Årsredovisning 2024

Suppliers and business partners
In 2024, Sampo Group strengthened the integration of 
its supplier codes of conduct into processes, developed 
due diligence practices, and monitored suppliers’ 
alignment with sustainability criteria. As Hastings 
implemented a supplier code of conduct in 2024, all 
Sampo Group companies now have a code of conduct 
outlining the expectations towards suppliers, including 
human and labour rights. Other actions taken to 
enhance the cooperation with suppliers were reviewing 
ESG questionnaires, as well as allocating training 
budgets and providing digital platforms and external 
consultancy support to assist in conducting the due 
diligence. All of these actions are meant to support 
Sampo Group’s work in preventing negative impacts to 
workers across the value chain.
Sampo Group also aims to promote positive impacts 
among its value chain workers. For example, 
Topdanmark cooperates with its suppliers in the 
building sector and engages in upskilling the key 
employees at the supplier through targeted education 
related to claims handling practices. In addition, Sampo 
Group engaged with its suppliers to ensure alignment 
with the Group’s policies and guidelines regarding 
labour practices in 2024.  
Underwriting and investment management
Sampo Group updated the Group’s responsible 
investment policies during 2024. The changes were 
linked, for example, to the SBTs. The development of 
the Group’s responsible investment practices continues 
during the coming years based on internal sustainability 
ambitions, external stakeholder feedback, and overall 
market development.
In 2024, Sampo Group screened its direct investments 
and corporate customers for breaches against the UN 
Global Compact principles. Based on the screenings, 
Sampo Group did not have any direct investments in 
companies with confirmed norm violations and no 
severe and confirmed inconsistencies were identified 
among the corporate customers either. During the year, 
Sampo Group also continued to screen its direct 
investments for sensitive sectors to manage any 
possible risks related to human and labour rights.
During the reporting year, Sampo Group’s investments 
in funds were managed by asset managers who are UN 
PRI signatories. A significant portion of these funds is 
also managed by asset managers who have committed 
to respecting the UN Global Compact principles.
Metrics and targets
Targets related to managing material 
negative impacts, advancing positive 
impacts, and managing material risks and 
opportunities
Sampo Group’s long-term goal is that all suppliers have 
signed a supplier code of conduct. However, for the 
time being, Sampo Group has not set measurable, time-
bound, and outcome-oriented group level targets for 
the metrics related to workers in the value chain. Sampo 
Group reviews processes to manage impacts, risks, and 
opportunities related to workers in the value chain 
regularly. In case it is assessed that an externally 
disclosed target on the group level is a valuable 
addition, the decision will be revisited.
Metrics related to Supplier Code of Conduct
In order to evaluate its effectiveness in mitigating the 
risk of potential negative impacts on value chain 
workers and their human and labour rights, Sampo 
Group measures the inclusion of supplier codes of 
conduct in its supplier agreements. Tracking the 
inclusion also supports Sampo Group in managing 
financial risks related to any negative impacts on value 
chain workers and the pursuit of opportunities from 
business relationships with responsible partners. 
Sampo Group started to track the inclusion of supplier 
codes of conduct in supplier agreements at group level 
in 2024. Performance is regularly monitored as part of 
Sampo Group’s annually published sustainability 
statement. Going forward, Sampo Group will monitor 
the need for additional group level metrics and 
implement them, if considered material.
The share of suppliers having signed a supplier code of 
conduct is measured by dividing the number of 
suppliers that have signed one of Sampo Group’s 
supplier codes of conduct (including suppliers that have 
their own code of conduct which Sampo Group has 
approved) by the number of all suppliers. The metric 
applies to both suppliers in Sampo Group’s upstream 
(e.g. suppliers of office equipment) and downstream 
value chain (e.g. suppliers in claims handling). Some 
suppliers, such as large IT companies and consultancies, 
are excluded from the metric. There are Group 
company-specific adjustments in the methodology due 
to differences in supply chain structures.
Results for the year 2024 are presented in the table 
Supplier Code of Conduct included in existing supplier 
agreements. The measurement of supplier codes of 
conduct is not validated by an external body other than 
the assurance provider of this Sustainability Statement.
Supplier Code of Conduct included in 
existing supplier agreements
Sampo Group
Metric 31 Dec. 2024
Share of suppliers  75.6% 
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 106

===== SIDA 107 =====

Consumers and end-users
Topic Impacts Risks and opportunities Strategy and actions
Customer health and 
safety
↑  C u s t o m e r  h e a l t h  a n d  s a f e t y  i s  a t  t h e  c o r e  o f  t h e  
insurance business and, therefore, also at the core 
of Sampo Group’s business. As Sampo Group’s 
strategy focuses on disciplined underwriting and 
careful risk management, the company has an 
actual positive impact on consumers’ and end-
users' health by providing insurance products, thus 
helping its customers in risk management. 
Time-horizon: short to medium term 
↑  S a m p o  G r o u p  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  b y  
offering consumers and end-users products and 
services they need and want. Opportunities can also 
be gained, for example, by cutting costs through 
digital solutions and by developing new products 
and services.
Time-horizon: short to medium term 
• Internal policies and guidelines (e.g. codes of 
conduct, underwriting principles, risk management 
principles)
• Effective governance structures and processes (e.g. 
feedback channels, loss prevention, risk 
management)
• Training and competence development 
programmes
• Metrics and targets (e.g. NPS, EPSI, Trustpilot)
Sales and marketing 
practices
↓  S a m p o  G r o u p  c a n  h a v e  p o t e n t i a l  n e g a t i v e  s o c i e t a l  
impact through irresponsible sales and marketing 
practices (e.g. inaccessibility, discrimination, 
misleading).
Time-horizon: short to medium term 
↓  P o s s i b l e  i r r e s p o n s i b l e  s a l e s  a n d  m a r k e t i n g  p r a c t i c e s  
can cause a financial risk for Sampo Group through 
legislative consequences (e.g. possible fines) and 
reputational damage. 
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. codes of 
conduct)
• Effective governance structures and processes (e.g. 
feedback channels, quality communications, 
responsible remuneration practices)
• Training and competence development 
programmes
Data privacy, 
information security, 
and cybersecurity
↓  A s  a n  i n s u r a n c e  c o m p a n y ,  S a m p o  G r o u p  h a n d l e s  
and stores large amounts of customers and other 
stakeholders’ personal data. Due to increasing 
digitalisation and the use of AI, there is a risk of, for 
example, information security breaches, 
cybersecurity attacks, and data privacy incidents, 
leading to potential negative impacts on consumers 
and end-users. 
Time-horizon: short to medium term
↓  S a m p o  G r o u p  i s  e x p o s e d  t o  d a t a  p r i v a c y ,  
information security, and cybersecurity risks due to 
the high quantity of sensitive data the company 
handles and processes. In the case of incidents 
related to privacy and data security, negative 
financial risks, such as fines and reputational 
damage, may be significant. 
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. codes of 
conduct, data privacy statement, information 
security principles, risk management principles)
• Effective governance structures and processes (e.g. 
frameworks and reporting structures, screenings, 
impact assessments, security measures, data 
processing agreements, risk analyses, continuity 
planning, quality systems and infrastructure)
• Training and competence development 
programmes
• Metrics and targets
The table presents Sampo Group’s material impacts, risks, and opportunities related to consumers and end-users 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 Customer health and safety is related to the ESRS sub-topic Personal safety of consumers and/or end-users. The topic Sales and 
marketing practises is related to the ESRS sub-topics Social inclusion of consumers and/or end-users and Information-related impacts for consumers and/or end-users. The topic Data privacy, information 
security, and cybersecurity is related to the ESRS sub-topic Information-related impacts for consumers and/or end-users.
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 107

===== SIDA 108 =====

Strategy
Material impacts, risks, and opportunities 
and their interaction with strategy and 
business model
Sampo Group provides insurance products and services 
to three main customer groups: private customers, 
commercial customers (including SMEs), and industrial 
customers. In addition to these groups, Sampo Group 
can have an impact on potential customers and end-
users of insurance policies, who themselves are not 
Sampo Group’s customers (e.g. beneficiaries). When 
assessing material impacts on consumers and end-
users, Sampo Group aims to consider all types of 
customers who may face material impacts from the 
company’s own operations or value chain. 
Sampo Group does not offer products or services that 
are inherently harmful to consumers’ or end-users’ 
health, safety, or freedom of expression. Instead, Sampo 
Group has an actual positive impact on consumers’ and 
end-users’ health and safety, for example by providing 
insurance products and services, thus helping 
customers in loss prevention, risk management, and in 
case of a claim. 
Sampo Group’s sales and marketing practices can have 
a potential negative impact on consumers and end-
users, for example, through inaccessibility of products 
and services, or if the needs of underserved groups are 
not fulfilled in a satisfactory manner. As an insurance 
provider, there is also a potential for Sampo Group to 
be associated with discrimination due to risk 
assessments that can in certain cases (e.g. due to legal 
restrictions) exclude customers from accessing 
insurance protection. For example, certain insurances 
may not be available to customers with specific risk 
profiles, or are only available with higher premiums.
As an insurance company, Sampo Group is required to 
handle large amounts of customers' personal data, and 
Sampo Group can, therefore, have a negative impact on 
consumers and end-users also through data privacy, 
information security, and cybersecurity. The privacy of 
customers can be jeopardised if Sampo Group’s data 
privacy and information security measures are breached 
(e.g. as a result of a cyber attack). Due to digitalisation 
and AI, for instance, the risk of information security and 
cybersecurity attacks can increase, leading to a higher 
amount of potential negative impacts.
When offering insurance to consumers who can be 
more vulnerable to health, privacy, or accessibility 
impacts (e.g. elderly people, people with disabilities, 
people lacking financial literacy) and to beneficiaries 
who themselves are not Sampo Group’s customers (e.g. 
children), it is especially important that Sampo Group 
offers these consumers and end-users accurate and 
accessible information about their insurance policies 
and coverage. To increase understanding about which 
stakeholders, including consumers and end-users, are 
particularly at risk of being harmed by negative human 
rights impacts, Sampo Group has conducted a human 
rights impact assessment. In addition, Sampo Group’s 
stakeholder dialogue and customer feedback channels 
serve as a way to engage with affected consumers and 
end-users and understand potential human rights risks.
Risks and risk management are inherent elements of 
insurance companies’ business activities and operating 
environment. At Sampo Group, the balance between 
risks, capital, and earnings requires that risks affecting 
profitability, as well as other material risks, are 
identified, assessed, and analysed. This means that 
underwriting risks are priced reflecting their inherent 
risk levels based on each individual customer’s specific 
risk profile, which may, for instance, increase the 
potential negative impact on consumers and end-users 
through sales and marketing practices. 
Impact, risk and opportunity 
management
Policies related to consumers and end-users
Sampo Group has several policies to manage its 
material impacts, risks, and opportunities related to 
consumers and end-users. These are, for example, 
Sampo Group’s Code of Conduct, Data Privacy 
Statement, and Information Security Principles. The 
policies are all reviewed annually, approved by Sampo’s 
Board of Directors, and available on Sampo’s website. In 
addition, each Group company has supplementary and 
more detailed policies (e.g. underwriting principles. 
distribution policies, data privacy statements), 
guidelines, and processes (e.g. due diligence) for their 
own purposes. The ultimate responsibility for the 
implementation of the group level principles and 
company-specific policies lies with the management of 
each individual Sampo Group company. To ensure 
compliance with laws, regulations, and internal policies, 
Sampo Group has training programmes which guide 
personal conduct and increase the competence of 
employees.
The Sampo Group Code of Conduct states that the 
Group complies with the International Bill of Human 
Rights, including the Universal Declaration of Human 
Rights and the two covenants, the Core Conventions of 
the International Labour Organization (ILO), the OECD 
Guidelines for Multinational Enterprises, and the UN 
Global Compact. The Code of Conduct also describes 
that Sampo Group is committed to the obligations 
related to human rights and the continuous 
development of related practices (e.g. human rights 
impact assessments, human rights due diligence 
processes). Sampo Group’s due diligence processes 
cover both the Group’s own operations and its value 
chain, including consumers and end-users. 
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 108

===== SIDA 109 =====

The Code of Conduct applies to all companies 
belonging to Sampo Group and it is each employee’s 
responsibility to comply with its contents. The Code of 
Conduct obligates employees to ensure that human 
rights are respected and upheld through all operations, 
including the downstream value chain.
Sampo Group communicates on the topics covered by 
the Code of Conduct to its consumers and end-users, 
for example, through company websites, sustainability 
reporting, and other customer communication 
materials. The engagement with stakeholders is 
described in more detail under the heading Interests 
and views of stakeholders (p. 64).
Sampo Group has not been made aware of any severe 
legal cases of non-adherence to global standards 
related to consumers and end-users in its downstream 
value chain during the reporting year.
Customer health and safety and Sales and marketing 
practices
The Sampo Group Code of Conduct sets the group level 
requirements for products and services (i.e. customer 
health and safety) at Sampo Group. The Code of 
Conduct states that Sampo Group strives to act in the 
best interest of its customers, offering products and 
services that customers need and want. The products 
and services should be fair, comprehensible, and 
designed to help meet the evolving needs of all 
customers. In addition, ESG considerations, including 
climate change, are to be taken into account in 
insurance underwriting. 
The Code of Conduct specifies that Sampo Group’s 
sales, marketing, and product information must be 
professional, comprehensive, accurate, balanced, and 
never misleading. Sampo Group takes appropriate care 
to ensure that customers are given transparent and 
easily accessible and understandable information about 
the costs, risks, and conditions relating to the product 
or service in question, as well as the reasons leading to 
a decision regarding an insurance application, where 
applicable. In addition, at Sampo Group all customers 
are to be treated fairly and no individual customer is 
given preferential treatment at the expense of other 
customers. Insurance premiums are only based on 
relevant data and not on discriminating factors.
Sampo Group has controls in place to ensure that the 
information provided to customers is accessible, 
relevant, and timely before a customer commits to any 
purchase, and that the company satisfies all regulatory 
and conduct obligations. Sampo Group aims to clearly 
inform customers of their complaint options, as well as 
to ensure a fair and transparent complaint process. 
Possible measures to provide remedy to consumers and 
end-users depend on the nature of the impact. Sampo 
Group takes action on a case-by-case basis and 
according to established internal processes. When 
evaluating the effectiveness of mitigation approaches, 
Sampo Group also uses information obtained through 
stakeholder dialogue. 
Data privacy, information security, and cybersecurity
Sampo Group’s policies on data privacy, information 
security, and cybersecurity lay out how Sampo Group is 
committed to processing personal data in a lawful, fair, 
and transparent manner, while respecting human rights 
in all aspects of data management. The policies 
highlight how Sampo Group protects information and 
upholds cybersecurity. These policies also state that 
high levels of data privacy, information security, and 
cybersecurity are top priorities for Sampo Group. 
Processes for engaging with consumers and 
end-users about impacts
Sampo Group has customer experience programmes 
(or similar) which are spread across the organisations 
and the different customer touchpoints. The 
programmes enable the Group to both collect customer 
data and monitor the related results. Sampo Group 
engages with consumers and end-users at several 
stages during the customer journey, such as before, 
during, and after a customer transaction. Customers are, 
for example, offered the possibility to leave feedback on 
the customer journey or based on a certain transaction.
Customer feedback is collected daily, weekly, or 
monthly depending on the situation. Feedback is 
reviewed and any questions or comments are followed 
up with the customer where relevant. Customer 
feedback is collected, for example, by phone, email, 
SMS, or chat. The operational responsibility for 
engagement with consumers and end-users lies with 
the top management of the Sampo Group companies.
Sampo Group gains insight into the effectiveness of its 
engagement through multiple channels, such as 
customer satisfaction surveys (e.g. NPS, EPSI, 
Trustpilot) and customer contact points (e.g. email, 
phone, chat, meetings). Feedback can reduce the risk of 
the customer leaving, and it is also used to find areas of 
improvement, for example regarding service, products, 
processes, and systems. In addition, the Customer 
Ombudsman engages with customers who have a 
complaint, and may, based on the engagement, suggest 
changes to, for example, the customer handling 
processes, claims procedures, or product terms and 
conditions. 
Sampo Group has collected the perspectives of 
affected consumers and end-users, for example, 
through the Group’s human rights impact assessment. 
The assessment included an analysis of Sampo Group’s 
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 109

===== SIDA 110 =====

existing data and the use of credible proxies as a part of 
the desktop research. Impacts on vulnerable groups 
were also considered in the assessment.
As stated in the Sampo Group Code of Conduct, 
insurance premiums are only based on relevant data 
and not on discriminating factors, such as sexual 
orientation, religious belief, or ethnic background. 
Sampo Group expects its suppliers to uphold the same 
standards in their own operations.
When a customer or insured is not able to manage their 
own interests due to, for example, age, sickness, injury, 
or disability, Sampo Group ensures in accordance with 
local regulatory requirements that there is a trustee or 
guardian that can take care of their interests. Sampo 
Group also has instructions and guidelines on how to 
engage with customers in vulnerable situations (e.g. 
managing serious incidents with a caring attitude, 
ensuring privacy when communicating with customers 
with hearing disabilities, handling indemnities to an 
insured under guardianship).
Processes to remediate negative impacts 
and channels for consumers and end-users to 
raise concerns
Sampo Group offers multiple channels for customers to 
raise concerns or needs. Customers can be directly in 
contact with the company through, for example, 
customer service (e.g. phone, website, app, chat) and 
customer surveys. Indirect contact with the company is 
possible through the Customer Ombudsman, 
whistleblowing channels, and external complaints 
boards. The whistleblowing channels are either 
internally or externally managed, depending on the 
Group company. Sampo Group encourages its 
suppliers, for example, through supplier codes of 
conduct and contract discussions, to provide similar 
platforms for customers to raise concerns. Some of 
Sampo Group’s reporting channels, such as 
whistleblowing channels, are also available for the 
consumers and end-users of suppliers and business 
partners.
Sampo Group monitors and measures customer 
satisfaction continuously. Both positive and negative 
feedback is carefully analysed and used to further 
develop products and services and improve the 
customer experience. Quality assurance based on 
customer feedback is also important. Sampo Group 
follows the customer journey to find the root causes of 
the feedback, and to restore the customer relationship, 
if needed. The insight gained is utilised in training and in 
improving processes and the overall customer journey.
By encouraging dialogue, Sampo Group can identify 
and address any dissatisfaction among consumers and 
end-users. To foster transparency and build trust, 
Sampo Group has a list of its most material and publicly 
available principles and policies on its website. 
Furthermore, Sampo Group upholds non-retaliation 
policies to safeguard individuals who come forward 
with concerns, ensuring they can do so without fear of 
reprisal. The mechanisms to ensure that users can trust 
the whistleblowing channels to raise concerns and are 
protected from retaliation are described in the section 
Business conduct (p. 116).
Sampo Group has several processes for providing 
remedy or contributing to remedy, depending on the 
situation in question. In case of a customer complaint 
related to the sales and marketing of products and 
services, the priority is to discuss with the customer to 
find a solution that is satisfactory to both parties. If a 
consensus cannot be reached, the customer is entitled 
to appeal to external complaints boards (or similar), in 
accordance with local practices in each Sampo Group 
country. In addition, as required by law, certain Sampo 
Group companies have internal customer representative 
functions that the customer can contact to submit a 
complaint. Regardless of the outcome of appeal cases, 
Sampo Group always analyses how it can improve its 
practices.
Sampo Group has procedures for investigating 
breaches and processes for corrective actions to 
protect the personal data of consumers and end users. 
Data privacy and information security incidents are 
analysed and handled according to fixed processes, and 
they are assessed and reported in a timely manner to 
the local authorities, when applicable. If the risk to 
consumers and end users is considered high, they are 
notified of the incident. 
Sampo Group evaluates the effectiveness of the 
remedies it provides to ensure that any negative 
impacts on consumers and end-users are addressed 
when needed. This is achieved through systematic 
follow-up procedures that include monitoring customer 
satisfaction post-resolution, analysing patterns in 
complaints and resolutions, and conducting reviews of 
remediation processes to identify areas for 
improvement. Sampo Group also follows up on every 
data privacy or information security incident to assess 
how similar incidents can be avoided in the future to 
ensure the rights and freedoms of data subjects.
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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===== SIDA 111 =====

Taking action on material impacts on 
consumers and end-users, and approaches to 
managing material risks and pursuing 
material opportunities related to consumers 
and end-users, and effectiveness of those 
actions
Sampo Group adheres to the Code of Conduct and 
supplementary policies to prevent irresponsible sales 
and marketing practices, ensuring that all customer 
communication is clear, relevant, and timely. Sampo 
Group regularly assesses the products for 
appropriateness and compliance with regulatory 
obligations, supported by continuous training 
programmes that enhance the conduct and 
competence of customer-facing teams. Sampo Group 
actively collects customer feedback, and has 
transparent complaint processes in place, with options 
for review through external complaints boards.
Sampo Group allocates resources across product and 
service development, IT, and risk management, among 
other things, to further improve its sales and marketing 
practices, as well as its customers’ privacy, health, and 
safety. Sampo Group also collaborates with authorities 
and regulators and works with relevant networks (e.g. 
related to customer experience, cybersecurity, and data 
security), industry associations (e.g. Finance Finland, 
Insurance Sweden, Finance Norway, Insurance and 
Pension Denmark, Association of British Insurers), and 
forums for knowledge sharing. These collaborations 
provide Sampo Group a possibility to share knowledge 
and experiences regarding topics such as climate 
change adaptation, loss prevention, risk management, 
health, and safety.
Sampo Group ensures effective complaints handling 
and remediation processes for any material negative 
impacts on customers by closely monitoring customer 
feedback, results of the customer satisfaction surveys, 
and cases raised with external complaints boards. When 
a negative impact originates from the Group’s actions, 
appropriate remedies are based on the nature of the 
breach. In instances where customers are negatively 
impacted, Sampo Group has established incident 
management processes to oversee and ensure that 
remediation activities are both appropriate to the 
situation and executed as effectively as possible. 
Governance frameworks, including product reviews and 
customer forums, facilitate proactive identification of 
systemic risks.
No severe human rights issues or incidents connected 
to Sampo Group’s consumers or end-users were 
reported to the Group during the reporting year.
Customer health and safety and Sales and marketing 
practices 
During 2024, Sampo Group continued to provide loss 
prevention services to consumers and end-users. The 
main purpose of loss prevention is to prevent damage 
from occurring, but it also increases safety and reduces 
risk and economic cost, as well as environmental 
impact, as reduced damage means less need for repairs 
and rebuilding. During the year, Sampo Group focused 
on communicating easy-to-understand advice on loss 
prevention to customers using press releases, content 
marketing activities, social media, and websites. In 
addition, If, together with its partners, offered house 
assessments to private customers and building checks 
for SMEs that own residential buildings in certain 
markets. The house assessments provide the customer 
with a report that helps them to both plan the 
maintenance of the property and minimise the risk of 
unpleasant surprises. The building checks and the 
hands-on advice to larger customers within the SME 
segment, whom If often meets face-to-face, help 
customers to identify where maintenance and fire 
safety measures are most needed. They also make 
customers aware of risks and provide suggestions for 
mitigating actions.
Continuously improving the quality of its services in 
both digital and analogue channels is important to 
Sampo Group. During 2024, the Group aimed to 
enhance the way customers communicate with the 
company through various initiatives. This included, 
among other things, further development of digital 
platforms and testing of new communication channels. 
Additionally, understanding customer experiences 
through different channels remained one of Sampo 
Group’s focus areas, as it enables identification of 
opportunities for enhancements to customer journeys 
and customer satisfaction. 
A part of Sampo Group’s responsible sales and 
marketing practices is quality policies and processes, 
and therefore, the Group conducted annual policy 
reviews during the year. For example, Topdanmark 
implemented the guidelines on green marketing from 
the Danish Consumer Ombudsman. As a result, a key 
action was to update business processes and policies 
on communication on environmental initiatives, 
products, and services to ensure compliance with 
legislation. In addition, Sampo Group continued to 
proactively contact customers to ensure that they are 
correctly insured. 
Data privacy, information security, and cybersecurity
During 2024, Sampo Group took a series of measures to 
bolster data protection and ensure compliance with 
industry standards and regulations. This included, for 
example, raising awareness within the organisation 
about the importance of data privacy, information 
security, and cybersecurity, and providing training to 
employees on the latest developments, new laws, and 
regulations (e.g. Digital Operational Resilience Act 
DORA).
Sampo Group regularly updates its policies, guidelines, 
and training materials to stay current with the evolving 
landscape of data privacy, information security, 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
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===== SIDA 112 =====

cybersecurity. During 2024, this continued through 
annual policy reviews conducted across the Group. 
Sampo Group, for example, updated privacy notices 
and ethical guidelines (or similar) to ensure artificial 
intelligence (AI) is used responsibly, with a particular 
focus on data security in automated and machine 
learning processes. During the year, all employees of If 
were instructed on the use of AI tools, for instance.
In 2024, Sampo Group monitored the processing of 
personal data to ensure it is carried out transparently 
and with respect for individuals’ privacy. The key 
actions were the performance of data protection impact 
assessments and records of processing activities before 
new processing activities were initiated, as well as when 
changes to existing processing activities were planned. 
To ensure compliance with the regulation, Sampo 
Group reviewed all new systems and applications from 
a privacy perspective.
In 2024, If conducted a larger internal monitoring 
activity to ensure that it accommodates all data subject 
access requests according to the requirements of the 
General Data Protection Regulation (GDPR). The 
company continued the implementation of technical 
measures to better ensure the security of personal data 
in the context of electronic communication with 
customers. In addition, If initiated several actions to 
enable better control for customers in relation to their 
personal data. In 2024, If also established a Data 
Governance Committee to promote clear 
responsibilities and improved guidelines for how data 
can be used.
Sampo Group has several actions planned for 2025 
regarding data privacy, information security, and 
cybersecurity, some of them already underway. Due to 
the Topdanmark transaction, one key action is to 
integrate relevant activities with If in a way that ensures 
continued compliance with data privacy and 
information security regulations and mitigates the 
potential risks for consumers and end-users. There are 
also other actions planned for 2025 to improve and 
strengthen the protection of personal data. These 
actions address, for example, unstructured data, access 
logging, privacy by design and default, as well as data 
ownership structure and governance.
Metrics and targets
Targets related to managing material 
negative impacts, advancing positive 
impacts, and managing material risks and 
opportunities
Customer health and safety and Sales and marketing 
practices 
In accordance with the Sampo Group Code of Conduct, 
Sampo Group strives to act in the best interests of its 
customers. This means that the aim is to provide 
products and services that are fair, comprehensible, and 
designed to help meet the evolving needs of customers.
Sampo Group uses the Net Promoter Score (NPS) to 
measure customer satisfaction, which allows the Group 
to advance positive impacts on consumers and end-
users. Using NPS also supports monitoring of potential 
negative impacts and risks and acting on them. The NPS 
is an index ranging from -100 to 100 that measures the 
willingness of customers to recommend a company’s 
products or services to others. It is used as a proxy for 
measuring the customer’s overall satisfaction with a 
company’s product or service, and the customer’s 
loyalty to the brand. Transactional Net Promoter Score 
(tNPS) is an overall metric that assesses the customer’s 
opinion on a certain business transaction and captures a 
wide range of customer experiences related to, for 
example, price, product, billing, brand, and marketing. 
The tNPS score shows whether customers want to 
recommend the company to others after they have 
been in contact with the company. It is calculated as the 
net result of the share of promoters (who replied 9–10) 
minus the share of detractors (who replied 0–6) on the 
question of to what extent they would recommend the 
company to others.
Sampo Group has set time-bound and outcome-
oriented targets for customer satisfaction. The targets 
are specific to each individual Sampo Group company, 
and their scope differs between the Group companies 
due to company-specific characteristics (e.g. size, 
structure, operating countries). External stakeholders 
have not been directly involved in target setting. 
However, consumers and end-users have been 
indirectly involved, as customer-facing organisational 
units have been included in the target setting. The 
targets are presented in the table Customer satisfaction 
(tNPS) (p. 114). 
Sampo Group actively monitors and analyses the tNPS, 
and the results are regularly reported to the respective 
top managements and internal committees to assess 
overall performance. Sampo Group tracks the tNPS 
performance internally on a monthly basis and has set 
targets to ensure continuous improvement. Sampo 
Group also publishes the results and targets externally 
on a quarterly basis. Through systematic measurement 
of customer satisfaction, Sampo Group wants to both 
identify the factors that are valued by the company’s 
customers and recognise the parts of the customer 
journey that should be improved. In addition to 
improving the customer experience in general, the 
results are used in training as well as in developing 
products, services, and customer-related processes. 
Additionally, Sampo Group collects feedback through 
various channels, including customer complaints and 
customer satisfaction surveys. The feedback not only 
contributes to tNPS but also provides deeper insights 
into the customer experience, enabling Sampo Group to 
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===== SIDA 113 =====

address concerns proactively. Sampo Group is 
committed to actively addressing customer feedback, 
and low tNPS scores prompt engagement with 
customers to resolve their issues and inform service 
enhancements. Examples of improvements made based 
on customer feedback include clarifying terms and 
conditions and enhancing customer communications. 
These processes ensure consistent elevation of service 
quality and customer satisfaction.
The NPS methodology can have its limitations, such as 
oversimplification of customer sentiment, and a lack of 
detailed feedback on specific areas for improvement. 
However, follow-up with individual customers can 
provide a deeper insight into areas of potential 
development. The measurement of customer 
satisfaction is not validated by an external body other 
than the assurance provider of this Sustainability 
Statement. 
In 2024, If’s customer satisfaction remained high, but 
the tNPS result for Business area Private was somewhat 
below the previous year. Topdanmark’s customer 
satisfaction improved in digital channels in 2024. 
However, the results related to the phone channel 
decreased slightly. Hastings exceeded its tNPS target in 
2024. The underlying claims journey tNPS stabilised and 
results related to retail journeys continued to improve.
Data privacy, information security, and cybersecurity
The goal of Sampo Group’s data privacy operations is 
to protect the employees’, customers’, and other 
stakeholders’ personal data. In addition, information 
security and cybersecurity measures ensure protection 
of all types and forms of information according to its 
sensitivity and importance to Sampo Group, and in 
compliance with applicable rules and regulations. The 
key metrics used are the number of complaints from 
data subjects and data protection authorities (DPAs), 
data privacy incidents reported to local data protection 
authorities, and information security and cybersecurity 
incidents reported to the authorities within the 
reporting year.
Complaints from data subjects are based on Sampo 
Group’s internal systems that capture complaints. 
Generally, Sampo Group’s Data Protection Officers 
(DPOs) receive complaints from both customers and 
DPAs. Complaints can be received via different 
channels (e.g. email, phone, post/letter) depending on 
the Group company and local legislation in question. If a 
data subject has contacted the local data protection 
authorities directly, the complaint is forwarded to 
Sampo Group. 
Sampo Group’s DPOs (or similar) assess whether 
internally reported data privacy incidents require 
external reporting to local DPAs. The types of incidents 
that are deemed reportable are based on legislation 
(e.g. the GDPR). According to the GDPR, a personal 
data breach is a breach of security leading to the 
accidental or unlawful destruction, loss, alteration, 
unauthorised disclosure of, or access to, personal data 
transmitted, stored or otherwise processed. However, 
there are regional differences in which data privacy 
incidents are required to be reported to the local DPAs 
based on their individual guidance. In 2024, the majority 
of Sampo Group’s incidents were reported in the UK.
Information security and cybersecurity incidents are 
monitored internally at Sampo Group on a subsidiary 
level. Reporting on severe cases to the authorities is 
based on local legislation and is the responsibility of 
legal or information security units (or similar).
The measurement of the number of complaints from 
data subjects and data protection authorities, data 
privacy incidents reported to local data protection 
authorities, and information security and cybersecurity 
incidents reported to the authorities are not validated 
by an external body other than the assurance provider 
of this Sustainability Statement.
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===== SIDA 114 =====

Customer satisfaction (tNPS)
Sampo Group
Metric Target 2024
If (business area Private) 2024: 60 57
Topdanmark
2025: 60
2027: 70 57
Hastings 2024: 50 56
Complaints from data subjects and data protection authorities
Sampo Group 
Metric 2024
Complaints from data subjects 135
Complaints from data protection authorities 3
Data privacy incidents reported to local data protection 
authorities
Sampo Group 
Metric 2024
Data privacy incidents reported to local data protection authorities 414
Information security and cybersecurity incidents reported to the 
authorities
Sampo Group
Metric 2024
Information security and cybersecurity incidents reported to the 
authorities 0
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===== SIDA 115 =====

Governance information
Business conduct
Topic Impacts Risks and opportunities Strategy and actions
Corruption and 
bribery
↓  S a m p o  G r o u p  c a n  h a v e  p o t e n t i a l  n e g a t i v e  i m p a c t  o n  
society, as financial institutions tend to be favoured 
channels for financial crime, corruption, and bribery, 
for example, through customer support functions, 
investments, suppliers, or business partners.
Time-horizon: short to medium term
↓  S a m p o  G r o u p  c a n  f a c e  r e p u t a t i o n a l  r i s k s ,  l e g a l  r i s k s ,  
business risks, and potential costs if it fails to combat 
financial crime, corruption, or bribery in all their forms.
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. codes of 
conduct, responsible investment policies)
• Effective governance structures and processes (e.g. 
general risk management measures, screening of 
direct investments and corporate customers against 
international norms and standards, encouraging 
sustainability in supply chains, reporting channels)
• Training and competence development programmes
• Metrics and targets (e.g. reported incidents)
Responsible 
business 
practices
↑  A c t u a l  p o s i t i v e  i m p a c t  c a n  o c c u r  t h r o u g h  q u a l i t y  r i s k  
management, which is at the core of Sampo Group’s 
business operations. Risk management ensures that 
Sampo Group can provide safety and financial 
security to its customers, investors, and society in 
general.
↑  E m p h a s i s i n g  s u s t a i n a b i l i t y  a n d  r e s p o n s i b l e  b u s i n e s s  
practices in strategy and business operations may 
result in positive impacts across Sampo Group’s value 
chain.
↓  S a m p o  G r o u p  c a n  h a v e  p o t e n t i a l  n e g a t i v e  i m p a c t  o n  
suppliers and business partners if it fails to manage its 
supplier relationships according to agreed terms and 
conditions (e.g. delays in payments).
Time-horizon: short to medium term
↓  F o r  a n  i n s u r a n c e  c o m p a n y  l i k e  S a m p o  G r o u p ,  
responsible business practices and quality risk 
management (e.g. adequate management and control 
systems, internal standards and processes) are at the 
core of the business. However, due to the size of the 
company and its value chain, it is not possible to 
completely remove the risk for potential negative 
impacts (e.g. risk of non-compliance due to increasing 
regulation or human error).
↓  I f  s u s t a i n a b i l i t y  i s  n o t  a n  i n t e g r a t e d  p a r t  o f  g o v e r n a n c e  
and business management, it can cause a financial risk 
for Sampo Group due to possible legislative 
consequences (e.g. fines) and reputational damage, for 
example. 
↑  T h e r e  m i g h t  b 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 in the medium term, as ESG integration helps in 
preparing for future regulation and the sustainable 
development of society (e.g. green transformation), for 
instance.
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. risk 
management principles, compliance principles, 
codes of conduct)
• Effective governance structures and processes (e.g. 
Sampo Group steering framework, risk management 
governance framework, regulated risk management 
measures, sustainability reporting and governance 
structure)
• Training and competence development programmes
The table presents Sampo Group’s material impacts, risks, and opportunities related to business conduct 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 Corruption and bribery is related to the ESRS sub-topic with the same name. The topic Responsible business practices is related to the ESRS 
sub-topics Corporate culture, protection of whistle-blowers, and Management of relationships with suppliers including payment practices.
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===== SIDA 116 =====

Impact, risk, and opportunity 
management
Business conduct policies and corporate 
culture
Sampo Group’s policy regarding business conduct and 
corporate culture is the Sampo Group Code of Conduct, 
which is reviewed annually and approved by Sampo’s 
Board of Directors. The Code states that Sampo Group 
complies with applicable legislation and the rules and 
regulations of competent authorities in all its activities. 
In addition to the Group’s Code of Conduct, each 
Sampo Group company has its own supplementary 
policies, guidelines, and processes (e.g. HR policies, 
underwriting policies, responsible investment policies, 
supplier codes of conduct). Sampo Group is also a 
participant in the UN Global Compact supporting its 
principles on human rights, labour rights, the 
environment, and anti-corruption.
The Sampo Group Code of Conduct applies to all 
companies belonging to Sampo Group. The Group 
companies offer regular training (e.g. e-learning, 
workshops) to all employees on the topics covered by 
the Code and are committed to communicating the 
topics to their employees (e.g. policy updates on the 
intranet). The frequency of the training varies from 
annual to biennial depending on the Group company 
and the topic in question.
Whistleblowing channels
Sampo Group has whistleblowing channels through 
which employees and relevant interest groups can 
report anonymously if they have reasonable grounds to 
suspect that somebody employed by Sampo Group has 
breached the Sampo Group Code of Conduct, 
legislation, regulations, or other rules that are relevant 
to the insurance industry. Material whistleblowing 
notifications reported through the whistleblowing 
channels are reported to the parent company, Sampo, 
as a part of regular compliance and sustainability 
reporting to ensure group level monitoring of these 
matters.
In addition to the whistleblowing channels, Sampo 
Group encourages its employees to report grievances 
related to unethical practices, as well as possible 
violations of laws, regulations, or internal policies 
through other internal reporting channels. Grievances 
can also be reported directly to a leader, HR, or 
compliance units, for example.
Sampo Group has defined structures for processing 
whistleblowing notifications. The company ensures that 
the outcomes and remedies related to whistleblowing 
systems accord with internationally recognised human 
rights. 
Information about the whistleblowing channels and 
other internal reporting channels is proactively 
communicated to employees through the intranet, for 
example. Sampo Group also offers training to its own 
employees, including information about the designation 
and training of those reviewing the reports. The 
employees designated with this task receive training 
when they are appointed to the position (e.g. 
onboarding, on-the-job training). Maintaining objectivity 
is essential for the employees handling the reports. 
Sampo Group ensures that those handling the reports 
are separate from those whom the report concerns, and 
the investigators or investigating committees are 
separate from the chain of management involved in the 
matter.
All whistleblowing reports are investigated promptly 
and in a confidential manner, while always protecting 
the identity of the whistleblower. Sampo Group 
prohibits any form of retaliation (e.g. physical, 
psychological, economic) against an employee who in 
good faith raises a concern about suspected or actual 
misconduct through any reporting channel, or who 
cooperates in an investigation of misconduct.
Management of relationships with suppliers
Sampo Group complies with applicable local legislation 
and regulations in its payment practices. In addition, 
Sampo Group has internal guidelines in place (e.g. 
accounting instructions, claims guidelines) to ensure 
timely payment. Automated systems and digital 
invoicing help in preventing late payments.
Sampo Group is a major procurer of goods and 
services, especially in claims handling and, therefore, 
has an impact on the economy, environment, and 
people. In addition, Sampo Group emphasises 
sustainability factors when working with suppliers, as 
sustainability issues can carry reputational and 
operational risks if not managed correctly.
The Sampo Group Code of Conduct provides the group 
level guiding principles for sustainable supply chain 
management. According to the Code of Conduct, 
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.
Environmental and social considerations are integral to 
Sampo Group’s supplier selection process. In addition to 
the Group’s Code of Conduct, each Sampo Group 
company has its own supplementary policies (e.g. 
supplier codes of conduct), guidelines, and processes 
(e.g. risk assessments) that guide supplier selection. 
Topics covered in these policies include, for example, 
human rights, labor rights, environmental 
considerations, and anti-corruption.
Sampo Group is committed to encouraging and 
supporting the company’s suppliers in their efforts to 
use more sustainable methods in their operations. By 
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===== SIDA 117 =====

actively requesting innovative solutions, resource 
efficiency, transparency, and responsibility from 
suppliers, Sampo Group aims to minimise its negative 
impact and stimulate sustainable production and 
consumption. Set requirements, in combination with 
close cooperation with suppliers, enable Sampo Group 
to develop its business while also contributing to 
sustainable development.
Prevention and detection of corruption and 
bribery
Sampo Group can be exposed to corruption and bribery 
especially through its customer support functions (e.g. 
sales, claims handling), investments, as well as suppliers 
and business partners (e.g. procurement, claims 
handling, IT). Customer support functions are at risk of 
corruption, for example due to financial transactions 
and handling of personal data. Investment operations 
can be vulnerable, for example, due to exposure to 
industries and markets with varying levels of corruption 
risk. Suppliers and business partners may face risks 
associated with the dependency on third-party 
partnerships and intricate procurement operations.
Allegations or incidents of corruption and bribery are 
generally detected through reporting channels (e.g. 
whistleblowing channels), screening of customers and 
direct investments, and supplier selection and risk 
assessment processes. The risks are mitigated by 
internal control systems. This includes commitments to 
international initiatives (e.g. the UN Global Compact), 
policies and guidelines (e.g. codes of conduct, 
investment policies), employee training, and other 
manual and automatic control activities. 
The Sampo Group Code of Conduct sets the overall 
guiding principles on working against corruption and 
bribery within Sampo Group. In addition, each Group 
company has adopted supplementary policies and 
guidelines for its own purposes. These annually updated 
guidance documents contain, for example, rules on 
gifts, participation in events, and hospitality, as well as 
information on expectations regarding employees, and 
roles and responsibilities.
The managing director of each company in Sampo 
Group has the ultimate responsibility to ensure that 
sufficient resources are allocated to the prevention of 
corruption and bribery. Each Group company organises 
duties and takes other necessary and appropriate 
measures to comply with the applicable local rules and 
various sanctions regimes, which may be imposed by 
the UN and/or the EU.
Reporting on anti-corruption and anti-bribery activities, 
as well as on potential incidents, is organised in a 
manner that ensures that the management and the 
boards of directors of relevant Group companies 
receive all material information without undue delay, 
and that Sampo’s Risk Management organisation is 
informed of all relevant incidents. 
The number of whistleblowing notifications reported 
through the whistleblowing channels is reported to the 
parent company, Sampo, as part of regular compliance 
reporting. Sampo’s Risk Management organisation is 
responsible for overseeing the reporting of relevant 
incidents to Sampo’s Audit Committee and the Board of 
Directors.
Sampo Group provides training (e.g. e-learning, during 
contract discussions) on business conduct matters to 
ensure that employees, suppliers, and other business 
partners have sufficient knowledge. Related and 
relevant policies are available for all Group employees 
via intranet and for other stakeholders on the Group 
companies’ websites.
All Sampo Group employees and top management (e.g. 
CEOs) are offered training (e.g. e-learning) on anti-
corruption and anti-bribery at least biennially. Hence, 
also all employees who work in the functions most at 
risk for negative impacts (e.g. customer support 
functions, investment management, and supply chain 
management) receive training on the topic. Anti-
corruption and anti-bribery are part of training 
programmes covering business ethics and conduct. In 
addition, employees are informed, for example, on the 
intranet, when related policies have been revised.
In 2024, Sampo Group reviewed its policies and training 
material related to corruption and bribery. In addition to 
annual policy updates, Sampo Group initiated projects 
and raised awareness regarding the topic using several 
methods. For example, If initiated an internal company-
wide project to work against organised crime, while 
Hastings supplemented its existing mandatory training 
on corruption and bribery by introducing a new video 
series on recognising fraudulent activity and hosted a 
Fraud Awareness Week for employees. In the future, 
Sampo Group will continue its various activities and 
training programmes, which include training on anti-
money laundering, anti-bribery, anti-corruption, and 
anti-fraud.
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===== SIDA 118 =====

Metrics and targets
Incidents of corruption or bribery
In 2024, Sampo Group was not convicted for incidents 
of corruption or bribery and, therefore, did not pay any 
related fines. For the same reason, Sampo Group did 
not need to take specific actions related to breaches in 
procedures and standards of anti-corruption and anti-
bribery. In 2024, there were no public legal cases 
regarding corruption or bribery brought against Sampo 
Group either.
Incidents of corruption and bribery included in the 
reporting are confirmed incidents that the Group 
companies report to Sampo as part of regular 
sustainability and compliance and/or risk reporting. The 
Group companies receive this information through their 
established reporting channels, such as whistleblowing 
channels. The measurements related to corruption and 
bribery are not validated by an external body other than 
the assurance provider of this Sustainability Statement.
Incidents of corruption or bribery
Sampo Group
Metric 2024
Confirmed incidents of corruption or bribery 0
Confirmed incidents in which own workers 
were dismissed or disciplined for corruption 
or bribery-related incidents 0
Payment practices
Due to the complexity of Sampo Group’s payment 
systems, the diversity of its supplier base, and 
confidentiality considerations, Sampo Group is currently 
unable to provide a specific average time for invoice 
payments and information on its standard payment 
terms on a group level. However, Sampo Group is 
committed to fair and responsible payment practices 
and is actively working to improve related reporting.
Sampo Group’s payment terms are influenced by 
various factors, including the nature of the supplier 
relationship, the country or geographical region of 
operation, and market standards. Sampo Group 
recognises the importance of timely payments to its 
suppliers and aims to ensure that its payment practices 
are transparent and equitable across the company’s 
supply chain. Insurance companies tend to have a good 
liquidity position as insurance payments provide cash 
flow. As at 31 December 2024, Sampo Group was not 
party to any legal proceedings due to late payments.
During 2024, Sampo Group started to investigate 
reporting related to payment practices. The plan is to 
develop reporting in accordance with the ESRS 
guidance in the coming years. 
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Annexes
Annex 1: ESRS content index
Disclosure requirement Location
ESRS 2 General disclosures
BP-1 – General basis for preparation of the sustainability statement p. 56
BP-2 – Disclosures in relation to specific circumstances p. 56
GOV-1 – The role of the administrative, management and supervisory 
bodies p. 56
GOV-2 – Information provided to and sustainability matters addressed by 
the undertaking’s administrative, management and supervisory bodies p. 58
GOV-3 – Integration of sustainability-related performance in incentive 
schemes p. 59
GOV-4 – Statement on due diligence p. 59
GOV-5 – Risk management and internal controls over sustainability 
reporting p. 61
SBM-1 – Strategy, business model and value chain p. 61
SBM-2 – Interests and views of stakeholders p. 64
SBM-3 – Material impacts, risks, and opportunities and their interaction 
with strategy and business model p. 66
IRO-1 – Description of the processes to identify and assess material 
impacts, risks, and opportunities p. 68
IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s 
sustainability statement p. 70
ESRS E1 Climate change
E1-1 – Transition plan for climate change mitigation p. 79
E1-2 – Policies related to climate change mitigation and adaptation p. 80
E1-3 – Actions and resources in relation to climate change policies p. 80
E1-4 – Targets related to climate change mitigation and adaptation p. 82
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions p. 84
ESRS E5 Resource use and circular economy
E5-1 – Policies related to resource use and circular economy p. 88
E5-2 – Actions and resources related to resource use and circular 
economy p. 88
E5-3 – Targets related to resource use and circular economy p. 89
Disclosure requirement Location
ESRS S1 Own workforce
S1-1 – Policies related to own workforce p. 91
S1-2 – Processes for engaging with own workers and workers’ 
representatives about impacts p. 92
S1-3 – Processes to remediate negative impacts and channels for own 
workers to raise concerns p. 93
S1-4 – 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 p. 93
S1-5 – Targets related to managing material negative impacts, advancing 
positive impacts, and managing material risks and opportunities p. 95
S1-6 – Characteristics of the undertaking’s employees p. 96
S1-7 – Characteristics of non-employee workers in the undertaking’s own 
workforce p. 98
S1-8 – Collective bargaining coverage and social dialogue p. 98
S1-9 – Diversity metrics p. 99
S1-10 – Adequate wages p. 99
S1-11 – Social protection p. 99
S1-12– Persons with disabilities p. 99
S1-13 – Training and skills development metrics p. 100
S1-14 – Health and safety metrics p. 100
S1-15 – Work-life balance metrics p. 100
S1-16 – Remuneration metrics (pay gap and total remuneration) p. 101
S1-17 – Incidents, complaints and severe human rights impacts p. 101
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Disclosure requirement Location
ESRS S2 Workers in the value chain
S2-1 – Policies related to value chain workers p. 103
S2-2 – Processes for engaging with value chain workers about impacts p. 104
S2-3 – Processes to remediate negative impacts and channels for value 
chain workers to raise concerns p. 105
S2-4 – 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 p. 105
S2-5 – Targets related to managing material negative impacts, advancing 
positive impacts, and managing material risks and opportunities p. 106
ESRS S4 Consumers and end-users
S4-1 – Policies related to consumers and end-users p. 108
S4-2 – Processes for engaging with consumers and end-users about 
impacts p. 109
S4-3 – Processes to remediate negative impacts and channels for 
consumers and end-users to raise concerns p. 110
S4-4 – Taking action on material impacts on consumers and end-users, 
and approaches to managing material risks and pursuing material 
opportunities related to consumers and end-users, and effectiveness of 
those actions p. 111
S4-5 – Targets related to managing material negative impacts, advancing 
positive impacts, and managing material risks and opportunities p. 112
ESRS G1 Business conduct
G1-1 – Business conduct policies and corporate culture p. 116
G1-2 – Management of relationships with suppliers p. 116
G1-3 – Prevention and detection of corruption and bribery p. 117
G1-4 – Incidents of corruption or bribery p. 118
G1-6 – Payment practices p. 118
   
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Annex 2: Data points deriving from other EU legislation
Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS 2 GOV-1 Board's gender diversity 
paragraph 21 (d)
Indicator number 13 of Table 
#1 of Annex 1
Commission Delegated 
Regulation (EU) 2020/1816, 
Annex II
p. 56
ESRS 2 GOV-1 Percentage of board members 
who are independent paragraph 21 (e)
Delegated Regulation (EU) 
2020/1816, Annex II
p. 56
ESRS 2 GOV-4 Statement on due diligence 
paragraph 30
Indicator number 10 Table #3 
of Annex 1
p. 59
ESRS 2 SBM-1 Involvement in activities related 
to fossil fuel activities paragraph 40 (d) i
Indicators number 4 Table #1 
of Annex 1
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Table 1: 
Qualitative information on 
Environmental risk and Table 
2: Qualitative information on 
Social risk
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS 2 SBM-1 Involvement in activities related 
to chemical production paragraph 40 (d) ii
Indicator number 9 Table #2 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS 2 SBM-1 Involvement in activities related 
to controversial weapons paragraph 40 (d) iii
Indicator number 14 Table #1 
of Annex 1
Delegated Regulation (EU) 
2020/1818, Article 12(1) 
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS 2 SBM-1 Involvement in activities related 
to cultivation and production of tobacco 
paragraph 40 (d) iv
Delegated Regulation (EU) 
2020/1818, Article 12(1) 
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS E1-1 Transition plan to reach climate 
neutrality by 2050 paragraph 14
Regulation (EU) 2021/1119, 
Article 2(1)
p. 79
ESRS E1-1 Undertakings excluded from Paris-
aligned Benchmarks paragraph 16 (g)
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 1: 
Banking book – Climate 
Change transition risk: Credit 
quality of exposures by 
sector, emissions and 
residual maturity
Delegated Regulation (EU) 
2020/1818, Article 12.1 (d) to 
(g), and Article 12.2
p. 79
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BOARD OF DIRECTORS’ REPORT 2024 121

===== SIDA 122 =====

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS E1-4 GHG emission reduction targets 
paragraph 34
Indicator number 4 Table #2 
of Annex 1
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 3: 
Banking book – Climate 
change transition risk: 
alignment metrics
Delegated Regulation (EU) 
2020/1818, Article 6
p. 82
ESRS E1-5 Energy consumption from fossil 
sources disaggregated by sources (only high 
climate impact sectors) paragraph 38
Indicator number 5 Table #1 
and Indicator no. 5 Table #2 
of Annex 1
Not material
ESRS E1-5 Energy consumption and mix 
paragraph 37
Indicator number 5 Table #1 
of Annex 1
Not material
ESRS E1-5 Energy intensity associated with 
activities in high climate impact sectors 
paragraphs 40 to 43
Indicator number 6 Table #1 
of Annex 1
Not material
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG 
emissions paragraph 44
Indicators number 1 and 2 
Table #1 of Annex 1
Article 449a; Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 1: 
Banking book – Climate 
change transition risk: Credit 
quality of exposures by 
sector, emissions and 
residual maturity
Delegated Regulation (EU) 
2020/1818, Article 5(1), 6 and 
8(1)
p. 84
ESRS E1-6 Gross GHG emissions intensity 
paragraphs 53 to 55
Indicators number 3 Table #1 
of Annex 1
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 3: 
Banking book – Climate 
change transition risk: 
alignment metrics
Delegated Regulation (EU) 
2020/1818, Article 8(1)
p. 83
ESRS E1-7 GHG removals and carbon credits 
paragraph 56
Regulation (EU) 2021/1119, 
Article 2(1)
Not material
ESRS E1-9 Exposure of the benchmark 
portfolio to climate-related physical risks 
paragraph 66
Delegated Regulation (EU) 
2020/1818, Annex II 
Delegated Regulation (EU) 
2020/1816, Annex II
Phased-in
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BOARD OF DIRECTORS’ REPORT 2024 122

===== SIDA 123 =====

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS E1-9 Disaggregation of monetary 
amounts by acute and chronic physical risk 
paragraph 66 (a)
ESRS E1-9 Location of significant assets at 
material physical risk paragraph 66 (c)
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 paragraphs 
46 and 47; Template 5: 
Banking book – Climate 
change physical risk: 
Exposures subject to 
physical risk
Phased-in
ESRS E1-9 Breakdown of the carrying value of 
its real estate assets by energy-efficiency 
classes paragraph 67 (c).
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 paragraph 
34;Template 2:Banking book 
-Climate change transition 
risk: Loans collateralised by 
immovable property – 
Energy efficiency of the 
collateral
Phased-in
ESRS E1-9 Degree of exposure of the portfolio 
to climate-related opportunities paragraph 69
Delegated Regulation (EU) 
2020/1818, Annex II
Phased-in
ESRS E2-4 Amount of each pollutant listed in 
Annex II of the E-PRTR Regulation (European 
Pollutant Release and Transfer Register) 
emitted to air, water and soil, paragraph 28
Indicator number 8 Table #1 
of Annex 1, Indicator number 
2 Table #2 of Annex 1, 
Indicator number 1 Table #2 
of Annex 1, Indicator number 
3 Table #2 of Annex 1
Not material
ESRS E3-1 Water and marine resources 
paragraph 9
Indicator number 7 Table #2 
of Annex 1
Not material
ESRS E3-1 Dedicated policy paragraph 13 Indicator number 8 Table # 2 
of Annex 1
Not material
ESRS E3-1 Sustainable oceans and seas 
paragraph 14
Indicator number 12 Table #2 
of Annex 1
Not material
ESRS E3-4 Total water recycled and reused 
paragraph 28 (c)
Indicator number 6.2 Table 
#2 of Annex 1
Not material
ESRS E3-4 Total water consumption in m³ per 
net revenue on own operations paragraph 29
Indicator number 6.1 Table 
#2 of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (a) i Indicator number 7 Table #1 
of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (b) Indicator number 10 Table #2 
of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (c) Indicator number 14 Table #2 
of Annex 1
Not material
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BOARD OF DIRECTORS’ REPORT 2024 123

===== SIDA 124 =====

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS E4-2 Sustainable land / agriculture 
practices or policies paragraph 24 (b)
Indicator number 11 Table #2 
of Annex 1
Not material
ESRS E4-2 Sustainable oceans / seas 
practices or policies paragraph 24 (c)
Indicator number 12 Table #2 
of Annex 1
Not material
ESRS E4-2 Policies to address deforestation 
paragraph 24 (d)
Indicator number 15 Table #2 
of Annex 1
Not material
ESRS E5-5 Non-recycled waste paragraph 37 
(d)
Indicator number 13 Table #2 
of Annex 1
Not material
ESRS E5-5 Hazardous waste and radioactive 
waste paragraph 39
Indicator number 9 Table #1 
of Annex 1
Not material
ESRS 2 – SBM-3 - S1 Risk of incidents of 
forced labour paragraph 14 (f)
Indicator number 13 Table #3 
of Annex I
Not material
ESRS 2 – SBM-3 - S1 Risk of incidents of child 
labour paragraph 14 (g) 
Indicator number 12 Table #3 
of Annex I
Not material
ESRS S1-1 Human rights policy commitments 
paragraph 20
Indicator number 9 Table #3 
and Indicator number 11 
Table #1 of Annex I
p. 91
ESRS S1-1 Due diligence policies on issues 
addressed by the fundamental International 
Labor Organisation Conventions 1 to 8, 
paragraph 21
Delegated Regulation (EU) 
2020/1816, Annex II
p. 91
ESRS S1-1 processes and measures for 
preventing trafficking in human beings 
paragraph 22
Indicator number 11 Table #3 
of Annex I
p. 91
ESRS S1-1 workplace accident prevention 
policy or management system paragraph 23
Indicator number 1 Table #3 
of Annex I
p. 91
ESRS S1-3 grievance/complaints handling 
mechanisms paragraph 32 (c)
Indicator number 5 Table #3 
of Annex I
p. 93
ESRS S1-14 Number of fatalities and number 
and rate of work-related accidents paragraph 
88 (b) and (c)
Indicator number 2 Table #3 
of Annex I
Delegated Regulation (EU) 
2020/1816, Annex II
p. 100
ESRS S1-14 Number of days lost to injuries, 
accidents, fatalities or illness paragraph 88 (e)
Indicator number 3 Table #3 
of Annex I
Phased-in
ESRS S1-16 Unadjusted gender pay gap 
paragraph 97 (a)
Indicator number 12 Table #1 
of Annex I
Delegated Regulation (EU) 
2020/1816, Annex II
p. 101
ESRS S1-16 Excessive CEO pay ratio 
paragraph 97 (b)
Indicator number 8 Table #3 
of Annex I
p. 101
ESRS S1-17 Incidents of discrimination 
paragraph 103 (a)
Indicator number 7 Table #3 
of Annex I
p. 101
ESRS S1-17 Non-respect of UNGPs on Business 
and Human Rights and OECD paragraph 104 
(a)
Indicator number 10 Table #1 
and Indicator no. 14 Table #3 
of Annex I
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818 Art 12 (1)
p. 101
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BOARD OF DIRECTORS’ REPORT 2024 124

===== SIDA 125 =====

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS 2 – SBM-3 – S2 Significant risk of child 
labour or forced labour in the value chain 
paragraph 11 (b)
Indicators number 12 and 13 
Table #3 of Annex I
p. 103
ESRS S2-1 Human rights policy commitments 
paragraph 17
Indicator number 9 Table #3 
and Indicator no. 11 Table #1 
of Annex 1
p. 103
ESRS S2-1 Policies related to value chain 
workers paragraph 18
Indicator number 11 and 4 
Table #3 of Annex 1
p. 103
SRS S2-1 Non-respect of UNGPs on Business 
and Human Rights principles and OECD 
guidelines paragraph 19
Indicator number 10 Table #1 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818, Art 12 (1)
p. 103
ESRS S2-1 Due diligence policies on issues 
addressed by the fundamental International 
Labor Organisation Conventions 1 to 8, 
paragraph 19
Delegated Regulation (EU) 
2020/1816, Annex II
p. 103
ESRS S2-4 Human rights issues and incidents 
connected to its upstream and downstream 
value chain paragraph 36
Indicator number 14 Table #3 
of Annex 1
p. 105
ESRS S3-1 Human rights policy commitments 
paragraph 16
Indicator number 9 Table #3 
of Annex 1 and Indicator 
number 11 Table #1 of Annex 1
Not material
ESRS S3-1 Non-respect of UNGPs on Business 
and Human Rights, ILO principles or and 
OECD guidelines paragraph 17
Indicator number 10 Table #1 
Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818, Art 12 (1)
Not material
ESRS S3-4 Human rights issues and incidents 
paragraph 36
Indicator number 14 Table #3 
of Annex 1
Not material
ESRS S4-1 Policies related to consumers and 
end-users paragraph 16
Indicator number 9 Table #3 
and Indicator number 11 
Table #1 of Annex 1
p. 108
ESRS S4-1 Non-respect of UNGPs on Business 
and Human Rights and OECD guidelines 
paragraph 17
Indicator number 10 Table #1 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818, Art 12 (1)
p. 108
ESRS S4-4 Human rights issues and incidents 
paragraph 35
Indicator number 14 Table #3 
of Annex 1
p. 111
ESRS G1-1 United Nations Convention against 
Corruption paragraph 10 (b)
Indicator number 15 Table #3 
of Annex 1
p. 116
ESRS G1-1 Protection of whistle-blowers 
paragraph 10 (d)
Indicator number 6 Table #3 
of Annex 1
p. 116
ESRS G1-4 Fines for violation of anti-
corruption and anti-bribery laws paragraph 24 
(a)
Indicator number 17 Table #3 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II)
p. 118
ESRS G1-4 Standards of anti-corruption and 
anti-bribery paragraph 24 (b)
Indicator number 16 Table #3 
of Annex 1
p. 118
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BOARD OF DIRECTORS’ REPORT 2024 125

===== SIDA 126 =====

Annex 3: Reporting requirements related to the Delegated Regulation (EU) 2022/1214
Template 1 Nuclear and fossil gas related activities
Row Nuclear energy related activities
1.
The undertaking carries out, funds or has exposures to research, development, 
demonstration and deployment of innovative electricity generation facilities that 
produce energy from nuclear processes with minimal waste from the fuel cycle.  YES 
2.
The undertaking carries out, funds or has exposures to construction and safe operation 
of new nuclear installations to produce electricity or process heat, including for the 
purposes of district heating or industrial processes such as hydrogen production, as 
well as their safety upgrades, using best available technologies.  YES 
3.
The undertaking carries out, funds or has exposures to safe operation of existing 
nuclear installations that produce electricity or process heat, including for the 
purposes of district heating or industrial processes such as hydrogen production from 
nuclear energy, as well as their safety upgrades.  YES 
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of 
electricity generation facilities that produce electricity using fossil gaseous fuels.  YES 
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, 
and operation of combined heat/cool and power generation facilities using fossil 
gaseous fuels.  YES 
6.
The undertaking carries out, funds or has exposures to construction, refurbishment 
and operation of heat generation facilities that produce heat/cool using fossil gaseous 
fuels.  YES 
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BOARD OF DIRECTORS’ REPORT 2024 126

===== SIDA 127 =====

Template 2 Taxonomy-aligned economic activities (denominator)
Based on turnover
EURm
Row Economic activities
Amount and proportion
CCM + CCA
Climate change 
mitigation (CCM)
Climate change 
adaptation (CCA)
Amount % Amount % Amount %
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI —  —% —  —% —  —% 
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 4  0.0% 4  0.0% —  —% 
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI —  —% —  —% —  —% 
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
7.
Amount and proportion of other taxonomy-aligned economic activities not referred 
to in rows 1 to 6 above in the denominator of the applicable KPI 121  0.6% 121  0.6% 0  0.0% 
8. Total applicable KPI 125  0.6% 125  0.6% 0  0.0% 
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BOARD OF DIRECTORS’ REPORT 2024 127

===== SIDA 128 =====

Template 2 Taxonomy-aligned economic activities (denominator)
Based on CapEX
EURm
Row Economic activities
Amount and proportion
CCM + CCA
Climate change 
mitigation (CCM)
Climate change 
adaptation (CCA)
Amount % Amount % Amount %
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI —  —% —  —% —  —% 
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 1  0.0% 1  0.0% —  —% 
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
7.
Amount and proportion of other taxonomy-aligned economic activities not referred 
to in rows 1 to 6 above in the denominator of the applicable KPI 196  1.0% 195  1.0% 1  0.0% 
8. Total applicable KPI 196  1.0% 195  1.0% 1  0.0% 
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BOARD OF DIRECTORS’ REPORT 2024 128

===== SIDA 129 =====

Template 3 Taxonomy-aligned economic activities (numerator)
Based on turnover
EURm
Row Economic activities
Amount and proportion
CCM + CCA
Climate change 
mitigation (CCM)
Climate change 
adaptation (CCA)
Amount % Amount % Amount %
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI —  —% —  —% —  —% 
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 0  0.3% 0  0.3% —  —% 
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 4  3.1% 4  3.1% —  —% 
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI —  —% —  —% —  —% 
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
7.
Amount and proportion of other taxonomy-aligned economic activities not referred 
to in rows 1 to 6 above in the numerator of the applicable KPI 121  92.2% 121  92.0% 0  0.3% 
8.
Total amount and proportion of taxonomy-aligned economic activities in the 
numerator of the applicable KPI 125  95.6% 125  95.3% 0  0.3% 
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===== SIDA 130 =====

Template 3 Taxonomy-aligned economic activities (numerator)
Based on CapEX
EURm
Row Economic activities
Amount and proportion
CCM + CCA
Climate change 
mitigation (CCM)
Climate change 
adaptation (CCA)
Amount % Amount % Amount %
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI —  —% —  —% —  —% 
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 1  0.3% 1  0.3% —  —% 
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section 
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the 
applicable KPI 0  0.0% 0  0.0% —  —% 
7.
Amount and proportion of other taxonomy-aligned economic activities not referred 
to in rows 1 to 6 above in the numerator of the applicable KPI 196  97.2% 195  96.7% 1  0.5% 
8.
Total amount and proportion of taxonomy-aligned economic activities in the 
numerator of the applicable KPI 196  97.6% 195  97.1% 1  0.5% 
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===== SIDA 131 =====

Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
Based on turnover
EURm
Row Economic activities
Amount and proportion
CCM + CCA
Climate change 
mitigation (CCM)
Climate change 
adaptation (CCA)
Amount % Amount % Amount %
1.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI —  —% —  —% —  —% 
2.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 0  0.0% 0  0.0% —  —% 
3.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 0  0.0% 0  0.0% —  —% 
4.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 1  0.0% 1  0.0% —  —% 
5.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 1  0.0% 1  0.0% —  —% 
6.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 0  0.0% 0  0.0% —  —% 
7.
Amount and proportion of other taxonomy-eligible but not taxonomy-aligned 
economic activities not referred to in rows 1 to 6 above in the denominator of the 
applicable KPI 480  2.4% 470  2.4% 10  0.0% 
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned 
economic activities in the denominator of the applicable KPI 483  2.4% 473  2.4% 10  0.0% 
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===== SIDA 132 =====

Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
Based on CapEX
EURm
Row Economic activities
Amount and proportion
CCM + CCA
Climate change 
mitigation (CCM)
Climate change 
adaptation (CCA)
Amount % Amount % Amount %
1.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI —  —% —  —% —  —% 
2.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI —  —% —  —% —  —% 
3.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 0  0.0% 0  0.0% —  —% 
4.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 1  0.0% 1  0.0% 0  0.0% 
5.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 1  0.0% 1  0.0% —  —% 
6.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic 
activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 
2021/2139 in the denominator of the applicable KPI 0  0.0% 0  0.0% —  —% 
7.
Amount and proportion of other taxonomy-eligible but not taxonomy-aligned 
economic activities not referred to in rows 1 to 6 above in the denominator of the 
applicable KPI 610  3.1% 577  2.9% 34  0.2% 
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned 
economic activities in the denominator of the applicable KPI 613  3.1% 579  2.9% 34  0.2% 
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BOARD OF DIRECTORS’ REPORT 2024 132

===== SIDA 133 =====

Template 5 Taxonomy non-eligible economic activities
Based on turnover
EURm
Row Economic activities Amount %
1.
Amount and proportion of economic activity referred to 
in row 1 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.26 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI —  —% 
2.
Amount and proportion of economic activity referred to 
in row 2 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.27 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI 7  0.0% 
3.
Amount and proportion of economic activity referred to 
in row 3 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.28 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI 0  0.0% 
4.
Amount and proportion of economic activity referred to 
in row 4 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.29 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI —  —% 
5.
Amount and proportion of economic activity referred to 
in row 5 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.30 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI —  —% 
6.
Amount and proportion of economic activity referred to 
in row 6 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.31 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI —  —% 
7.
Amount and proportion of other taxonomy-non-eligible 
economic activities not referred to in rows 1 to 6 above 
in the denominator of the applicable KPI 19,151  96.2% 
8.
Total amount and proportion of taxonomy-non-eligible 
economic activities in the denominator of the applicable 
KPI 19,158  96.3% 
Template 5 Taxonomy non-eligible economic activities
Based on CapEX
EURm
Row Economic activities Amount %
1.
Amount and proportion of economic activity referred to 
in row 1 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.26 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI —  —% 
2.
Amount and proportion of economic activity referred to 
in row 2 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.27 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI 0  0.0% 
3.
Amount and proportion of economic activity referred to 
in row 3 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.28 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI 0  0.0% 
4.
Amount and proportion of economic activity referred to 
in row 4 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.29 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI —  —% 
5.
Amount and proportion of economic activity referred to 
in row 5 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.30 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI 0  0.0% 
6.
Amount and proportion of economic activity referred to 
in row 6 of Template 1 that is taxonomy-non-eligible in 
accordance with Section 4.31 of Annexes I and II to 
Delegated Regulation 2021/2139 in the denominator of 
the applicable KPI —  —% 
7.
Amount and proportion of other taxonomy-non-eligible 
economic activities not referred to in rows 1 to 6 above 
in the denominator of the applicable KPI 18,987  95.4% 
8.
Total amount and proportion of taxonomy-non-eligible 
economic activities in the denominator of the applicable 
KPI 18,987  95.4% 
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BOARD OF DIRECTORS’ REPORT 2024 133

===== SIDA 134 =====

Key figures
Financial highlights 2024 2023
2022 
(restated)
2022 
(published) 2021 2020
Group
Gross written premiums & brokerage income EURm  9,931  8,870  8,375  —  —  — 
Insurance revenue, net EURm  8,249  7,412  7,168  —  —  — 
Insurance service result, net EURm  1,394  1,193  1,062  —  —  — 
Underwriting result EURm  1,316  1,164  1,031  1,314  1,282  967 
Net financial result EURm  636  560  1,056  —  —  — 
Profit before taxes (P&C operations) EURm  1,559  1,481  1,924  1,863  3,171  380 
Net profit for the equity holders EURm  1,154  1,323  2,107  1,427  2,567  37 
Operating result EURm  1,193  1,046  —  —  —  — 
Combined ratio %  84.3  84.6  85.8  82.1  81.4  83.4 
Undiscounted underlying combined ratio, current year, % %  85.5  87.1  —  —  —  — 
Solvency ratio1 3 %  177  182  210  210  185  176 
Financial leverage %  26.9  25.3  24.4  25.6  23.8  28.6 
Return on own funds %  21.3  18.1  —  —  —  — 
Return on equity own funds %  29.5  24.7  —  —  —  — 
Return on equity %  16.1  15.6  4.2  -1.3  26.8  3.1 
Average number of staff  14,280  13,935  13,550  13,550  13,274  13,227 
If 2024 2023
2022 
(restated)
2022 
(published) 2021 2020
Gross written premiums EURm  5,860  5,468  5,432  —  —  — 
Insurance revenue, net EURm  5,258  4,996  5,024  —  —  — 
Insurance service result/underwriting result EURm  890  842  673  985  891  801 
Net financial result EURm  464  539  888  —  —  — 
Premiums written before reinsurers' share (IFRS 4) EURm  —  —  —  5,432  5,134  4,823 
Premiums earned (IFRS 4) EURm  —  —  —  5,002  4,772  4,484 
Profit before taxes EURm  1,256  1,358  1,550  1,217  1,077  901 
Combined ratio %  83.1  83.1  86.6  80.3  81.3  82.1 
Cost ratio %  20.9  21.2  21.6  21.1  21.4  21.5 
Risk ratio %  62.1  61.9  65.0  59.2  59.9  60.7 
Adjusted risk ratio, current year, %5 %  61.5  61.3  62.3  —  —  — 
Undiscounted adjusted risk ratio, current year, %6 %  64.4  64.7  65.2  —  —  — 
Loss ratio %  67.6  67.6  70.7  64.9  65.5  66.4 
Expense ratio %  15.5  15.6  15.9  15.4  15.8  15.8 
Average number of staff  8,070  7,858  7,496  7,496  7,223  7,182 
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BOARD OF DIRECTORS’ REPORT 2024 134

===== SIDA 135 =====

Topdanmark 2024 2023
2022 
(restated)
2022 
(published) 2021 2020
Gross written premiums EURm  1,553  1,339  1,308  —  —  — 
Insurance revenue, net EURm  1,470  1,288  1,255  —  —  — 
Insurance service result/underwriting result EURm  233  194  230  224  227  182 
Net financial result EURm  60  27  -28  —  —  — 
Premiums written before reinsurers' share, P&C insurance (IFRS 4) EURm  —  —  —  1,391  1,383  1,315 
Premiums earned, P&C insurance (IFRS 4) EURm  —  —  —  1,326  1,285  1,227 
Profit before taxes EURm  137  162  158  220  346  167 
Combined ratio %  84.2  85.0  81.7  83.1  82.3  85.2 
Loss ratio %  66.0  66.9  64.4  66.8  66.7  69.0 
Expense ratio %  18.1  18.1  17.2  16.3  15.6  16.2 
Average number of staff  2,412  2,160  2,381  2,381  2,395  2,428 
Hastings 2024 2023
2022 
(restated)
2022 
(published) 2021 2020
GWP & brokerage income EURm  2,565  2,063  1,636  —  —  — 
Insurance revenue, net EURm  1,522  1,128  889  —  —  — 
Insurance service result, net EURm  268  157  159  —  —  — 
Underwriting result EURm  190  128  128  104  164  — 
Net financial result EURm  41  44  27  —  —  — 
Premiums written before reinsurers' share (IFRS 4) EURm  —  —  —  1,313  1,127  103 
Net premiums written (IFRS 4) EURm  —  —  —  727  495  137 
Premiums earned (IFRS 4) EURm  —  —  —  594  499  63 
Profit before taxes EURm  193  129  107  73  127  -16 
Operating ratio % 88.5 89.8  87.2  89.7  80.3  — 
Loss ratio % 61.6 63.3  57.2  83.7  62.2  — 
Average number of staff  3,736  3,200  3,021  3,021  3,005  2,974 
Holding 2024 2023
2022 
(restated)
2022 
(published) 2021 2020
Profit before taxes EURm  -29  -160  146  146  1,331  -826 
Average number of staff  61  54  50  50  63  67 
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BOARD OF DIRECTORS’ REPORT 2024 135

===== SIDA 136 =====

Per share key figures 2024 2023
2022 
(restated)
2022 
(published) 2021 2020
Earnings per share EUR  2.25  2.62  3.97  2.69  4.63  0.07 
Earnings per share, continuing operations2 EUR  2.25  2.12  2.88  —  —  — 
Earning per share, discontinuing operations EUR  —  0.50  1.09  —  —  — 
Operational result per share EUR  2.33  2.07  —  —  —  — 
Equity per share EUR  13.11  14.47  18.70  17.44  23.39  20.56 
Net asset value per share EUR  13.11  15.30  20.01  18.74  25.48  19.82 
Market capitalisation4 EURm  21,196  19,876  25,112  25,112  24,093  19,199 
Dividend per share EUR 1.70 1.80  2.60  2.60  4.10  1.70 
Dividend payout ratio %  75.5  68.8  65.4  96.7  88.6  78.7 
Effective dividend yield %  4.3  4.5  5.3  5.3  9.3  4.9 
Price/earnings ratio 17.5 15.1  12.3  18.1  9.5  16.0 
Number of shares at 31 Dec. 1,000 538,248 501,797 514,369 514,369 546,812 555,352
Average number of shares 1,000 512,114 505,939 530,296 530,296 554,317 555,352
Weighted average number of shares 1,000 512,114 505,939 530,296 530,296 554,317 555,352
A shares 2024 2023 2022 2022 2021 2020
Number of shares at 31 Dec. 1,000 538,048 501,597 514,169 514,169 545,612 554,152
Average  number of shares 1,000 511,914 505,739 530,096 530,096 553,117 554,152
Weighted average number of shares 1,000 511,914 505,739 530,096 530,096 553,117 554,152
Weighted average share price EUR 40.11 39.36 44.25 44.25 40.50 32.35
Adjusted share price, high4 EUR 42.37 45.21 49.97 49.97 47.33 42.46
Adjusted share price, low4 EUR 37.38 34.53 35.85 35.85 33.82 21.34
Adjusted closing price EUR 39.38 39.61 48.82 48.82 44.06 34.57
Share trading volume during the financial year 1,000 178,910 178,801 257,879 257,879 243,763 376,964
Relative share trading volume %  34.9  35.4  48.6  48.6  44.1  68.0 
B shares 2024 2023 2022 2022 2021 2020
Number of shares at 31 Dec. 1,000 200 200 200 200 1,200 1,200
Average number of shares 1,000 200 200 200 200 1,200 1,200
1 The Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC).
2 Earnings per share on continuing operations for comparative period 2022 includes the divested operations i.e. Topdanmark Life operations.
3 The solvency ratio for 2023 is pro forma figure excluding the effect of Saxo Bank on the Group SCR. 
4 Share prices have been adjusted to reflect the separation of Mandatum Group in the partial demerger. 
5 Adjusted risk ratio illustrates the underlying underwriting performance as it excludes certain volatile effects such as large and severe weather and prior year development on risk ratio.
6Undiscounted adjusted risk ratio excludes the effect from current year discounting on adjusted risk ratio and illustrates the underlying current year underwriting performance. 
The number of shares used at the reporting date was 538,247,772 and the average number during the financial period  512,114,448.
In calculating the key figures the tax corresponding to the result for the accounting period has been taken into account. 
In the net asset value per share, the Group valuation difference on the listed subsidiary Topdanmark has been taken into account in the comparison year. At the end of the financial year 2024, Topdanmark 
was no longer a listed company
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BOARD OF DIRECTORS’ REPORT 2024 136

===== SIDA 137 =====

Calculation of key figures
The key figures have been calculated in accordance with the decree issued by the Ministry of Finance and the specifying regulations and instructions of the Financial Supervisory 
Authority. The Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC) and Insurance Companies Act (521/2008).
Additional information on the Group’s alternative performance measures is on the Group’s website www.sampo.com.
Return on equity, %
+ total comprehensive income attributable to owners of the parent x 100%+ total equity attributable to owners of the parent
(average of values 1 Jan. and the end of reporting period)
Return on equity own funds, %
+ operating result (annualised) x 100 %+ Unrestricted Tier 1 Own funds
(average of values 1 Jan. and the end of reporting period)
Return on own funds, %
+ operating result (annualised) x 100 %+ SII own funds
(average of values 1 Jan. and the end of reporting period)
Equity/assets ratio, %
+ total equity attributable to owners of the parent x 100%+ balance sheet total
Financial leverage1
financial debt x 100%equity + financial debt
1The Group’s financial leverage includes only long-term funding.
Insurance revenue, net
+ insurance revenue, gross
- reinsurers' share of insurance revenue
- quota share premium expense (Hastings)
insurance revenue, net
Underwriting result
+ insurance revenue, net
+ other income (Hastings)
- claims incurred
- operating expenses
underwriting result
Operating result
+ P&C operations’ (incl. Sampo plc) profit after tax
- non-controlling interest in P&C operations
- unrealised gains/losses on investments (excl. derivatives) in P&C 
operations- result effect from changes in discount rates in P&C operations
- non-operational amortisations in P&C operations
- non-recurring items
- adjustment on taxes
operating result
Combined ratio for P&C insurance, %
+ claims incurred
+ operating expenses x 100%+ insurance revenue, net
+ other revenue (Hastings)
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BOARD OF DIRECTORS’ REPORT 2024 137

===== SIDA 138 =====

Risk ratio for P&C insurance, %
+ claims incurred
– claims settlement expenses x 100%insurance revenue, net
Cost ratio for P&C insurance, %
+ operating expenses
+ claims settlement expenses x 100%insurance revenue, net
Loss ratio for P&C insurance, %
+ claims incurred x 100%insurance revenue, net
Expense ratio for P&C insurance, %
+ operating expenses x 100%insurance revenue, net
Operating ratio for Hastings, %
+ claims incurred
+ acquisition costs
+ other operating expenses
+ operational depreciation and amortisation x 100%+ insurance revenue, net
+ other revenue
Per share key figures
Earnings per share
profit for the financial period attributable to owners of the parent
adjusted average number of shares
Operating result per share
operating result
adjusted average number of shares
Equity per share
equity attributable to owners of the parent
adjusted number of shares at the balance sheet date
Net asset value per share
+ equity attributable to owners of the parent
± valuation differences on listed Group companies
adjusted number of shares at balance sheet date
Market capitalisation
number of shares at the balance sheet date x closing share price at the 
balance sheet date
Dividend payout ratio
Dividend per share x 100%Earnings per share
Effective dividend yield
Dividend per share x 100%Adjusted closing price
Price/earnings ratio
Adjusted closing price
Earnings per share
Relative share trading volume
Share trading volume during the financial year x 100%Average number of A shares
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BOARD OF DIRECTORS’ REPORT 2024 138

===== SIDA 139 =====

Exchange rates used in reporting
1–12/2024 1–9/2024 1–6/2024 1–3/2024 1–12/2023
EURSEK
Income statement (average) 11.4345 11.4143 11.3945 11.2814 11.4745
Balance sheet (at end of period) 11.4590 11.3000 11.3595 11.5250 11.0960
DKKSEK
Income statement (average) 1.5327 1.5300 1.5274 1.5127 1.5406
Balance sheet (at end of period) 1.5365 1.5156 1.5232 1.5453 1.4888
NOKSEK
Income statement (average) 0.9831 0.9850 0.9912 0.9880 1.0048
Balance sheet (at end of period) 0.9715 0.9605 0.9968 0.9851 0.9871
EURDKK
Income statement (average) 7.4589 7.4589 7.4579 7.4562 7.4510
Balance sheet (at end of period) 7.4578 7.4560 7.4575 7.4580 7.4529
EURGBP
Income statement (average) 0.8467 0.8514 0.8547 0.8563 0.8697
Balance sheet (at end of period) 0.8292 0.8354 0.8464 0.8551 0.8691
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BOARD OF DIRECTORS’ REPORT 2024 139

===== SIDA 140 =====

Group’s IFRS Financial Statements
Statement of profit and other 
comprehensive income     .......................................... 141
Consolidated balance sheet   ................................. 142
Statement of changes in equity    .......................... 143
Statement of cash flows     ........................................ 144
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FINANCIAL STATEMENTS 2024 140

===== SIDA 141 =====

Statement of profit and other comprehensive income
EURm Note 1-12/2024 1-12/2023
Insurance revenue  9,450  8,417 
Insurance service expenses  -7,684  -7,076 
Reinsurance result  -372  -148 
Insurance service result 1  1,394  1,193 
Net investment income 2  888  1,006 
Net finance income or expense from insurance 
contracts 3  -252  -446 
Insurance finance income or expense, gross  -309  -529 
Insurance finance income or expense, reinsurance  57  83 
Net financial result  636  560 
Other income 4  312  277 
Other expenses 5  -685  -457 
Finance expenses 7  -103  -93 
Share of associates' profit or loss  6  1 
Profit before taxes  1,559  1,481 
Income taxes 15,16  -330  -339 
Profit from the continuing operations  1,229  1,142 
Discontinued operations, net of tax 30  —  251 
Divested operations, net of tax  -26  — 
Net profit  1,203  1,393 
EURm Note 1-12/2024 1-12/2023
Other comprehensive income 8
Items reclassifiable to profit or loss
Exchange differences  -4  -1 
Cash flow hedges  1  -1 
Total items reclassifiable to profit or loss, net of tax  -3  -3 
Items not reclassifiable to profit or loss
Actuarial gains and losses from defined pension plans  0  -6 
Taxes  0  1 
Total items not reclassifiable to profit or loss, net of 
tax  0  -5 
Other comprehensive income total, net of tax  -3  -8 
Total comprehensive income  1,200  1,386 
Profit attributable to
Owners of the parent  1,154  1,323 
Non-controlling interests  50  70 
Total comprehensive income attributable to
Owners of the parent  1,151  1,316 
Non-controlling interests  50  70 
Earnings per share (EPS), EUR  2.25  2.62 
Earnings per share, continuing operations, EUR  2.25  2.12 
In the comparative year, Mandatum segment is presented in a single line as discontinued 
operations. For further information, please see note 30. 
	
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FINANCIAL STATEMENTS 2024 141

===== SIDA 142 =====

Consolidated balance sheet
EURm Note 12/2024 12/2023
Assets
Property, plant and equipment 10  284  318 
Intangible assets 11  3,637  3,637 
Investments in associates  4  12 
Financial assets 12,13,14  16,090  15,757 
Deferred income tax 15  2  3 
Reinsurance contract assets 19  2,618  2,282 
Other assets 17  880  800 
Cash and cash equivalents  962  1,415 
Total assets  24,478  24,225 
Liabilities
Insurance contract liabilities 18,19,20,21  12,286  11,716 
Subordinated debts 22  1,642  1,645 
Other financial liabilities 22  1,395  1,269 
Deferred income tax 15  535  567 
Other liabilities 23  1,562  1,342 
Total liabilities  17,419  16,538 
Equity 25
Share capital  98  98 
Reserves  3,531  1,530 
Retained earnings  4,176  6,378 
Other components of equity  -746  -743 
Equity attributable to owners of the parent  7,059  7,263 
Non-controlling interests  —  424 
Total equity  7,059  7,687 
Total equity and liabilities  24,478  24,225 
	
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FINANCIAL STATEMENTS 2024 142

===== SIDA 143 =====

Statement of changes in equity
EURm
Share 
capital
Legal 
reserve
Invested 
unres-
tricted 
equity
Transla-tion 
of foreign 
opera-tions
Available- 
for-sale 
financial 
assets
Cash flow 
hedges Total
Non- 
control-ling 
interest Total
Equity at 31 December 2022 (IFRS 17)  98  4  1,527  8,482  -741  248  0  9,618  560  10,178 
Impact of IFRS 9 transition 1 January 2023  —  —  —  248  —  -248  —  —  —  — 
Equity at 1 January 2023  98  4  1,527  8,730  -741  —  0  9,618  560  10,178 
Changes in equity
Acquired non-controlling interests  —  —  —  -11  —  —  —  -11  -3  -14 
Dividends 3  —  —  —  -1,321  —  —  —  -1,321  -187  -1,508 
Transferred assets at fair value in the demerger  —  —  —  -1,835  —  —  —  -1,835  —  -1,835 
Acquisition of own shares  —  —  —  -555  —  —  —  -555  —  -555 
Other changes in equity  —  —  —  51  —  —  —  51  -15  36 
Profit for the reporting period  —  —  —  1,323  —  —  —  1,323  70  1,393 
Other comprehensive income for the period  —  —  —  -5  -1  —  -1  -8  —  -8 
Total comprehensive income  —  —  —  1,318  -1  —  -1  1,316  70  1,386 
Equity at 31 December 2023  98  4  1,527  6,378  -742  —  -1  7,263  424  7,687 
Changes in equity
Directed share issue 2  —  —  2,000  —  —  —  —  2,000  —  2,000 
Acquired non-controlling interests 2  —  —  —  -1,666  —  —  —  -1,666  -334  -2,000 
Compulsory acquisition of non-controlling interests 2  —  —  —  -265  —  —  —  -265  -59  -325 
Transaction costs related to the acquisition of non-
controlling interests  —  —  —  -31  —  —  —  -31  —  -31 
Dividends 3  —  —  —  -903  —  —  —  -903  -69  -972 
Acquisition of own shares  —  —  —  -475  —  —  —  -475  —  -475 
Other changes in equity  —  —  —  -14  —  —  —  -14  -11  -25 
Profit for the reporting period  —  —  —  1,154  —  —  —  1,154  50  1,203 
Other comprehensive income for the period  —  —  —  —  -4  —  1  -3  —  -3 
Total comprehensive income  —  —  —  1,153  -4  —  1  1,151  50  1,200 
Equity at 31 December 2024  98  4  3,527  4,176  -746  —  —  7,059  —  7,059 
Retained 
earnings1
1 IAS 19 Pension benefits had a net effect of EUR -0 million (-5) on retained earnings.
2 The share issue was directed at Topdanmark’s non-controlling interests.  For further information related to the acquired non-controlling interests and liability to non-controlling interests recognised in  the 
reporting period, see note 28.
3 Dividend per share EUR 1.70 (2.60)
On 12 December 2024, Sampo plc cancelled 11,747,690 own shares acquired during the financial year 2024. 
	
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Statement of cash flows
EURm 1–12/2024 1–12/2023
Operating activities
Profit before tax  1,533  1,765 
Adjustments
Depreciation and amortisation  180  158 
Unrealised gains and losses arising from valuation  -227  -559 
Realised gains and losses on investments  -58  -280 
Change in liabilities for insurance and investment 
contracts
 383  1,146 
Other adjustments  132  -537 
Adjustments total  410  -72 
Change (+/-) in assets of operating activities
Investments 1  -223  -86 
Other assets  -98  -208 
Total  -321  -294 
Change (+/-) in liabilities of operating activities
Financial liabilities  122  176 
Other liabilities  5  -196 
Paid taxes  -331  -277 
Paid interest  -91  -132 
Total  -296  -429 
Net cash from (or used in) operating activities  1,327  970 
Investing activities
Investments in subsidiary shares  —  -247 
Divestments in subsidiary shares  —  20 
Investments in tangible and intangible assets  -142  0 
Divestments in equipment and intangible assets  17  5 
Net cash from (or used in) investing activities  -125  -223 
EURm 1–12/2024 1–12/2023
Financing activities
Dividends paid  -903  -1,321 
Dividends paid to non-controlling interests  -69  -187 
Acquisition of non-controlling interests  -325  -14 
Transaction costs related to acquisition of non-
controlling interests
 -31  — 
Acquisition of own shares  -475  -555 
Issue of debt securities 2  194  142 
Repayments of debt securities in issue 2  -50  -473 
Net cash used in (or from) financing activities  -1,660  -2,407 
Total cash flows  -458  -1,660 
Cash and cash equivalents at the beginning of reporting period  1,415  3,073 
Effects of exchange rate changes  5  3 
Cash and cash equivalents at the end of reporting period  962  1,415 
Net change in cash and cash equivalents  -458  -1,660 
Additional information to the cash flow statement 1–12/2024 1–12/2023
Interest income received  512  751 
Dividend income received (excl. profit sharing from funds)  42  92 
Total out-going cashflows from leases  -39  -37 
1 Investments include investment property and financial assets.
2 Changes in short-term issues and repayments of debt securities are presented as net amounts.
Both in the financial year and the comparative year, the statement of cash flows includes both 
continuing and discontinued/divested operations. Profit before tax is therefore the total of Group’s 
profit and the discontinued/divested operations’ profit before taxes. In the financial year, 
subsequently,  operating activities include EUR -26 million from divested activities. In the 
comparative year, the operating activities include EUR 173 million from the discontinued operations, 
investing activities EUR 20 million and financing activities EUR -280 million. Cash flows from 
financing activities include an internal dividend of EUR -150 million and a group contribution of EUR 
-29 million to Sampo plc. In addition, Mandatum repaid the subordinated loan to Sampo plc EUR 
100 million in September 2023.
The items of the statement of cash flows cannot be directly concluded from the balance sheets due 
to e.g. exchange rate differences, and acquisitions and disposals of subsidiaries during the period.
Cash and cash equivalents include cash at bank and in hand EUR 682 million (1,081) and short-term 
deposits (max 3 months) EUR 280 million (334).
	
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Group’s notes to the financial statements 
Summary of material accounting principles   . 146
Segment information   .............................................. 161
Result by segment for twelve months 
ended 31 December 2024     ..................................... 162
Result by segment for twelve months 
ended 31 December 2023    ..................................... 163
Balance sheet by segment at 
31 December 2024     ................................................... 164
Balance sheet by segment at 
31 December 2023    ................................................... 165
Geographical information     ..................................... 166
Other notes     ................................................................. 167
1 Insurance service result      ....................................... 167
2 Net investment income     ....................................... 168
3 Net finance income or expense from 
insurance contracts      .................................................. 168
4 Other income    .......................................................... 169
5 Other expenses    ...................................................... 169
6 Auditor's fees   .......................................................... 170
7 Finance expenses      .................................................. 170
8 Components of other comprehensive 
income   ........................................................................... 170
9 Earnings per share   ................................................ 171
10 Property, plant, equipment    ............................. 172
11 Intangible assets    .................................................... 173
12 Financial assets     .................................................... 175
13 Determination and hierarchy of fair values   . 178
14 Movements in level 3 financial instruments 
measured at fair value    ........................................... 182
15 Deferred tax assets and liabilities    ................ 184
16 Taxes    ....................................................................... 188
17 Other assets        .......................................................... 188
18 Insurance contract liabilities       .......................... 189
19 Reconciliation of insurance contract 
liabilities    ....................................................................... 190
20 Assets for insurance acquisition cash 
flows   .............................................................................. 199
21 Non-life claims development      .......................... 199
22 Financial liabilities     .............................................. 208
23 Other liabilities       .................................................... 211
24 Employee benefits     ............................................. 212
25 Equity and reserves      ........................................... 216
26 Incentive schemes    ............................................. 217
27 Investments in subsidiaries    ............................ 220
28 Acquisition of Topdanmark's 
non-controlling interest      ......................................... 221
29 Related party disclosures  ................................ 222
30 Discontinued operations     ................................. 222
31 Business combinations    ...................................... 223
32 Contingent liabilities and commitments     .... 224
33 Subsequent events after the 
balance sheet date    .................................................. 226
34 Risk management disclosure    ......................... 227
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Group’s notes to the financial statements 
Summary of material 
accounting principles
Sampo plc (business ID 0142213-3) is a Finnish public 
company listed in Helsinki Nasdaq. Sampo has a dual 
listing in Nasdaq Stockholm and in Nasdaq 
Copenhagen. It is domiciled in Helsinki and the 
headquarters are at Fabianinkatu 27, 00100 Helsinki, 
Finland. The consolidated financial statements of 
Sampo Group include Sampo plc together with its 
subsidiaries and associates as of 31 December 2024. 
The group subsidiaries have insurance and financing 
activities in Finland, Sweden, Norway, Denmark, the 
Baltic countries, and the United Kingdom. 
A copy of the Group’s financial statements is available 
at the internet address www.sampo.com. 
Basis of preparation
Sampo Group has prepared the consolidated financial 
statements for 2024 in compliance with the 
International Financial Reporting Standards (IFRSs). In 
preparing the financial statements, Sampo has applied 
all the standards and interpretations relating to its 
business, adopted by the commission of the EU and 
effective on 31 December 2024.
The annual improvements or other amendments to the 
standards, adopted at the beginning of 2024, had no 
material impact on the Group’s financial statements 
reporting.
In preparing the notes to the consolidated financial 
statements, attention has also been paid to the Finnish 
accounting and company legislation and applicable 
regulatory requirements.
The going concern accounting assumption has been 
assessed by the Board and used in the preparation of 
the financial statements.
The consolidated financial statements are presented in 
euro (EUR), rounded to the nearest million, unless 
otherwise stated.
The Board of Directors of Sampo plc accepted the 
financial statements for issue on 12 March 2025. In 
accordance with Limited Liability Companies Act, the 
Annual General Meeting has the right to approve or 
reject the consolidated financial statements or change 
the statements after they have been issued. 
Consolidation
Subsidiaries 
The consolidated financial statements combine the 
financial statements of Sampo plc and all its 
subsidiaries. Companies in which the Group has control 
are consolidated as subsidiaries. Control exists when the 
Group has more than half of the voting power or it has 
power over the entity together with exposure to 
variable returns from its involvement there, and the 
ability to use its power to affect the amount of these 
returns. Subsidiaries are consolidated from the date on 
which control is transferred to the Group and cease to 
be consolidated from the date that control ceases.
The acquisition method of accounting is used for the 
purchase of subsidiaries. The cost of an acquisition is 
allocated to the identifiable assets, liabilities and 
contingent liabilities, which are measured at the fair 
value of the date of the acquisition. Acquisition-related 
costs are recognised through profit or loss. Possible 
non-controlling interest of the acquired entity is 
measured either at fair value or at proportionate 
interest in the acquiree’s net assets. The acquisition-
specific choice affects both the amount of recognised 
goodwill and non-controlling interest. The excess of the 
aggregate of consideration transferred, non-controlling 
interest and possibly previously held equity interest in 
the acquiree, over the Group’s share of the fair value of 
the identifiable net assets acquired, is recognised as 
goodwill.
The accounting policies used throughout the Group for 
the purposes of consolidation are consistent with 
respect to similar business activities and other events 
taking place in similar conditions. All intra-group 
transactions and balances are eliminated upon 
consolidation.
Non-controlling interests
The technical division of profit for the financial year and 
the total comprehensive income to the owners of the 
parent and non-controlling interests is presented after 
the statement of comprehensive income. The share of 
profits is attributed to non-controlling interests even if it 
should be negative. 
Non-controlling interests are presented in the balance 
sheet separately as part of equity. 
Non-controlling interests in an acquiree are measured 
either at fair value or as a proportionate share of net 
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assets of the acquiree. The choice is made for each 
acquisition separately. 
At the end of the financial year, due to the acquisition of 
non-controlling interests in Topdanmark, the total 
equity of consolidated financial statements did not 
include the non-controlling interest share. 
At the end of financial year, as the proportion of equity 
held by non-controlling interests changed, the carrying 
amounts of both the equity owners of the parent and 
the non-controlling interests were adjusted to reflect 
the changes. The difference between the book value of 
the NCI and the consideration paid was recognised 
directly in equity (retained earnings), and attributed to 
the owners of the parent company. 
Going forward, Sampo will allocate all of Topdanmark’s 
profits, after the completion of the acquisition, to the 
owners of the parent company. During the financial 
year, the NCI’s share of the profit was calculated as 
weighted average on their remaining share of 
ownership.   
Foreign currency translation
The consolidated financial statements are presented in 
euro, which is the functional and reporting currency of 
the Group and the parent company. Items included in 
the financial statements of each of the Group entities 
are measured using their functional currency, being the 
currency of the primary economic environment in which 
the Group operates. Foreign currency transactions are 
translated into the appropriate functional currency 
using the exchange rates prevailing at the dates of 
transactions or the average rate for a month. The 
balance sheet items denominated in foreign currencies 
are translated into the functional currency, at the rate 
prevailing at the balance sheet date.
Exchange differences arising from the translation of 
transactions and monetary balance sheet items 
denominated in foreign currencies into functional 
currency are recognised as translation gains and losses 
in profit or loss. 
The income statements of Group entities whose 
functional currency is other than euro are translated 
into euro at the average rate for the period, and the 
balance sheets at the rates prevailing at the balance 
sheet date. The resulting exchange differences are 
included in equity and their change in other 
comprehensive income. When a subsidiary is divested 
entirely or partially, the cumulative exchange 
differences are included in the income statement under 
sales gains or losses. 
Goodwill and fair value adjustments arising from an 
acquisition of a foreign entity are treated as if they were 
assets and liabilities of the foreign entity. Exchange 
differences resulting from the translation of these items 
at the exchange rate of the balance sheet date are 
included in equity, and their change in other 
comprehensive income.
Exchange rate differences arising from a monetary item, 
accounted for as Sampo’s net investment in a foreign 
operation (subsidiary), are recognised in other 
comprehensive income. 
A monetary item included in the net investment in a 
foreign operation may be denominated in the functional 
currency of Sampo (reporting entity), in the functional 
currency of the foreign operation or in a currency other 
than the functional currency of either the reporting 
entity or the foreign operation. When a foreign 
subsidiary is divested entirely or partially, the 
cumulative exchange differences are reclassified from 
equity to profit or loss. 
The following exchange rates were applied in the 
consolidated financial statements: 
1 euro (EUR) = 
Balance sheet 
date
Average 
exchange rate 
Swedish krona (SEK) 11.4590 11.4345
Danish krona (DKK) 7.4578 7.4589
Pound sterling (GBP) 0.8292 0.8467
Segment reporting
The Group’s segmentation is based on business areas 
whose risks and performance bases as well as 
regulatory environment differ from each other. The 
control and management of business and management 
reporting are organised in accordance with the business 
segments. The Group’s business segments are If, 
Topdanmark, Hastings, and Holding.
Geographical information has been given on income 
from external customers and non-current assets. The 
reported areas are Finland, Sweden, Norway, Denmark, 
United Kingdom, and the Baltic countries.
In the inter-segment and inter-company pricing, for 
both domestic and cross border transactions, market-
based prices are applied. The pricing is based on the 
Code of Conduct on Transfer Pricing Documentation in 
the EU and OECD guidelines.
Inter-segment transactions, assets and liabilities are 
eliminated in the consolidated financial statements.
Non-current assets held for sale 
and discontinued operations
Non-current assets and the assets and liabilities related 
to discontinued operations are classified as held for 
sale, if their carrying amount will be recovered 
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principally through sales transactions rather than from 
continuing use. For this to be the case, the sale must be 
highly probable, and the asset or disposal group must 
be available for immediate sale in its present condition, 
subject only to terms that are usual and customary for 
sales of such assets. In addition, the management must 
be committed to a plan to sell, and the sale should be 
expected to qualify for recognition as a completed sale 
within one year from the date of classification. The 
classification, presentation, and measurement 
requirements of non-current assets or disposal groups 
held for sale also apply to those that are held for 
distribution to owners acting in their capacity as 
owners.
Assets that meet the criteria to be classified as held for 
sale are measured at the lower of carrying amount and 
fair value less costs to sell. Immediately before the initial 
classification of the asset as held for sale, the carrying 
amount of the asset shall be measured in accordance 
with applicable IFRSs. If the fair value less costs to sell is 
the lower, the Group recognises an impairment loss at 
initial reclassification. Gains for subsequent increases in 
fair value are recognised through profit or loss. Once 
reclassified, any depreciation or recognition of 
associates’ share of profit or loss on such assets ceases. 
Income and expense recognition 
principles related to insurance 
contracts 
The introduction of IFRS 17 changed the structure of the 
statement of profit or loss to reflect the key sources of 
profit. The insurance service result, comprising of 
insurance revenue, insurance service expenses, and 
reinsurance result, reflects the result relating to 
underwriting and servicing insurance policies. The net 
financial result reflects the impacts arising from financial 
components of insurance contracts.  
Insurance revenue
Insurance revenue reflects the compensation that 
Sampo receives from the policyholder in return for the 
transfer of risk (insurance contract services) on an 
earned basis. The insurance revenue recognised in the 
reporting period is based on premium receipts and 
expected premium receipts, allocated linearly over the 
underlying terms of the insurance contracts, i.e. based 
on the passage of time. The liability for remaining 
coverage is reduced with a corresponding amount as 
the insurance revenue.  
Insurance service expenses
The insurance service expenses comprise of both claims 
incurred and operating expenses. 
Claims incurred for the reporting period include claims 
payments during the period and changes in the liability 
for incurred claims. The change in liability for the 
incurred claims includes the changes in undiscounted 
best estimate, discounted risk adjustment, and the 
changes in discounting effect due to changes in 
underlying best estimate or changes in payment 
patterns. The claims incurred also include claims 
handling expenses and changes in the loss component.
Operating expenses reported in the insurance service 
result relate to administrative expenses arising from the 
handling of insurance contracts. Additionally, the 
operating expenses include the acquisition cash flows 
recognised in profit or loss, where the liability for 
remaining coverage changes with a corresponding 
amount. 
Reinsurance result 
Reinsurance result comprises both reinsurance premium 
expenses and reinsurer’s share of claims incurred. 
Reinsurance premium expenses related to reinsurance 
contracts held are recognised similarly to insurance 
revenue and reflect the premium payments attributable 
to the reporting period for the reinsurance contract 
services received. Any commissions received reduce 
the reinsurance premium expenses. The reinsurers’ 
share of claims incurred is reported consistently with 
direct insurance expenses, including changes in the risk 
of non-performance.
Insurance finance income or expense
The insurance finance income or expenses included in 
the net financial result reflect the impacts arising from 
financial components. These include changes in the 
liability for incurred claims related to changes in 
discount rates and time value of money (unwinding). 
Therefore, the effect from changes in interest rates, as 
well as interest expense, is presented in its entirety as 
insurance finance income or expenses. The effect of 
changes in indexation of annuities is also presented 
within insurance finance income or expenses. Amounts 
related to reinsurance contracts are presented 
separately. The option to present changes in 
discounting effect in other comprehensive income is not 
applied.
In 2024, Sampo updated the accounting policy for the 
presentation of the change in discounting effect relating 
to risk adjustment. The change in discounting effect is 
now allocated between the insurance service expenses 
and insurance finance income and expense. 
Net investment income 
Interest and dividends
Interest income and expenses are recognised in the 
income statement using the effective interest rate 
method. This method recognises income and expenses 
on the instrument evenly in proportion to the amount 
outstanding over the period to maturity. Dividends on 
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equity securities are recognised as revenue when the 
right to receive payment is established.
Fees and commissions
The fees and transaction costs of financial instruments 
measured at fair value through profit or loss are 
recognised in profit or loss when the instrument is 
initially recognised.
Revenue from contracts with 
customers
Other income consists of income from insurance-related 
services provided, that do not involve a transfer of 
significant insurance risk, and are therefore accounted 
for under IFRS 15 Revenue from contracts with 
customers. Such income is primarily attributable to sales 
commission and services for administration, claims 
settlement, etc. in insurance contracts on behalf of 
other parties.
Furthermore, If Group’s subsidiary Viking Assistance 
Group AS provides roadside assistance. Income from 
these services is recognised when roadside assistance 
has been provided. 
The subsidiary Hastings has revenue from broker 
activities in accordance with IFRS 15 Revenue from 
Contracts with Customers. The revenue consists 
principally of fees and commissions relating to the 
arrangement of third party underwritten insurance 
contracts and ancillary products.
Revenue from insurance brokerage activities is 
recognised at the point of sale to the customer, and 
revenue from other retail services is recognised when 
the service has been completed. Revenue arising from 
insurance broking activities is measured on an agency 
basis, net of cost, at the fair value of the income 
receivable after adjusting for any allowance for 
expected future cancellation refunds. Hastings may also 
provide contracts for the provision of other ad hoc, 
point-in-time services to customers. Such income is 
recognised when the performance obligation has been 
satisfied at the expected value of consideration. 
In the consolidated financial statements, the fees and 
commissions from external broker activities are 
included in Other income or Other expenses.
Financial assets and liabilities 
Initial recognition and derecognition
Financial assets and liabilities are measured at the initial 
recognition at fair value. If the acquired financial assets 
and liabilities are not measured at fair value, transaction 
costs directly attributable to acquisition or issue are 
added or deducted respectively.
Purchases and sales of financial assets at fair value 
through profit or loss are recognised and derecognised 
on the trade date, which is the date on which the Group 
commits to purchase or sell the asset. Loans and other 
receivables are recognised when cash is advanced.
Financial assets and liabilities are offset, and the net 
amount is presented in the balance sheet only when the 
Group has a legally enforceable right to set off the 
recognised amounts, and it intends to settle on a net 
basis, or to realise the asset and settle the liability 
simultaneously.
Financial assets are derecognised when the contractual 
rights to receive cash flows have expired or the Group 
has substantially transferred all the risks and rewards of 
ownership. Financial liabilities are derecognised when 
the obligation specified in the contract is discharged, 
cancelled or expired.
Classification and measurement principles of 
financial assets
Financial assets are classified as being subsequently 
measured either at amortised cost, at fair value through 
other comprehensive income (FVOCI), or at fair value 
through profit or loss (FVPL). The majority of Sampo 
Group’s financial assets are classified at fair value 
through profit or loss, and only a limited amount of 
financial assets is measured at amortised cost. No 
financial assets are classified as FVOCI.
The classification of financial assets into these 
measurement categories is based on Sampo Group’s 
business model for managing the financial assets and 
the contractual cash flow characteristics of the financial 
assets. The Group’s business model reflects how the 
portfolios of financial assets are managed to achieve 
business objectives and to generate cash flows. The 
factors considered in determining the portfolio’s 
business model include how the financial assets’ 
performance is evaluated and reported to management, 
how risks are assessed and managed, past experience 
of how the cash flows have been collected, and how 
compensation is linked to performance. 
Financial assets at fair value through profit 
or loss
Financial assets classified as at fair value through profit 
or loss include mainly investments in equity instruments 
and funds, debt instruments, and other loans. 
Equity instruments are classified and measured at fair 
value through profit or loss. 
Debt instruments, such as bonds and other interest-
bearing securities, are classified as measured at fair 
value through profit or loss when the business model 
reflects the assets being managed and evaluated on a 
fair value basis. The instruments are initially recognised 
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and subsequently measured at fair value. Transaction 
costs that are directly attributable to the issue or 
acquisition of the assets are expensed in profit or loss.
Gains and losses arising from changes in fair value, or 
realised on disposal, together with related interest 
income and dividend, are recognised in the income 
statement under net investment income.
Derivative instruments that are not designated as 
hedges and do not meet the requirements for hedge 
accounting are classified as financial assets at fair value 
through profit or loss. Derivatives are initially 
recognised at fair value. Derivative instruments are 
carried as assets when the fair value is positive and as 
liabilities when the fair value is negative. Derivative 
instruments are recognised at fair value, and gains and 
losses arising from changes in fair value, together with 
realised gains and losses, are recognised in the income 
statement under net investment income.
Financial assets measured at amortised cost
A financial asset is measured at amortised cost only if 
the objective of the business model is to hold a financial 
asset in order to collect contractual cash flows, and the 
contractual cash flows of the financial asset meet the 
SPPI criteria (solely payments of principal and interest -
criteria, SPPI), i.e. it is consistent with the basic lending 
arrangement. SPPI criteria is met when the financial 
instrument’s contractual cash flows are solely payments 
of principal and interest on the principal amount 
outstanding. Financial assets measured at amortised 
cost comprise mainly debt instruments, loans, and 
receivables. 
Financial assets measured at amortised costs are 
initially recognised at their fair value, including 
transaction costs directly attributable to the acquisition 
of the asset. Loans and other receivables are 
subsequently measured at amortised cost using the 
effective interest rate method.
Interest revenue is calculated using the effective 
interest rate method. Under IFRS 9, financial assets 
subsequently measured at amortised cost are subject to 
loss allowance, that is, expected credit losses (ECL) 
requirements.
Financial liabilities
Financial liabilities, including subordinated debt 
securities, debt securities in issue, and other financial 
liabilities, are subsequently measured at amortised cost 
using the effective interest rate method. Interest 
expenses and gains or losses on derecognition are 
recognised in the income statement.
Derivative financial liabilities are measured at fair value 
through profit or loss. 
If debt securities issued are redeemed before maturity, 
they are derecognised and the difference between the 
carrying amount and the consideration paid at 
redemption is recognised in profit or loss.
Fair value
The fair value of financial instruments is determined 
primarily by using quoted prices in active markets. 
Instruments are measured either at a bid price or at the 
last trade price, if there is an auction policy in the stock 
market of the price source. An exception are the 
syndicated loans, which are measured at a mid-price 
because of the lower liquidity. The financial derivatives 
are also measured at the last trade price. If the financial 
instrument has a counter-item that will offset its market 
risk, the same price source is used in assets and 
liabilities to that extent. If a published price quotation 
does not exist for a financial instrument in its entirety, 
but active markets exist for its component parts, the fair 
value is determined based on the relevant market prices 
of the component parts.
Fair values of financial assets are based on either 
published price quotations or valuation techniques 
based on market observable inputs, where available. If 
these are not available, the fair value is established by 
using generally accepted valuation techniques, 
including recent arm’s length market transactions 
between knowledgeable, willing parties, reference to 
the current fair value of another instrument that is 
substantially the same, discounted cash flow analysis, 
and option pricing models. For a limited amount of 
assets, the value needs to be determined using these 
other techniques. 
The carrying amount of cash and cash equivalents, as 
well as settlement receivables included in other assets is 
used as an approximation of fair value.
The financial instruments measured at fair value have 
been classified into three hierarchy levels in the notes, 
depending on, e.g. if the market for the instrument is 
active, or if the inputs used in the valuation technique 
are observable. 
On level 1, the measurement of the instrument is based 
on quoted prices in active markets for identical assets 
or liabilities.
On level 2, inputs for the measurement of the 
instrument include also other than quoted prices 
observable for the asset or liability, either directly or 
indirectly by using valuation techniques.
On level 3, the measurement is based on other inputs 
rather than observable market data. 
In level 3 equity investment is valued by using the 
excess return model, in which the value of a company is 
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the sum of capital currently invested in the company 
and the present value of excess returns that the 
company expects to make in the future. 
For private equity funds the valuation of the underlying 
investments is conducted by the fund manager who has 
all the relevant information required in the valuation 
process. The valuation is usually updated quarterly 
based on the value of the underlying assets and the 
amount of debt in the fund. There are several valuation 
methods, which can be based on, for example, the 
acquisition value of the investments, the value of 
publicly traded peer companies, the multiple based 
valuation or the cash flows of the underlying 
investments. 
Impairment of financial assets
Sampo assesses, at the end of each reporting period, 
whether there is any objective evidence that a financial 
asset, other than those at fair value through profit or 
loss, may be impaired. A financial asset is impaired, and 
impairment losses are recognised based on the 
estimated future cash flows of the financial asset if 
there is objective evidence of impairment as a result of 
one or more loss events that occurred after the initial 
recognition of the asset, and if that event has an impact 
that can be reliably estimated.
There is objective evidence of impairment, if, for 
example, an issuer or debtor encounters significant 
financial difficulties that will lead to insolvency, and to 
estimation that the customer will probably not be able 
to meet the obligations to the Group. When there is 
objective evidence of impairment of a financial asset 
carried at amortised cost, the amount of the loss is 
measured as the difference between the receivable’s 
carrying amount and the present value of estimated 
future cash flows discounted at the receivable’s original 
effective interest rate. The difference is recognised as 
an impairment loss in profit or loss. In Sampo Group the 
impairment is assessed individually for each asset.
Financial assets measured at amortised cost
In accordance with IFRS 9, Sampo applies a forward-
looking ECL model, which in Sampo Group is mainly 
applicable to financial assets measured at amortised 
cost. Impairment requirements do not apply to equity 
instruments or other financial instruments measured at 
FVPL. Expected credit losses reflect past events, i.e. 
historical loss experience, current conditions, and 
forecasts of future economic conditions.
Sampo applies a general approach for impairment in 
which a loss allowance is calculated either for 12-month 
expected credit losses or a lifetime expected credit 
losses. A three-staged model is used to determine the 
ECL at each reporting date. In stage 1, the credit risk has 
not increased significantly. Loss allowance is measured 
at an amount equal to 12-month expected credit losses. 
In stages 2 and 3, the credit risk has increased 
significantly since initial recognition and the loss 
allowance is measured at an amount equal to the 
lifetime expected credit losses. In stage 3, the financial 
asset is assessed to be credit-impaired (at default), and 
the interest is calculated on the credit-impaired amount 
instead of gross carrying amount.
In Sampo Group, the general approach is based on 
three components, namely probability of default (PD), 
loss given default (LGD), and exposure at default 
(EAD).
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Derivative financial instruments 
and hedge accounting
Derivative financial instruments are classified as those 
held for trading and those held for hedging, including 
interest rate derivatives, credit risk derivatives, foreign 
exchange derivatives, equity derivatives and 
commodity derivatives. Derivative instruments are 
measured initially at fair value. All derivatives are carried 
as assets when fair value is positive, and as liabilities 
when fair value is negative.
Derivatives held for trading
Derivative instruments that are not designated as 
hedges are treated as held for trading. They are 
measured at fair value and the change in fair value, 
together with both realised gains and losses and 
interest income and expenses, is recognised in profit or 
loss.
Hedge accounting
Sampo Group may hedge its operations against interest 
rate risks, currency risks, and price risks through fair 
value hedging and cash flow hedging. Cash flow 
hedging is used as a protection against the variability of 
the future cash flows. During the financial year, cash 
flow hedging has been applied in Hastings.
Hedge accounting applies to hedges that are effective 
in relation to the hedged risk and meet the hedge 
accounting requirements of IFRS 9. The hedging 
relationship between the hedging instrument and the 
hedged item, as well as the risk management objective 
and strategy for undertaking the hedge, are 
documented at the inception of the hedge. 
Cash flow hedging
Cash flow hedging is used to hedge the interest cash 
flows of individual floating rate debt securities or other 
floating rate assets or liabilities. The hedging 
instruments used include currency forward contracts. 
Derivative instruments which are designated as hedges 
and are effective as such, are measured at fair value. 
The effective part of the change in fair value is 
recognised in other comprehensive income. 
The cumulative change in fair value is transferred from 
equity and recognised in profit or loss in the same 
period that the hedged cash flows affect profit or loss.
When a hedging instrument expires, is sold, terminated, 
or the hedge no longer meets the criteria for hedge 
accounting, the cumulative change in fair value remains 
in equity until the hedged cash flows affect profit or 
loss.
Leases
Group as lessee
All lease contracts are primarily recognised in the 
balance sheet in accordance with IFRS 16 Leases. The 
only optional exemptions include certain short-term 
contracts with a duration under 12 months or low-value 
contracts, for which the lease payments can be 
recognised as an expense on a straight-line basis over 
the lease term.
Right-of-use assets related to lease contracts (right to 
use an underlying asset) are recognised in the asset 
side as part of Property, plant and equipment and the 
corresponding lease liabilities in the liability side, as part 
of Other liabilities. A right-of-use asset is recognised at 
the commencement date of the lease and measured at 
cost that includes the amount of the initial 
measurement of the liability and potential prepaid rents 
to the lessor. Right-of-use assets are amortised on a 
straight-line basis over the lease period. Lease liability is 
also recognised at the commencement date and 
measured at the present value of the lease payments.
Depreciations on right-of-use assets and interests on 
lease liabilities are recognised in the income statement.
Intangible assets
Goodwill
Goodwill represents the excess of the cost of an 
acquisition (made after 1 January 2004) over the fair 
value of the Group’s share of net identifiable assets, 
liabilities, and contingent liabilities of the acquired entity 
at the date of acquisition. Goodwill on acquisitions 
before 1 January 2004 is accounted for in accordance 
with the previous accounting standards, and the 
carrying amount is used as the deemed cost in 
accordance with the IFRS. 
Goodwill is measured at historical cost less accumulated 
impairment losses. Goodwill is not amortised. Instead, it 
is tested at least annually for impairment.
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Other intangible assets
IT software and other intangible assets, whether 
procured externally or internally generated, are 
recognised in the balance sheet as intangible assets 
with finite useful lives if it is probable that the expected 
future economic benefits that are attributable to the 
assets will flow to the Group and the cost of the assets 
can be measured reliably. The cost of internally 
generated intangible assets is determined as the sum of 
all costs directly attributable to the assets. Research 
costs are recognised as expenses in profit or loss as 
they are incurred. Costs arising from the development 
of new IT software or from significant improvement of 
existing software are recognised only to the extent they 
meet the above-mentioned requirements for being 
recognised as assets in the balance sheet.
Intangible assets with finite useful lives are measured at 
historical cost less accumulated amortisation and 
impairment losses. Intangible assets are amortised on a 
straight-line basis over the estimated useful life of the 
asset. The estimated useful lives by asset class are as 
follows:
• IT software 3-10 years
• Other intangible assets 3-10 years
Intangible assets with an indefinite useful life, such as 
brands and trademarks acquired in business 
combinations, are not amortised. Instead, they are 
tested at least annually for impairment.
Amortisations and impairment losses are recognised in 
the statement of profit or loss in other expenses. 
Property, plant and equipment
Property, plant and equipment comprise properties 
occupied for Sampo’s own activities, office equipment, 
fixtures and fittings, and furniture. 
Property, plant and equipment are measured at 
historical cost less accumulated depreciation and 
impairment losses.
Improvement costs are added to the carrying amount 
of a property when it is probable that the future 
economic benefits that are attributable to the asset will 
flow to the Group. Costs for repairs and maintenance 
are recognised as expenses in the period in which they 
were incurred.
Items of property, plant and equipment are depreciated 
on a straight-line basis over their estimated useful life. In 
most cases, the residual value is estimated at zero. Land 
is not depreciated. Estimates of useful life are reviewed 
at financial year-ends and the useful life is adjusted if 
the estimates change significantly. The estimated useful 
lives by asset class are as follows:
• Buildings 20-50 years
• Components of buildings 15-20 years
• Property and leasehold improvements 4-10 years
• IT equipment and motor vehicles 2-5 years 
• Other equipment 3-15 years 
Depreciations and impairment losses are recognised in 
the statement of profit or loss in other expenses. 
Depreciation of property, plant or equipment will be 
discontinued if the asset in question is classified as held 
for sale in accordance with IFRS 5 Non-current Assets 
Held for Sale and Discontinued Operations.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
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Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
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Impairment of intangible assets 
and property, plant and equipment
At each reporting date, the Group assesses whether 
there is any indication that an intangible asset or an 
item of property, plant or equipment may be impaired. 
If any such indication exists, the Group will estimate the 
recoverable amount of the asset. In addition, goodwill, 
intangible assets not yet available for use, and 
intangible assets with an indefinite useful life will be 
tested for impairment annually, independent of any 
indication of impairment. For impairment testing the 
goodwill is allocated to the cash-generating units of the 
Group from the date of acquisition. In the test, the 
carrying amount of the cash-generating unit, including 
the goodwill, is compared with its recoverable amount.
The recoverable amount is the higher of an asset’s fair 
value less costs to sell and its value in use. The value in 
use is calculated by estimating future net cash flows 
expected to be derived from an asset or a cash-
generating unit, and by discounting them to their 
present value using a pre-tax discount rate. If the 
carrying amount of an asset is higher than its 
recoverable amount, an impairment loss is recognised in 
profit or loss. In conjunction with this, the impaired 
asset’s useful life will be re-determined.
The impairment loss is reversed if there has been a 
change in circumstances and the recoverable amount 
has changed after the recognition of the impairment 
loss, but no more than to the carrying amount that it 
would have been without recognition of the impairment 
loss. Impairment losses recognised for goodwill are not 
reversed.
Insurance contracts 
Sampo Group has applied IFRS 17 Insurance Contracts 
from 1 January 2023. Sampo Group’s operations are 
focused on the P&C business and Sampo primarily uses 
the premium allocation approach (PAA) under IFRS 17. 
The risks involved in insurance contracts are widely 
elaborated in the Group’s note 34. 
P&C operations
Scope
In the Group’s P&C insurance contracts, insurance risk is 
considered significant. Insurance contracts issued by 
third party underwriters (panel underwriters), which do 
not transfer any insurance risk to the Group companies, 
are not in the scope of IFRS 17 but instead accounted 
for under IFRS 15 Revenue from Contracts with 
Customers.
Insurance contracts containing one or more 
components within the scope of different accounting 
standards are accounted for separately. Sampo 
evaluates the insurance contracts to identify 
components from the contracts. For example, an 
insurance contract may include an investment 
component or a component for services other than 
insurance contract services (or both).
Level of aggregation 
Insurance contracts are aggregated into portfolios of 
insurance contracts. The portfolios comprise contracts 
with similar risks that are managed together. These 
portfolios are further divided into annual cohorts, i.e. 
contracts not issued more than one year apart.
In Sampo Group's P&C operations, portfolios are 
determined based on a segmentation of business, or a 
combination of line of business (as defined by the 
management), business area and country. Portfolios are 
determined separately for each legal entity or based on 
product lines. 
Sampo Group has identified some onerous contracts, 
but, all in all, their amount is insignificant.
The carrying amount of the portfolios of insurance and 
reinsurance contracts determines their presentation as 
assets or liabilities in the balance sheet.
Contract boundary 
The initial measurement of a group of insurance 
contracts includes all future cash flows arising within 
the contract boundary. In determining which cash flows 
fall within the contract boundary, substantive rights and 
obligations arising from the terms of the contract, 
together with applicable laws and regulations, are 
considered.
In Sampo Group’s P&C operations, the majority of 
contracts have a one-year contract boundary, typically 
until the next renewal date, i.e. the contract has one-
year coverage period during which there are 
substantive rights and obligations.
Measurement 
In accordance with IFRS 17, a general measurement 
model (GMM) is applicable to all insurance contracts to 
measure insurance contract liabilities. Under the general 
measurement model, insurance contracts are measured 
based on future cash flows, adjusted to reflect the time 
value of money, including a risk adjustment, and a 
contractual service margin (CSM). 
When certain eligibility criteria are met, insurers may 
apply a simplified approach, the premium allocation 
approach (PAA), for the measurement of insurance 
contracts. PAA is eligible for insurance contracts with a 
coverage period of one year or less. This approach is 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
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Sustainability Statement Group’s notes to the financial statements Sampo plc’s notes to the financial statements
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also available for contracts where the PAA would not 
materially differ from the results of the GMM. In Sampo 
Group's P&C operations, PAA is applied to all insurance 
contracts, because the coverage period for most of the 
insurance contracts is one year or less, and for longer 
insurance contracts the qualifying eligibility criteria are 
fulfilled. 
The measurement of insurance liabilities consists of the 
liability for remaining coverage (LRC) and acquisition 
cash flow asset, and liability for incurred claims (LIC), 
the latter including both reported but not settled claims, 
as well as incurred but not reported claims (IBNR).
On the initial recognition of P&C operations’ groups of 
insurance contracts, the carrying amount of LRC is 
measured as the premiums initially received less 
insurance acquisition cash flows. In case of onerous 
contracts, a loss component is recognised.
The acquisition cash flows reducing the carrying 
amount of LRC mainly include staff costs related to 
sales personnel and commissions, as well as certain 
costs related to selling policies through price 
comparison websites. Any overhead costs are expensed 
immediately. Sampo Group's P&C operations in the 
private business area have elected to recognise 
acquisition cash flows as an expense at the date when 
they are incurred. For other business areas, the 
acquisition costs are deferred over the coverage period 
of the contracts, generally one year, or longer in case of 
expected renewals.
Any acquisition cash flows paid relating to a group of 
insurance contracts not yet recognised, are presented 
as a separate acquisition cash flow asset and included in 
the related portfolio’s total carrying amount.   
The liability for remaining coverage relates to the 
obligation to investigate and pay valid claims that have 
not yet occurred. At subsequent reporting periods, the 
carrying amount of LRC is increased by premiums 
received during the period and decreased by the 
amount recognised as insurance revenue for services 
provided in the period, which for most products is 
based on the passage of time (straight line basis). 
Consequently, any premium receipts pertaining to 
insurance services to be provided after the closing date 
remain in this liability. The carrying amount is also 
increased for any premiums received in subsequent 
periods, less additional insurance acquisition cash flows 
paid. The carrying amount of LRC is not discounted or 
adjusted with the effect of financial risk, as the time 
between providing services and the related premium 
due date generally is no more than a year.
For groups of onerous contracts, a loss component is 
part of the liability for remaining coverage. The loss 
component is calculated as the difference between the 
liability measured with the general measurement model 
and with the premium allocation approach.
The liability for incurred claims (LIC) is intended to 
cover the future payments of all claims incurred, 
including claims not yet reported to the company and 
all claims handling expenses. Sampo Group measures 
the liability for incurred claims (LIC) for the group of 
insurance contracts at the amount of estimated 
fulfilment cash flows relating to incurred claims. 
Fulfilment cash flows consist of three components, 
namely expected cash flows, discounting and risk 
adjustment. The estimated future cash flows (best 
estimate) are calculated with the aid of statistical 
methods or through individual assessments of individual 
claims. 
Both the best estimate and risk adjustment are 
discounted to present value using standard actuarial 
methods and applying market-based yield curves. The 
curves are constructed based on a risk-free rate and an 
illiquidity premium for each of the main currencies.
Discounting
Sampo Group's P&C operations have determined the 
discount rates based on a bottom-up approach. The 
interest rate curve includes a risk-free rate (excluding 
credit risk adjustment) and an illiquidity premium for 
each currency. The illiquidity premium is mainly derived 
based on a portfolio of high-rated bonds for the liquid 
part of the interest rate curve. Beyond this, the curve 
converges to the ultimate forward rate, consistent with 
the EIOPA curves. Discount rates are constructed 
separately for the main currencies applied in Sampo 
Group’s subsidiaries.
The discounting effect of current-year liabilities for 
incurred claims and changes in the cash flows is 
recognised in the insurance service result. Unwinding of 
interest rates, effect of changes in interest rates, and 
other financial assumptions are presented as insurance 
finance income or expense in profit or loss. Sampo 
Group has elected not to apply the OCI option allowed 
under IFRS 17. 
Risk adjustment 
In accordance with IFRS 17, an explicit risk adjustment is 
included in the measurement of insurance liabilities. The 
risk adjustment reflects the cost of uncertainty 
associated with the amount and timing of cash flows 
arising from non-financial risk and the degree of risk 
aversion. The risks typically considered in P&C 
operations, when assessing risk adjustment, are reserve 
risk, longevity risk, inflation risk, and premium risk.
In Sampo Group, the risk adjustment is derived through 
a confidence level technique whereby management 
determines the appropriate quantile. The risk 
adjustment is calculated at the subsidiary level and 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
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aggregated into the consolidated Sampo Group level 
risk adjustment, without any diversification effects 
assumed. Under the premium allocation approach, the 
risk adjustment is only included in LIC, unless a group of 
insurance contracts is onerous.
Reinsurance contracts 
The PAA model is applied to reinsurance contracts held. 
The corresponding accounting policies as for measuring 
the insurance contracts issued are applied when 
measuring the reinsurance contracts held. Thus, 
correspondingly to insurance liabilities for issued 
insurance contracts, the reinsurance assets for 
reinsurance contracts held consist of asset for 
remaining coverage and asset for incurred claims. The 
asset for incurred claims also takes into consideration 
the effect of the risk of non-performance by the issuer 
of the reinsurance contract.
Investment components are included in the reinsurance 
contracts held for cash flows repaid to a policyholder in 
all circumstances, i.e. regardless of whether an insured 
event occurs or not. Identified amounts of investment 
components are excluded from recognised amounts for 
reinsurance result in the statement of profit and other 
comprehensive income. 
Life operations
Sampo Group’s life operations were reclassified as 
discontinued operations during the first quarter of 
comparative period 2023.
Employee benefits 
Post-employment benefits
Post-employment benefits include pensions and life 
insurance.
Sampo has defined benefit plans in Sweden and 
Norway, and defined contribution plans in other 
countries. The most significant defined contribution 
plan is that arranged through the Employees’ Pensions 
Act (TyEL) in Finland.
In the defined contribution plans, the Group pays fixed 
contributions to a pension insurance company and has 
no legal or constructive obligation to pay further 
contributions. The obligations arising from a defined 
contribution plan are recognised as an expense in the 
period to which the obligation relates.
In the defined benefit plans, the company still has 
obligations after paying the contributions for the 
financial period and bears their actuarial and/or 
investment risk. The obligation is calculated separately 
for each plan using the projected unit credit method. In 
calculating the amount of the obligation, actuarial 
assumptions are used. The pension costs are recognised 
as an expense for the service period of employees.
Defined benefit plans are both funded and unfunded. 
The amounts reported as pension costs during a 
financial year consist of the actuarially calculated 
earnings of old-age pensions during the year, calculated 
straight-line, based on pensionable income at the time 
of retirement. The calculated effects in the form of 
interest expense for crediting/appreciating the 
preceding years’ established pension obligations are 
then added. The calculation of pension costs during the 
financial year starts at the beginning of the year and is 
based on assumptions about such factors as salary 
growth and price inflation throughout the duration of 
the obligation and on the current market interest rate 
adjusted to take into account the duration of the 
pension obligations.
The current year pension cost and the net interest of 
the net liability is recognised through profit or loss in 
pension costs. The actuarial gains and losses and the 
return of the plan assets (excluding net interest) are 
recognised as a separate item in other comprehensive 
income.
The fair value of the plan assets covered by the plan is 
deducted from the present value of future pension 
obligations and the remaining net liability or net asset is 
recognised separately in the balance sheet.
The Group has also certain voluntary defined benefit 
plans, which have no material significance.
Termination benefits
An obligation based on the termination of employment 
is recognised as a liability when the Group is verifiably 
committed to terminating the employment of one or 
more persons before the normal retirement date, or to 
granting benefits payable upon termination as a result 
of an offer to promote voluntary redundancy. As no 
economic benefit is expected to flow to the employer 
from these benefits in the future, they are recognised 
immediately as expenses. Obligations maturing more 
than 12 months later than the balance sheet date are 
discounted. The benefits payable upon termination at 
Sampo are the monetary and pension packages related 
to redundancy.
Share-based payments
During the financial year, Sampo had four valid share-
based incentive schemes settled in cash (the long-term 
incentive schemes 2020 I, 2020 II, 2020 III, and 2024 for 
the management and key employees).  
Topdanmark had a share-based incentive scheme that 
was converted to a phantom equity plan in the last 
quarter of the financial year. Hastings had a share-based 
incentive scheme settled in cash during the financial 
year. More information on the different incentive 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s 
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