Årsredovisning 2024

Value chain
Sampo Group
Significant groups of products, services and markets
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 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. In the United Kingdom (UK) P&C 
insurance market, Sampo Group operates through the 
digital insurer Hastings, which is one of the largest retail 
motor insurance providers in the UK and a challenger in 
the home insurance market with a fast-growing 
customer base.
Sampo Group’s operations are diversified by 
geography, line of business, and customer group. The 
Group’s main operating countries are Finland, Sweden, 
Norway, Denmark, the UK, and the Baltic countries.
As at 31 December 2024, Sampo Group’s total 
employee headcount was 15,581. The number of 
employees by geographical areas is presented under 
the disclosures related to own workforce (p. 96).
Sampo Group’s insurance revenue totalled EUR 9,450 
million in 2024. For more information on the breakdown 
of revenue in accordance with operating segments, see 
Result by segment for twelve months ended 31 
December 2024 in the Financial Statements.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 62

===== SIDA 63 =====

Sustainability programme
Sampo Group
Integration of sustainability into business
Sampo Group integrates sustainability into its core 
business. In terms of insurance operations this means, 
for example, that Sampo Group takes ESG 
considerations into account in underwriting (e.g. sets 
expectations for corporate clients to respect 
international norms and standards as defined by the UN 
Global Compact, integrates sustainability into 
underwriting principles and/or other relevant policies), 
provides loss prevention services (e.g. risk management 
services), handles claims in a sustainable way, and 
develops products and services in accordance with 
relevant legal requirements (e.g. the EU Taxonomy). 
Sampo Group’s sustainability-related goals apply to all 
Group operations rather than to specific customer 
groups and markets. 
Sampo Group has a sustainability programme, which 
drives group level sustainability work. The programme 
consists of three strategic sustainability themes: Climate 
and environment, People and communities, and 
Business management and practices, which are in turn 
divided into more specific topics relevant for the 
Group’s sustainability work. The group level programme 
is put into practice by the Sampo Group companies and 
the work is monitored continuously. 
Sampo Group has set general objectives for each 
sustainability theme. Additionally, metrics and targets 
are in place to monitor the progress in more detail. 
Performance against the set targets is presented, for 
example, in this Sustainability Statement. Science-based 
climate targets are disclosed under the Climate change 
standard, employee engagement is covered under the 
Own workforce standard, customer satisfaction falls 
under the Consumers and end-users standard, and 
metrics related to supplier codes of conduct can be 
found under the Workers in the value chain standard. 
Compliance with internal policies and guidelines is 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 63

===== SIDA 64 =====

discussed under multiple standards, as many of them 
focus on describing material policies and guidelines.
In 2024, Sampo Group’s sustainability programme was 
reshaped to better address the regulatory demands, 
while also including areas that are critical especially for 
a company operating in the P&C insurance sector. In 
addition, the selected topics link to Sampo Group’s 
overall business and strategy and are important to the 
Group’s various stakeholders. 
Interests and views of stakeholders
Sampo Group’s primary stakeholder groups are 
customers, investors, employees, suppliers and other 
business partners, investee companies, and local 
communities. Each primary stakeholder group has 
several subcategories as described in the table 
Stakeholder engagement and dialogue (p. 65). 
Sampo Group engages with all its stakeholder groups 
through a number of forums and on multiple topics. The 
intention is to engage in activities and dialogue that are 
best aligned with the needs 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, and providing suitable 
forums for dialogue.
The purpose of stakeholder engagement is to build 
trust between Sampo Group and its stakeholders and to 
seek common benefits. The stakeholder engagement 
helps 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 for the company’s key initiatives. In addition, 
Sampo Group considers stakeholder engagement to be 
a valuable source of information. The different 
stakeholders are experts in their own fields and can 
offer knowledge and expertise for the purposes of the 
Group. When relevant, Sampo Group can also offer its 
time and expertise to support the stakeholders.
As a result of the continuous dialogue, Sampo Group’s 
key stakeholders support the Group’s chosen strategy 
and business model. The views and interests of 
stakeholders are considered, where possible, when 
developing the strategy. As a result of stakeholder 
engagement, Sampo Group aims to advance its 
operations and relationship with stakeholders further. 
Examples of actions taken include improved external 
communications, customer service, and internal 
reporting. Sampo Group’s Board of Directors is 
informed about the views and interests of stakeholders 
as part of regular reporting and when considered 
necessary.
Engagement with own workforce, workers in the 
value chain, and customers and end-users
The interests, views, and rights of Sampo Group’s own 
workforce inform and support the company’s strategic 
decisions. Sampo Group strives for a constructive, 
trustful, and open dialogue with employees and their 
elected representatives with the purpose of developing 
the company and safeguarding the correct treatment of 
all employees. Sampo Group recognises, for example, 
the importance of workforce engagement, health, 
safety, wellbeing, work-life balance, diversity, equity and 
inclusion (DEI), and professional development. 
Sampo Group indirectly engages with its value chain 
workers on material topics through its suppliers, 
investee companies and corporate customers. The 
perspectives of value chain workers provide important 
insights for identifying and understanding the Group’s 
impacts on human rights and labour practices across its 
activities and business relationships. Engagement with 
value chain workers is integrated into daily business 
operations, for example, through due diligence 
processes.
For Sampo Group, the needs, preferences, and 
wellbeing of consumers and end-users is a key input 
informing strategy, and the Group’s business model is 
primarily shaped based on the interests of its 
customers. Sampo Group’s employees who develop and 
deliver insurance products and services are constantly 
monitoring and taking customers’ interests into 
consideration. The recognition of the interests of 
customers is complemented by the inputs and views of 
Sampo Group’s employees, suppliers, and other 
business partners in shaping the Group business model 
and strategy. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 64

===== SIDA 65 =====

Stakeholder engagement and dialogue
Sampo Group
Key stakeholder group Forum for dialogue and approximate frequency Examples of discussion topics
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)
• Customer 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 (biannual/annual)
• Performance appraisals and dialogue with leaders (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
• Employee engagement surveys
• Performance and development plans
• Sustainable workplace
Suppliers and other business partners (e.g. 
analysts, rating agencies)
• 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)
• Change in Group structure
• Future plans
• Products and services
Investee companies • Virtual and face-to-face meetings (varying)
• AGMs of the investee companies (varying)
• Financial performance
• Market situation in general
• Regulatory development
• Sustainability in general
Local communities (e.g. regulators, supervisors, 
industry associations, educational institutions, 
NGOs, general public, the media)
• Virtual and face-to-face meetings (weekly)
• Events (varying)
• Company publications, e.g. magazines (varying)
• Financial performance
• Regulatory development
• Sustainability in general
• Climate change
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 65

===== SIDA 66 =====

Material impacts, risks, and opportunities, 
and their interaction with strategy and 
business model
Sampo Group has conducted a double materiality 
assessment as required by the CSRD. The results of the 
assessment are presented in the figure Double 
materiality matrix. 
At Sampo Group, resilience to sustainability issues is 
ensured by continuous adaptation of risk assessment 
and pricing strategies to account for emerging 
sustainability factors, thereby ensuring long-term 
profitability and stability of the business. Adapting 
strategy and business model according to sustainability 
issues is critical for Sampo Group in terms of 
maintaining customer confidence and reducing financial 
risks, and the Group continuously invests in its people 
and technology to ensure that it maintains its 
competitive edge. Combined with careful risk 
management, this enables Sampo Group to deliver 
quality customer experience, attractive margins, and 
strong financial resilience. Resilience towards material 
impacts, risks, and opportunities is assessed as a part of 
Sampo Group’s existing processes for sustainability 
management, risk management, and strategy 
development. For more information on how Sampo 
Group’s strategy and business model interacts with 
material impacts, risks, and opportunities, see the 
Strategy section under each reported topical ESRS 
standard.	
Double materiality matrix
Sampo Group
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 66

===== SIDA 67 =====

2024 is the first reporting year after conducting a 
double materiality assessment, and as such Sampo 
Group reports no changes to the material impacts, risks, 
and opportunities compared to the previous year. All 
the impacts, risks, and opportunities reported in the 
Sustainability Statement 2024 are covered by the ESRS 
disclosure requirements, as Sampo Group does not 
include additional, entity-specific disclosures in the 
statement. However, Sampo Group has introduced 
entity-specific metrics to complement the disclosure 
requirements related to the ESRS standards E5 
Resource use and circular economy, S1 Own workforce, 
S2 Workers in the value chain, and S4 Consumers and 
end-users. Based on the identified risks and 
opportunities in the double materiality assessment, 
Sampo Group does not expect there to be material 
adjustments within the next annual reporting period to 
the carrying amounts of assets and liabilities reported in 
the related financial statements.
A short summary of the material sustainability topics is 
presented next. A more thorough specification of the 
material topics, related impacts, risks, and opportunities, 
as well as Sampo Group’s approach to managing them 
is presented at the beginning of each topical ESRS 
standard of this Sustainability Statement.
Climate change
The climate impact of Sampo Group’s own operations is 
minor, as the direct GHG emissions are relatively low. 
When considering the whole value chain, including 
investments and suppliers, the negative impact of GHG 
emissions is more significant. Sampo Group has 
recognised both climate-related physical risks and 
transition risks. Physical risks include more frequent and 
severe natural disasters and changing 
weather patterns, which can translate into increased 
claims due to damages caused, for example, by storms 
and floods. Transition risks, on the other hand, emerge 
during the shift to a low-carbon economy. These risks 
are driven by changes in the regulatory environment, 
new technology, changing customer behaviour, and 
increased interest in and concern for environmental 
matters. There are also climate-related opportunities, 
for example, in underwriting, and Sampo Group can 
take advantage of the possibly increasing demand for 
insurance products and services which provide 
protection against physical risks and support climate 
change adaptation.
Resource use and circular economy
Sampo Group uses resources in its business operations, 
especially in claims handling. Resource use inherently 
causes negative environmental impact, which Sampo 
Group can mitigate by adopting and increasing circular 
practices in product development and claims handling.  
Circular practices can also lead to cost reductions for 
Sampo Group in the long-term due to reduced use of 
virgin materials.
Own workforce
Sampo Group strives to create an engaging work 
environment, which fosters creativity, innovation, and 
wellbeing, promotes DEI, and encourages employees on 
their career paths, thus creating positive social impact. 
When employees feel like they belong in an 
organisation, they are more likely to stay longer. Failing 
to meet these expectations can lead to increased 
employee turnover and difficulties in recruiting 
competent workforce, which in turn can create a 
financial risk.
Workers in the value chain
Sampo Group has an impact on workers in the value 
chain especially through its downstream suppliers (e.g. 
suppliers in claims operations), business partners, 
corporate customers, and investees. The risk of 
negative impacts related to labour practices and human 
rights can be mitigated with strong policies and 
governance structures, but they cannot be completely 
eliminated. Due to increasing regulation and possible 
reputational issues, negative impacts can also cause 
financial risks.
Consumers and end-users 
Through careful risk management and disciplined 
underwriting, Sampo Group can have a positive impact 
on consumers and end-users’ health and safety, which 
provides business opportunities for the Group. Failing 
to meet customer expectations related to topics such 
as data privacy or sales practices can impact Sampo 
Group’s customers negatively and, therefore, create 
financial and reputational risks.
Business conduct
At Sampo Group, sustainable corporate governance 
and solid business practices are seen as a baseline. By 
promoting high standards related to topics such as anti-
corruption and bribery and risk management, Sampo 
Group can contribute to the overall security of society. 
  
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 67

===== SIDA 68 =====

Impact, risk, and opportunity 
management
Description of the process to identify and 
assess material impacts, risks, and 
opportunities
The purpose of Sampo Group’s double materiality 
assessment was to identify sustainability matters, which 
could trigger risks or opportunities that influence 
Sampo Group’s ability to create and protect value 
(financial materiality), as well as sustainability matters 
related to Sampo Group’s business, which could have 
positive or negative impacts on society, people, or the 
environment (impact materiality). The double 
materiality assessment served as a source for 
identifying the information to be included in this 
Sustainability Statement. The assessment was 
conducted in collaboration with an external partner, and 
the work and its results were presented to Sampo’s 
Board and its Audit Committee during the project. The 
methodology used in the double materiality assessment 
follows the legislative requirements and supporting 
guidance provided by the European Financial Reporting 
Advisory Group (EFRAG).
The double materiality assessment started with 
identifying an initial list of sustainability topics 
potentially material for Sampo Group. The list was 
compiled based on, for example, the ESRS standards, 
GRI, SASB standard for the insurance sector, industry 
benchmarking, media and megatrend analysis, Sampo 
Group’s previous materiality assessment, ESG ratings 
and reports, information on Sampo Group’s 
investments, and investor meetings and feedback. 
Representatives from Sustainability, Risk Management, 
HR, Strategy, and Investor Relations functions 
participated in identifying the impacts, risks, and 
opportunities associated with the sustainability topics 
through workshops. The identified impacts, risks, and 
opportunities were mapped based on their expected 
location in Sampo Group’s value chain. It was also 
defined during which time-horizons (short-term: less 
than 1 year, medium-term: 1–5 years, or long-term: over 
5 years) it can be expected that the impacts, risks, and 
opportunities would materialise.
Each Sampo Group company conducted its own double 
materiality assessment in parallel with the group level 
assessment, and their results were reviewed against the 
group level results to ensure that all material topics are 
covered and group level alignment is ensured. In Sampo 
Group’s double materiality assessment, the group level 
view is emphasised. Therefore, the exact results of 
individual group companies’ own assessments may 
deviate from the group level assessment.
In the assessment of impacts, Sampo Group utilised 
regular dialogue with stakeholders, and documentation 
of affected stakeholders’ perspectives collected 
continuously through the Group’s existing channels. 
Regarding social impacts, findings from Sampo Group’s 
human rights impact assessment were utilised in order 
to include perspectives from affected stakeholders. 
Sampo Group’s main stakeholders and forums for 
stakeholder dialogue are presented as a part of this 
Sustainability Statement (p. 64). 
When assessing impact materiality, each sustainability 
topic was categorised based on whether its impact on 
society, people, or environment is positive or negative, 
and whether it is actual or potential. The criteria used 
for defining the impact materiality score for each topic 
were scale and scope, and for negative impacts, 
irremediable character of the impact was included in 
the assessment. For potential positive and negative 
impacts Sampo Group estimated the likelihood of the 
impact occurring. 
When assessing financial materiality, each sustainability 
topic was categorised based on whether it potentially 
causes more risks or opportunities to the business and 
value creation. The identified impacts and dependencies 
of Sampo Group's business model on sustainability 
topics acted as the starting point for the risk and 
opportunity identification. The criteria used for defining 
the financial materiality assessment for each topic were 
the potential magnitude of its financial effects, and 
likelihood of occurrence. 
Thresholds were set based on the quantitative 
assessment of severity/financial effect and likelihood, 
using the expertise and perspectives of involved 
stakeholders. Sampo Group set thresholds separately 
for impact materiality and financial materiality. When 
assessing the threshold for financial materiality, for 
example, the scale of impact (whether the impact 
concerns all the Group companies) as well as the 
potential impact on Sampo Group’s reputation and 
share price were considered. Sustainability topics were 
determined to be material if the severity/financial effect 
and the likelihood of the related impacts, risks, and 
opportunities exceeded the threshold values.
Sampo Group assessed each applicable criterion for a 
specific impact, risk, and opportunity on the same scale, 
and completed the quantitative assessment by 
qualitative descriptions. Impact, risk, and opportunity 
assessment was discussed in workshops with internal 
stakeholders, including representatives from the Sampo 
Group companies. Sampo’s Board and its Audit 
committee validated the final results of the double 
materiality assessment as a part of the reporting on the 
Sustainability Statement. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 68

===== SIDA 69 =====

Sustainability-related risks are a part of Sampo Group’s 
overall risk management, and follow the same risk 
management process as the Group’s other risks. The 
sustainability risks identified as part of the overall risk 
management were taken into consideration in the 
double materiality assessment. Identified impacts are 
considered and addressed indirectly through Sampo 
Group’s risk management process when they are 
related to the Group’s risks. 
Sampo Group had already integrated the key risks and 
opportunities identified as a part of the double 
materiality assessment into the Group’s overall risk 
management systems. Sampo Group’s process for 
identifying, assessing, and managing sustainability 
opportunities is integrated into the Group’s 
management protocols, ensuring strategic alignment 
with business objectives and operational decisions.  
The double materiality assessment described in this 
Sustainability Statement was the first one Sampo Group 
has conducted and thus there have been no changes to 
how the assessment was conducted compared to 
previous reporting periods. Sampo Group’s double 
materiality assessment will be reviewed annually, and 
any changes to the process or results will be reported in 
future sustainability statements. 
Additional process description related to 
environmental and governance topics
Climate change
In addition to the double materiality assessment, Sampo 
Group uses GHG emissions calculations, climate-related 
scenario analyses, and different risk management 
practices, such as internal model, price analyses, stress 
tests, and sensitivity analysis, to identify and assess 
climate-related impacts, risks, and opportunities. Sampo 
Group has considered both its own operations and its 
value chain when identifying the climate-related 
impacts, risks, and opportunities. 
Sampo Group assesses climate-related physical and 
transition risks in its own operations and value chain as 
part of the existing risk management practices. These 
include, for example, group level and company-specific 
stress tests and scenario analyses, in which the severity 
of natural catastrophes is assumed to increase. The 
scope, method, and results of the group level scenario 
analysis are described in this Sustainability Statement 
(p. 78). In the short term, physical climate risks arise in 
the form of changes in claims frequencies and/or 
severity of the climate-related events that are already 
relevant in the current climate in the Nordics, such as 
wind storms, floods, heavy rainfall, landslides, erosion, 
and heatwaves. In the medium to long term, increased 
weather-related losses will likely increase the exposure 
for P&C insurers.
Climate-related transition risks are associated with 
changes in the regulatory environment, new 
technology, changing customer behaviour, and 
increased stakeholder concern. Companies insured by 
Sampo Group may be exposed to litigation under new 
regulation related to climate change, leading, for 
example, to increased claims costs in liability insurance. 
Increased concern from stakeholders (e.g. from 
investors, customers, and reinsurers) can lead to 
increased costs for due diligence and a need to 
discontinue business relationships with certain suppliers 
and customers. 
Sampo Group has noted that there are also 
opportunities related to climate change, such as 
underwriting opportunities and possibilities to invest in 
new green technologies. Increased climate-related 
physical risks can also lead to increased demand for 
insurance products and services providing protection 
against physical risks and supporting climate change 
adaptation. Development of new products and services 
is part of Sampo Group's normal business development 
and innovation. Risk management services are already 
part of Sampo Group’s services to both corporate and 
private customers.
Pollution and Water and marine resources
Sampo Group has assessed that pollution and water 
and marine resources are not among the most material 
sustainability topics for a company operating in the P&C 
insurance industry. Therefore, Sampo Group has not 
comprehensively screened its assets, business activities, 
and site locations or conducted consultations with 
affected communities regarding these topics.
Biodiversity and ecosystems
Sampo Group has assessed that biodiversity and 
ecosystems is not among the most material 
sustainability topics for a company operating in the P&C 
insurance industry. Therefore, Sampo Group has not 
comprehensively screened its site locations and value 
chain or conducted consultations with affected 
communities regarding the topic. Sampo Group’s most 
relevant impacts, dependencies, risks, and opportunities 
related to biodiversity and ecosystems are linked to its 
value chain, mainly underwriting and investment 
operations. Sampo Group has conducted an initial 
screening of its investment portfolio to assess its 
exposure to sectors connected to high biodiversity 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 69

===== SIDA 70 =====

impacts and risks. Sampo Group aims to develop its 
data collection and reporting based on the findings of 
the assessment.
Resource use and circular economy
The process for identifying material impacts, risks, and 
opportunities related to resource use and circular 
economy has focused on information already existing 
within Sampo Group. Affected communities were not 
specifically identified in relation to resource use and 
circular economy due to Sampo Group's industry, 
business model, and limited use of resources in its own 
operations. Sampo Group has several channels for 
dialogue with stakeholders, where topics such as 
circular economy and resource use can be raised 
(p. 65). Sampo Group has assessed that resource use 
inherently has a negative impact on the environment, 
but the severity of the impact can be mitigated through 
the Group’s actions.
Business conduct
When identifying and assessing material impacts, risks, 
and opportunities, Sampo Group has evaluated the 
geographical context of its operations, considering the 
regulatory landscape that may influence the impacts. 
The nature of Sampo Group's insurance services, 
including product offerings and service delivery 
methods, has been reviewed to identify actual and 
potential impacts. Operating within the P&C insurance 
sector, Sampo Group has recognised the industry-
specific risks and opportunities.
Disclosure Requirements in ESRS covered by 
the undertaking’s sustainability statement
Based on the results of the double materiality 
assessment, Sampo Group reports material disclosure 
requirements related to the ESRS topical standards E1 
Climate change, E5 Resource use and circular economy, 
S1 Own workforce, S2 Workers in the value chain, S4 
Consumers and end users, and G1 Business conduct as 
part of this Sustainability Statement. In addition to the 
sustainability topics covered by the ESRS standards, 
Sampo Group has recognised responsible underwriting 
and investment management as material topics. Sampo 
Group does not report entity-specific disclosures 
related to these topics, but they are covered, where 
applicable, under the ESRS standards E1 Climate 
change, S2 Workers in the value chain, and S4 
Consumers and end-users. A full list of disclosure 
requirements complied with in preparing this 
Sustainability Statement is presented in the ESRS 
content index in Annex 1 (p. 119).
According to the double materiality assessment, Sampo 
Group does not report disclosure requirements related 
to the ESRS standard E4 Biodiversity and ecosystems. 
Currently the topic is not amongst the most material 
based on Sampo Group’s internal analysis and external 
stakeholder feedback. Additionally, the disclosure 
requirements laid out by the ESRS standard are in many 
cases not applicable to companies in the insurance 
sector. Nevertheless, biodiversity and ecosystems is a 
topic Sampo Group will closely follow and work on, and 
it is also connected to the Group’s climate work and 
reporting. Sampo Group will re-evaluate the materiality 
and reporting requirements related to the topic in the 
coming years. 
The disclosure requirements related to ESRS standard 
S3 Affected communities were also excluded from this 
Sustainability Statement. As a P&C insurance company 
operating mainly in the Nordic countries, Sampo 
Group’s direct impacts on topics such as adequate 
housing and freedom of expression were considered 
limited. However, Sampo Group reports on its 
stakeholder management as part of the ESRS 2 
standard, and considers topics related to affected 
communities where relevant. 
Sampo Group does not report disclosure requirements 
related to the ESRS standards E2 Pollution and E3 
Water and marine resources, as the impacts, risks, and 
opportunities related to these topics are not considered 
material for the Group.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 70

===== SIDA 71 =====

Environmental information
EU Taxonomy
The EU Taxonomy is a classification system that 
translates the EU’s climate and environmental 
objectives into criteria for specific economic activities 
for investment purposes. The basic principle of the 
Taxonomy is that for an economic activity to be 
recognised as environmentally sustainable (Taxonomy-
aligned), it must make a substantial contribution to at 
least one of the EU’s climate and environmental 
objectives, which are climate change mitigation; climate 
change adaptation; sustainable use and protection of 
water and marine resources; transition to a circular 
economy; pollution prevention and control; and 
protection and restoration of biodiversity and 
ecosystems. In addition, the economic activity cannot 
significantly harm any of these objectives and must 
meet the minimum safeguards criteria. The Taxonomy 
Delegated Acts establish and maintain criteria (i.e. 
technical screening criteria) for activities which have a 
substantial positive environmental impact.
Companies are required to report on Taxonomy 
eligibility (i.e. reporting on whether the economic 
activity is included in the Taxonomy Climate Delegated 
Act) and Taxonomy alignment (i.e. reporting on 
whether the economic activity meets the technical 
criteria for i) substantial contribution, ii) do no 
significant harm, and iii) comply with minimum 
safeguards). 
Insurance companies are required to report KPIs on 
sustainable underwriting activities and sustainable 
investments. The first one refers to the proportion of 
the non-life gross written premiums (GWP) – in relation 
to total non-life GWP – corresponding to insurance 
activities identified as environmentally sustainable in the 
Taxonomy, and the second one to the proportion of the 
insurer’s or reinsurer’s investments – in relation to total 
insurer’s or reinsurer’s investments – that are directed at 
or associated with funding economic activities that 
qualify as environmentally sustainable.
In 2024, the weighted averages of Sampo Group’s 
Taxonomy-aligned activities concerning both 
underwriting and investments were 1.3 per cent 
(turnover-based) and 1.3 per cent (capital expenditures-
based).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 71

===== SIDA 72 =====

Underwriting activities 
Non-life insurance and reinsurance are recognised as 
enabling economic activities that can make a 
substantial contribution to the environmental objective 
of climate change adaptation. At the time of writing this 
statement, the EU Taxonomy does not define other 
environmental objectives for insurance activities. 
The non-life insurance activities listed in the Taxonomy 
Delegated Acts are medical expense insurance, income 
protection insurance, workers’ compensation insurance, 
motor vehicle liability insurance, other motor insurance, 
marine, aviation, and transport insurance, fire and other 
damage to property insurance, and assistance. 
Methodology 
To be Taxonomy-eligible, a non-life insurance activity 
must provide coverage against climate-related perils 
(e.g. floods, landslides, heat stress). Sampo Group 
follows in its methodology the European Commission 
Notice on the interpretation of certain legal provisions 
of the Disclosures Delegated Act under Article 8 of the 
EU Taxonomy Regulation, published on 21 December 
2023. This means that solely the share of insurance 
premiums that pertain to the coverage of climate-
related perils is reported as eligible. The premiums for 
which Sampo Group has not been able to obtain the 
necessary data related to climate-related perils are 
reported as non-eligible.
For an eligible insurance activity to be classified as 
Taxonomy-aligned, it must fulfil the technical screening 
criteria of:
• Substantial contribution to climate change 
adaptation:  
– Leadership in modelling and pricing of climate risks
– Product design 
– Innovative insurance coverage solutions 
– Data sharing 
– High level of s e r v i c e  i n  p o s t - d i s a s t e r  s i t u a t i o n  
• Do No Significant Harm (DNSH) climate change 
mitigation criteria: The activity does not include 
insurance of the extraction, storage, transport, or 
manufacture of fossil fuels or insurance of vehicles, 
property, or other assets dedicated to such purposes.
When assessing the Taxonomy alignment, Sampo 
Group has concentrated on the most relevant products 
in terms of climate change adaptation, which are mainly 
related to fire and other damage to property line of 
business. For the products where potential alignment 
with the technical screening criteria was identified, a 
more thorough and granular product-level analysis (e.g. 
based on a policy, country, or element) was conducted 
to identify the specific premiums that are in scope for 
Taxonomy-alignment. Only the part of the premiums 
that pertains to the coverage of climate-related perils 
was deemed to be aligned.
For assessing the DNSH-criteria, Sampo Group has used 
NACE codes to extract contracts that could be related 
to the extraction, storage, transport, or manufacture of 
fossil fuels, and those are excluded from the Taxonomy 
aligned premiums. This screening has been performed 
on Sampo Group’s industrial and commercial 
customers.
For an economic activity to be considered as Taxonomy-
aligned, a company carrying the activity must also meet 
the minimum safeguards, which are due diligence and 
remedy procedures implemented to ensure alignment 
with the OECD Guidelines for Multinational Enterprises 
and the UN Guiding Principles on Business and Human 
Rights. Sampo Group has implemented the required 
policies and taken actions to be compliant with the 
safeguards. Sampo Group has, for example, conducted a 
human rights impact assessment, and continues to 
ensure that the adequate human rights due diligence 
processes are maintained and constantly developed. As 
part of the Taxonomy alignment assessment, the Group 
companies have also assessed their compliance with the 
minimum safeguards separately. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 72

===== SIDA 73 =====

Underwriting KPIs 
The analysis, which is based on the above-mentioned 
interpretations, shows that 3.0 per cent (2.2 in 2023) of 
Sampo Group’s total non-life GWP were Taxonomy-
eligible and 1.3 per cent (1.0 in 2023) of total non-life 
GWP were Taxonomy-aligned in 2024. All the 
Taxonomy-aligned premiums are related to fire and 
other damage to property insurance. In 2024, Sampo 
Group was able to increase the share of Taxonomy-
aligned premiums due to increased alignment within If’s 
property portfolio and customisation of Topdanmark’s 
insurance for private houses.
Sampo Group continues to integrate the EU Taxonomy 
into its business strategy and product development 
processes while monitoring the market expectations 
and customer needs in this area. In the coming years, 
Sampo Group aims to increase the share of Taxonomy-
aligned underwriting activities in its insurance portfolio.
Taxonomy-eligible and Taxonomy-aligned non-life insurance and re-insurance activities 
Sampo Group
Substantial contribution to climate change 
adaptation DNSH (Do No Significant Harm)
Economic activities
Absolute 
premiums, 
2024
Proportion of 
premiums, 
2024
Proportion of 
premiums, 
2023
Climate 
change 
mitigation
Water and 
marine 
resources
Circular 
economy Pollution
Biodiversity 
and 
ecosystems
Minimum 
safeguards
(EURm) % % Y/N Y/N Y/N Y/N Y/N Y/N
A.1. Non-life insurance and reinsurance 
underwriting Taxonomy-aligned 
activities (environmentally sustainable) 127  1.3%  1.0% Y Y Y Y Y Y
A.1.1 Of which reinsured —  —%  —% Y Y Y Y Y Y
A.1.2 Of which stemming from reinsurance 
activity —  —%  —% Y Y Y Y Y Y
A.1.2.1 Of which reinsured (retrocession) —  —%  —% Y Y Y Y Y Y
A.2 Non-life insurance and reinsurance 
underwriting Taxonomy-eligible but not 
environmentally sustainable activities 
(not Taxonomy-aligned activities) 161  1.7%  1.2% 
B. Non-life insurance and reinsurance 
underwriting Taxonomy-non-eligible 
activities 9,216  97.0%  97.8% 
Total (A.1 + A.2 + B) 9,504  100.0%  100.0% 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 73

===== SIDA 74 =====

Investment activities
The EU Taxonomy requires insurance companies to 
report the proportion of underlying investments that 
are Taxonomy-eligible and -aligned. To facilitate this 
type of reporting at portfolio level, all holdings need to 
be screened and analysed in relation to the economic 
activities of the Taxonomy.  
Methodology
Sampo Group analysed all underlying investments 
according to the Taxonomy reporting requirements, 
except for sovereign exposures that are to be excluded 
from the Taxonomy analysis. In Sampo Group’s analysis, 
exposures to municipalities were not categorised as 
sovereign exposure. When analysing Taxonomy 
eligibility and alignment, derivatives and investments to 
undertakings not falling under the scope for publishing 
non-financial information under Directive 2013/34/EU 
(i.e. non-NFRD companies) were excluded from the 
numerator, in line with the reporting requirements set in 
the Taxonomy Disclosures Delegated Act. Reporting 
requirements also obligate insurance undertakings to 
distinguish the proportion of the investments held in 
respect of life insurance contracts, where the 
investment risk is borne by the policyholders, and the 
proportion of remaining investments. Sampo Group has 
no investments held in respect of life insurance 
contracts where the investment risk is borne by the 
policyholders.
The Taxonomy analysis of Sampo Group’s investments 
was performed with the use of data from an external 
data provider, ISS ESG (ISS). ISS identified companies 
engaged in economic activities covered by the 
Taxonomy and produced all Taxonomy indicators 
directly based on the respective investee companies’ 
own reporting of Taxonomy eligibility and alignment. 
The indicators were provided based on both underlying 
companies’ revenue and capital expenditures. As 
security-specific (e.g. mortgage bonds) eligibility and 
alignment data is still scarce, most of the securities’ 
eligibility and alignment data was matched to the 
issuer’s reported data. Companies’ reported eligibility 
and alignment data was not modified in any way by the 
data provider or by Sampo Group, and therefore it 
includes some discrepancies (e.g. breakdown of 
alignment to environmental objectives does not 
correspond to total alignment).
The relevant investment assets were further analysed 
according to the Taxonomy reporting requirements by 
using both data provided by ISS and data gathered 
based on each individual security's issuer. The 
investments in undertakings categorised as non-NFRD 
companies were identified by using data provided by 
ISS. As ISS does not cover all NFRD companies, some 
unidentified NFRD companies may have been included 
in the assets not covered by the analysis. Investments in 
undertakings from the EU and non-EU countries have 
been identified using the securities' issuers' country 
code. Similarly, investments in undertakings categorised 
as financial and non-financial have been identified using 
the securities' issuers' internal sector information to 
determine the main sector the companies operate in 
(e.g. NACE codes). Fund investments were analysed 
using look-through data where available. Some look-
through data is updated in longer cycles and thus the 
most recent available look-through data was used for 
the EU Taxonomy calculations.
The underlying investments analysed also included 
Sampo Group’s real assets (property, plant and 
equipment as well as investment property), cash and 
cash equivalents, investments in associated companies 
and intangible assets and they are included in the 
denominator of the Taxonomy calculations. 
For Sampo Group’s real assets, no activities with EU 
taxonomy eligibility or alignment were found. All 
investments in associated companies were in non-NFRD 
companies and thus included no EU Taxonomy 
eligibility or alignment figures. Cash and cash 
equivalents were analysed based on the counterparties 
but due to the nature of the instruments (e.g. cash and 
money market instruments), no EU Taxonomy eligibility 
or alignment was reported. The intangible assets of 
Sampo Group were also not found to have activities 
related to the EU Taxonomy.
Investment KPIs
According to the analysis, the turnover and capital 
expenditures-based Taxonomy eligibility of Sampo 
Group’s covered assets as at 31 December 2024 was 3.1 
per cent (3.5 in 2023) and 3.6 per cent (4.2 in 2023), 
respectively and the turnover-based and capital 
expenditures-based Taxonomy alignment of Sampo 
Group’s covered assets was 0.7 per cent (0.7 in 2023) 
and 1.0 per cent (0.9 in 2023), respectively. As 
expected, the reported numbers are low, as most of the 
underlying companies are not subject to mandatory 
Taxonomy reporting, and reported eligibility and 
alignment are low in general.
Sampo Group reports the additional KPIs related to 
fossil gas and nuclear energy sectors, laid down by the 
Delegated Regulation (EU) 2022/1214, regarding its 
investment activities. The KPIs are presented in Annex 3 
of this Sustainability Statement (p. 126). Due to minimal 
exposure to those sectors in its insurance activities, 
data limitations, and current market practices, Sampo 
Group does not consider the additional KPIs applicable 
to its underwriting activities. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 74

===== SIDA 75 =====

Taxonomy-eligible and Taxonomy-aligned investment activities 
Sampo Group, 31 December 2024
EURm
The weighted average value of all the 
investments of insurance or reinsurance 
undertakings that are directed at funding, or 
are associated with Taxonomy-aligned 
economic activities relative to the value of 
total assets covered by the KPI, with 
following weights for investments in 
undertakings per below:
The weighted average value of all the 
investments of insurance or reinsurance 
undertakings that are directed at funding, or 
are associated with Taxonomy-aligned 
economic activities, with following weights 
for investments in undertakings per below:
Turnover-based:  0.7% Turnover-based: 131
Capital expenditures-based:  1.0% Capital expenditures-based: 201
The percentage of assets covered by the KPI 
relative to total investments of insurance or 
reinsurance undertakings (total AuM). 
Excluding investments in sovereign entities.
The monetary value of assets covered by 
the KPI. Excluding investments in sovereign 
entities.
Coverage ratio:  94.4% Coverage: 19,903
Additional, complementary disclosures: breakdown of denominator of the KPI
The percentage of derivatives relative to 
total assets covered by the KPI:
The value in monetary amounts of 
derivatives:
 0.0% 1
The proportion of exposures to financial and 
non-financial undertakings not subject to 
Articles 19a and 29a of Directive 2013/34/
EU over total assets covered by the KPI:
Value of exposures to financial and non-
financial undertakings not subject to Articles 
19a and 29a of Directive 2013/34/EU:
For non-financial 
undertakings:  21.9% 
For non-financial 
undertakings: 4,363
For financial undertakings:  28.1% For financial undertakings: 5,591
The proportion of exposures to financial and 
non-financial undertakings from non-EU 
countries not subject to Articles 19a and 29a 
of Directive 2013/34/EU over total assets 
covered by the KPI:
Value of exposures to financial and non-
financial undertakings from non-EU 
countries not subject to Articles 19a and 29a 
of Directive 2013/34/EU:
For non-financial 
undertakings:  12.0% 
For non-financial 
undertakings: 2,390
For financial undertakings:  14.1% For financial undertakings: 2,809
The proportion of exposures to financial and 
non-financial undertakings subject to 
Articles 19a and 29a of Directive 2013/34/
EU over total assets covered by the KPI:
Value of exposures to financial and non-
financial undertakings subject to Articles 19a 
and 29a of Directive 2013/34/EU:
Additional, complementary disclosures: breakdown of denominator of the KPI
For non-financial 
undertakings:  10.1% 
For non-financial 
undertakings: 2,020
For financial undertakings:  20.1% For financial undertakings: 4,008
The proportion of exposures to other 
counterparties and assets over total assets 
covered by the KPI:
Value of exposures to other counterparties 
and assets:
 19.7% 3,921
The proportion of the insurance or 
reinsurance undertaking’s investments other 
than investments held in respect of life 
insurance contracts where the investment 
risk is borne by the policy holders, that are 
directed at funding, or are associated with, 
Taxonomy-aligned economic activities1:
Value of insurance or reinsurance 
undertaking’s investments other than 
investments held in respect of life insurance 
contracts where the investment risk is borne 
by the policy holders, that are directed at 
funding, or are associated with, Taxonomy-
aligned economic activities1:
 100.0% 19,903
The value of all the investments that are 
funding economic activities that are not 
Taxonomy-eligible relative to the value of 
total assets covered by the KPI2:
Value of all the investments that are funding 
economic activities that are not Taxonomy-
eligible2:
 96.3% 19,158
The value of all the investments that are 
funding Taxonomy-eligible economic 
activities, but not Taxonomy-aligned relative 
to the value of total assets covered by the 
KPI3:
Value of all the investments that are funding 
Taxonomy-eligible economic activities, but 
not Taxonomy-aligned3:
 3.1% 614
1 The figure on the table equals the total amount of Sampo Group’s investments covered by the KPI 
other than investments held in respect of life insurance contracts where the investment risk is 
borne by the policy holders. The turnover-based and capital expenditures-based alignment for 
these investments are 0.7 per cent and 1.0 per cent respectively.
2 Turnover-based figure is reported on the table. Capital expenditures-based figure is 95.4 per cent.
3 Turnover-based figure is reported on the table. Capital expenditures-based figure is 3.6 per cent.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 75

===== SIDA 76 =====

Additional, complementary disclosures: breakdown of numerator of the KPI
The proportion of Taxonomy-aligned 
exposures to financial and non-financial 
undertakings subject to Articles 19a and 29a 
of Directive 2013/34/EU over total assets 
covered by the KPI:
Value of Taxonomy-aligned exposures to 
financial and non-financial undertakings 
subject to Articles 19a and 29a of Directive 
2013/34/EU:
For non-financial undertakings: For non-financial undertakings:
Turnover-based:  0.6% Turnover-based: 121
Capital expenditures-based:  0.9% Capital expenditures-based: 185
For financial undertakings: For financial undertakings:
Turnover-based:  0.1% Turnover-based: 10
Capital expenditures-based:  0.1% Capital expenditures-based: 16
The proportion of the insurance or 
reinsurance undertaking’s investments other 
than investments held in respect of life 
insurance contracts where the investment 
risk is borne by the policy holders, that are 
directed at funding, or are associated with, 
Taxonomy-aligned:
Value of insurance or reinsurance 
undertaking’s investments other than 
investments held in respect of life insurance 
contracts where the investment risk is borne 
by the policy holders, that are directed at 
funding, or are associated with, Taxonomy-
aligned:
Turnover-based:  0.7% Turnover-based: 131
Capital expenditures-based:  1.0% Capital expenditures-based: 201
The proportion of Taxonomy-aligned 
exposures to other counterparties and 
assets in over total assets covered by the 
KPI:
Value of Taxonomy-aligned exposures to 
other counterparties and assets over total 
assets covered by the KPI:
Turnover-based:  —% Turnover-based: —
Capital expenditures-based:  —% Capital expenditures-based: —
Breakdown of the numerator of the KPI per environmental objective
Taxonomy-aligned activities – provided ‘do-no-significant-harm’(DNSH) and social 
safeguards positive assessment:
(1) Climate change 
mitigation Turnover:  0.6% 
Transitional 
activities:
Turnover:   0.1% 
CapEx:  0.4% 
CapEx:  1.0% 
Enabling 
activities:
Turnover:  0.1% 
CapEx:  0.5% 
(2) Climate change 
adaptation Turnover:  0.0% 
Enabling 
activities: Turnover:  0.0% 
CapEx:  0.0% CapEx:  0.0% 
(3) The sustainable use 
and protection of water 
and marine resources Turnover:  0.0% 
Enabling 
activities: Turnover:  0.0% 
CapEx:  0.0% CapEx:  0.0% 
(4) The transition to a 
circular economy Turnover:  0.0% 
Enabling 
activities: Turnover:  0.0% 
CapEx:  0.0% CapEx:  0.0% 
(5) Pollution prevention 
and control Turnover:  0.0% 
Enabling 
activities: Turnover:  0.1% 
CapEx:  0.0% CapEx:  0.1% 
(6) The protection and 
restoration of 
biodiversity and 
ecosystems
Turnover:  —% 
Enabling 
activities: Turnover:  —% 
CapEx:  —% CapEx:  —% 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 76

===== SIDA 77 =====

Climate change
Topic Impacts Risks and opportunities Strategy and actions
GHG emissions and 
climate-related risks
↓  G H G  e m i s s i o n s  c a u s e  a c t u a l  n e g a t i v e  i m p a c t  o n  t h e  
environment. As an insurance company, Sampo 
Group's own direct emissions are not significant, but 
when considering the Group’s entire value chain, 
including suppliers and investments, the impact is 
more material.
Time-horizon: short, medium, and long term
↓  T h e  i n c r e a s i n g  s c a l e  a n d  f r e q u e n c y  o f  p h y s i c a l  
climate-related risks, such as storms, floods, heavy 
rains, landslides, erosion, and heat waves, can 
increase Sampo Group’s claims costs and cause 
financial risks for the Group. Climate-related physical 
risks are already relevant in the short term, and they 
are likely to grow in the medium to long term.
↓  S a m p o  G r o u p  c a n  f a c e  p o t e n t i a l  r e p u t a t i o n a l  r i s k s  
related to GHG emissions or not achieving the set 
emission reduction targets.
↓  S a m p o  G r o u p  c a n  f a c e  f i n a n c i a l  a n d  r e p u t a t i o n a l  
risks arising from increasing climate-related 
legislation (e.g. possible fines).
Time-horizon: short, medium, and long term
• Commitments to reduce GHG emissions (e.g. SBTi)
• Internal policies and guidelines (e.g. responsible 
investment policies, underwriting principles, codes 
of conduct)
• Effective governance structures and processes (e.g. 
risk management, screening, engagement)
• Consideration of climate-related risks in the pricing 
of the products and services and in reinsurance
• Internal training, competence development 
programmes, and awareness raising
• Metrics and targets (e.g. SBTs related to own 
operations, investments, and suppliers)
Product and service 
offering
↑  S a m p o  G r o u p  h a s  p o t e n t i a l  p o s i t i v e  i m p a c t  t h r o u g h  
the development of climate-friendly products and 
services (e.g. related to loss prevention and risk 
management). Non-life insurance and reinsurance 
are recognised by the EU Taxonomy as enabling 
economic activities that can make a substantial 
contribution to the environmental objective of 
climate change adaptation.
Time-horizon: short, medium, and long term
↑  D e v e l o p m e n t  o f  s u s t a i n a b l e  p r o d u c t s  a n d  s e r v i c e s  
can provide business opportunities for Sampo Group 
(e.g. related to loss prevention, risk management, 
the EU Taxonomy).
↓  S a m p o  G r o u p  c a n  f a c e  p o t e n t i a l  f i n a n c i a l  r i s k s  i f  i t  i s  
not able to provide customers with sustainable 
products and services that meet their needs.
Time-horizon: short, medium, and long term
• Development of sustainable products and services 
based on customers’ needs and aligned with the EU 
Taxonomy
• Climate resilience in product development and 
pricing
• Loss prevention and risk management services
The table presents Sampo Group’s material impacts, risks, and opportunities related to climate change identified in the double materiality assessment and their connection to Sampo Group’s strategy and 
actions. The topics are linked to the ESRS sub-topics. The topic GHG emissions and climate-related risks is related to the ESRS sub-topics climate change mitigation and climate change adaptation. The 
topic Product and service offering is related to the ESRS sub-topic climate change adaptation.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 77

===== SIDA 78 =====

Strategy
Material impacts, risks, and opportunities 
and their interaction with strategy and 
business model
Sampo Group’s underwriting operations are exposed to 
both physical risks and transition risks. Physical risks are 
risk factors affecting the financial position and results of 
Sampo Group. Physical climate-related risks include 
storms, floods, heavy rains, landslides, erosion, 
hailstorms, and heat waves. The scale or frequency of 
these natural disasters can increase claims costs. 
Transition risks, on the other hand, relate to changes in 
the regulatory environment, the introduction of new 
technologies, changes in customer behaviour, and 
increased stakeholder concern for climate and 
environmental matters, for example. The European 
Insurance and Occupational Authority (EIOPA) has 
identified transition risks linked to policy, legal issues, 
technology, market sentiment, and reputation for non-
life insurers. 
Sampo Group’s investments can also be exposed to 
both physical risks and transition risks, depending on 
the investment in question. Investments are particularly 
exposed to physical risks in the form of losses incurred 
from extreme weather events. The transition to a low-
carbon society with potentially increasing 
environmental and climate regulation, more stringent 
emission requirements, and changes in market 
preferences could in turn cause transition risks for the 
Group’s investments and possible revaluation of assets 
as operating models in carbon intense sectors change.
Sampo Group’s capital planning, a forecast of own 
funds and capital requirements over a three-year 
planning period, and own risk and solvency assessment 
(ORSA) processes include scenario analyses, stress 
tests, sensitivity analyses, and reverse stress tests, 
including scenarios related to natural catastrophes. 
Climate scenario analysis
Sampo Group has together with the external vendor 
ORTEC Finance analysed the Group’s investment 
portfolio's exposure to systemic economic and financial 
climate change risks in four different climate scenarios 
over the next 40 years. The impact on the insurance 
results was also analysed based on the impact on 
macroeconomic variables as well as the potential effect 
on claims related to natural catastrophes, including the 
consequences for the pricing of insurance contracts.
The four scenarios analysed are the following:
• Net-Zero (NZ): This scenario describes an easy and 
smooth transition where political and social 
organisations act quickly and predictably to achieve 
net-zero CO2 emissions by 2050.
• Net-Zero Financial Crisis (NZFC): In this scenario, the 
transition to a greener economy happens in a 
disorderly manner. Sudden divestments to align 
portfolios to the Paris Agreement goals in 2026 have 
disruptive effects on financial markets with sudden 
repricing followed by stranded assets and a sentiment 
shock.
• Limited Action (LA): In this scenario, policymakers 
implemented limited nationally determined 
contributions (NDCs) but fall short of meeting the 
Paris Agreement goals. The global warming reaches 
2.8°C, and this causes high physical impact.
• High Warming (HW): In this scenario, the world fails 
to meet the Paris Agreement goals, and global 
warming reaches 4.2°C above pre-industrial levels by 
2100. Physical climate impacts cause large reductions 
in economic productivity and increased impacts from 
extreme weather events. This scenario focuses on 
physical risk as the green transition does not happen.
The methodology used to assess systemic climate 
change risks and opportunities related to Sampo 
Group’s investments combines climate science with 
econometric and financial modelling. The methodology 
relies on the following key assumptions: 
• The scenarios used are climate science informed 
scenarios. Each scenario differs in terms of 
assumptions about policy and technology changes, 
physical risks, and pricing-in mechanisms. The 
scenarios are chosen to explore a range of plausible 
outcomes.
• The E3ME model by Cambridge Econometrics models 
the world’s economic and energy systems and the 
environment. It is a quantitative framework for 
analysing the impacts of Energy-Environment-
Economy (E3) policies over the short, medium and 
long term. It is widely used globally for policy 
assessment as well as for forecasting and research, 
and in this context, it is used to model the impact of 
transition risk on the evolution of macroeconomic 
variables. Currently, the E3ME model does not 
explicitly account for physical risk factors and is, 
therefore, complemented by methods to account for 
the impact of gradual physical risks and extreme 
weather events on the evolution of macroeconomic 
variables.
• Stochastic financial modelling that translates shocks 
to macroeconomic variables to risk-return metrics for 
different geographies, sectors, and asset classes is 
used in the last step to translate the climate-informed 
outputs from the previous steps, i.e. the impact of 
transition risks and physical risks on the evolution of 
macroeconomic variables in the different scenarios. In 
addition, assumptions about pricing-in and sentiment 
shocks in financial markets, and how they impact 
asset returns and risk for a large number of economic 
and financial market variables are made.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 78

===== SIDA 79 =====

Impact on investment results
The climate scenario analysis was first conducted in 
2023, and the results were reweighted based on the 
investment allocation as at 30 September 2024. The 
results of the scenario analysis form a set of data that 
can be analysed from various perspectives. The results 
are presented relative to a baseline that does not take 
into account any specific assumptions about climate 
change. Instead, the baseline relies on historical 
relationships and long-term views shaped by current 
market conditions.
According to the results of the climate scenario 
analysis, Sampo Group’s current investment portfolio is 
relatively resilient to climate change risk in all four 
scenarios. This is due to the significant allocation to 
fixed income instruments, which tend to be less 
affected than equities, as well as the geographical 
allocation towards mainly the Nordics and other 
European countries where the effects of climate change 
are expected to be lower than in other parts of the 
world. According to the analysis, in the short run, the 
main risk is related to the pricing-in shock in the NZFC 
scenario. In the long run, there will be a negative impact 
on the returns in all scenarios, due to increased physical 
risks. In addition, returns from high GHG emitting 
sectors are particularly affected in both net-zero 
scenarios (NZ and NZFC).
Impact on insurance results
To assess the impact of the climate scenarios on the 
insurance results, the forecasts for macro variables 
(GDP and inflation) and their direct effect on insurance 
results in combination with assumptions for effects on 
natural catastrophe claims and repricing of insurance 
contracts under the different climate scenarios were 
used. The climate scenario analysis was performed for 
If’s insurance portfolio (including Topdanmark), but the 
results are stated on a relative basis in terms of the 
insurance result and could be seen as broadly 
representative for the entire Sampo Group. Also, the 
business not included in the analysis, i.e. Hastings, has a 
very low share of home insurance business and, 
consequently, considered to have relatively low 
exposure to natural catastrophes. 
The sensitivity to increased physical risk was assessed 
by including increased natural catastrophe claims in the 
HW scenario, and separately considering re-pricing due 
to increased claims cost.
According to the scenario analysis, the combined effect 
of changes in GDP and inflation in the HW scenario 
compared to the NZ scenario leads to a relatively 
limited impact on the insurance result. This is mainly 
due to offsetting effects stemming from how different 
economies are affected in the Nordic region. However, 
the assumed impact on natural catastrophe claims is 
more material, in particular in the scenario without 
repricing and the apparent offsetting effect of repricing 
actions. The scenario analysis hence indicates that 
although the direct impact from macroeconomic 
impacts is relatively limited, increased claims costs 
could materially influence the insurance results, and 
appropriate repricing of the insurance contracts will be 
particularly important in such a scenario. With P&C 
insurance contracts almost exclusively being renewed 
on a yearly basis within Sampo Group, the resilience 
towards trends in claims for whatever reason is typically 
high given the focus on financial control, clear financial 
targets, and general underwriting focus within the 
Group.
Transition plan for climate change mitigation
Sampo Group is developing its transition plan for 
climate change mitigation, which is based on its SBTs. 
To reach the targets, Sampo Group has identified 
relevant decarbonisation levers and actions to be taken 
in the coming years. Sampo Group is committed to 
further develop its transition plan according to 
applicable regulation and frameworks, and will report 
on the development annually as part of its sustainability 
reporting.
Once finalised, Sampo Group is planning to embed the 
transition plan in its overall strategy and financial 
planning, for example, by allocating sufficient resources 
to the development and implementation of the climate 
action plans in order to reach its SBTs. Currently, the 
implementation of Sampo Group’s transition plan is not 
expected to require allocation of specific investments or 
funding beyond normal costs related to business 
development. However, this will be re-evaluated while 
developing the plan further. 
Sampo Group has estimated that its key assets and 
products do not currently contain sources for significant 
locked-in emissions, as the Group does not operate in a 
GHG intensive sector. Sampo Group is not excluded 
from the EU Paris-aligned benchmarks.
Sampo Group’s insurance and investment activities are 
covered by the EU Taxonomy. The Group’s Taxonomy 
disclosures, including the description of future plans, are 
presented in the section EU Taxonomy (p. 71).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 79

===== SIDA 80 =====

Science-based targets
Sampo Group has set SBTs in line with the SBTi’s 
methodology to limit global warming to 1.5°C.	Sampo 
Group’s commitment to the SBTi has been approved by 
the company’s management and the Board of Directors.
Sampo Group joined the SBTi in October 2023. 
Mandatory group level targets for own operations and 
investments were developed during 2024, and the 
targets were validated by the SBTi and published in 
November 2024. Sampo Group reports on progress 
against the targets annually as part of the company’s 
sustainability reporting starting from financial year 
2025. In addition to the group level targets related to 
own operations and investments, Sampo Group has set 
voluntary SBTs for suppliers on a subsidiary level. 
Sampo Group works towards the SBTs to reduce GHG 
emissions related to its own operations, investments, 
and suppliers. The Group’s actions regarding own 
operations include purchasing renewable electricity, 
switching to biogas and district heating, changing to 
LED lighting, optimising the use of office space, and 
transitioning its vehicle fleet to electric and hybrid cars. 
Measures related to investments include regular 
monitoring using screenings, engagement with investee 
companies (e.g. investor events, AGMs), development 
of the Group’s coal phase-out plan, and normal portfolio 
turnover. In addition, Sampo Group engages with and 
encourages its suppliers to set SBTs. Sampo Group’s 
climate targets are presented in detail in the table 
Science-based targets (p. 83).
Impact, risk and opportunity 
management
Policies related to climate change mitigation 
and adaptation
Sampo Group’s policy regarding climate change 
mitigation and adaptation is the Sampo Group Code of 
Conduct, which is reviewed annually and approved by 
Sampo’s Board of Directors. The Code of Conduct 
states that Sampo Group complies with climate-related 
legislation, is committed to combatting climate change, 
and supports the Paris Agreement. The policy is also 
supported by Sampo Group’s commitment to the SBTi 
and involvement in various initiatives (e.g. UN Global 
Compact).
The Sampo Group Code of Conduct covers all Sampo 
Group’s own operations. Sampo Group also expects its 
suppliers and other business partners to comply with 
the principles of the Code of Conduct throughout their 
own operations and supply chains. In addition to the 
Sampo Group Code of Conduct, each Group company 
has adopted supplementary and more detailed policies, 
guidelines, and processes for their own purposes, to 
guide the work related to climate change mitigation and 
adaptation. These include, for example, sustainability 
policies, supplier codes of conduct, and responsible 
investment policies.
The Sampo Group Code of Conduct together with the 
company-specific policies address climate change 
mitigation and adaptation, energy efficiency, and 
renewable energy deployment. Sampo Group takes 
ESG considerations, including climate change, into 
account in product and service development, insurance 
underwriting, investment operations, and supply chain 
management. The Group strives to reduce the 
consumption of resources (e.g. energy, water) and 
improve the efficient use of those resources. 
Additionally, Sampo Group is committed to reducing 
emissions and waste generated from business 
operations, while incorporating the concepts of 
reduction, re-use, and recycling. Sampo Group also 
prioritises renewable energy sources, when possible. 
Sampo Group encourages its customers, investee 
companies, suppliers, and other business partners to 
uphold similar environmental and climate commitments, 
and consults and cooperates with its stakeholders on 
environmental and climate matters.
Actions and resources in relation to climate 
change policies
Sampo Group has assessed that it has a negative 
impact on climate change through the GHG emissions 
of its own operations and value chain. However, Sampo 
Group has emission reduction targets and a series of 
actions to mitigate the negative impact and to reduce 
the GHG emissions in line with the SBTi’s framework.
Climate change mitigation
Through its SBTs, Sampo Group is committed to 
reducing its total Scope 1 and 2 emissions by 42 per 
cent by 2030 compared to the 2022 base year. This 
translates to an emission reduction of 2,514 tCO2eq. 
Sampo Group has identified switching to renewable 
energy and reducing energy use in offices and 
electrifying the car fleet as the main decarbonisation 
levers. Sampo Group has assessed that the majority of 
the required emission reductions will be achieved by 
switching to renewable energy and reducing energy use 
in offices. In 2025, Sampo Group will further develop its 
reporting on decarbonisation levers and their 
quantitative contributions.
Sampo Group has also set SBTs for investments and 
voluntary SBTs (If and Topdanmark) for suppliers. The 
identified decarbonisation levers or actions related to 
these Scope 3 emissions are supplier engagement, 
sustainable claims handling, and responsible investment.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 80

===== SIDA 81 =====

Own operations
In 2024, Sampo Group’s climate change mitigation 
actions focused on the decarbonisation levers that are 
expected to reduce the company’s Scope 1 and 2 
emissions and contribute towards the Group’s SBTs.
For the past years, Sampo Group has strived to 
transition to renewable energy sources for electricity 
and district heating across its locations. In 2024, 
Hastings’ Bexhill and Leicester offices switched to 100 
per cent renewable energy sources for both electricity 
and biogas, and If had solar panels installed on the 
office in Bergshamra. In addition, Sampo Group 
promoted energy efficiency in 2024, for example, by 
implementing environmental standards for energy 
efficiency in its offices.
Sampo Group also expects emission reductions from 
the shift to electric vehicles (EVs). In 2024, If started to 
pay for the installation cost of EV charging outlets at 
home for employees in Denmark who are entitled to a 
car benefit, and Hastings upgraded the company car 
parks in both Bexhill and Leicester with EV charging 
stations.
In addition to aiming for Scope 1 and 2 emission 
reductions from its own operations, Sampo Group 
strives to better understand the extent of its Scope 3 
emissions. In 2024, Sampo Group conducted an 
inventory of its reported Scope 3 emissions and 
assessed which Scope 3 categories are material and 
need further development. As a result of the 
assessment, data quality in the categories Purchased 
goods and services, Capital goods, Upstream 
transportation and distribution, Business travelling, and 
Employee commuting was improved. In addition, 
Hastings conducted a spend-based assessment of its 
Purchased goods and services, leading to a large 
increase in reported emissions in this category.
During 2025, Sampo Group will continue its emission 
reduction actions and initiatives, and monitor progress 
against the Scope 1 and 2 targets. Collectively, these 
measures are expected to reduce the Group’s GHG 
emissions. Regarding its Scope 3 emissions, Sampo 
Group plans to further develop GHG emission reporting, 
especially regarding the gaps identified in the 2024 
assessment and align reporting across the Group. The 
company also recognises that emissions from insurance 
activities (i.e. insurance associated emissions) represent 
an important part of its Scope 3 emissions and, 
therefore, this category will be assessed in the coming 
years.
Investments
To achieve the Group’s SBTs for investments, Sampo 
Group has devised a strategy that revolves around 
strategic asset allocation and proactive investee 
engagement. This means that investments in companies 
and assets that offer strong financial returns and align 
with the Group’s climate objectives are prioritised. 
During 2024, Sampo Group developed its investment 
monitoring and reporting related to the SBTs, and 
practices to engage with its investee companies 
regarding emission reduction targets when needed. 
During 2025, the plan is to continue this work and 
prepare for reporting according to the SBTi’s 
methodology. 
In 2024, Sampo Group conducted an annual carbon 
footprint analysis of its investment portfolio for 
enhanced disclosure and transparency around climate-
related risks. Sampo Group also continued to perform 
sector-based and norm-based screenings for its direct 
investment portfolio to identify and make decisions 
regarding companies that are involved in certain 
industries as well as companies’ adherence to 
international norms concerning environmental 
protection. To support these practices and to ensure 
quality monitoring of investments from a sustainability 
point of view going forward, Sampo Group reviewed its 
ESG data service providers during the year.
Suppliers
Sampo Group works with its suppliers on topics related 
to climate change. Supplier engagement offers a way to 
influence decarbonisation efforts within the supply 
chain when granular emissions data is challenging to 
track or unavailable. Sampo Group’s supplier 
engagement targets focus on engaging a defined set of 
suppliers in the near term to set their own SBTs for all 
applicable scopes and categories.
In 2024, If initiated a process to assess how many of its 
suppliers within motor and property claims have set 
SBTs or equivalent to be able to support and incentivise 
remaining suppliers to set targets going forward. 
Topdanmark will apply the same approach to all 
suppliers in its portfolio within purchased goods and 
services.
Sustainable claims handling
Sampo Group can contribute to climate change 
mitigation by emphasising energy and resource 
efficiency, and use of renewable energy in claims 
handling operations. For example, If has implemented a 
sustainable building module as part of its most 
comprehensive building insurance for commercial 
buildings in Norway in 2023 and Sweden in 2024. 
Through this module, which is based on BREEAM 
certification systems, If provides concrete advice, 
guidance, and financial support for sustainable 
measures, such as the use of solar panels and energy 
efficiency measures, in the reconstruction after major 
damage. In 2024, Topdanmark engaged with partners in 
the construction sector on the possibility of choosing 
reused materials instead of new materials in the context 
of building claims, while still taking cost and safety into 
consideration.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 81

===== SIDA 82 =====

Climate change adaptation
During 2024, loss prevention remained an important 
theme for Sampo Group. If and Topdanmark continued 
to provide loss prevention services, such as on-site risk 
assessments and house assessments, for their 
customers. This is to identify specific and cost-effective 
preventative measures, which can reduce the 
customers’ climate-related risks. Hastings also provided 
guidance to its customers on loss prevention, including 
winter car check reminders and recommendations on 
how to mitigate issues at home, such as freezing 
pipework. In addition, in 2024, Hastings created a Geo-
Spatial Data Scientist team working to assess the value 
of climate-related data enrichment, producing address-
level scores covering weather claims risk (e.g. flood, 
freeze) and supporting the Underwriting team with 
climate-related risk selection and accumulation 
management.
Sampo Group participates in various research projects 
together with universities, research institutes, and 
clients. The aim of this work is to better understand 
risks and to support the clients in their risk 
management, but also to contribute to a more 
sustainable society. For example, If has regularly 
published an extreme weather report in Norway – the 
previous one was published in 2023 and the next is 
planned for 2025. The report is prepared together with 
CICERO Center for Climate Research and IVL Swedish 
Environmental Research Institute. The report 
investigates how well Norwegian municipalities are 
prepared for extreme weather. Topdanmark, under the 
auspices of Insurance & Pension Denmark, provides 
data to help the Danish municipalities identify the 
largest risk areas in relation to extreme weather, such as 
heavy rainfall.
Metrics and targets
Targets related to climate change mitigation 
and adaptation
Sampo Group’s climate targets are aligned with the 
SBTi’s methodology, which supports the Paris 
Agreement. This approach is in line with the policy 
objectives stated in the Sampo Group Code of Conduct.
Sampo Group’s target for own operations (Scope 1 and 
2 emissions) follows the absolute contraction approach.  
Sampo Group’s target boundary includes all Sampo 
Group companies. Only minor offices have been 
excluded from the boundary as emissions from these 
are deemed insignificant. The market-based approach 
was used to calculate the Scope 2 GHG emissions 
included in the target.
The targets for the listed equity, corporate bond, fund, 
ETF, and corporate loan investment portfolio have been 
set using the temperature rating approach and the 
target for the commercial real estate portfolio using the 
sectoral decarbonisation approach. Sampo Group’s 
portfolio targets cover 57.9 per cent of its total 
investment and lending by total assets as of 2022. As of 
that year, required activities made up 57.9 per cent of 
Sampo Group’s total investment and lending by total 
assets, while optional activities made up 5.6 per cent 
and out-of-scope activities made up 36.5 per cent.
Sampo Group has had dialogue with several 
stakeholders when committing to the SBTi and setting 
the targets. These have included, for example, investors, 
large corporate customers, and the company’s 
management and boards of directors. Progress against 
Sampo Group’s targets will be monitored regularly 
internally and reported externally in the sustainability 
statement.
There were no changes in the targets during the 
reporting year. The Scope 1 and 2 GHG emissions for the 
baseline year 2022 and comparative year 2023 were 
recalculated to reflect changes in the reporting 
boundary (e.g. Mandatum and Topdanmark Life were 
excluded from the boundary). In addition, errors related 
to data collection were corrected. Also, the GHG 
emissions of investments (Scope 3, category 15) were 
recalculated for the baseline year 2022 and 
comparative year 2023 to align with other regulatory 
frameworks (e.g. the EU Taxonomy).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 82

===== SIDA 83 =====

Science-based targets
Sampo Group
 
Scope Target 2024 results
Own operations 
(Scope 1 and 2)
• Sampo Group commits to reduce absolute scope 1 and 2 GHG emissions by 42 
per cent by 2030 from a 2022 base year.
• Sampo Group’s SBTs were approved in November 2024. The Group will start 
reporting on its progress against the targets from the year 2025 onwards.
Investments 
(Scope 3, category 15)
• Sampo Group commits to align its scope 1 + 2 portfolio temperature score by 
invested value of its listed equity, corporate bond, fund, ETF and corporate 
loan portfolio from 2.78°C in 2022 to 2.09°C by 2029.
• Sampo Group commits to align its scope 1 + 2 + 3 portfolio temperature score 
by invested value of its listed equity, corporate bond, fund, ETF and corporate 
loan portfolio from 2.91°C in 2022 to 2.29°C by 2029.
• Sampo Group commits to reduce its real estate direct investment and 
corporate loan portfolio GHG emissions by 57.7 per cent per square meter by 
2029 from a 2022 base year.
• Sampo Group’s SBTs were approved in November 2024. The Group will start 
reporting on its progress against the targets from the year 2025 onwards.
Suppliers* 
(Scope 3, category 1)
• If: 30 per cent of suppliers by spend, covering purchased goods and services, 
will have science-based targets by 2028.
• Topdanmark: 20 per cent of suppliers by spend, covering purchased goods and 
services, will have science-based targets by 2028. 
• If: 15.8 per cent
• Topdanmark: 17.1 per cent
* Sampo Group has set SBTs in accordance with the SBTi’s sector-specific guidelines for the financial sector, which require companies to set targets for own operations (Scopes 1 and 2) and investments 
(Scope 3, category 15). In addition, Sampo Group has voluntary climate targets for its supply chain on a subsidiary level.
GHG emissions intensity (total GHG emissions per net revenue)
Sampo Group
GHG intensity per net revenue
2023 
(Comparative) 2024 % 2024 / 2023
Total GHG emissions (location-based) 
per net revenue (tCO2eq/EUR) 0.000044 0.000035  -21.5 %
Total GHG emissions (market-based) 
per net revenue (tCO2eq/EUR) 0.000045 0.000035  -21.6 %
The denominator used when calculating the GHG emissions intensity is the Total insurance revenue 
(Sampo Group’s Financial Statements, Statement of profit and other comprehensive income and 
Note 1 Insurance service result).
Biogenic emissions
Sampo Group
Metric 2024
Scope 1 (tCO2eq) 170
Scope 2, market-based (tCO2eq) 2,768
Scope 3 (tCO2eq) 97
Total biogenic emissions 3,035
Biogenic emissions arise from direct combustion of biomass or biodegradation. In Sampo Group’s 
reporting these emissions are accounted for in Scopes 1, 2, and 3 in cases where the combusted 
fuel is assumed to have a portion of biomass. The biogenic emissions are not included in the GHG 
emissions reported on page 84.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 83

===== SIDA 84 =====

Gross Scopes 1, 2, 3 and Total GHG emissions
Sampo Group
Retrospective Milestones and target years
2022 
(Base year)
2023 
(Comparative) 2024 % 2024 / 2023 2025 2030 (2050)
Annual 
% target / 
base year
Scope 1 GHG emissions
Gross Scope 1 GHG emissions (tCO2eq)  1,197  1,115  883  -20.9 % -42%*
Percentage of Scope 1 GHG emissions from regulated 
emission trading schemes (%) - - - -
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions (tCO2eq)  2,482  1,738  1,886  8.5 %
Gross market-based Scope 2 GHG emissions (tCO2eq)  4,789  4,111  3,570  -13.2 % -42%*
Significant Scope 3 GHG emissions
Total gross indirect Scope 3 GHG emissions (tCO2eq)  353,054  370,412  326,376  -11.9 %
1 Purchased goods and services  2,017  1,652  14,493  777.3 %
[Optional sub-category: Cloud computing and data 
centre services] - - - -
2 Capital goods  111  2,247  2,843  26.5 %
3 Fuel and energy-related activities (not included in 
Scope 1 or Scope 2)  1,555  1,432  1,244  -13.1 %
4 Upstream transportation and distribution -  52  456  773.3 %
5 Waste generated in operations  273  232  260  12.2 %
6 Business travelling  5,592  6,306  6,318  0.2 %
7 Employee commuting  5,141  6,712  6,860  2.2 %
8 Upstream leased assets - - - -
9 Downstream transportation - - - -
10 Processing of sold products - - - -
11 Use of sold products - - - -
12 End-of-life treatment of sold products - - - -
13 Downstream leased assets -  139  41  -70.2 %
14 Franchises - - - -
15 Investments  338,364  351,641  293,860  -16.4 %
Total GHG emissions
Total GHG emissions (location-based) (tCO2eq)  356,733  373,266  329,145  -11.8 %
Total GHG emissions (market-based) (tCO2eq)  359,039  375,638  330,828  -11.9 %
The figures for 2022 and 2023 were recalculated to reflect changes in the reporting boundary and correct errors in data collection. For investments, the calculation method was aligned with other 
regulatory frameworks (e.g. the EU Taxonomy) and the current Group structure. The increase in Sampo Group’s Scope 3 GHG emissions in 2024 was mainly due to improved data quality and calculation 
methods, particularly at Hastings, and changes in emission factors.
Category 15 Investments concerns Sampo Group’s financed emissions for Scopes 1 and 2. Investment categories included in the calculations are direct equity and fixed income investments and fund 
investments. The coverage was 74.2 per cent of Sampo Group’s financial assets (including associated companies). Sampo Group’s Scope 3 financed emissions were 4,020,003 tCO2eq in 2024. 
* Sampo Group has a combined near-term target for Scope 1 and Scope 2 (market-based) emissions. Sampo Group’s emission reduction targets and results are disclosed in detail on page 83.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 84

===== SIDA 85 =====

Emission factors and calculation details
Sampo Group
Activity Calculation details Emission factor reference
Stationary combustion Stationary combustion includes combustion of natural gas (If, Topdanmark, and 
Hastings), biogas (Hastings), gas oil (Hastings), and fuel oil (If). 
DESNZ 2024
Mobile combustion Mobile combustion is calculated based on litres of fuel or kilometres driven, 
depending on the availability of data. If data is unavailable, the data is 
extrapolated based on the number and type of cars. The estimated fuel 
consumption per vehicle is based on national statistics.
DESNZ 2024; South Pole derived based on Drivmedel 2022 (diesel) and 
Värmeforsk 2023 (petrol)
Refrigerants The calculation is based on the consumption of refrigerants (Hastings). DESNZ 2024
Electricity The calculation is based on purchased electricity (MWh). For smaller offices, 
the electricity consumption is extrapolated based on average consumption per 
FTE or office area (m2). The residual mix emission factors used for the market-
based method are higher than the emission factors for the location-based 
method, leading to market-based emissions being higher than location-based 
emissions. 
AIB 2023; DESNZ 2024; Ecoinvent v3.10; EI 2023; IEA electricity emission 
factors 2023; IPCC, 2014
District heating Purchased district heating (MWh) is reported by If, Topdanmark, and Sampo. 
For smaller offices, district heating is extrapolated based on average 
consumption per FTE or office area (m2).
Euroheat & Power, 2023; Finnish Energy Statistics 2023; Swedenergy 2023; 
supplier-specific emission factors
District cooling Purchased district cooling (MWh) is reported by If and Sampo. For smaller 
offices, district cooling is extrapolated based on average consumption per FTE 
or office area (m2). 
South Pole derived average based on suppliers, 2023; supplier-specific 
emission factors
Purchased goods and 
services
Purchased goods and services includes water (m3), paper (tonnes), and cloud 
services (number of users) in all Group companies. Topdanmark reports on 
some office supplies (e.g. plastic items) and Sampo on food services. Hastings 
reports the financial records of its purchased goods and services. The 
calculations are based on supplier-specific, hybrid, average data, and spend-
based methods.
AIB 2023; CEDA 4.01 Global; Cloud Carbon Footprint, 2021; DESNZ 2023; 
Ecoinvent v.3.3.8 2021; EI 2022, Ecoinvent v.3.9.1.; Google, 2012; Amazon, 2021; 
IPCC, 2014; Microsoft, 2021; SCA Ortviken 2012; Mondi, 2022
Capital goods Capital goods includes purchased IT equipment (number and model of devices) 
and larger renovations (cost).
CEDA 4.01 Global; supplier-specific emission factors
Fuel and energy-related 
activities
Fuel and energy-related activities are calculated with the supplier-specific 
method, average method, and hybrid method. 
Ecoinvent v3.10; national statistics
Upstream transportation 
and distribution
Upstream transportation includes letters sent to customers. The calculation is 
based on the number of letters and the destination.
DESNZ 2024 (road and air freight); CEDA 4.01 Global
Waste generated in 
operations
Waste data is only available for larger offices. For smaller offices, data is 
extrapolated based on average consumption per FTE or office area (m2).
ADEME 2023 BC V8.9; DESNZ 2023 and 2024; Ecoinvent v3.9 and 3.10; World 
Bank waste statistics 2024
Business travelling Business travelling includes travel by air, train, ferry, bus, staff cars, rental cars, 
and taxis, as well as hotel accommodation. The calculations are based on 
activity or spend data. Emissions from hotel stays are calculated with country 
or city-specific emission factors.
CEDA 4.01 Global; DESNZ 2024; Cornell Hotel Sustainability Benchmark Index 
2023; RDC flight data 2024
Employee commuting The category Employee commuting also includes remote working and is based 
on a survey, which was conducted in all Group companies. The survey was 
either sent out to all employees or targeted groups and the results were 
extrapolated to represent all employees. 
Anthesis 2021, DESNZ 2024 (WFH assumptions); IEA electricity emission 
factors 2023; national statistics
Downstream leased 
assets 
The category Downstream leased assets is reported by Topdanmark. The 
calculation is based on consumption data (electricity, natural gas) and the 
actual size of the leased location during the period January–June 2024. 
AIB 2023; Ecoinvent v3.10; DESNZ 2023
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 85

===== SIDA 86 =====

Calculation principles and assumptions
Sampo Group’s GHG emission calculations include If 
(Nordic and Baltic offices), Topdanmark (Danish 
offices), Hastings (UK and Gibraltar offices), and Sampo 
(Finnish office). An external data provider, South Pole, 
conducts the calculations based on data provided by 
Sampo Group. The data inventory, emission factors, and 
assumptions are based on the GHG Protocol, and 
include the main greenhouses gases CO2, CH4, N2O, SF6, 
HFCs, PFCs, and NF3 converted to CO2 equivalents. The 
selection of assumptions and emission factors follows a 
conservative approach. Where activity or spend data 
for the inventory is lacking, extrapolations and 
estimations are used. 
The data behind Sampo Group’s Scope 3 category 1–14 
emissions consists of 49.0 per cent primary data and 
51.0 per cent secondary data. Primary data includes 
data from directly reported activities (e.g. fuel 
consumption), supplier-specific data (e.g. IT equipment 
reported with supplier information), and the employee 
commuting survey. Secondary data includes spend-
based (e.g. services) and extrapolated data (e.g. office 
waste). Regarding Scope 3 category 15 (investments), 
out of all investments covered by the data provider, 
66.4 per cent is based on primary data, i.e. emissions 
reported by investees, and 33.6 per cent is based on 
secondary data, i.e. estimations.
Emissions from vehicle and property repairs in claims 
handling have been estimated using data from 2021. An 
external research institute commissioned by If 
calculated the emissions using the life cycle assessment 
methodology (LCA) and a mix of primary and 
secondary data from a representative number of vehicle 
and property claims cases. Spend data from claims was 
used to estimate the total emissions for vehicle and 
property repairs. If’s estimated emissions for vehicle and 
property repairs amounted to 88,618 tCO2eq. These 
emissions are not currently included in Sampo Group’s 
Scope 3 inventory (category 11 Use of sold products) 
due to the level of uncertainty, but may be included in 
the future as reporting and data quality develop.
Scope 3 categories 8 Upstream leased assets, 9 
Downstream transportation, 10 Processing of sold 
products and 12 End-of-life treatment of sold products 
are not considered relevant for Sampo Group as the 
energy use for leased assets (vehicles and IT 
equipment) is accounted for in Scopes 1 and 2, its 
operations do not include activities where non-paid 
transportation and distribution apply, and the Group 
does not sell tangible products. The relevance of 
category 14 Franchises will be further investigated in 
2025.
The calculation methodology for Sampo Group 
investments’ GHG emissions follows the GHG Protocol’s 
investment-specific method. The emissions from 
investments are allocated to Sampo Group based on its 
proportional share of investments in investee 
companies. The proportional share is calculated by 
using Enterprise Value Including Cash (EVIC) to 
represent the total value of each investee company. The 
absolute GHG emissions of investee companies are 
collected using an external service provider, Bloomberg 
L.P., where the primary source used is company 
reported emissions followed by estimated emissions. 
The scope of investments' GHG emissions includes 
Sampo Group’s financial assets and investments in 
associates. Due to the lack of reliable data, Sampo 
Group did not obtain GHG emissions data for its 
sovereign exposure and derivatives. Moreover, the data 
provider does not cover all investment assets (e.g. 
private companies). Due to these data gaps, the 
coverage was 74.2 per cent of Sampo Group’s financial 
assets (including associated companies). Sampo Group 
has not used its own estimations for financed emissions 
yet as the data coverage by the external data provider 
has been relatively good and using estimates would 
affect the data quality. Hence, Sampo Group uses the 
transitional provision for not including information from 
the value chain. In order to fill the gaps, Sampo Group 
will evaluate the possibility to use extrapolation as a 
way of estimating the missing emissions data in the 
future.
The GHG emissions for the year 2024 are not validated 
by an external body other than the assurance provider 
of this Sustainability Statement.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 86

===== SIDA 87 =====

Resource use and circular economy
Topic Impacts Risks and opportunities Strategy and actions
Resource use and 
circular economy
↓  S a m p o  G r o u p  h a s  a  n e g a t i v e  i m p a c t  o n  t h e  
environment as it uses resources, for example, in its 
claims handling operations (e.g. construction 
material, car parts). By recycling and increasing the 
number of reused parts in claims handling, Sampo 
Group can limit the negative environmental impact. 
Time-horizon: short, medium and long term
↑  I n c r e a s i n g  c i r c u l a r  e c o n o m y - b a s e d  r e s o u r c e  f l o w  i n  
claims handling can create cost savings for Sampo 
Group, for example, through purchasing of reused 
parts instead of new ones and reselling of used 
materials instead of disposing.
↓  T h e r e  i s  a  r i s k  o f  r e p u t a t i o n a l  d a m a g e  a n d  a d d e d  
costs if Sampo Group fails to seize opportunities 
related to circular economy. This is, for example, 
due to difficulties in finding or using recycled or 
reused materials.
Time-horizon: short, medium and long term
• Internal policies and guidelines (e.g. supplier codes 
of conduct)
• Effective governance structures and processes (e.g. 
recycling, reuse and repair in claims handling, 
sustainable supply chain management)
• Metrics and targets (e.g. reused parts, glass repairs)
The table presents Sampo Group’s material impacts, risks, and opportunities related to resource use and circular economy identified in the double materiality assessment and their connection to Sampo 
Group’s strategy and actions. The topics are linked to the ESRS sub-topics. The topic Resource use and circular economy is related to the ESRS sub-topic Resource inflows, including resource use.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 87

===== SIDA 88 =====

Impact, risk, and opportunity 
management
Policies related to resource use and circular 
economy
The group level policy regarding resource use and 
circular economy is the Sampo Group Code of Conduct, 
which is reviewed annually and approved by Sampo’s 
Board of Directors. The Code of Conduct states that 
Sampo Group should reduce the consumption of 
resources (e.g. energy, water) and improve the resource 
efficiency, as well as reduce pollution, emissions, and 
waste generated from business operations, while 
incorporating the concepts of reduction, reuse, and 
recycling. The Sampo Group Code of Conduct covers all 
of the Group’s own operations. Additionally, Sampo 
Group expects its suppliers and other business partners 
to comply with the principles of the Code of Conduct 
throughout their own operations and supply chains.
In addition to the Sampo Group Code of Conduct, each 
Group company has adopted its own supplementary 
and more detailed policies, guidelines, and processes to 
guide the work related to resource use and circular 
economy in their own operations and value chain. The 
Group companies have, for example, sustainability 
policies to guide the work related to office space 
upgrades and supplier codes of conduct, which outline 
the expectations placed on suppliers with regards to 
environmental considerations. The Board of Directors or 
other governing body of each Sampo Group company 
approves the policies in the respective company, and 
the executive management is responsible for the 
implementation.
Sampo Group’s supplier codes of conduct are publicly 
available and are based on the 10 principles of the UN 
Global Compact. The codes of conduct require 
suppliers to encourage the development and diffusion 
of low emission technologies that protect the 
environment, are less polluting, use resources in a more 
sustainable manner, recycle more of their waste and 
products, and handle residual waste in a more 
acceptable manner than the technologies for which 
they were substitutes. Suppliers are expected to 
continuously improve their climate and environmental 
efforts, reduce the consumption of resources and 
ensure the efficient use of these resources, and reduce 
pollution, emissions and waste from business activities. 
The supplier codes of conduct apply to suppliers with 
whom Sampo Group conducts business, including the 
suppliers’ subsidiaries and sub-suppliers. The codes also 
apply to all of the suppliers’ employees, whether 
permanent or temporary.
Actions and resources related to resource 
use and circular economy
The most significant impacts, risks, and opportunities 
regarding resource use and circular economy for 
Sampo Group are related to suppliers in the company’s 
downstream value chain. Sampo Group does not 
produce, sell, or handle physical products requiring 
natural resources, but can instead affect the resource 
use in its value chain via insurance policies and claims 
handling processes. P&C insurance products and 
services affect the amount of resources used mainly 
through the policyholders’ claims related to vehicles, 
buildings, furniture, electronics, and other property. 
Sampo Group’s suppliers and business partners are 
central to the claims handling process, and Sampo 
Group is committed to taking environmental and 
climate considerations into account, for example, by 
encouraging and supporting circular efforts in these 
processes.
In 2024, Sampo Group cooperated with its suppliers in 
claims handling to increase material reuse, recycling, 
and repairs related to property and vehicle claims. 
Sampo Group also continued to focus on specific 
requirements it has set for its suppliers to promote 
circular economy. For instance, If’s property and vehicle 
repair partners must comply with the sector-specific 
Additional Environmental Requirements (AER), which 
are incorporated into the purchasing agreements. These 
requirements include requirements to repair instead of 
using new parts, reuse spare parts and repair more, 
reduce material usage, demolish less, increase remote 
work using video and sensors, reduce transportation, 
use material with environmental certification (when 
available), and increase the use of electric and hybrid 
vehicles. During the year, Sampo Group also updated 
existing policies (e.g. supplier codes of conduct, 
sustainability policies) regarding resource use and 
circular economy. These activities will continue in 2025.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 88

===== SIDA 89 =====

Metrics and targets
Targets related to resource use and circular 
economy
Sampo Group has not set measurable, time-bound and 
outcome-oriented targets for its resource use and 
circular economy actions on group level. The circular 
economy solutions in claims handling operations are 
developing, but continue to also be subject to several 
uncertainties. Therefore, Sampo Group has evaluated 
that setting group level targets at this stage is not 
justifiable from an environmental or financial viewpoint. 
However, Sampo Group reviews processes to manage 
impacts, risks, and opportunities related to resource use 
and circular economy regularly, and in case it is 
assessed that a group level externally disclosed target is 
a valuable addition, the decision will be revisited.
Metrics related to resource use and circular 
economy
Sampo Group measures the progress of its resource use 
and circular economy efforts, for instance, with the 
metrics presented in the table Circular economy in 
claims handling (car repairs). The share of reused parts 
and the share of glass repairs in car repair claims have 
been selected as key metrics, as they reflect Sampo 
Group’s goals of promoting circular economy and 
reducing resource use. Sampo Group has chosen to 
initially focus on car repairs, as the maturity of reused 
parts market in this segment is higher compared to 
house repairs, for instance. Sampo Group measures the 
proportion of reused parts and glass repairs based on 
monetary amount spent and the number of claims.
Sampo Group’s group level progress against these 
metrics has been measured starting 2024. The 
measurement is not validated by an external body other 
than the assurance provider of this Sustainability 
Statement.
Circular economy in claims handling 
(car repairs)
Sampo Group
Metric 2024
Share of reused parts  4.5% 
Share of glass repairs  35.3% 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 89

===== SIDA 90 =====

Social information
Own workforce
Topic Impacts Risks and opportunities Strategy and actions
Human rights and 
labour practices
↓  S a m p o  G r o u p  c a n  h a v e  a  n e g a t i v e  i m p a c t  o n  
human rights and labour rights of its own 
workforce, as a result of unethical labour practices 
or breaching of Sampo Group’s Code of Conduct, 
for example.
Time-horizon: short term
↓  S a m p o  G r o u p  c a n  f a c e  a  f i n a n c i a l  r i s k  d u e  t o  
increasing and tightening legislation related to 
human rights and labour rights (e.g. possible fines, 
reputational damage).
Time-horizon: short term
• Internal policies and guidelines (e.g. codes of 
conduct, HR policies)
• Effective governance structures and processes (e.g. 
reporting channels, forums for dialogue, employee 
engagement surveys, collective bargaining and 
freedom of association)
• Internal training and competence development 
programmes
• Metrics and targets
Employee health, 
wellbeing, and 
competence
↑  T h r o u g h  S a m p o  G r o u p ’ s  w e l l b e i n g  i n i t i a t i v e s  a n d  
competence development programmes, the mental 
and physical health of employees can be improved. 
This in turn can have a potential positive impact on 
the employees’ motivation and facilitate their 
professional growth and skills advancement. 
Focusing on employee wellbeing and competence 
development can result in motivated and engaged 
employees.
Time-horizon: short term
↓  A  l a c k  o f  c o m p e t e n t  e m p l o y e e s  c a n  p o s e  a  f i n a n c i a l  
risk for Sampo Group. If employees are not 
engaged and do not feel that there are 
opportunities to develop competencies, talented 
and unhappy employees might leave the company, 
taking their skill set with them.
↓  I n c r e a s e d  s i c k  l e a v e s  a n d  e m p l o y e e  t u r n o v e r ,  f o r  
instance due to inadequate work-life balance, can 
pose a financial risk for Sampo Group.
↑  E n g a g e d  a n d  c o m p e t e n t  e m p l o y e e s  c a n  c r e a t e  
opportunities for Sampo Group, as dedicated 
employees create results by delivering first-class 
customer experiences daily. For this reason, 
investing in personnel practices and an empowering 
work environment makes good business sense. 
Time-horizon: short term
• Internal policies and guidelines (e.g. codes of 
conduct, HR policies)
• Effective governance structures and processes (e.g. 
activities to support physical and mental health, 
workplace initiatives, quality offices, attractive 
remuneration packages)
• Internal training and competence development 
programmes
• Metrics and targets (e.g. employee engagement 
eNPS or similar)
Diversity, equity, and 
inclusion (DEI)
↑  S a m p o  G r o u p  c a n  h a v e  a  p o s i t i v e  i m p a c t  o n  D E I  i n  
its own workforce as a result of the actions taken 
by the Group. Emphasising DEI can cultivate a 
sense of belonging amongst employees.
Time-horizon: short term 
↓  I f  S a m p o  G r o u p ' s  o w n  w o r k f o r c e  i s  n o t  d i v e r s e ,  t h e  
Group may not be able to serve its diverse 
customer base, which can create a financial risk 
through lower productivity or innovation, for 
example. 
↑  D E I  c a n  c r e a t e  f i n a n c i a l  o p p o r t u n i t i e s  f o r  S a m p o  
Group, as companies performing well in this area 
can be more innovative and profitable, and attract 
talent.
Time-horizon: short term 
• Internal policies and guidelines (e.g. codes of 
conduct)
• Effective governance structures and processes (e.g. 
diversity models/programmes, employee initiatives, 
reporting channels)
• Internal training and competence development 
programmes
• Metrics and targets (e.g. related to gender 
diversity)
The table presents Sampo Group’s material impacts, risks, and opportunities related to own workforce identified in the double materiality assessment and their connection to Sampo Group’s strategy and 
actions. The topics are linked to the ESRS sub-topics. The topic Human rights and labour practices is related to the ESRS sub-topics Working conditions and Other work-related rights. The topic Employee 
health, wellbeing, and competence is related to the ESRS sub-topics Working conditions, Equal treatment and opportunities for all, and Other work-related rights. The topic Diversity, equity, and inclusion is 
related to the ESRS sub-topics Equal treatment and opportunities for all and Other work-related rights.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 90

===== SIDA 91 =====

Strategy
Material impacts, risks, and opportunities 
and their interaction with strategy and 
business model
Engaged employees are an instrumental part of Sampo 
Group’s strategy and business model. Sampo Group’s 
business activities depend on the company’s ability to 
create an empowering work environment and on the 
employees’ motivation to contribute to the company’s 
goals. The dedication and expertise of the workforce 
drive customer satisfaction and are the foundation of 
competitive advantage. The interests, views, and rights 
of Sampo Group’s employees inform strategic decisions 
and shape the corporate culture.
When assessing material impacts on its own workforce, 
Sampo Group considers all types of employees who 
may face significant impacts from the company’s own 
operations or value chain. This encompasses 
permanent, temporary, full-time, and part-time 
employees, and non-employees. For example, the 
double materiality assessment, human rights impact 
assessment, and employee engagement surveys inform 
the Group which types of employees or employee 
groups in its own workforce may be at greater risk of 
negative impacts. These can include underrepresented 
groups (e.g. based on ethnic background, gender, 
sexual orientation, disabilities) and employees working 
in high pressure environments (e.g. contact centres). 
Within Sampo Group, potential negative impacts 
related to its own employees may be tied to individual 
incidents rather than systemic human rights issues.
Sampo Group has identified potential risks stemming 
from a lack of diversity (e.g. lack of representation of 
minority groups), discrimination within the workforce as 
well as higher illness statistics and employee turnover in 
certain parts of the Group (e.g. contact centres). These 
factors may limit the ability to serve a diverse customer 
base in the best possible way and thus impact the 
Group’s financial performance.
Impact, risk and opportunity 
management
Policies related to own workforce
Sampo Group’s policy related to its own workforce is 
the Sampo Group Code of Conduct, which is reviewed 
annually and approved by Sampo’s Board of Directors. 
The Code of Conduct covers topics such as human 
rights and labour practices, employee health, wellbeing, 
and competence development, as well as DEI. The Code 
of Conduct prohibits forced and compulsory labour, 
child labour, and human trafficking and requires the 
Group companies to take measures to identify, avoid 
and/or tackle such human rights violations in their own 
operations and value chain. When developing the Code 
of Conduct, Sampo Group consults both internal (e.g. 
employees, management) and external stakeholders 
(e.g. investors, rating agencies, authorities, external 
consultants), depending on need. 
The Code of Conduct applies to all Sampo Group 
companies and in all countries of operation. The 
operative management in each Sampo Group company 
is responsible for the implementation of the Code of 
Conduct and it is the personal responsibility of every 
Sampo Group employee to comply with the Code. 
Sampo Group offers regular training (e.g. e-learning, 
workshops) on the topics covered by the Code of 
Conduct. The Code of Conduct is available to all 
stakeholders on Sampo Group’s website. In addition to 
the Code of Conduct, each Group company has 
adopted supplementary policies and guidelines for their 
own purposes. 
Sampo Group complies with all applicable human rights, 
labour rights, and employment legislation. In addition to 
national laws and regulations, Sampo Group is 
committed to respecting human rights as set out in the 
International Bill of Human Rights including the 
Universal Declaration of Human Rights, the International 
Covenant on Civil and Political Rights, the International 
Covenant on Economic, Social and Cultural Rights, and 
those stated in the core conventions of the International 
Labour Organization (ILO). Sampo Group is a 
participant in the UN Global Compact, and respects the 
principles related to human rights and labour rights.
Sampo Group’s policies and related training are part of 
the commitment to maintain open channels of 
communication with its own workforce and to 
objectively address human rights impacts that could 
potentially arise within the operations, ensuring the 
provision of suitable remedial actions, when necessary. 
Remedy may be provided, for example, in the form of 
support from HR, employee representatives, and health 
and safety delegates, insurance cover, and rehabilitation 
depending on the type of adverse impact and local 
regulations.
Sampo Group engages with its own workforce regularly 
and has multiple channels for this purpose. More 
information is available under the headings Processes 
for engaging with own workers and workers’ 
representatives about impacts (p. 92) and Interests and 
views of stakeholders (p. 64).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 91

===== SIDA 92 =====

Employee health, wellbeing, and competence
Sampo Group has health and safety policies addressing 
workplace accident prevention, and the company 
provides occupational health care in accordance with 
the legislation in each operating country. Sampo Group 
investigates health and wellbeing risks regularly and 
takes preventive action to mitigate potential risks, when 
considered relevant. All Sampo Group companies 
perform risk assessments, and any incidents and risks 
detected are handled accordingly and reported in the 
relevant incident reporting tools. Along with employee 
surveys, the risk assessments and incident reports 
provide valuable indications to further develop the 
business processes and work environment.
Sampo Group has work environment committees (or 
similar) set up in accordance with local legislation. 
These committees’ responsibilities include monitoring 
the work environment, developing health and safety 
procedures, and ensuring a high quality of physical and 
psychosocial wellbeing. The duties of the work 
environment committees can vary between the Group 
companies. 
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 training options depend on which part of 
the organisation the employees work in. 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 cycles.
Over the years, Sampo Group has seen a growth of 
community-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.
Diversity, equity, and inclusion
Sampo Group respects each individual’s human rights 
and does not tolerate any kind of discrimination, 
bullying, harassment, or any other type of abusive 
behaviour. The Code of Conduct states that 
discrimination is strictly prohibited, for example, on the 
grounds of age, disability, national extraction or social 
origin, racial and ethnic origin, colour, family 
commitments, gender, gender identity, political opinion, 
employees’ representative activities, religion, sensitive 
medical conditions, sexual orientation, or any other 
personal characteristics. In addition, discriminatory 
practices regarding recruitment, job assignment, 
training and development, promotion, remuneration 
and other benefits, or general conduct in the workplace 
are not tolerated. Reported cases related to 
discrimination and harassment are investigated and 
corrective action is taken.
At Sampo Group, it is important that all employees feel 
included and can be themselves at work. All Group 
companies have DEI policies and/or programmes and 
have taken action to raise awareness and address DEI 
and vulnerable groups within their own workforce. DEI 
topics are advanced, for example, through internal 
employee communities or diversity boards, setting 
company-specific diversity targets, and promoting DEI 
in recruitment and the leadership pipeline.
Processes for engaging with own workers 
and workers’ representatives about impacts
Sampo Group engages regularly and directly with 
employees and their representatives to gain insight into 
the employees’ perspectives, receive feedback, and 
identify development needs. All Sampo Group 
companies have decided on the highest level of 
responsibility for engagement based on their respective 
organisational structures. Forums for dialogue include, 
for example, leader-employee dialogues, work 
environment councils, meetings with union 
representatives, exit interviews, and employee 
engagement surveys. In addition, employees can raise 
concerns through whistleblowing channels and internal 
reporting channels.
The employee engagement surveys cover the physical 
and psychosocial work environment. The surveys 
address questions related to wellbeing and DEI, and the 
results are also examined according to demographic 
groups, including minority groups. Aggregated data 
from the surveys allow management teams to identify 
development areas, set targets, and measure the 
effectiveness of implemented actions. Leaders discuss 
the results with their teams, with the support of HR if 
needed, and take relevant action. In addition to the 
employee engagement surveys, Sampo Group aims to 
gain insight into the perspectives of vulnerable groups 
through different company and employee-driven 
initiatives around the topics of disabilities, women in the 
workforce, language, and inclusion of different cultures 
and religions, for example.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 92

===== SIDA 93 =====

Processes to remediate negative impacts 
and channels for own workers to raise 
concerns
Sampo Group strives for a constructive and trustful 
dialogue with employees and their elected 
representatives, such as unions, with the purpose of 
developing the company and safeguarding the correct 
treatment of all employees. Sampo Group promotes a 
culture of open discussion in which grievances can be 
aired and addressed proactively. Employees are 
encouraged to report unethical practices or possible 
violations of laws, regulations, or internal policies 
directly, for example, to a leader, HR, union 
representative, compliance units, or through the 
reporting channels. 
Sampo Group systematically monitors employee 
feedback received through, for example, employee 
surveys and reporting channels. Sampo Group ensures 
that actionable insights are addressed through 
formalised HR processes and leadership review. In 
addition to the internal reporting channels, Sampo 
Group has externally managed whistleblowing channels 
through which employees and other stakeholders can 
raise concerns anonymously. 
Any incident breaching the Code of Conduct will be 
investigated and the need for corrective action 
assessed on a case-by-case basis. Information about the 
different channels is available on the company intranets 
and communicated to employees during onboarding 
and regularly through internal communications 
campaigns.
The effectiveness of the different channels and the 
employees’ willingness to openly voice opinions and 
misconduct are assessed, for example, through the 
employee engagement surveys. Processes for handling 
whistleblowing cases are discussed in the section 
Business conduct (p. 116).
Taking action on material impacts on own 
workforce, and approaches to mitigating 
material risks and pursuing material 
opportunities related to own workforce, and 
effectiveness of those actions
Through the policies and processes described earlier, 
such as the Sampo Group Code of Conduct, Sampo 
Group aims to ensure that its employees are not subject 
to material negative impacts. In case of a negative 
impact occurs, Sampo Group’s remediation processes 
are followed. The Group investigates all suspected 
breaches on a case-by-case basis to determine the 
actions needed in response. Sampo Group engages with 
relevant internal stakeholders (e.g. HR, Legal, 
Compliance) in developing an action plan to address 
potential negative impacts, as well as assessing the root 
cause of the incident and preventative measures to be 
taken going forward.
In 2024, Sampo Group provided training on the topics 
covered by the Code of Conduct and other company-
specific policies to all new and existing employees. The 
aim is to ensure that all Sampo Group employees are 
aware of and act in accordance with the Group’s 
policies for human rights and labour practices.
During 2024, Sampo Group conducted a human rights 
impact assessment, which included an analysis of 
potential human rights risks on the Group’s own 
employees. The assessment covered risks related to 
Sampo Group’s own operations across the Nordics, the 
Baltics, and the UK, and also included non-employees, 
where relevant. Based on the assessment, Sampo Group 
mapped its due diligence measures in order to identify 
whether appropriate processes were in place for 
preventing the identified risks. The assessment is 
reviewed regularly and updated based on need.
Sampo Group wants to be an attractive and responsible 
employer, and invests in creating a corporate culture 
which nurtures health and wellbeing, work-life balance, 
and career development. Sampo Group offers, for 
example, flexible working hours and hybrid work, 
sports, volunteering, occupational health services, and 
training and career development. Sampo Group 
monitors the effectiveness of these measures, for 
example, through employee engagement, turnover, and 
other health and safety metrics. The main responsibility 
for managing material impacts lies with the respective 
HR functions who work with the business to ensure that 
employees are not negatively impacted and seek to 
maintain or strengthen positive impacts.
Employee health, wellbeing, and competence
In 2024, Sampo Group conducted regular employee 
engagement surveys, which provide opportunities for 
employees to share feedback on a range of subjects. 
The surveys enable Sampo Group to identify any issues 
and opportunities related to its employees. The 
feedback is analysed, and Sampo Group aims to make 
improvements to the most material matters. Sampo 
Group tracks the effectiveness of actions taken through 
analysis of future survey responses. Based on feedback 
received, If, for example, paid special attention to 
activities which build a strong feedback culture to 
strengthen organisational, team, and personal growth 
during 2024. Communication activities focused, among 
other things, on building awareness and sharing good 
feedback practices and tools. During the year, due to 
Sampo’s acquisition of Topdanmark and the following 
integration with If, Topdanmark conducted two 
additional employee engagement surveys to closely 
follow the employees’ mental wellbeing in times of 
organisational change. These surveys helped identify 
specific areas that needed attention and further 
communication (e.g. fear of job loss, fear of losing close 
colleagues).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 93

===== SIDA 94 =====

Employee health and wellbeing remained a high priority 
for Sampo Group in 2024. At Sampo Group, the mental 
and physical wellbeing of employees is managed by 
implementing preventative measures (e.g. wellbeing 
campaigns and webinars, preventative occupational 
healthcare, good design of offices, financial advice), 
focusing on work–life balance (e.g. workplace flexibility, 
working time reduction, dependent care, special leave), 
offering employees meaningful work assignments, 
education, and organising team activities and sports 
programmes. The actions have been directed at all 
employees of the individual Group companies. 
During 2024, Sampo Group continued to develop the 
hybrid working model and flexible working options to 
better incorporate the employees’ needs and 
preferences. This was done, for instance, by investing in 
IT infrastructure and equipment, redesigning office 
spaces, and training leaders in remote leadership. 
During the year, Sampo Group tested Microsoft 365 
Copilot to learn about the product and take advantage 
of the opportunities it can bring to the workforce. At 
Topdanmark, the re-design of office spaces focused on 
accommodating employees with neurodiverse 
challenges. This meant having the right lighting and 
designing workspaces to reduce visual and auditory 
noise. The adaption of the physical workspace to 
accommodate all employees was done to mitigate the 
risk of losing skilled employees due to a lack of sense of 
belonging, but also to secure the inclusion of all 
employees. This work will continue in 2025. 
In 2024, Sampo Group’s key activities for enabling a 
positive impact on employee competence included 
investments in digitalisation and development of tools 
to support employees in their work, reinforcing 
resources dedicated to competence development, 
organising learning events, and updating employee 
courses and competence development processes. For 
instance, If continued to develop the mandatory 
learning programme One Responsible If. The 
programme deals with key ethical and practical 
guidelines, such as those outlined in If’s Ethics and 
Sustainability policies. In addition, it includes an e-
course on incident reporting with the aim to ensure that 
all employees are aware of the channels and the types 
of incidents that should be reported. Also, Hastings’ 
Early Careers programme continued, offering 
apprenticeships, graduates, and other scheme 
opportunities. A Leadership Excellence pilot 
programme was also implemented at Hastings, 
providing leaders and employees with skills and tools to 
support their existing roles, create a consistent standard 
of leadership, and develop their careers. Sampo Group’s 
development programmes aim to provide positive 
impacts across its own workforce. In 2025, Sampo 
Group will continue its efforts to promote opportunities 
for employees to develop their knowledge and roles.
For example through the above mentioned actions, 
Sampo Group actively manages the financial risks 
deriving from potential failure to adequately foster the 
employees’ health, wellbeing, and competence 
development. Having dedicated employees also allows 
for better customer interactions and is thus an 
opportunity for the Group. Going forward, the goal is to 
further support the employees’ mental and physical 
wellbeing, and allow for new professional development 
opportunities.
Diversity, equity, and inclusion
In 2024, Sampo Group focused on DEI, for example, 
through equal pay and equitable working conditions for 
all employees. These were exhibited through different 
initiatives taken by the Group. 
During the year, Sampo Group initiated several projects 
related to equal pay, which included, for example, 
reviews of job architecture and pay grades, 
improvement of existing systems, improvement of 
internal reporting processes to obtain timely salary 
data, and development of policies and recruitment 
practices. The projects continue in 2025 to ensure the 
Group's ability to comply with the new EU regulation on 
Equal Pay for Equal Work or Work of Equal Value 
Between Men and Women in 2026, for example. 
In 2024, Sampo Group and its employees hosted DEI 
events and forums (e.g. Hastings’ Inclusion Council and 
DEI awareness campaigns), organised training (e.g. If 
trained all leaders in competence-based interview 
techniques to reduce unconscious bias), and took part 
in initiatives (e.g. Hastings’ 30% Club training 
programme). While aimed at creating positive impacts 
on Sampo Group’s employees, these also contribute to 
the management of DEI-related risks and opportunities 
the Group has identified. The actions have been 
directed at all employees of individual Sampo Group 
companies.
Sampo Group’s DEI work is also communicated in job 
advertisements, and recruitment processes are 
developed to include different types of assessments, 
including the use of personality tests, case 
presentations, structured interview guidelines, 
references, and a four-eye-principle to avoid decisions 
being influenced by unconscious bias and 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 94

===== SIDA 95 =====

discrimination. For example, If developed its existing 
employer branding initiatives to incorporate more of 
the company’s DEI work in 2024. In 2025, If continues 
to examine the employer brand, to appeal to a more 
diverse workforce, which is impacted by societal trends 
such as immigration and generational values. 
Going forward, Sampo Group will continue its efforts in 
relation to DEI. The plan is to improve methods to 
develop inclusive leadership, which contributes to 
increased psychological safety. Sampo Group will also 
focus on neurodiversity and disability through various 
activities, which include forming communities of best 
practice that can be consulted to make decisions more 
inclusive. These actions aim at fostering a diverse and 
inclusive culture and collecting insights to further 
enhance equal treatment of employees. Furthermore, 
they support Sampo Group in ensuring compliance with 
its Code of Conduct and zero tolerance for 
discrimination.
Metrics and targets
Targets related to managing material 
negative impacts, advancing positive 
impacts, and managing material risks and 
opportunities
Sampo Group has set time-bound and outcome-
oriented targets for employee engagement surveys to 
address impacts, risks, and opportunities related to 
employee safety, wellbeing, competencies, and 
diversity, for example. These themes are aligned with 
the policy objectives stated in the Sampo Group Code 
of Conduct, which aim at providing encouraging and 
rewarding working conditions, as well as fair and equal 
treatment.
The employee engagement results are based on 
surveys that employees fill out to assess their 
experience of working at a Sampo Group company. 
Employee engagement surveys are conducted at 
subsidiary level instead of group level to ensure the 
suitability of the surveys for each Group company and 
its individual needs and characteristics. The 
engagement surveys are sent out to all employees who 
have an active employment contract with Sampo Group 
when the survey is conducted. The surveys are 
conducted at least annually, and the results are 
reported to the respective management teams.
Sampo Group has set the employee engagement 
targets using internal and external benchmarking and 
historical data, for example. To assess the level of 
results, Sampo Group monitors trends internally and, 
when possible, compares the results to industry 
averages within its operating countries. Meeting the set 
targets can be considered as an excellent performance.
In addition to the top management of the Sampo Group 
companies, representatives from different parts of the 
Group have been involved in drafting the employee 
engagement targets. The targets are also discussed 
with union representatives, and external stakeholders’ 
feedback is considered, where relevant. The results of 
the employee engagement surveys and other data 
related to own workforce are used by the management 
teams of the Sampo Group companies as input into the 
organisational development processes.
Employee engagement
Sampo Group
Survey Scale Target
2024
H1 H2
If: HeartBeat -100–100 2024: 50 52 54
Topdanmark: 
Ennova 
Enagagement 
Survey -100–100 2025: 79 80 80
Hastings: Your 
Voice 0–100 2024: 72 77 78
Sampo plc: 
Work Life 
Survey -100–100 - - 42
The surveys are company-specific and not comparable to each 
other. Sampo’s survey is conducted annually in autumn. For If, 
Topdanmark, and Sampo, the scale is from -100 to 100. In 
general, scores above zero can be considered good/positive, 
while those above 50 can be considered excellent. However, 
score levels can vary according to industry and organisational 
type, for example. For Hastings’ survey, results above 70 can be 
considered as high.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 95

===== SIDA 96 =====

Calculation principles
Metrics related to own workforce are reported 
according to the requirements of the ESRS standard. 
The calculations are based on either headcount or full-
time equivalent (FTE) and the method used is disclosed 
in conjunction with each metric. Hourly paid employees, 
summer workers, non-employees, and trainees are 
excluded from the headcount and FTE calculations. For 
FTE, the work time is adjusted in case an employee is 
on a longer leave, such as parental leave. Year-end 
figures are used in reporting unless otherwise indicated. 
Sampo Group only collects information on binary 
gender due to legal restrictions and lack of system 
support and, therefore, reporting includes data on 
women and men only. More specific calculation 
principles are described alongside the metrics. 
The metrics for own workforce have not been validated 
by an external body other than the assurance provider 
of this Sustainability Statement. There are no figures 
related to own workforce in the Sampo Group Financial 
Statements.
Characteristics of the undertaking’s 
employees
As at 31 December 2024, the total number of 
employees at Sampo Group was 15,581. The number of 
employees increased slightly in all Group companies 
during the year. The increase was the highest at 
Hastings, in the UK, due to business growth.
In 2024, the majority of Sampo Group’s employees 
worked in the UK, Denmark, Sweden, Finland, and 
Norway. The share of women was slightly higher 
compared to men, but overall the binary gender 
balance was relatively equal. Sampo Group’s employees 
were mainly employed full-time on permanent contracts 
at the end of the year. 
Headcount is used for calculating the total number of 
employees, non-guaranteed hours employees, full and 
part-time employees, and permanent and temporary 
employees. A small number of employees work in what 
is called ‘Other countries’ in Group reporting. These 
countries have been combined in reporting due to the 
size of operations in these countries. ‘Other countries’ 
includes Spain, Gibraltar, France, Germany, the 
Netherlands, and the United States. 
In 2024, Sampo Group’s turnover rate and the number 
of terminations remained at the same level as in 
previous years. The turnover rate is calculated by 
dividing the number of employees who have left Sampo 
Group during the reporting year by average headcount. 
The figure includes external voluntary and involuntary 
turnover. 
Total number of employees by gender
Sampo Group, 31 December 2024
Gender Number of employees
Female 8,134
Male 7,447
Other -
Not reported -
Total employees 15,581
Total number of employees by country
Sampo Group, 31 December 2024
Country Number of employees
United Kingdom 4,314
Denmark 2,977
Sweden 2,770
Finland 2,130
Norway 1,827
Latvia 573
Estonia 514
Spain 230
Lithuania 190
Gibraltar 32
Germany 8
Netherlands 8
France 7
United States 1
Total employees 15,581
Number of terminations and turnover 
rate 
Sampo Group, 2024
Country Terminations Turnover rate
United Kingdom 776  19.9% 
Denmark 416  13.7% 
Sweden 312  11.4% 
Finland 130  6.1% 
Norway 143  8.1% 
Baltic countries 93  7.4% 
Other countries 102  36.8% 
Sampo Group, 
total 1,972  13.1% 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 96

===== SIDA 97 =====

Information on employees by gender
Sampo Group, 31 December 2024
Female Male Other Not disclosed Total
Number of employees
8,134 7,447 - - 15,581
Number of permanent employees
8,016 7,384 - - 15,400
Number of temporary employees
118 63 - - 181
Number of non-guaranteed hours employees
168 126 - - 294
Number of full-time employees
7,125 7,170 - - 14,295
Number of part-time employees
1,007 279 - - 1,286
Information on employees by country
Sampo Group, 31 December 2024
United Kingdom Denmark Sweden Finland Norway Baltic countries Other countries Total
Number of employees
4,314 2,977 2,770 2,130 1,827 1,277 286 15,581
Number of permanent employees
4,268 2,940 2,754 2,111 1,791 1,250 286 15,400
Number of temporary employees
46 37 16 19 36 27 0 181
Number of non-guaranteed hours employees
0 142 93 0 59 0 0 294
Number of full-time employees
3,741 2,766 2,576 1,955 1,736 1,245 276 14,295
Number of part-time employees
573 211 194 175 91 32 10 1,286
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 97

===== SIDA 98 =====

Characteristics of non-employee workers in 
the undertaking’s own workforce
As at 31 December 2024, the total number of non-
employees at Sampo Group was 3,283. The number of 
non-employees is reported as headcount. Non-
employees are employees in the company’s workforce 
who are not employed by the company (e.g. self-
employed individuals or employees provided by staffing 
agencies). At Sampo Group, non-employees work 
within IT and in customer service centres, for example.
Collective bargaining coverage and social 
dialogue
As at 31 December 2024, 60.9 per cent of Sampo 
Group’s employees were covered by collective 
bargaining agreements. The figure only includes 
employees who are fully covered by collective 
bargaining agreements in locations where trade unions 
are formally recognised. Nevertheless, the agreements 
apply to most employees’ (excluding top management) 
terms of employment even if they are not covered by 
the agreement. There are several collective bargaining 
agreements within Sampo Group’s operations in the 
European Economic Area, depending on the 
geographic location and national practices. In Sampo 
Group’s operations in the UK, trade unions are not 
formally recognised, but employment terms are 
compared to market practices at regular intervals. 
Sampo Group has no Global Framework Agreements. If 
has established an agreement on an information and 
consultation procedure with the workers’ 
representatives, based on the European Works 
Councils’ stipulation. The highest level of engagement 
with workers’ representatives takes place in the 
Communication Council, which is chaired by If's CEO. 
The Communication Council meets quarterly to address 
topics concerning more than one country or business 
area. 
The collective bargaining coverage is calculated by 
dividing the number of employees covered by collective 
bargaining agreements by the total number of 
employees using headcount. Estimations were used to 
calculate workplace representation.
Collective bargaining coverage and social dialogue
Sampo Group, 31 December 2024
Collective bargaining coverage Social dialogue
Coverage rate Employees – EEA Employees – Non-EEA
Workplace representation 
(EEA only)
0–19% - United Kingdom -
20–39% - - -
40–59% - - -
60–79% - - Denmark, Sweden
80–100% Denmark, Sweden, Finland, Norway - Finland, Norway
The table includes countries with more than 50 employees, representing over 10% of total employees.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 98

===== SIDA 99 =====

Diversity metrics
The age distribution within Sampo Group has 
historically been stable, and remained so in 2024. Age 
distribution is calculated by headcount at year-end. 
As at 31 December 2024, the binary gender distribution 
at the four highest management levels of Sampo Group 
shows that there is still room for diversity at the very 
top. However, at the levels immediately below top 
management, the balance between women and men is 
more equal. Sampo Group defines top management as 
the Sampo Group CEO (level 1), the subsidiaries’ CEOs 
(level 2), executives reporting to any of the CEOs (level 
3), and management level employees reporting to these 
executives (level 4). 
Gender distribution at top management level
Gender
Level 1 (the Group CEO)
Level 2 (the CEOs of Sampo plc’s 
subsidiaries) Level 3 (reporting to any of the CEOs) Level 4 (reporting to level 3)
31 Dec. 2024 31 Dec. 2024 31 Dec. 2024 31 Dec. 2024
Female 0  0.0% 0  0.0% 9  25.7% 77  40.8% 
Male 1  100.0% 3  100.0% 26  74.3% 112  59.2% 
Sampo Group, total 1  100.0% 3  100.0% 35  100.0% 189  100.0% 
Distribution of employees by age group
Age group 31 Dec. 2024
Under 30 years old 3,264  20.9% 
30–50 years old 8,730  56.0% 
Over 50 years old 3,587  23.0% 
Sampo Group, total 15,581  100.0% 
Adequate wages
At Sampo Group, remuneration is based on objective 
criteria, such as work experience, competence, position, 
and responsibilities, and all employees are paid an 
adequate wage which is in line with applicable 
benchmarks. Pay and additional benefits are not based 
on or affected by gender or any other non-professional 
aspect. Sampo Group has, for example, job title and job 
position structures to ensure that employees in the 
same position are employed under the same conditions, 
and internal and external benchmarks are used in 
setting the salary ranges.
Social protection
All Sampo Group employees are covered by social 
protection against loss of income due to major life 
events such as sickness, unemployment, employment 
injury and acquired disability, parental leave, and 
retirement.
Persons with disabilities
Sampo Group does not collect data on personal 
characteristics, such as disabilities, due to legal 
restrictions.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 99

===== SIDA 100 =====

Training and skills development metrics
At Sampo Group, all employees are eligible to 
participate in regular career development reviews. In 
2024, Sampo Group implemented new reporting 
processes for career development reviews to meet the 
ESRS reporting requirements. Reporting on this topic 
will be further developed in 2025 to ensure data 
accuracy. The percentage of employees who 
participated in performance and career development 
reviews is calculated by dividing the number of 
employees who participated in these reviews by the 
year-end headcount, broken down by gender. 
Percentage of employees who 
participated in regular performance and 
career development reviews by gender
Gender 2024
Female  66.2% 
Male  64.0% 
Sampo Group, total  65.1% 
Health and safety metrics
All Sampo Group’s employees were covered by a health 
and safety management system on 31 December 2024. 
The system refers to the occupational healthcare 
services that the employer offers to employees. The 
system can be either statutory or offered voluntarily. 
The percentage of employees in Sampo Group’s own 
workforce covered by a health and safety management 
system is calculated using headcount.
During 2024, there were no fatalities as a result of work-
related injuries at Sampo Group, and the number of 
work-related accidents remained stable. Sampo Group 
reports the rate of recordable work-related accidents 
for the first time in 2024. The rate is calculated by 
dividing the number of cases by the estimated total 
hours worked and multiplied by one million. The rate 
represents the number of cases per one million hours 
worked. The disclosed metrics concern employees in 
Sampo Group’s own workforce.
Sampo Group does not collect data on work-related ill 
health, fatalities due to work-related ill health, or days 
lost due to work-related ill health due to legal 
restrictions. 
Percentage of employees covered by 
health and safety management system
Sampo Group
Metric 31 Dec. 2024
Percentage of employees who are covered 
by health and safety management system  100.0% 
Work-related injuries and fatalities
Sampo Group
Metric 2024
Number of fatalities as a result of work-
related injuries 0
Number of recordable work-related 
accidents 80
Rate of recordable work-related accidents 3.4
Work-life balance metrics
At Sampo Group, all employees are entitled to family-
related leave through social policy or collective 
bargaining agreements. The percentage of employees 
who took family-related leave is calculated by dividing 
the number of employees who were on family-related 
leave divided by year-end headcount, broken down by 
gender.
Percentage of employees who took 
family-related leave
Gender 2024
Female  10.2% 
Male  6.3% 
Sampo Group, total  8.3% 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 100

===== SIDA 101 =====

Remuneration metrics (pay gap and total 
remuneration)
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, and 
leave of absence. The calculation principles of the 
gender pay gap have been modified in 2024 to reflect 
the requirements of the ESRS.
Sampo Group calculated the annual total remuneration 
ratio of the highest paid individual to the median annual 
remuneration for the first time in 2024. The median 
remuneration data is retrieved from local payroll 
systems and includes fixed net compensation, holiday 
pay, bonuses, and all incentive schemes. Overtime 
compensation and pensions are excluded. The median 
annual remuneration figure is based on the number of 
employees in an employment relationship with Sampo 
Group at 31 December 2024, regardless of them being 
employed a full year or not.
Pay gap related metrics are calculated using FTE 
average. Exchange rates may have an impact on the 
remuneration figures presented in this statement. 
Gender pay gap
Sampo Group
Metric 2024
Fixed remuneration  19.8% 
Fixed and variable remuneration  24.5% 
Annual total remuneration ratio of the 
highest paid individual to the median 
annual remuneration
Sampo Group
Metric 2024
Pay ratio 89.6
Incidents, complaints, and severe human 
rights impacts
In 2024, no severe human rights incidents, defined as 
severe violations of human rights and labour rights 
legislation concerning Sampo Group’s own workforce, 
were reported. Two incidents of discrimination and 
harassment were reported. These include incidents of 
discrimination as defined in the Sampo Group Code of 
Conduct and incidents of harassment that have led to 
formal consequences (e.g. warning or dismissal). The 
total number of complaints filed through Sampo 
Group’s channels for people in the own workforce was 
22. These are complaints reported by employees 
through grievance mechanisms and whistleblowing 
channels, concerning social, human rights, and labour 
rights matters. The figure includes all applicable 
complaints filed during 2024 regardless of their status 
at the end of the reporting year. None of the incidents 
or complaints reported during the year resulted in fines, 
penalties, or compensation for damages.
Number of incidents of discrimination 
and harassment
Sampo Group
Metric 2024
Number 2
Number of severe human rights incidents
Sampo Group
Metric 2024
Number 0
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 101

===== SIDA 102 =====

Workers in the value chain
Topic Impacts Risks and opportunities Strategy and actions
Suppliers and business 
partners
↓  S a m p o  G r o u p  h a s  n o t  i d e n t i f i e d  a c t u a l  n e g a t i v e  
impacts related to its suppliers and business 
partners. Potential negative impacts related to 
human rights and labour practices can occur across 
Group's entire value chain. Potential negative 
impacts can be mitigated, but due to the large 
number of suppliers and business partners, it is not 
possible to completely remove the risk for negative 
impacts on workers in the value chain (e.g. related 
to working conditions and equal treatment).
↑  S a m p o  G r o u p  c a n  h a v e  a  p o t e n t i a l  p o s i t i v e  i m p a c t  
on the sustainability of its suppliers and business 
partners through its own actions. This can also 
improve the working conditions of its suppliers’ 
workforce (e.g. job stability and health). 
Time-horizon: short to medium term
↓  I f  S a m p o  G r o u p ' s  s u p p l i e r s  o r  b u s i n e s s  p a r t n e r s  
exploit their employees, this may lead to legal, 
reputational, and operational risks for the supplier 
or partner in question. This could become an 
operational risk for Sampo Group, having to find a 
new partner or experience delays and poor quality 
in deliveries. 
↓  S a m p o  G r o u p  c a n  f a c e  a  f i n a n c i a l  r i s k  d u e  t o  
increasing and tightening legislation related to 
human rights and labour rights (e.g. possible fines, 
reputational damage).
↑  H a v i n g  s t a b l e  b u s i n e s s  r e l a t i o n s h i p s  w i t h  
responsible suppliers and business partners can be 
a competitive advantage and create financial 
opportunities for Sampo Group.
Time-horizon: short to medium term
• Policies and guidelines (e.g. supplier codes of 
conduct)
• Effective governance structures and processes (e.g. 
supplier risk assessments, audits, questionnaires, 
engagement)
• Internal training and competence development 
programmes
• Metrics and targets (e.g. share of suppliers signing a 
code of conduct)
Underwriting and 
investment 
management
↑  S a m p o  G r o u p  c a n  h a v e  a  p o t e n t i a l  p o s i t i v e  i m p a c t  
on the entire value chain, including workers in the 
value chain, by adopting responsible investment 
and underwriting practices.
Time-horizon: medium to long term
↓  I f  S a m p o  G r o u p  w e r e  t o  i n v e s t  i n  o r  i n s u r e  
industries whose operations are harmful for value 
chain workers, it could cause reputational damage 
and financial risks for the Group.
↑  F o r  S a m p o  G r o u p ,  f i n a n c i a l  o p p o r t u n i t i e s  o f  
responsible investment are limited, as sustainability 
is seen as a baseline. In the long run, there may be 
more opportunities, as the availability of 
information increases, and sustainability can also 
provide reputational value.
Time-horizon: medium to long term
• Commitments to responsible investment and 
underwriting (e.g. PRI, SBTi)
• Internal policies and guidelines (e.g. responsible 
investment policies, underwriting principles)
• Effective governance structures and processes (e.g. 
screening, engagement)
• Metrics and targets (e.g. SBTs)
The table presents Sampo Group’s material impacts, risks, and opportunities related to workers in the value chain identified in the double materiality assessment and their connection to Sampo Group’s 
strategy and actions. The topics are linked to the ESRS sub-topics. The topics Suppliers and business partners and Underwriting and investment management are related to the ESRS sub-topics Working 
conditions and Other work-related rights.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
BOARD OF DIRECTORS’ REPORT 2024 102

===== SIDA 103 =====

Strategy
Material impacts, risks, and opportunities 
and their interaction with strategy and 
business model
Sampo Group has an impact on workers in the value 
chain through its suppliers and business partners, 
corporate customers, and investments. For example, 
based on the double materiality assessment and the 
human rights impact assessment, Sampo Group has 
identified that especially workers in its downstream 
value chain (e.g. suppliers in claims handling) could be 
negatively affected. These workers may face risks 
inherent to their roles and operating contexts, which are 
mitigated, amongst other things, by the suppliers' 
adherence to the required health and safety standards 
outlined in Sampo Group's supplier codes of conduct.
Ensuring that human and labour rights are respected by 
the suppliers is important for Sampo Group to mitigate 
financial risks and seize opportunities. Suppliers 
breaching human rights and labour rights may face 
legal, reputational, and operational consequences, 
which may, in turn, become an operational risk for 
Sampo Group. A stable business relationship with a 
responsible supplier is a competitive advantage and 
can, therefore, be seen as an opportunity, too.
Sampo Group develops its understanding of particularly 
vulnerable value chain workers for instance through 
self-assessment questionnaires completed by suppliers 
and engagement with investee companies, corporate 
customers, and suppliers. Examples of particularly 
vulnerable groups within Sampo Group’s value chain 
include different minorities and migrant workers.
Sampo Group includes all value chain workers who may 
be materially impacted by its operations, products, 
services, and business relationships in its disclosures. 
However, the main focus is on direct suppliers (Tier 1) 
where Sampo Group is expected to have the largest 
impact. In addition, impacts Sampo Group may have 
through its investees and corporate customers are also 
considered.
Sampo Group’s upstream value chain encompasses 
suppliers of office supplies and services (e.g. software 
and hardware companies) as well as providers of other 
business services (e.g. consultants, external data 
providers) that support the running of the business. The 
downstream value chain includes, for example, suppliers 
of vehicle and property repair contractors, as well as 
healthcare providers. The key activities related to 
Sampo Group’s products and services that are carried 
out by suppliers include property, vehicle, and content 
repairs, health and hospital services, and travel services. 
Sampo Group acknowledges the varying levels of 
human and labour rights risks associated with different 
industries and regions related to its business, 
particularly in sectors such as construction and vehicle 
repair. 
The majority of Sampo Group’s suppliers in claims 
handling are based in the Nordics, where the risk for 
human rights violations in general is considered lower 
than in many other regions globally. However, the value 
chains can be long and complex, and especially certain 
sectors such as construction, mining, transportation, 
and electronics are associated with risks to human 
rights and labour rights. Workers may be exposed to 
unhealthy or unsafe working conditions including, for 
example, long hours and exposure to hazardous 
substances. Risks also include forced labour and child 
labour, discrimination, and violations of privacy. These 
risks can be considered systemic.
Sampo Group’s downstream value chain also 
encompasses the workforce and supply chains of its 
investee companies and corporate customers, through 
which the Group can have an impact on workers that 
goes beyond its own operating countries. This could, for 
example, include a risk of forced labour, unhealthy 
working conditions, or discrimination and harassment, 
as these risks can exist in industries or regions where 
the investee companies or corporate customers 
operate. As these risks materialise further down the 
value chain, Sampo Group’s possibilities to limit the 
impacts are limited. 
Impact, risk and opportunity 
management
Policies related to value chain workers
Sampo Group’s policy related to workers in the value 
chain is the Sampo Group Code of Conduct, which is 
reviewed annually and approved by Sampo’s Board of 
Directors. The Code of Conduct is mandatory for all 
Sampo Group companies and must be personally 
upheld by every Group employee. 
The Code of Conduct states that Sampo Group 
complies with all applicable human rights, labour rights, 
and employment legislation. In addition, Sampo Group 
is committed to respecting human rights as set out in 
the International Bill of Human Rights including the 
Universal Declaration of Human Rights, the International 
Covenant on Civil and Political Rights, the International 
Covenant on Economic, Social and Cultural Rights, and 
those stated in the core conventions of the International 
Labour Organization (ILO). Sampo Group also adheres 
to the principles of the UN Global Compact and follows 
the internationally recognised standards on business 
and human rights, such as the UN Guiding Principles on 
Business and Human Rights and the OECD Guidelines 
for Multinational Enterprises. Hence, Sampo Group is 
committed to the obligations related to human rights 
and the continuous development of related practices 
(e.g. human rights due diligence processes including 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
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human rights impact assessments) covering both its 
own operations and its value chain.	
Sampo Group has due diligence processes aligned with 
the OECD Guidelines for Multinational Enterprises. 
These processes allow Sampo Group to identify, avoid 
and address possible adverse impacts on human rights, 
labour rights, the environment and anti-corruption 
commitments associated with its suppliers as well as 
underwriting and investment operations.  
As stated in the Code of Conduct, Sampo Group 
condemns all forms of forced and compulsory labour as 
well as child labour and modern slavery (e.g. human 
trafficking) in the Group’s own operations and value 
chain. In addition to the Sampo Group Code of Conduct, 
each Group company has adopted supplementary and 
more detailed policies, guidelines, and processes for 
their own purposes.
Sampo Group has not been made aware of severe 
confirmed cases of non-adherence to global standards 
for value chain workers in its upstream and downstream 
value chain during the reporting year. This includes 
direct suppliers (Tier 1), direct investments, and 
corporate customers.
Suppliers and business partners
The Sampo Group Code of Conduct is the group level 
guidance document on supplier codes of conduct. The 
Group’s company-specific supplier codes of conduct set 
the minimum requirements that suppliers are expected 
to meet on topics such as fair and equal treatment, 
privacy, employment terms, working hours, fair wages, 
health and safety, and freedom of association and 
collective bargaining. The codes of conduct are based 
on the UN Global Compact and its underlying 
conventions, and apply to suppliers and sub-suppliers. 
The supplier codes of conduct are approved by the 
boards of directors or other governing bodies of the 
respective Sampo Group company. The ultimate 
responsibility for implementation lies with the top 
management of each Group company. The policies are 
available on the Group companies’ websites and they 
are communicated to suppliers.
Sampo Group engages with its suppliers, for example, 
through dialogue, self-assessment questionnaires, 
reviews and site visits. In case of a breach against a 
supplier code of conduct, Sampo Group engages with 
the supplier to bring about improvements in the 
supplier’s business conduct. Sampo Group monitors the 
situation and actions depend on the corrective 
measures taken by the supplier. Sampo Group can 
terminate the supplier contract if the supplier does not 
take steps to remediate the situation within a 
reasonable timeframe.
Underwriting and investment management
Sampo Group provides insurance to corporate 
customers in accordance with its underwriting 
principles and manages its investments in accordance 
with its responsible investment policies. Sampo Group 
updates its policies related to insurance and investment 
operations annually and they are approved by the 
boards of directors of each Group company. The 
policies include, among other things, descriptions on 
how to take sustainability risks and sustainability criteria 
into account in insurance and investment activities. 
Sampo Group conducts norm-based screening of direct 
investments and corporate customers against 
international norms and standards (e.g. the UN Global 
Compact principles, 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) using 
external service providers. If Sampo Group detects a 
violation of norms or standards, depending on the 
severity, nature, and extent of the breach, measures 
taken may consist of direct dialogue or other type of 
engagement action. As a measure of last resort, the 
investment can be sold or insurance contract 
terminated if the investee company or corporate 
customer does not take corrective action.
In addition to norm-based screening, Sampo Group 
excludes certain sectors from direct investments unless 
pre-defined criteria are fulfilled. Examples of such 
sectors are tobacco, coal, and controversial weapons, 
due to potential human rights risks, labour rights risks, 
reputational risk, and/or regulatory risks.
Processes for engaging with value chain 
workers about impacts
Sampo Group does not engage directly with its value 
chain workers or their legitimate representatives or 
credible proxies. However, indirect engagement can 
occur through suppliers, investee companies, or 
corporate customers. The engagement can be part of 
formal due diligence processes or regular monitoring of 
business relationships (e.g. meetings, self-assessment 
questionnaires, business reviews). These processes 
allow Sampo Group to understand and manage impacts 
on the workers in its value chain. 
The frequency and method of engagement depends on 
assessed risk, which links, for example, to the type and 
size of the business partner in question. The 
effectiveness of engagement is monitored, for example, 
through follow-up meetings with suppliers and 
corporate customers or through external partners 
during engagement with investee companies. 
Sampo Group gains insight into the perspectives of its 
value chain workers mainly through human rights due 
diligence processes. These include, for example, 
conducting human rights impact assessments, 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
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evaluating suppliers' adherence to sustainability criteria, 
and screening investments and corporate customers. 
Processes to remediate negative impacts 
and channels for value chain workers to raise 
concerns
The Sampo Group Code of Conduct, supplier codes of 
conduct, and responsible investment and underwriting 
practices set clear requirements related to value chain 
workers. If non-compliance with the requirements is 
detected, Sampo Group will engage with the supplier, 
investee company, or corporate customer in question to 
rectify the situation and align them with the Group’s 
policies, with plans to review and follow up on these 
actions. If the error or contract breach is major, or the 
supplier, investee company, or corporate customer is 
unwilling to make improvements within a given 
timeframe, Sampo Group may terminate the contract or 
divest. 
Most of Sampo Group’s whistleblowing channels are 
available to all stakeholders, including value chain 
workers, for reporting suspicions of violations against 
legislation or unethical conduct. The whistleblowing 
channels are either internally or externally managed, 
depending on the Group company, and allow 
anonymous reporting. In addition, the majority of 
Sampo Group’s supplier codes of conduct or related 
contracts state that suppliers must provide channels for 
reporting grievances. Suppliers are also required to 
report any breaches against the principles of the codes 
of conduct to Sampo Group. In addition to making 
relevant policies and channels available to value chain 
workers, Sampo Group does not specifically assess how 
well they are aware of the processes to raise concerns.
Incidents reported through Sampo Group’s 
whistleblowing channels are investigated promptly in 
accordance with applicable legislation. Sampo Group 
ensures the effectiveness of its channels through 
internal and external communications and training. The 
Group is also committed to develop its approaches 
further. The whistleblowing channels are discussed in 
detail in the section Business conduct (p. 116).
Taking action on material impacts on value 
chain workers, and approaches to managing 
material risks and pursuing material 
opportunities related to value chain workers, 
and effectiveness of those actions
In 2024, Sampo Group conducted a group-wide human 
rights impact assessment, where risks related to human 
rights topics across the Group’s operations and value 
chain, including those related to suppliers, investments, 
and corporate customers, were assessed. The 
assessment covered the identification of human rights 
risks in relation to Sampo Group’s own operations in the 
Nordics, the Baltics, and the UK, as well as key upstream 
and downstream activities and their geographies. The 
work also included a plan for developing the Group’s 
due diligence processes further in order to address 
identified risks. During 2024, to support the group level 
work, the Group companies developed, for example, 
their human rights-related process descriptions, 
policies, and practices (e.g. supplier codes of conduct, 
human rights policies, whistleblowing channels). This 
work also strengthened Sampo Group’s compliance 
with the minimum safeguards of the EU Taxonomy 
(p. 71).
Based on the assessment, Sampo Group develops its 
processes to improve its abilities in detecting, 
preventing, and mitigating potential negative impacts 
on human rights and labour practices of the Group’s 
value chain workers. Additionally, Sampo Group 
continues its regular and on-going work with all relevant 
suppliers and business partners, investees, and 
corporate customers to ensure compliance with the 
Group’s policies.
Sampo Group uses its continuous processes to 
determine whether engagement or other additional 
actions with the given supplier, corporate customer, or 
investee company are needed to address any potential 
negative impacts on value chain workers. Similarly, 
Sampo Group’s policies, screening, and engagement 
practices allow for mitigating risks and pursuing 
opportunities that have been identified related to 
workers within the Group’s value chain.
Sampo Group has not identified actual material 
negative impacts on its value chain workers and no 
severe human rights issues or incidents have been 
reported to Sampo in the Group’s upstream or 
downstream value chain in 2024. Potential negative 
impacts on value chain workers are monitored, for 
example, through supplier self-assessment 
questionnaires, site visits, reviews, and potential 
contract terminations, which can occur due to a 
supplier’s or business partner’s non-compliance with 
Sampo Group’s sustainability requirements. 
In case any material negative impacts on value chain 
workers were to occur, Sampo Group has processes in 
place for reporting and addressing grievances and to 
take corrective action. Responsibility for the 
management of any material impacts on value chain 
workers is allocated to each Group company’s 
respective departments, such as Procurement, 
Investment management, Insurance operations (e.g. If’s 
Business area Industrial), and Sustainability. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
Report ≡
Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
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