scope 2, and, if appropriate,
Scope 3 greenhouse gas (GHG) emissions, and therelated risks.

pp. 30–38, 88–89, 127–131

www.sampo.com/sustainability/
climate-and-environment/climaterelated-metrics-and-targets-

pp. 13, 30–38, 80, 84,
86, 97–99

www.sampo.com/sustainability/
climate-and-environment/climaterelated-metrics-and-targets-c) Describe the targets used by the organisation to
manage climate-related risks and opportunities andperformance against targets.

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Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Appendix 5: SASB content index
The table below presents page references in this report or to other reports mentioned and/or URL locations related to metrics applied in the Sustainability Accounting Standards
Board’s (SASB) industry-specific standards for the Insurance Sustainability Accounting Standard. Due to the demerger of Mandatum in 2023, the industry-specific standards for the
Asset Management & Custody Activities Sustainability Accounting Standard have been left out from the index. The selected metrics are based on the materiality assessment
conducted in 2021, and they have not been reassessed according to updates made to the standards by the International Sustainability Standards Board (ISSB) in 2023. During 2023–
2024, Sampo Group concentrates on meeting the regulatory sustainability reporting requirements, and re-evaluates the approach to SASB/ISSB reporting.

Topic

Accounting metric

Code

Location for Sampo Group level
disclosure in this report

Location for Sampo Group level
disclosure on the website

p. 39

Sampo Group's Board of Directors'
Report and Financial Statements 2023
pp. 144–145: www.sampo.com/year2023.
The estimate is that there will be no
significant losses.

pp. 101–104

www.sampo.com/sustainability/business-management-and-practises/
sustainable-sales-and-marketingpp. 101–104

www.sampo.com/sustainability/business-management-and-practises/
sustainable-sales-and-marketing

p. 79

Sampo Group's Board of Directors'
Report and Financial Statements 2023
pp. 88, 137 and Sampo Group's Risk
Management Report 2023:
www.sampo.com/year2023.

pp. 79–91

www.sampo.com/sustainability/
investment-management-andoperations

Insurance Sustainability Accounting Standard
Total amount of monetary losses as a result of legal
proceedings associated with marketing andTransparent information and fair communication of insurance products related
advice for customers
information to new and returning customers
Transparent information and fairadvice for customers
Complaints-to-claims ratio
Transparent information and fair Description of approach to informing customers
advice for customers
about products

Incorporation of ESG factors ininvestment management

Total invested assets, by industry and asset class

Incorporation of ESG factors ininvestment management

Description of approach to incorporation of ESG
factors in investment management processes andstrategies

SUSTAINABILITY REPORT 2023

FN-IN-270a.1
FN-IN-270a.2
FN-IN-270a.4

FN-IN-410a.1
FN-IN-410a.2

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Introduction

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and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices

Appendix 6: The UN Sustainable Development Goals
Sampo plc has assessed the UN SDGs and theunderlying targets to identify the SDGs to which Sampo
Group can contribute the most. All 17 SDGs and 169
underlying targets were evaluated in relation to thecompany’s business and sustainability themes.
According to the assessment, Sampo Group has astrong impact on SDGs 3, 5, 8, 12, and 13. Therefore,
Sampo Group has chosen to focus on these goals.
Sampo Group aims to contribute to the SDGs positively,
among other things, by improving its own operations,

SUSTAINABILITY REPORT 2023

by being active in its respective communities, and by
engaging with its value chain.
In addition to the group level SDGs, each individualGroup company has identified the SDGs that are most
relevant for them. More information on If, Topdanmark,and Hastings’ work towards the SDGs is available in thecompanies’ own reporting.

140

Reporting of the Group companies:
www.sampo.com/year2023
Additional information:www.sampo.com/sustainability/sustainabilitygovernance/initiatives-and-commitments≡

Introduction

Business management
and practices

Strategicsustainability themes Link to SDG

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices

Relevant SDG sub-targets

Businessmanagement andpractices(8.8) Provide a decent and attractive work environment that supports labour rights• Sampo Group promotes safe and secure working environments for all workers.
(12.5) Reduce waste generation through prevention, reduction, recycling, and reuse• Sampo Group has set, e.g. requirements and targets for own operations and supply chains.
(12.6) Encourage companies to adopt sustainable practices and to integrate sustainability information into their reporting cycle• Sampo Group publishes sustainability reporting.
(13.2) Integrate climate change measures into policies, strategies, and planning• Sampo Group has made commitments to the SBTi and works on science-based climate targets.

Corporate culture(3.4) Promote mental health and well-being• Sampo Group promotes health and well-being to its employees and offers prevention and treatment services.
(5.1) End all forms of discrimination against all women and girls everywhere• Sampo Group works against all forms of discrimination.
(5.5) Ensure women’s equal opportunities in leadership at all levels of decision-making• Sampo Group promotes equal opportunities for all.
(8.5) Achieve full and productive employment and decent work for all, including for young people and persons with disabilities, and equal pay
for work of equal value• Sampo Group works against all forms of discrimination and is committed to equal pay for work of equal value.
(8.6) Substantially reduce the proportion of youth not in employment, education, or training• Sampo Group offers education, competence development, and traineeships within the industry.
(8.8) Provide a decent and attractive work environment that supports labour rights• Sampo Group promotes safe and secure work environments for all workers.

Investment
management andoperations(8.8) Provide a decent and attractive work environment that supports labour rights• Sampo Group’s investee companies must respect human rights, labour rights, the environment, and anti-corruption.
(12.6) Encourage companies to adopt sustainable practices and to integrate sustainability information into their reporting cycle• Sampo Group engages with its investee companies where applicable.
(13.2) Integrate climate change measures into policies, strategies, and planning• Sampo Group screens its investments and has made commitments to the SBTi and works on science-based climate targets.

Products andservices(3.4) Promote mental health and well-being• Sampo Group, e.g. develops preventive services within physical and mental health.
(8.8) Provide a decent and attractive work environment that supports labour rights• Sampo Group’s corporate clients and suppliers must respect human rights, labour rights, the environment, and anti-corruption.
(12.5) Reduce waste generation through prevention, reduction, recycling, and reuse• Sampo Group has set, e.g. requirements and targets for its suppliers and the overall supply chain management.
(12.6) Encourage companies to adopt sustainable practices and to integrate sustainability information into their reporting cycle• Sampo Group has set, e.g. requirements and targets for its suppliers and the overall supply chain management.
(13.1) Strengthen resilience and adaptive capacity to climate-related hazards and natural disasters in all countries• Sampo Group develops, e.g. risk management services and preventative measures that increase resilience and climate change adaptation.
(13.3) Improve education, awareness raising, and human and institutional capacity for climate change mitigation, adaptation, impact reduction,and early warning• Sampo Group has set, e.g. requirements and targets for its suppliers and the overall supply chain management.

Communities(3.4) Promote mental health and well-being• Sampo Group makes donations and contributes through other humanitarian efforts.
(13.3) Improve education, awareness raising, and human and institutional capacity for climate change mitigation, adaptation, impact reduction,and early warning• Sampo Group, e.g. finances research, raises awareness, and engages in dialogue with stakeholders on climate change.

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and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

Appendices≡

Independent practitioner’s assurance report(Translated from the original report in Finnish language.)

To the management of
Sampo plc
Scope
We have been engaged by Sampo plc (hereafter
Sampo) to perform a ‘limited assurance engagement,’
as defined by International Standards on Assurance
Engagements, hereafter referred to as the engagement,
to report on Sampo’s sustainability information (the“Subject Matter”) contained in Sampo Group’s
Sustainability Report for the period from 1 January 2023
to 31 December 2023 (the “Report”).
Other than as described in the preceding paragraph,
which sets out the scope of our engagement, we did
not perform assurance procedures on the remaining
information included in the Report, and accordingly, we
do not express a conclusion on this information.

Criteria applied by Sampo
In preparing the Subject Matter, Sampo applied the
Global Reporting Initiative (GRI) Sustainability
Reporting Standards, Task Force on Climate-related
Financial Disclosure (TCFD), and Sustainability
Accounting Standards Board (SASB) reporting
frameworks (the “Criteria”). As a result, the Subject
Matter information may not be suitable for anotherpurpose.

SUSTAINABILITY REPORT 2023

Sampo’s responsibilities
Sampo’s management is responsible for selecting theCriteria, and for presenting the Subject Matter inaccordance with that Criteria, in all material respects.
This responsibility includes establishing and maintaining
internal controls, managing adequate records andmaking estimates that are relevant to the preparation of
the Subject Matter, such that it is free from material
misstatement, whether due to fraud or error.

Ernst & Young’s responsibilities
Our responsibility is to express a conclusion on thepresentation of the Subject Matter based on theevidence we have obtained.
We conducted our engagement in accordance with theInternational Standard for Assurance Engagements
Other Than Audits or Reviews of Historical Financial
Information (ISAE 3000 (Revised)), and the terms ofreference for this engagement as agreed with Sampo
on 26 June 2023. Those standards require that we planand perform our engagement to express a conclusion
on whether we are aware of any material modifications
that need to be made to the Subject Matter in order for
it to be in accordance with the Criteria, and to issue areport. The nature, timing, and extent of the procedures
selected depend on our judgment, including anassessment of the risk of material misstatement,
whether due to fraud or error.

142

We believe that the evidence obtained is sufficient andappropriate to provide a basis for our limited assurance
conclusions.

Our independence and quality
management
We have maintained our independence and confirm
that we have met the requirements of the Code of
Ethics for Professional Accountants issued by theInternational Ethics Standards Board for Accountants
and have the required competencies and experience toconduct this assurance engagement.
Ernst & Young also applies International Standard on
Quality Management 1, Quality Management for Firms
that Perform Audits or Reviews of Financial Statements,
or Other Assurance or Related Services engagements,
which requires that we design, implement and operate asystem of quality management including policies orprocedures regarding compliance with ethicalrequirements, professional standards and applicablelegal and regulatory requirements.

Introduction

Business management
and practices

Corporate
cultureDescription of procedures
performed
Procedures performed in a limited assurance
engagement vary in nature and timing from, and areless in extent than for a reasonable assurance
engagement. Consequently, the level of assurance
obtained in a limited assurance engagement issubstantially lower than the assurance that would havebeen obtained had a reasonable assurance engagement
been performed. Our procedures were designed toobtain a limited level of assurance on which to base ourconclusion and do not provide all the evidence thatwould be required to provide a reasonable level ofassurance.
Although we considered the effectiveness ofmanagement’s internal controls when determining thenature and extent of our procedures, our assurance
engagement was not designed to provide assurance oninternal controls. Our procedures did not include testing
controls or performing procedures relating to checking
aggregation or calculation of data within IT systems.

Investment management
and operations

Communities

Appendices≡

Our procedures included:

Conclusiona) An update of our knowledge and understanding of
Sampo's material sustainability topics, organisation,
and activities.
b) Interviews with senior management to understandSampo's sustainability management.
c) Interviews with personnel responsible for gatheringand consolidation of the sustainability information tounderstand the systems, processes and controls
related to gathering and consolidating theinformation.
d) Assessing sustainability data from internal andexternal sources, and checking the data to reporting
information on a sample basis to check the accuracyof the data.
e) Performing recalculation of reported informationand evaluating the correctness of underlying dataand narrative disclosures.

Based on our procedures and the evidence obtained,
we are not aware of any material modifications thatshould be made to the Subject Matter in Sampo Group’s
Sustainability Report for the period from 1 January to 31
December 2023, in order for it to be in accordance with
the Criteria.

We also performed such other procedures as we
considered necessary in the circumstances.

A limited assurance engagement consists of making
enquiries, primarily of persons responsible for preparing
the Subject Matter and related information, andapplying analytical and other appropriate procedures.

SUSTAINABILITY REPORT 2023

Products
and services

143

Helsinki, 27 March 2024
Ernst & Young Oy
Authorised Public Accountant Firm
Terhi Mäkinen
Authorised Public Accountant

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Communities

AppendicesSignatures to the Sustainability Report
Helsinki, 27 March 2024

Sampo plc
Board of Directors

Antti Mäkinen
Chair

Jannica Fagerholm
Vice Chair

Torbjörn Magnusson
Group CEO

Christian Clausen

Fiona Clutterbuck

Georg Ehrnrooth

Steve Langan

Risto Murto

Markus Rauramo

Annica Witschard

SUSTAINABILITY REPORT 2023

144≡

Introduction

Business management
and practices

Corporate
cultureInvestment management
and operations

Products
and services

Contacts
Sampo plc
Fabianinkatu 2700100 Helsinki
FinlandBusiness ID
0142213-3
Registered domicile
HelsinkiPhone+358 10 516 0100
E-mailfirstname.lastname@sampo.fi
Internetwww.sampo.com
For any questions or feedback on
the report please contact
Johanna Tynkkynen
Head of Sustainability
Sampo plc
johanna.tynkkynen@sampo.fi+358 10 516 0067

SUSTAINABILITY REPORT 2023

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Communities

Appendices≡