Årsredovisning 2025

reasonable due to the number of Board members. The 
number of the Directors and the composition of the 
Board shall enable the Board of Directors to perform its 
duties efficiently. As at 31 December 2025, the share of 
women on Sampo’s Board of Directors was 37.5 per 
cent and the share of men was 62.5 per cent. Sampo’s 
Nomination and Remuneration Committee regularly 
evaluates progress towards the gender diversity target 
and takes action as necessary when preparing the 
proposal to the next Annual General Meeting (AGM).
Roles and responsibilities
Sampo’s Board of Directors is responsible for and has 
the ultimate oversight of group level sustainability, 
containing the entire range of environmental, social, and 
governance (ESG) matters. The Board has assigned its 
Audit Committee to monitor Sampo Group’s 
sustainability reporting and activities, such as reporting 
in accordance with the CSRD, the double materiality 
assessment (DMA), and the Group’s sustainability 
programme. Both the regulatory sustainability reporting 
and the Sampo Group sustainability programme enable 
the Board and the top management to monitor overall 
sustainability work and related targets. The annually 
published sustainability statement, including the double 
materiality assessment, and the annually updated 
Sampo Group Code of Conduct are reviewed by the 
Audit Committee and approved by the Board of 
Directors.  
Sampo’s Board of Directors elects and releases the 
Group CEO and appoints the Sampo Group Executive 
Committee (GEC). The Group CEO is in charge of the 
daily management of Sampo. The GEC supports the 
Group CEO in the preparation of strategic issues 
relating to Sampo Group, in the handling of operational 
matters that are significant or involve questions of 
principle, and in ensuring a good internal flow of 
information.
Sampo Group’s Chief Financial Officer (CFO), who is a 
member of the GEC, directs Sampo’s Sustainability unit. 
The Group CFO also ensures that adequate reporting 
on sustainability matters is provided to the Group CEO. 
Sampo’s Sustainability unit is responsible for the 
development and coordination of sustainability at 
group level. The Group CFO and the Sustainability unit 
report to the Board of Directors and the Audit 
Committee on material impacts, risks, and opportunities 
and associated targets, when needed.
Skills and expertise
Sampo has identified materially important areas of 
expertise which have to be sufficiently covered by the 
Board members’ range of skills and experience. These 
include, for example, risk management, regulatory 
framework and legal requirements, system of 
governance, and material impacts, risks, and 
opportunities related to the insurance and financial 
markets. Sampo has an externally disclosed Board skills 
matrix, which shows all materially important areas of 
expertise, and the number and percentage of Board 
members who have strong experience in each area 
(self-assessment).
In addition to the above mentioned topics, non-financial 
experience has been identified as a materially important 
area of expertise in the Board skills matrix. It is defined 
as the ability to interpret a company's non-financial 
information (including information related to ESG 
matters), identify key issues, set appropriate controls, 
and take necessary measures based on this information. 
It also includes understanding of a listed company's 
non-financial reporting requirements and auditing 
arrangements and ability to oversee them. In addition to 
the existing expertise the Board members possess, the 
Board of Directors has access to training on material 
topics, as needed. The Board members can also 
leverage knowledge, for example, through Board and/
or management positions they hold in other companies.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 58

===== SIDA 59 =====

Sustainability organisation and reporting structure
Sampo Group
GOV-2 – Information provided to and 
sustainability matters addressed by the 
undertaking’s administrative, management, 
and supervisory bodies
At Sampo Group, sustainability is seen as a business risk 
driver, and sustainability-related risks are a part of the 
Group’s overall risk management. This means that 
sustainability considerations have been incorporated 
into overall business and business practices (e.g. 
insurance and investment operations). Sampo’s Board 
of Directors is responsible for ensuring that the Group’s 
risks are properly managed and controlled, while the 
Audit Committee prepares Sampo Group’s risk 
management principles and other guidelines. 
Additionally, the Board of Directors oversees material 
impacts and opportunities related to strategy and major 
transactions together with the operative management.
The Group CFO and Sampo’s Head of Sustainability 
report to the Board of Directors and the Audit 
Committee on sustainability matters at least twice a 
year, and more frequently when necessary. In 2025, 
sustainability as a standalone topic was on the agenda 
at Board and/or Audit Committee meetings every other 
quarter. The impacts, risks, and opportunities identified 
in Sampo Group’s double materiality assessment are 
presented to the Board and its Audit Committee as part 
of regular Board reporting. The materiality assessment 
is reviewed annually, as required by the legislation, and 
any material changes are communicated to the Board.
In addition to Sampo’s Sustainability unit, other units, 
such as Compliance, Risk Management, Investment 
Management and Operations, and Human Resources 
(HR), provide regular reporting to the Board and/or its 
committees and the GEC. This reporting may also 
include sustainability matters, as sustainability is an 
integral part of operations. The Board and its 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 59

===== SIDA 60 =====

committees receive meeting materials before each 
Board and/or committee meeting and have time to 
provide feedback. During the meeting, a presentation 
on the topic in question is given prior to the discussion 
and any potential decision-making. 
In 2025, the Board of Directors addressed the material 
sustainability topics as part of the double materiality 
assessment review. The material sustainability topics 
are presented in this Sustainability Statement under the 
heading SBM-3 – Material impacts, risks, and 
opportunities, and their interaction with strategy and 
business model (p. 67). In addition, examples of topics 
addressed at the Board and/or Audit Committee 
meetings in 2025 include annual policy updates (e.g. 
Sampo Group Code of Conduct, Sampo Group 
Responsible Investment Policy), sustainability reporting 
(e.g. climate transition plan, EU Taxonomy, employee 
engagement, customer satisfaction), internal control, 
and regular compliance, governance, and risk reporting.
GOV-3 – Integration of sustainability-related 
performance in incentive schemes
At Sampo Group, variable compensation is used to 
ensure the competitiveness of the total remuneration 
package and can be either short term or long term. 
Sampo's Board of Directors resolves all group level 
remuneration matters. The Nomination and 
Remuneration Committee supports the Board of 
Directors by preparing the proposals to the Board on 
the remuneration of the GEC members, Sampo Group's 
long-term incentive schemes (LTIs), maximum pay-outs 
based on short-term incentive programmes (STIs), as 
well as the actual payments to be made to the members 
of the GEC.
Sampo’s Remuneration Policy for Governing Bodies 
states that the performance measures of the STIs and 
LTIs of the Group CEO may include, for example, 
shareholder value creation, financial or operative key 
performance indicators (KPIs), and sustainability 
performance criteria. The Board members are 
independent of the companies and do not participate in 
variable compensation programmes.	
Torbjörn Magnusson retired from his position as 
Sampo’s Group CEO on 30 September 2025. In June 
2025, the Board of Directors appointed Morten 
Thorsrud as the new Group CEO effective from 1 
October 2025. Detailed information on the 
remuneration of both Magnusson and Thorsrud, based 
on the time they worked as Group CEO of Sampo in 
2025, is available in Sampo plc’s Remuneration Report 
for Governing Bodies 2025.
The Group CEO participates in a one-year STI 
programme, where the payout is triggered by an 
underlying performance criterion and the outcome is 
determined on the basis of key financial and non-
financial performance criteria related to Sampo Group 
and its subsidiaries. The maximum amount that can be 
paid to the Group CEO from the 2025 programme 
corresponds to 12 months' fixed salary. Part of the 
payout shall be deferred for at least three years as 
required in the regulatory framework applicable to 
Sampo.
Both Magnusson and Thorsrud also participate in the 
LTI scheme 2025 for Sampo Group’s key employees. 
The Group CEO has been allocated 117,847 (former 
Group CEO 196,284) performance incentive units with a 
value equivalent to 150 per cent of his annual base 
salary at the time of allocation. The number of 
performance incentive units that will vest ranges from 
0–117,847 (0–196,284 as regards the former Group CEO) 
and is dependent on performance criteria related to the 
development of the total shareholder return, 
operational performance, and sustainability. In addition, 
the performance incentive units are subject to Sampo A 
share price movements over the performance period. 
The scheme has a three-year performance period and at 
pay-out from the 2025 scheme, the Group CEO is 
obliged to purchase Sampo A shares with 50 per cent 
of the pay-out after deducting income tax and other 
comparable charges. The shares are subject to disposal 
restrictions for three years, after which the Board of 
Directors shall decide on the possible release.
10 per cent of the reward from the LTI scheme 2025 is 
subject to the performance of Sampo Group’s work 
related to sustainability. The sustainability performance 
criterion consists of Group and subsidiary balanced 
scorecards relating to the development, 
implementation, and execution of science-based targets 
(SBTs). In addition to the LTI criterion, Sampo Group 
did not factor further greenhouse gas (GHG) emission 
reduction targets into remuneration in 2025.
GOV-4 – Statement on due diligence
The main aspects and steps of Sampo Group’s due 
diligence process are described under the applicable 
disclosure requirements in this Sustainability Statement. 
The table Main aspects and steps of the due diligence 
process (p. 61) lists the reported information. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 60

===== SIDA 61 =====

Main aspects and steps of the due diligence process
Sampo Group
Core elements of 
due diligence Paragraphs in the Sustainability Statement
General disclosures and Governance information Environmental information Social information
Embedding due 
diligence in 
governance, 
strategy, and 
business model
• How sustainability matters are addressed in Sampo 
Group's management (p. 59)
• STIs, LTIs, and the ESG criteria included in 
remuneration (p. 60)
• Material impacts, risks, and opportunities (IROs), and 
their linkage to the Group's strategy and business 
model (p. 67)
• Material IROs in relation to business conduct (p. 121)
• STIs, LTIs and the ESG criteria-related to science-
based targets (p. 60)
• Material IROs in relation to climate change (p. 77) and 
resource use and circular economy (p. 91)
• Material IROs in relation to own workforce (p. 94), 
workers in the value chain (p. 107) and consumers 
and end-users (p. 113)
Engaging with 
affected 
stakeholders in 
all key steps of 
the due diligence
• How sustainability matters are addressed in Sampo 
Group's management (p. 59)
• How interests and views of stakeholders are taken 
into account in the Group’s strategy and business 
model (p. 65)
• How the process to identify IROs and assessing 
materiality is informed by the due diligence process 
and includes consultation with affected stakeholders 
(p. 69)
• Policies related to business conduct and corporate 
culture (p. 122)
• Process to identify and assess IROs related to climate 
change and resource use and circular economy, 
including how affected stakeholders have been 
considered (p. 69)
• Policies related to climate change (p. 81) and 
resource use and circular economy (p. 92)
• How interests and views of own workforce, workers 
in the value chain, and consumers and end-users are 
taken into account in strategy and business model 
(p. 65)
• Policies related to own workforce (p. 95), workers in 
the value chain (p. 108), and consumers and end-
users (p. 114) 
• Processes for engaging with own workforce (p. 96), 
workers in the value chain (p. 110), and consumers 
and end-users (p. 115), including grievance 
mechanisms and remediation of negative impacts
Identifying and 
assessing 
adverse impacts
• Description of the double materiality assessment, 
including specific information on the process to 
identify and assess governance-related negative 
impacts (p. 69)
• Identified material IROs, as well as how negative 
impacts interact with strategy and business model 
(p. 67)
• Description of the double materiality assessment, 
including additional description of the process to 
identify and assess climate and circular economy-
related negative impacts (p. 69)
• How negative impacts related to climate change 
interact with strategy and business model as well as 
additional information about climate-related risks 
(p. 78)
• Description of the double materiality assessment 
(p. 69)
• How negative impacts related to own workforce 
(p. 95), workers in the value chain (p. 108), and 
consumers and end-users (p. 114) interact with 
strategy and business model
Taking actions to 
address those 
adverse impacts
• Management of supplier relationships and prevention 
and detection of corruption and bribery (p. 122)
• Actions and resources related to climate change 
(p. 81) and resource use and circular economy 
(p. 92)
• Transition plan for climate change mitigation (p. 79)
• Actions and resources related to own workforce 
(p. 97), workers in the value chain (p. 111), and 
consumers and end-users (p. 117)
Tracking the 
effectiveness of 
these efforts and 
communicating
• Metrics and targets related to business conduct 
(p. 124)
• Metrics and targets related to climate change (p. 84) 
and resource use and circular economy (p. 93)
• Metrics and targets related to own workforce (p. 98), 
workers in the value chain (p. 112), and consumers 
and end-users (p. 118)
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 61

===== SIDA 62 =====

GOV-5 – Risk management and internal 
controls over sustainability reporting
Sampo Group’s risk management and internal control 
systems related to the sustainability reporting process 
are part of the Group’s overall risk management. As part 
of internal control framework, Sampo Group has 
comprehensive risk management procedures in place to 
ensure the functioning of the reporting processes, 
including sustainability reporting. Risk management 
procedures include risk identification, assessment, 
measurement, monitoring, and reporting.
Sampo Group identifies and assesses risks related to its 
operations on a regular basis. The process takes into 
account the causes and consequences of the risks and 
the existing controls. In addition to assessing the 
likelihood and impact of the risk realisation, Sampo 
Group assesses the need for possible additional 
measures. Based on the assessment, the risks are 
arranged in the order of their significance. During the 
risk identification and assessment, an owner is 
appointed for all identified risks. The owner is 
responsible for taking action and developing measures 
in relevant internal functions based on the findings.
Risks related to the sustainability reporting process are 
mainly linked to the accuracy or completeness of the 
data and information presented. Sampo Group controls 
these risks, for example, through internal policies and 
guidelines, well-defined responsibilities and duties, the 
use of the four-eyes principle, and other controls (e.g. 
access rights, reporting systems).
The most significant risks and related mitigation 
measures are regularly discussed, for example, in the 
Group’s risk committees. Chief Risk Officers (CROs) 
report risks to the respective senior management and 
the Board of Directors.
Strategy
SBM-1 – Strategy, business model, and value 
chain
Sampo Group’s strategy focuses on P&C insurance; 
investing in and developing its P&C insurance 
operations in the Nordic and Baltic regions and the UK. 
The strategy is based on disciplined underwriting, 
strong operational capabilities, and customer centricity. 
Combined with careful risk management, this enables 
Sampo Group to deliver growth at attractive margins 
and strong financial resilience, both of which the Group 
considers essential to value creation.
Sampo Group’s insurance operations are conducted 
through If and Hastings. The subsidiaries are responsible 
for pricing their products and services, organising their 
sales and implementation processes, ensuring the 
profitability, efficiency, quality, security, and continuity 
of their operations, as well as for liabilities towards their 
customers. The subsidiaries are also responsible for the 
management of assets and liabilities, risks, and 
capitalisation on the business area and company level.
Sampo Group provides safety to customers through its 
high-quality P&C insurance products. Safety is enabled 
by a detailed understanding of various risks that the 
Group underwrites. By pooling risks, Sampo Group 
balances the various risks of the customer base and 
provides insurance coverage for events that can be 
complex for customers to prepare for without P&C 
insurance products.
Safety and value creation are achieved through the 
expertise of Sampo Group’s employees and 
collaboration with suppliers and other business 
partners. The value created for customers flows in the 
form of compensation to the Group's employees and 
suppliers, and as potential returns to shareholders. This 
safety also benefits society at large, enabling other 
sectors to continue creating value through their value 
chains, which are insured for perils with Sampo Group’s 
P&C insurance solutions.
Sampo Group’s activities are divided into own 
operations, and an upstream and downstream value 
chain. The Group’s own operations are focused on P&C 
insurance operations, with an emphasis on underwriting 
and managing risk, customer support, and investment 
operations. Sampo Group’s upstream value chain 
includes suppliers of office products and services (e.g. 
ICT suppliers, external data providers) who support the 
running of the business. In the downstream value chain, 
Sampo Group has a large network of suppliers and 
business partners, of which suppliers in claims handling 
and loss prevention (e.g. vehicle and property repair 
contractors), and partners in health and travel services 
form a major part. The main features of Sampo Group’s 
value chain are described in the figure Value chain 
(p. 63).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 62

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

Value chain
Sampo Group
Significant groups of products, services and markets
Sampo Group’s operations are diversified by 
geography, line of business, and customer segment. The 
Group operates in Denmark, Sweden, Norway, Finland, 
the UK, and the Baltic countries. Sampo Group’s largest 
customer group is private individuals in the Nordics and 
the UK. The key product categories for private 
individuals are motor and home insurance, but the 
Group also offers other insurance covers in the Nordics, 
such as travel insurance and personal accident covers. 
Sampo Group’s second largest business segment is 
Nordic commercial insurance. While property and 
motor insurance risks dominate in the commercial 
segment, certain liability covers are also prominent.In 
addition, Sampo Group is a leading provider of 
industrial lines P&C insurance in the Nordic region.
As at 31 December 2025, Sampo Group’s total 
employee headcount was 16,157. The number of 
employees by geographical areas is presented under 
the disclosures related to own workforce in the section 
S1 – Own Workforce (p. 100).
Sampo Group’s insurance revenue totalled EUR 10,272 
million in 2025. More information on the breakdown of 
revenue in accordance with operating segments is 
available under the heading Result by segment for 
twelve months ended 31 December 2025 (p. 160) in the 
Financial Statements.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 63

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

Sustainability programme
Sampo Group
Integration of sustainability into business
Sampo Group’s strategy and purpose link to 
sustainability. The Group creates value and provides 
safety to its stakeholders and society through high-
quality P&C insurance solutions, which are developed 
by understanding risks and managing them responsibly. 
Sustainability is integrated into the Group’s core 
business operations. In terms of insurance operations, 
this means, for example, that the Group takes ESG 
considerations into account in underwriting (e.g. setting 
expectations for corporate customers to respect 
international norms and standards, integrating 
sustainability considerations into underwriting principles 
and other relevant policies), provides loss prevention 
services (e.g. risk management services), handles claims 
in a sustainable manner, and develops products and 
services in accordance with relevant legal requirements 
as well as customers’ needs and preferences. 
Sampo Group has a sustainability programme (see the 
figure), which supports the Group’s overall business and 
strategy, as well as drives group level sustainability 
work. The programme consists of three strategic 
sustainability themes: Climate and environment, People 
and communities, and Business management and 
practices, which are in turn divided into more specific 
topics relevant for the Group’s sustainability work. The 
sustainability programme addresses the regulatory 
demands, while also including areas that are critical 
especially for a company operating in the P&C 
insurance sector and important to the Group’s various 
stakeholders. The group level programme is put into 
practice by various business areas, operational 
departments, and units, and the work is monitored 
continuously. 
Sampo Group has set general objectives for each 
sustainability theme. Additionally, metrics and targets 
are in place to monitor the progress in more detail. 
Performance against the set targets is presented, for 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 64

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

example, in this Sustainability Statement. Science-based 
climate targets are disclosed under the E1 Climate 
change standard, metrics related to circular economy 
are disclosed under the E5 Resource use and circular 
economy standard, employee engagement is covered 
under the S1 Own workforce standard, customer 
satisfaction falls under the S4 Consumers and end-users 
standard, and metrics related to supplier codes of 
conduct can be found under the S2 Workers in the 
value chain standard. Compliance with internal policies 
and guidelines is discussed under multiple standards, as 
many of them focus on describing material policies and 
guidelines. Screening of investments and corporate 
customers is also addressed under several standards.
SBM-2 –Interests and views of stakeholders
Sampo Group’s key stakeholder groups are customers, 
investors, employees, suppliers and other business 
partners, investee companies, and local communities. 
Each key stakeholder group has several subcategories 
as described in the table Stakeholder engagement and 
dialogue (p. 66). Sampo Group’s stakeholders include 
potential and actual affected stakeholders (i.e., those 
affected by the Group’s business activities), and users 
of the Group’s Sustainability Statement. 
Sampo Group engages with all its stakeholder groups 
through a number of forums and on multiple topics. The 
intention is to engage in activities and dialogue that are 
best aligned with the needs of the Group and its 
stakeholders. Sampo Group seeks to ensure meaningful 
engagement with stakeholders, for example, by 
identifying relevant stakeholders, ensuring continuous 
and regular communication, and providing suitable 
forums for dialogue.
The purpose of stakeholder engagement is to build 
trust between Sampo Group and its stakeholders and to 
seek common benefits. The stakeholder engagement 
helps the Group to proactively consider the needs and 
wishes of its stakeholders. By focusing on stakeholder 
engagement, Sampo Group can mitigate potential risks, 
including uncertainty and dissatisfaction of its key 
stakeholder groups. Stakeholder engagement helps the 
Group foster its reputation, trust, and buy-in for the 
company’s key initiatives. In addition, Sampo Group 
considers stakeholder engagement to be a valuable 
source of information. The different stakeholders are 
experts in their own fields and can offer knowledge and 
expertise for the purposes of the Group. When relevant, 
Sampo Group can also offer its time and expertise to 
support the stakeholders.
As a result of the continuous dialogue, Sampo Group's 
key stakeholders can influence the Group's chosen 
strategy and business model over time. The views and 
interests of stakeholders are considered, where 
possible, when developing the strategy. As a result of 
stakeholder engagement, Sampo Group aims to 
advance its operations and relationship with 
stakeholders further. Examples of actions taken include 
improved external communications, customer service, 
and internal and external reporting, as well as 
developing processes according to best practices.
Sampo Group’s Board of Directors is informed about 
the views and interests of stakeholders as part of 
regular Board reporting and when considered 
necessary.
Engagement with own workforce, workers in the 
value chain, and customers and end-users
The interests, views, and rights of Sampo Group’s own 
workforce inform and support the Group’s strategic 
decisions. For instance, employee engagement surveys 
are conducted at least annually, and the results are 
reported to the respective management teams. The 
Group strives for a constructive, trustful, and open 
dialogue with employees and their elected 
representatives with the purpose of developing the 
company and safeguarding the correct treatment of all 
employees. The Group recognises the importance of 
workforce engagement, health, safety, wellbeing, work-
life balance, diversity, equity and inclusion (DEI), and 
professional development, among other factors. 
Sampo Group indirectly engages with value chain 
workers on material topics through its suppliers, 
investee companies, and corporate customers. The 
perspectives of these workers provide important 
insights for identifying and understanding the Group’s 
impacts on human rights and labour practices across its 
activities and business relationships. Engagement with 
value chain workers is integrated into daily business 
operations, for example, through due diligence 
processes.
For Sampo Group, the needs, preferences, and 
wellbeing of consumers and end-users is a key input 
informing strategy, and the Group’s business model is 
primarily shaped based on the interests of its 
customers. Sampo Group’s employees who develop and 
deliver insurance products and services are constantly 
monitoring and taking customers’ interests into 
consideration. The recognition of the interests of 
customers is complemented by the inputs and views of 
Sampo Group’s employees, suppliers, and other 
business partners in shaping the Group business model 
and strategy. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 65

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

Stakeholder engagement and dialogue
Sampo Group
Key stakeholder group Examples of forums for dialogue and approximate frequency Examples of discussion topics
Investors (current and potential shareholders and 
debt investors)
• Annual General Meeting (AGM) (annual)
• Capital Markets Day (CMD) (varying)
• Roadshows (quarterly)
• Events and seminars (quarterly)
• Virtual and face-to-face meetings (weekly)
• Financial performance and targets
• Strategy and Group structure
• Regulatory development
• Climate targets
• Executive remuneration
• Sustainability in general
Customers (e.g. private individuals, corporate 
customers, beneficiaries)
• Regular customer contact points, e.g. website, chat, contact 
centre (24/7 or daily)
• Customer feedback channels (24/7)
• Customer satisfaction surveys (24/7 or daily)
• Virtual and face-to-face meetings (daily)
• Customer Ombudsman (daily)
• Events and seminars (varying)
• Company publications, e.g. magazines (varying)
• Products and services 
• Loss prevention and claims handling
• Sustainability in general
• Market situation in general
• Responsible business practices (e.g. counteract financial crime 
and corruption)
Employees • Employee engagement surveys (biannual/annual)
• Performance appraisals and dialogue with leaders (varying)
• Work environment committees (varying)
• Meetings with union and employee representatives (varying)
• Employee representation and consultation forums (varying)
• Employee roadshows (on a needs basis)
• Social events (varying)
• Financial performance
• Diversity, equity, and inclusion
• Change in Group structure
• Employee engagement surveys
• Performance and development plans
• Business conduct, ethics, and sustainable workplace
Suppliers and other business partners (e.g. 
analysts, rating agencies)
• Questionnaires (varying)
• Virtual and face-to-face meetings (daily)
• Events and seminars (varying)
• Company publications, e.g. magazines (varying)
• Financial performance
• Sustainability in general (e.g. targets, performance, sustainability 
considerations, GHG emissions)
• Changes in Group structure
• Future plans
• Products and services
Investee companies • Virtual and face-to-face meetings (varying)
• Events and seminars (varying)
• AGMs of the investee companies (varying)
• Financial performance
• Market situation in general
• Regulatory development
• Sustainability in general (e.g. targets, performance, sustainability 
considerations, GHG emissions) 
Local communities (e.g. regulators, supervisors, 
industry associations, educational institutions, 
non-governmental organisations, general public, 
the media)
• Virtual and face-to-face meetings (weekly)
• Events and seminars (varying)
• Company publications, e.g. magazines (varying)
• Financial performance
• Regulatory development
• Sustainability in general
• Climate change
Sampo Group engages indirectly with value chain workers through its suppliers, investee companies, and corporate customers.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 66

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

SBM-3 – Material impacts, risks, and 
opportunities, and their interaction with 
strategy and business model
Sampo Group has conducted a double materiality 
assessment as required by the CSRD. The results of the 
assessment are presented in the figure Double 
materiality matrix. In 2025, Sampo Group reviewed its 
double materiality assessment. Based on the review, the 
Group reports no major changes to the material topics 
covered by the Sustainability Statement. Only minor 
adjustments were made in the reported impacts, risks, 
and opportunities to improve internal documentation, 
incorporate best practices (e.g. renaming and 
combining sustainability topics for clearer alignment 
with the ESRS standards), and enhance alignment of 
reporting across the Group. The adjustments are related 
to the topics E1 Climate change, S1 Own workforce, S2 
Workers in the value chain, S4 Consumers and end-
users, and G1 Business conduct.
All the impacts, risks, and opportunities reported in the 
Sustainability Statement 2025 are covered by the ESRS 
disclosure requirements, as Sampo Group does not 
include entity-specific disclosures in the statement. 
However, Sampo Group has introduced entity-specific 
metrics to complement the disclosure requirements 
related to the ESRS standards E1 Climate change, E5 
Resource use and circular economy, S1 Own workforce, 
S2 Workers in the value chain, and S4 Consumers and 
end-users. Based on the identified risks and 
opportunities in the double materiality assessment, 
Sampo Group does not anticipate any material 
adjustments to the carrying amounts of assets and 
liabilities reported in the related financial statements 
within the next annual reporting period.
Double materiality matrix
Sampo Group
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
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Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 67

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

At Sampo Group, resilience to sustainability issues is 
ensured by continuous adaptation of risk assessment 
and pricing strategies to account for emerging 
sustainability factors, thereby ensuring long-term 
profitability and stability of the business. Adapting the 
strategy and business model according to sustainability 
issues is critical for Sampo Group in terms of 
maintaining customer confidence and reducing financial 
risks, and the Group continuously invests in its people 
and technology to ensure that it maintains its 
competitive edge. Combined with careful risk 
management, this enables Sampo Group to deliver 
quality customer experience, attractive margins, and 
strong financial resilience. Resilience towards material 
impacts, risks, and opportunities is assessed as a part of 
Sampo Group’s processes for sustainability 
management, risk management, and strategy 
development. More information on how the Group’s 
strategy and business model interact with material 
impacts, risks, and opportunities is available in the 
Strategy section under the topical ESRS standards.	
A short summary of the material sustainability topics is 
presented next. A more thorough specification of the 
material topics, related impacts, risks, and opportunities, 
as well as Sampo Group’s approach to managing them 
is presented at the beginning of each topical ESRS 
standard of this Sustainability Statement.
Climate change
The climate impact of Sampo Group’s own operations is 
minor, as the direct GHG emissions are relatively low. 
When considering the whole value chain, including 
investments, insured assets, and suppliers, the negative 
impact of GHG emissions is more significant. 
Sampo Group has recognised both climate-related 
physical risks and transition risks. Physical risks include 
more frequent and severe natural disasters and 
changing weather patterns, which can translate into 
increased claims due to damages caused, for example, 
by storms and floods. Transition risks, on the other 
hand, emerge during the shift to a low-carbon 
economy. These risks are driven by changes in the 
regulatory environment, new technology, changing 
customer behaviour, and increased interest in and 
concern for environmental matters.
Climate-related physical risks are already relevant in the 
short term and are likely to grow in the medium to long 
term. At Sampo Group, the risks are managed through a 
combination of pricing, diversification, and reinsurance. 
The insurance solutions provide customers with 
coverage against natural hazards and provide support 
and incentives for loss prevention measures and claims 
handling. There can also be some climate-related 
opportunities in areas such as loss prevention.
Resource use and circular economy
Sampo Group uses resources in its business operations, 
particularly in claims handling. Resource use inherently 
causes negative environmental impacts, which the 
Group can mitigate by adopting and expanding circular 
practices in product development and claims handling.  
These practices can also lead to long-term cost 
reductions for Sampo Group by decreasing the use of 
virgin materials.
Own workforce
Sampo Group strives to create an engaging work 
environment that fosters creativity, innovation, and 
wellbeing, promotes DEI, and encourages employees on 
their career paths, thereby generating positive social 
impact. When employees feel a sense of belonging 
within an organisation, they are more likely to stay 
longer. Failing to meet these expectations can lead to 
increased employee turnover and challenges in 
recruiting a competent workforce, which, in turn, may 
pose a financial risk. 
Workers in the value chain
Sampo Group has an impact on workers in the value 
chain, especially through its downstream suppliers (e.g. 
suppliers within claims handling), business partners, 
corporate customers, and investees. The risk of 
negative impacts related to human rights and labour 
practices can be mitigated through strong policies and 
governance structures, but due to the complexity of the 
value chain and the limits of engagement, they cannot 
be entirely eliminated. Due to increasing regulation and 
potential reputational issues, such negative impacts 
may also lead to financial risks.
Consumers and end-users 
Through careful risk management and disciplined 
underwriting, Sampo Group can have a positive impact 
on the health and safety of consumers and end users, 
creating business opportunities for the Group. Failing to 
meet customer expectations related to issues such as 
data privacy or sales practices can negatively affect 
customers and, consequently, pose financial and 
reputational risks.
Business conduct
At Sampo Group, good corporate governance is seen as 
a baseline. By promoting high standards related to 
topics such as anti-corruption, anti-bribery, responsible 
business practices, and sustainable partnerships and 
supply chain, the Group can contribute to the overall 
security of society.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 68

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

Impact, risk and opportunity 
management
IRO-1 – Description of the process to identify 
and assess material impacts, risks, and 
opportunities
The purpose of Sampo Group’s double materiality 
assessment is to identify sustainability matters that 
could trigger risks or opportunities influencing the 
Group’s ability to create and protect value (financial 
materiality), as well as sustainability matters related to 
the Group’s business that could have positive or 
negative impacts on society, people, or the environment 
(impact materiality). The double materiality assessment 
serves as a basis for identifying the information to be 
included in the Sustainability Statement. The 
methodology used in the assessment follows the 
legislative requirements and supporting guidance 
provided by the European Financial Reporting Advisory 
Group (EFRAG).  
Sampo Group’s first double materiality assessment, 
completed in 2024, was conducted in collaboration with 
an external partner. Since then, the Group has 
continued to develop and carry out the assessment 
internally. As required by legislation, Sampo Group 
annually reviews its double materiality assessment and 
reports any changes to the process or results as part of 
the sustainability statement. In 2025, there were no 
major changes in the Group’s operations, and 
consequently, there are no changes in the reported 
material sustainability topics. During the 2025 review, 
Sampo Group enhanced its assessment process based 
on EFRAG’s additional methodological guidance and 
industry best practices. The following process 
description has been updated to reflect the adjustments 
made during the review.
The double materiality assessment began with the 
identification of an initial list of impacts, risks and 
opportunities associated with sustainability topics 
potentially material to Sampo Group. This list was 
compiled based on, for example, the sustainability 
topics and sub-topics included in the ESRS standards, 
GRI Standards, the SASB Standards for the insurance 
sector, industry benchmarking, media and megatrend 
analysis, Sampo Group’s previous materiality 
assessment, ESG ratings and reports, information on the 
Group’s investments, as well as investor meetings and 
feedback.
Representatives from different parts of the Group 
participated in workshops to identify and validate 
impacts, risks, and opportunities associated with the 
sustainability topics. In the workshops, impacts, risks, 
and opportunities were mapped according to their 
expected location within Sampo Group’s value chain. 
The expected time horizons during which the impacts, 
risks, and opportunities may materialise were also 
defined: short term (less than 1 year), medium term (1–5 
years), and long term (over 5 years).
In assessing impacts, Sampo Group drew on regular 
dialogue with stakeholders and documentation of 
affected stakeholders’ perspectives, which are collected 
continuously through the Group’s existing channels. For 
social impacts specifically, findings from Sampo Group’s 
human rights impact assessment were utilised to ensure 
the inclusion of affected stakeholders’ perspectives. 
Sampo Group’s main stakeholders and forums for 
stakeholder dialogue are presented as a part of this 
Sustainability Statement under the heading SBM-2 – 
Interest and views of stakeholders (p. 65). 
When assessing impact materiality, each identified 
impact was categorised based on whether its effect on 
society, people, or the environment was positive or 
negative, and whether it was actual or potential. The 
criteria used to determine the impact materiality score 
for each impact included scale and scope. For negative 
impacts, the irremediable character of the impact was 
also considered. For potential positive and negative 
impacts, Sampo Group estimated the likelihood of the 
impact occurring. In the event of a potential negative 
human rights impact, the severity was assumed to take 
precedence over likelihood, in accordance with the 
requirement in the ESRS 1. 
When evaluating financial materiality, each risk and 
opportunity was assessed based on its financial impact 
on the business and value creation, including financial 
performance and potential effects on Sampo Group’s 
reputation and share price, for instance. The identified 
impacts on society, people, and the environment and 
dependencies on natural, human and social resources of 
Sampo Group's business model served as the starting 
point for the risk and opportunity identification. The 
criteria used to assess financial materiality for each risk 
and opportunity were the potential magnitude of its 
financial effects and the likelihood of occurrence. 
Thresholds were set based on the quantitative 
assessment of severity of impact/size of financial effect 
and likelihood, using the expertise and perspectives of 
involved stakeholders. An impact, risk, or opportunity 
was determined to be material, if its total score, 
consisting of the assessed severity/financial effect and 
likelihood exceeded the threshold value. If at least one 
impact, risk or opportunity was determined to be 
material, the associated sustainability topic was 
assessed to be material. Sampo Group assessed each 
applicable criterion for a specific impact, risk, and 
opportunity on the same scale. The quantitative 
thresholds were used in order to facilitate the 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
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Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 69

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

judgement of materiality, and the comparability 
between topics and sub-topics. However, the 
assessment is primarily qualitative.   
Sustainability-related risks are part of Sampo Group’s 
overall risk management and follow the same process 
as the Group’s other risks. The sustainability risks 
identified through overall risk management were taken 
into account in the double materiality assessment. 
Identified impacts are considered and addressed 
indirectly through the Group’s risk management process 
when they relate to the Group’s risks. The Group’s 
process for identifying, assessing, and managing 
sustainability-related opportunities is embedded in its 
management protocols, ensuring strategic alignment 
with business objectives and operational decisions. 
Sampo’s Board and its Audit committee validate the 
final results of the double materiality assessment as a 
part of the reporting on this Sustainability Statement.  
Climate change
In addition to conducting the double materiality 
assessment, Sampo Group uses GHG emissions 
calculations, climate-related scenario analyses, and 
various risk management practices, such as internal 
models, price analyses, stress tests, and sensitivity 
analyses, to identify and evaluate climate-related 
impacts, risks, and opportunities. Both the Group’s own 
operations and its value chain are considered in the 
process.
Climate-related impacts are assessed by calculating the 
GHG emissions from the Group’s own operations 
(Scopes 1 and 2) as well as from its value chain, which 
includes investments, insured assets, and suppliers 
(Scope 3). The climate impact of Sampo Group’s Scope 
1 and 2 GHG emissions is minor, as the amount of 
emissions is relatively low. When considering the Scope 
3 GHG emissions from the whole value chain, the impact 
is more significant. The scope, methodology, and results 
of these calculations are described in this Sustainability 
Statement under the heading E1-6 – Gross Scopes 1, 2, 
and 3 and total GHG emissions (p. 86).
Sampo Group assesses climate-related physical and 
transition risks in its own operations and value chain as 
part of the existing risk management practices. These 
include, for example stress tests and scenario analyses, 
in which the severity of natural catastrophes is assumed 
to increase. The scope, methodology, and results of the 
Group’s scenario analysis are described in this 
Sustainability Statement under the heading 
SBM-3 – Material impacts, risks, and opportunities and 
their interaction with strategy and business model 
(p. 78). In the short term, physical climate risks arise in 
the form of changes in claims frequencies and/or 
severity of the climate-related extreme weather events 
that are already relevant in the current climate in the 
Nordics, such as windstorms, floods, heavy rainfall, 
hailstorms, landslides, erosion, and heatwaves. In the 
medium to long term, increased weather-related losses 
will likely increase the exposure for P&C insurers.
Climate-related transition risks are associated with 
changes in the regulatory environment, new 
technologies, shifting customer behaviour, and 
increased stakeholder concern. Companies insured by 
Sampo Group may be exposed to litigation under new 
climate-related regulations, which may lead, for 
example, to higher claims costs in liability insurance. 
Increased concern from stakeholders, such as investors, 
customers, and reinsurers, can result in increased due 
diligence costs and the need to discontinue business 
relationships with certain suppliers or customers.
Sampo Group has also identified some potential 
opportunities related to climate change, such as those 
associated with loss prevention and the potential to 
invest in new green technologies. An increase in 
climate-related physical risks can drive greater demand 
for loss prevention services that offer protection against 
such risks and support climate change adaptation. The 
development of new products and services is part of 
Sampo Group's ongoing business development and 
innovation. Risk management services are already 
included in the Group’s offering for both corporate and 
private customers. 
Pollution, and Water and marine resources
Sampo Group has assessed that pollution, and water 
and marine resources are not material sustainability 
topics for a company operating in the P&C insurance 
industry. Therefore, the Group has not screened its 
assets, business activities, and site locations or 
conducted consultations with affected communities 
regarding these topics.
Biodiversity and ecosystems
As a P&C insurance company, the impact of Sampo 
Group’s own operations on biodiversity and ecosystems 
is limited. Therefore, the Group has not screened its site 
locations or conducted consultations with affected 
communities regarding the topic. Sampo Group’s most 
relevant impacts, dependencies, risks, and opportunities 
related to biodiversity and ecosystems are linked to its 
value chain, primarily through underwriting and 
investment operations. The Group has conducted an 
initial screening of its investments and corporate 
customers to assess exposure to sectors associated 
with high biodiversity impacts and dependencies. Based 
on the initial findings, Sampo Group will further deepen 
the screening, by also considering sensitive geographic 
locations and actions to mitigate the impacts, in 
accordance with the recommendations of the Taskforce 
on Nature-related Financial Disclosures (TNFD). In 
addition, the Group will further develop its monitoring 
and reporting practices. In the coming years, Sampo 
Group will re-evaluate the materiality of this topic as 
part of the annual double materiality assessment. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 70

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

Resource use and circular economy
The process for identifying material impacts, risks, and 
opportunities related to resource use and circular 
economy is primarily based on information already 
available within Sampo Group, particularly regarding 
claims handling operations, where the Group’s impacts, 
risks, and opportunities related to this topic are largely 
concentrated. Affected communities were not 
specifically consulted in relation to resource use and 
circular economy due to the Group's industry, business 
model, and the limited use of resources in its own 
operations. Sampo Group has several channels for 
stakeholder dialogue where topics such as circular 
economy and resource use can be raised (p. 66).
Business conduct
When identifying and assessing material impacts, risks, 
and opportunities, Sampo Group has evaluated the 
geographical context of its operations, taking into 
account the regulatory landscape that may influence 
these impacts. Operating within the P&C insurance 
sector, Sampo Group has also recognised industry-
specific risks and opportunities, and considered the 
Group specific operations, including the product 
offerings and service delivery methods.
IRO-2 – Disclosure Requirements in ESRS 
covered by the undertaking’s sustainability 
statement
Based on the results of the double materiality 
assessment, Sampo Group reports material disclosure 
requirements related to the ESRS topical standards E1 
Climate change, E5 Resource use and circular economy, 
S1 Own workforce, S2 Workers in the value chain, S4 
Consumers and end users, and G1 Business conduct as 
part of this Sustainability Statement. A full list of 
disclosure requirements complied with in preparing this 
Sustainability Statement is presented in the ESRS 
content index in Annex 1 (p. 125). A list of data points 
deriving from other EU legislation can be found in 
Annex 2 (p. 127).
According to the double materiality assessment, Sampo 
Group does not report disclosure requirements related 
to the ESRS standard E4 Biodiversity and ecosystems. 
Currently the topic is not material based on the Group’s 
internal analysis and external stakeholder feedback. 
Additionally, the disclosure requirements laid out by the 
ESRS standard are in many cases not applicable to 
insurance companies. Nevertheless, biodiversity and 
ecosystems is a topic Sampo Group will closely follow 
and work on, and it is also connected to the Group’s 
climate work and reporting. Sampo Group will re-
evaluate the materiality and reporting requirements 
related to the topic annually as part of the double 
materiality assessment.
The disclosure requirements related to the ESRS 
standard S3 Affected communities were also excluded 
from this Sustainability Statement. As a P&C insurance 
company operating mainly in the Nordic countries, 
Sampo Group’s direct impacts on topics such as 
adequate housing and freedom of expression are 
considered limited. However, the Group reports on its 
stakeholder engagement as part of the ESRS 2 
standard, and considers topics related to affected 
communities where relevant. 
Sampo Group does not report on disclosure 
requirements related to the ESRS standards E2 
Pollution and E3 Water and marine resources, as the 
impacts, risks, and opportunities related to these topics 
are not considered material for the Group.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 71

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

Environmental information
EU Taxonomy
The EU Taxonomy (Taxonomy) is a classification system 
that translates the EU’s climate and environmental 
objectives into criteria for specific economic activities 
for investment purposes. The basic principle of the 
Taxonomy is that for an economic activity to be 
recognised as environmentally sustainable (Taxonomy-
aligned), it must make a substantial contribution to at 
least one of the EU’s climate and environmental 
objectives, which are climate change mitigation; climate 
change adaptation; sustainable use and protection of 
water and marine resources; transition to a circular 
economy; pollution prevention and control; and 
protection and restoration of biodiversity and 
ecosystems. In addition, the economic activity cannot 
significantly harm any of these objectives and must 
meet the minimum safeguards criteria. The Taxonomy 
Delegated Acts establish and maintain criteria (i.e. 
technical screening criteria) for activities which have a 
substantial positive environmental impact.
Companies are required to report on Taxonomy 
eligibility (i.e. reporting on whether the economic 
activity is included in the Taxonomy Delegated acts) 
and Taxonomy alignment (i.e. reporting on whether the 
economic activity meets the technical criteria for i) 
substantial contribution, ii) do no significant harm, and 
iii) comply with minimum safeguards). Insurance 
companies are required to report KPIs on sustainable 
underwriting activities and sustainable investments. The 
first one refers to the proportion of the non-life gross 
written premiums (GWP) – in relation to total non-life 
GWP – corresponding to insurance activities identified 
as environmentally sustainable in the Taxonomy, and 
the second one to the proportion of the insurer’s or 
reinsurer’s investments – in relation to total insurer’s or 
reinsurer’s investments – that are directed at or 
associated with funding economic activities that qualify 
as environmentally sustainable.
Sampo Group’s Taxonomy disclosures for the year 2025 
are based on the Delegated Regulation (EU) 2026/73, 
which adopted a set of measures to simplify the 
application of the Taxonomy. The effect of amended 
regulation on the Group’s reported figures are explained 
under the headings Underwriting activities (p. 73) and 
Investment activities (p. 75).
In 2025, the weighted averages of Sampo Group’s 
Taxonomy-aligned activities concerning both 
underwriting and investments were 1.8 per cent 
(turnover-based) and 2.1 per cent (capital expenditures-
based).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 72

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

Underwriting activities 
Non-life insurance and reinsurance are recognised by 
the Taxonomy as enabling economic activities that can 
make a substantial contribution to the environmental 
objective of climate change adaptation. At the time of 
writing this Sustainability Statement, the Taxonomy 
does not define other environmental objectives for 
insurance activities. The non-life insurance activities 
listed in the Taxonomy Delegated Acts are medical 
expense insurance, income protection insurance, 
workers’ compensation insurance, motor vehicle liability 
insurance, other motor insurance, marine, aviation, and 
transport insurance, fire and other damage to property 
insurance, and assistance. 
Methodology 
To be Taxonomy-eligible, a non-life insurance activity 
must provide coverage against climate-related perils 
(e.g. floods, landslides, heat stress). Sampo Group 
follows in its methodology the European Commission 
Notice on the interpretation of certain legal provisions 
of the Disclosures Delegated Act under Article 8 of the 
Taxonomy Regulation, published on 21 December 2023. 
This means that solely the share of insurance premiums 
that pertain to the coverage of climate-related perils is 
reported as eligible. The premiums for which Sampo 
Group has not been able to obtain the necessary data 
related to climate-related perils are reported as non-
eligible.
For an eligible insurance activity to be classified as 
Taxonomy-aligned, it must fulfil the technical screening 
criteria of:
• Substantial contribution to climate change 
adaptation:  
– Leadership in modelling and pricing of climate risks
– Product design 
– Innovative insurance coverage solutions 
– Data sharing 
– High level of s e r v i c e  i n  p o s t - d i s a s t e r  s i t u a t i o n  
• Do No Significant Harm (DNSH) climate change 
mitigation criteria: The activity does not include 
insurance of the extraction, storage, transport, or 
manufacture of fossil fuels or insurance of vehicles, 
property, or other assets dedicated to such purposes.
When assessing the Taxonomy alignment, Sampo 
Group has concentrated on the most relevant products 
in terms of climate change adaptation, which are mainly 
related to fire and other damage to property line of 
business. For the products where potential alignment 
with the technical screening criteria was identified, a 
more thorough and granular product-level analysis (e.g. 
based on a policy, country, or element) was conducted 
to identify the specific premiums that are in scope for 
Taxonomy-alignment. Only the part of the premiums 
that pertains to the coverage of climate-related perils 
was deemed to be aligned.
For assessing the DNSH-criteria, Sampo Group has used 
NACE codes to extract contracts that could be related 
to the extraction, storage, transport, or manufacture of 
fossil fuels, and those are excluded from the Taxonomy-
aligned premiums. This screening has been performed 
on Sampo Group’s industrial and commercial 
customers.
For an economic activity to be considered as Taxonomy-
aligned, a company carrying the activity must also meet 
the minimum safeguards, which are due diligence and 
remedy procedures implemented to ensure alignment 
with the Organisation for Economic Co-operation and 
Development (OECD) Guidelines for Multinational 
Enterprises and the UN Guiding Principles on Business 
and Human Rights. Sampo Group has implemented the 
required policies and taken actions to be compliant with 
the safeguards. Sampo Group has, for example, 
conducted a human rights impact assessment, and 
continues to ensure that the adequate human rights due 
diligence processes are maintained and constantly 
developed across the Group. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 73

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

Underwriting KPIs 
The analysis, which is based on the above-mentioned 
interpretations, shows that 3.9 per cent (3.0 per cent in 
2024) of Sampo Group’s total non-life GWP were 
Taxonomy-eligible and 1.1 per cent (1.3 per cent in 2024) 
were Taxonomy-aligned in 2025. All the Taxonomy-
aligned premiums are related to fire and other damage 
to property insurance. In 2025, Sampo Group’s share of 
Taxonomy-eligible and -aligned premiums remained at 
the same level compared to the previous year, and no 
new Taxonomy-aligned products were introduced.
Sampo Group reports the underwriting KPIs in 
accordance with the simplified reporting template as 
presented in the Delegated Regulation (EU) 2026/73. In 
2025, the Group did not utilise the option to omit 
assessing the Taxonomy eligibility and alignment for 
non-material premiums (premiums which cumulatively 
constitute less than 10 per cent of total non-life gross 
written premiums).
Sampo Group does not report eligibility or alignment 
related to nuclear and fossil gas activities. Breakdown of 
the underwriting eligibility and alignment figures in 
nuclear and gas activities cannot be derived as being 
covered by the applicable regulatory specifications, as 
these activities do not form constituents of the 
underwriting KPI.
Going forward, Sampo Group monitors the 
development of the legislation as well as the market 
expectations and customer needs in this area. In the 
coming years, Sampo Group aims to increase the share 
of Taxonomy-aligned underwriting activities in its 
insurance portfolio if considered material.
Taxonomy-eligible and Taxonomy-aligned non-life insurance and reinsurance activities 
Sampo Group
Non-life insurance and reinsurance underwriting 
activities
Absolute 
premiums, 
2025
Proportion of 
premiums, 
2025
Absolute 
premiums, 
2024
Proportion of 
premiums, 
2024
EURm % EURm %
Taxonomy-aligned activities 109  1.1% 127  1.3% 
Nuclear activities N/A N/A N/A N/A
Fossil gas activities N/A N/A N/A N/A
Taxonomy-eligible activities 400  3.9% 289  3.0% 
Nuclear activities N/A N/A N/A N/A
Fossil gas activities N/A N/A N/A N/A
Non-assessed activities considered non-material –  –% N/A N/A
Total 10,199  100.0% 9,504  100.0% 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 74

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

Investment activities
The Taxonomy requires insurance companies to report 
the proportion of underlying investments that are 
Taxonomy-eligible and -aligned. To facilitate this type 
of reporting at portfolio level, all holdings need to be 
screened and analysed in relation to the economic 
activities of the Taxonomy.
Methodology
As required by the legislation, Sampo Group analysed 
all underlying investments to the counterparties, which 
are subject to Articles 19a or 29a of Directive 2013/34/
EU, and Article 8 of the Taxonomy Regulation (so called 
Non-Financial Reporting Directive, NFRD, 
undertakings), as well as investment property. 
Exposures to counterparties which are not subject to 
the above mentioned articles and for which it is not 
possible to carry out an assessment of Taxonomy-
eligibility or Taxonomy-alignment (e.g. derivatives, cash 
and cash equivalents, on demand bank loans, goodwill, 
commodities and sovereign exposures) were left out of 
the analysis and are excluded from the denominator of 
the investment KPIs.
Reporting requirements also obligate insurance 
undertakings to distinguish the proportion of the 
investments held in respect of life insurance contracts, 
where the investment risk is borne by the policyholders, 
and the proportion of remaining investments. Sampo 
Group has no investments held in respect of life 
insurance contracts where the investment risk is borne 
by the policyholders.
The Taxonomy analysis of Sampo Group’s investments 
was performed with the use of data from an external 
data provider, Bloomberg Finance LP (Bloomberg). 
Bloomberg identified companies engaged in economic 
activities covered by the Taxonomy and produced all 
Taxonomy indicators directly based on the respective 
investee companies’ own reporting of Taxonomy 
eligibility and alignment. The indicators were provided 
based on both underlying companies’ revenue and 
capital expenditures. As security-specific (e.g. mortgage 
bonds) eligibility and alignment data is still scarce, most 
of the securities’ eligibility and alignment data was 
matched to the issuer’s reported data. Companies’ 
reported eligibility and alignment data was not modified 
in any way by the data provider or by Sampo Group, 
and therefore it includes some discrepancies (e.g. 
breakdown of alignment to environmental objectives 
does not correspond to total alignment).
The relevant investment assets were analysed 
according to the Taxonomy reporting requirements by 
using both data provided by Bloomberg and data 
gathered based on each individual security's issuer. The 
investments in the NFRD and non-NFRD undertakings 
were identified by using data provided by Bloomberg. 
Similarly, investments in undertakings categorised as 
financial and non-financial were identified by using 
Bloomberg. As Bloomberg does not cover all NFRD 
undertakings, some unidentified NFRD undertakings 
may have been included in the assets not covered by 
the analysis. Fund investments were analysed using 
fund look-through (FLT) data where available. Some 
FLT data is updated in longer cycles and thus the most 
recent available FLT data was used for the Taxonomy 
calculations. 
For Sampo Group’s investment property, no activities 
with Taxonomy eligibility or alignment were found. All 
investments in associated companies were in non-NFRD 
undertakings.
Investment KPIs
According to the analysis, the turnover and capital 
expenditures-based Taxonomy eligibility of Sampo 
Group’s covered assets as at 31 December 2025 was 
30.9 per cent and 35.6 per cent, respectively. The 
turnover-based and capital expenditures-based 
Taxonomy alignment of the Group’s covered assets was 
7.7 per cent and 9.9 per cent, respectively.
Due to the changes in the Taxonomy and the related 
reporting requirements, Sampo Groups’ investment 
KPIs for 2025 are not comparable with figures reported 
in the previous years. The most significant factor is the 
change of the scope of investments included in the 
reporting. As the covered assets (denominator of the 
KPIs) now only includes NFRD undertakings and 
investment property, the reported eligibility and 
alignment figures have increased.
As Sampo Group’s Taxonomy reporting for the financial 
year 2025 is mainly based on investee companies’ 2024 
reporting, the Group could not include in the disclosures 
information on non-assessed exposures of the investee 
companies. Sampo Group has not assessed any of its 
exposures to be non-material.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 75

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

Taxonomy-eligible and Taxonomy-aligned investment activities 
Sampo Group, 31 December 2025
Exposures % EURm
Total AUM  100.0% 17,160
Assets covered by the KPI  38.5% 6,607
% of covered assets
% 
Turnover based
%
CapEx based
Taxonomy-eligible  30.9%  35.6% 
Nuclear activities  1.0%  0.9% 
Fossil gas activities  0.2%  0.1% 
Taxonomy-aligned  7.7%  9.9% 
Undertakings subject to Article 19a and 29a of 
Directive 2013/34/EU  7.7%  9.9% 
of which non-financial undertakings  6.2%  8.3% 
of which financial undertakings  1.5%  1.6% 
Other covered counterparties and real estate assets  –%  –% 
Investments other than investments held in respect 
of life insurance contracts where the investment 
risk is borne by the policy holders  –%  –% 
Exposures included on a voluntary basis  –%  –% 
Transitional activities  1.3%  1.4% 
Enabling activities  3.8%  4.5% 
Nuclear activities  1.0%  0.9% 
Fossil gas activities  0.0%  0.0% 
Taxonomy-aligned per objective
% 
Turnover based
% 
CapEx based
Climate Change Mitigation (CCM)  7.5%  9.5% 
Climate Change Adaptation (CCA)  1.6%  1.5% 
Water and marine resources (WTR)  0.0%  0.0% 
Circular economy (CE)  0.1%  0.2% 
Pollution (PPC)  0.1%  0.1% 
Biodiversity and Ecosystems (BIO)  –%  –% 
Non-assessed exposures  –%  –% 
Exposures financing non-assessed non-material 
activities of counterparties  –%  –% 
Exposures financing counterparties reporting in 
accordance with Article 7(9) to this Regulation  –%  –% 
Non-assessed exposures considered non-material 
by the reporting entity  –%  –% 
Breakdown of covered assets % EURm
Undertakings subject to Article 19a and 29a of 
Directive 2013/34/EU  100.0% 6,606
of which Non-financial undertakings  49.1% 3,243
of which Financial undertakings  50.9% 3,364
Other covered counterparties and real estate assets  0.0% 0
Investments other than investments held in respect 
of life insurance contracts where the investment 
risk is borne by the policy holders  –% –
Exposures included on a voluntary basis  –% –
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 76

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

E1 Climate change
Topic Impacts Risks and opportunities Strategy and actions
Climate change 
mitigation
↓  G H G  e m i s s i o n s  c a u s e  a c t u a l  n e g a t i v e  i m p a c t  o n  t h e  
environment. As an insurance company, Sampo 
Group's own direct emissions are not significant, but 
when considering the Group’s entire value chain, 
including suppliers, investments and customers, the 
impact is more material.
• Time-horizon: short, medium, and long term
• Value chain location: own operations, upstream value 
chain, downstream value chain
↓  S a m p o  G r o u p  c a n  f a c e  p o t e n t i a l  r e p u t a t i o n a l  r i s k s  
related to GHG emissions or if it fails to achieve its set 
emission reduction targets.
↓  S a m p o  G r o u p  c a n  f a c e  f i n a n c i a l  a n d  r e p u t a t i o n a l  r i s k s  
arising from increasing climate-related legislation (e.g. 
compliance costs, possible fines).
↓  T r a n s i t i o n  r i s k s  r e l a t e d  t o  i n s u r i n g  n e w  t e c h n o l o g y ,  
changes in customer behaviour, and increased 
stakeholder concern can have a negative effect on 
Sampo Group’s underwriting, as well as claims costs 
and frequency.*
• Time-horizon: short, medium, and long term
• Value chain location: own operations, upstream value 
chain, downstream value chain
• Commitments to reduce GHG emissions (e.g. SBTi)
• Internal policies and guidelines (e.g. responsible 
investment policies, underwriting principles, codes of 
conduct)
• Effective governance structures and processes (e.g. 
risk management, screening, engagement)
• Sustainable claims handling and development of the 
handling of new types of claims
• Internal training, competence development 
programmes, and awareness raising
• Metrics and targets (e.g. SBTs related to own 
operations, investments, and suppliers)
• Sampo Group’s transition plan for climate change 
mitigation
Climate change 
adaptation
↑  S a m p o  G r o u p  h a s  p o t e n t i a l  p o s i t i v e  i m p a c t  t h r o u g h  
its insurance solutions which provide extensive 
coverage against natural hazards, support and 
incentives for loss prevention measures, and a high 
level of service in post disaster situations. The pricing 
of the products properly reflects climate change risk. 
Additionally, Sampo Group participates in research on 
climate change adaptation. Non-life insurance and 
reinsurance are recognised by the EU Taxonomy as 
enabling economic activities that can make a 
substantial contribution to the environmental 
objective of climate change adaptation.
• Time-horizon: short, medium, and long term
• Value chain location: own operations, upstream value 
chain, downstream value chain
↓  T h e  i n c r e a s i n g  s c a l e  a n d  f r e q u e n c y  o f  p h y s i c a l  
climate-related risks, such as storms, floods, heavy 
rains, landslides, erosion, hailstorms, and heat waves, 
can cause financial risks for Sampo Group (e.g. 
increased claims costs and decreased investment 
returns). 
↑  D e v e l o p m e n t  o f  s u s t a i n a b l e  p r o d u c t s  a n d  s e r v i c e s  
may provide some opportunities for Sampo Group 
(e.g. related to loss prevention and risk management).
• Time-horizon: short, medium, and long term
• Value chain location: own operations, upstream value 
chain, downstream value chain
• Development of sustainable products and services 
based on customers’ needs and applicable legislation
• Consideration of climate-related risks in underwriting, 
pricing of the products and services, and in 
reinsurance
• Diversification (e.g. by geographical areas and lines of 
business)
• Loss prevention and risk management services
• Claims handling and support in post-disaster 
situations
• Consideration of climate-related risks in investment 
operations (e.g. scenario analysis)
• Training and awareness raising among stakeholders 
(e.g. employees and customers)
• Support for research on loss prevention 
The table presents Sampo Group’s material impacts, risks, and opportunities related to climate change identified in the double materiality assessment and their connection to Sampo Group’s strategy and 
actions.
* IRO has been added as part of the 2025 DMA review.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 77

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

Strategy
SBM-3 – Material impacts, risks, and 
opportunities and their interaction with 
strategy and business model
Sampo Group’s underwriting operations are exposed to 
both physical risks and transition risks. Physical risks are 
risks related to the physical impacts of climate change 
and transition risks are risks related to the transition to a 
low-carbon economy. Physical climate-related risks 
include storms, floods, heavy rains, landslides, erosion, 
hailstorms, and heat waves. The scale or frequency of 
these natural disasters can increase claims costs. 
Transition risks, on the other hand, relate to changes in 
the regulatory environment, the introduction of new 
technologies, changes in customer behaviour, and 
increased stakeholder concern for climate and 
environmental matters, for example.
Sampo Group’s investments can also be impacted by 
both physical risks and transition risks, depending on 
the investment in question. Investments can be exposed 
to physical risks in the form of losses incurred from 
extreme weather events. The transition to a low-carbon 
society with potentially increasing environmental and 
climate regulation, more stringent emission 
requirements, and changes in market preferences could 
in turn cause transition risks for the Group’s investments 
and possible revaluation of assets as operating models 
in carbon intense sectors change.
Sampo Group’s capital planning, a forecast of own 
funds and capital requirements over a three-year 
planning period, and own risk and solvency assessment 
(ORSA) processes include scenario analyses, stress 
tests, sensitivity analyses, and reverse stress tests, 
including scenarios related to natural catastrophes. 
Climate scenario analysis
Sampo Group has together with the external service 
provider ORTEC Finance analysed the Group’s 
investment portfolio's exposure to systemic economic 
and financial climate risks in four different climate 
scenarios over the next 40 years. The impact on the 
insurance result was also analysed based on the impact 
on macroeconomic variables as well as the potential 
effect on claims related to natural catastrophes, 
including the consequences for the pricing of insurance 
contracts.
The four scenarios analysed are the following:
• Net-Zero (NZ), average global warming of 1.5°C by 
2100: This scenario describes an easy and smooth 
transition where political and social organisations act 
quickly and predictably to achieve net-zero CO2 
emissions by 2050. The scenario corresponds to 
Intergovernmental Panel on Climate Change’s (IPCC) 
‘very low emissions’ scenario: SSP1-RCP1.9.
• Net-Zero Financial Crisis (NZFC), average global 
warming of 1.5°C by 2100: In this scenario, the 
transition to a greener economy happens in a 
disorderly manner. Sudden divestments to align 
portfolios to the Paris Agreement goals in 2026 have 
disruptive effects on financial markets with sudden 
repricing followed by stranded assets and a sentiment 
shock. The scenario corresponds to IPCC’s ‘very low 
emissions’ scenario: SSP1-RCP1.9.
• Limited Action (LA), average global warming of 2.8°C 
by 2100: In this scenario, policymakers implemented 
limited nationally determined contributions (NDCs) 
but fall short of meeting the Paris Agreement goals. 
Global warming reaches 2.8°C, and this causes high 
physical impact. The scenario corresponds to IPCC’s  
‘intermediate emissions’ scenario: SSP2-RCP4.5.
• High Warming (HW), average global warming of 
4.2°C by 2100: In this scenario, the world fails to meet 
the Paris Agreement goals, and global warming 
reaches 4.2°C above pre-industrial levels. Physical 
climate impacts cause large reductions in economic 
productivity and increased impacts from extreme 
weather events. This scenario focuses on physical risk 
as the green transition does not happen. The scenario 
corresponds to IPCC’s ‘high emissions’ scenario: 
SSP3-RCP7.0.
The methodology used to assess systemic climate 
change risks and opportunities related to Sampo 
Group’s investments combines climate science with 
econometric and financial modelling. The methodology 
relies on the following key assumptions: 
• The scenarios used are climate science informed 
scenarios. Each scenario differs in terms of 
assumptions about policy and technology changes, 
physical risks, and pricing-in mechanisms. The 
scenarios are chosen to explore a range of plausible 
outcomes.
• The E3ME model by Cambridge Econometrics models 
the world’s economic and energy systems and the 
environment. It is a quantitative framework for 
analysing the impacts of Energy-Environment-
Economy (E3) policies over the short, medium and 
long term. It is widely used globally for policy 
assessment as well as for forecasting and research. In 
this context, it is used to model the impact of 
transition risk on the evolution of macroeconomic 
variables. Currently, the E3ME model does not 
explicitly account for physical risk factors and is, 
therefore, complemented by methods to account for 
the impact of gradual physical risks and extreme 
weather events on the evolution of macroeconomic 
variables.
• Stochastic financial modelling that translates shocks 
to macroeconomic variables to risk-return metrics for 
different geographies, sectors, and asset classes is 
used in the last step to translate the climate-informed 
outputs from the previous steps (i.e. the impact of 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 78

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

transition risks and physical risks on the evolution of 
macroeconomic variables in the different scenarios). 
In addition, assumptions about pricing-in and 
sentiment shocks in financial markets, and how they 
impact asset returns and risk for a large number of 
economic and financial market variables are made.
Impact on investment result
The climate scenario analysis was first conducted in 
2023, and the results were reweighted based on the 
investment allocation as at 30 September 2025. The 
results of the scenario analysis form a set of data that 
can be analysed from various perspectives. The results 
are presented relative to a baseline that does not take 
into account any specific assumptions about climate 
change. Instead, the baseline relies on historical 
relationships and long-term views shaped by current 
market conditions.
According to the results of the climate scenario 
analysis, Sampo Group’s current investment portfolio is 
relatively resilient to climate change risk in all four 
scenarios. This is due to the significant allocation to 
fixed income instruments, which tend to be less 
affected than equities, as well as the geographical 
allocation towards mainly the Nordics and other 
European countries where the effects of climate change 
are expected to be lower than in other parts of the 
world. According to the analysis, in the short run, the 
main risk is related to the pricing-in shock in the NZFC 
scenario. In the long run, there will be a negative impact 
on the returns in all scenarios, due to increased physical 
risks. In addition, returns from high GHG emitting 
sectors are particularly affected in both net-zero 
scenarios (NZ and NZFC).
Impact on insurance result
To assess the impact of the climate scenarios on the 
insurance results, Sampo Group used the forecasts for 
macro variables (gross domestic product, GDP, and 
inflation) and their direct effect on insurance results in 
combination with assumptions for effects on natural 
catastrophe claims and repricing of insurance contracts 
under the different climate scenarios. The sensitivity to 
increased physical risk was assessed by including 
increased natural catastrophe claims in the HW 
scenario, and separately considering repricing due to 
increased claims cost. The analysis has been performed 
across the relevant insurance operations throughout 
Sampo Group.
According to the scenario analysis, the combined effect 
of changes in GDP and inflation in the HW scenario 
compared to the NZ scenario leads to a relatively 
limited impact on the insurance result. This is mainly 
due to offsetting effects stemming from how different 
economies are affected in the Nordic and UK region. 
However, the assumed impact on natural catastrophe 
claims is more material, in particular in the scenario 
without repricing and the apparent offsetting effect of 
repricing actions. The scenario analysis hence indicates 
that although the direct impact from macroeconomic 
impacts is relatively limited, increased claims costs 
could materially influence the insurance results, and 
appropriate repricing of the insurance contracts will be 
particularly important in such a scenario. With P&C 
insurance contracts almost exclusively being renewed 
on a yearly basis within Sampo Group, the resilience 
towards trends in claims for whatever reason is typically 
high given the focus on financial control, clear financial 
targets, and general underwriting focus within the 
Group.
E1-1 – Transition plan for climate change 
mitigation
During 2025, Sampo Group continued to develop its 
transition plan for climate change mitigation. The 
Group’s transition plan is based on its SBTs and related 
decarbonisation levers for own operations, investments, 
and suppliers, as well as the processes and resources 
needed to implement these. Sampo Group has aligned 
its transition plan with its overall strategy and business 
model, particularly through its investment and claims 
handling operations. In the coming years, the Group will 
continue to develop the transition plan, for example by 
investigating decarbonisation efforts related to 
underwriting activities. As a transition enabler, Sampo 
Group can reduce GHG emissions from its value chain 
especially by engaging with corporate customers, 
investee companies, and suppliers and encouraging 
them to set SBTs. 
Sampo Group has not been excluded from the EU Paris-
aligned benchmarks. As a company operating in the 
financial sector, locked-in emissions from own 
operations (Scopes 1 and 2) are not relevant for Sampo 
Group, as these operations are not GHG intensive. 
Additionally, the Group has estimated that its insurance 
products and investments do not contain sources for 
significant locked-in emissions due to the nature of 
these assets. For instance, insurance contracts are 
usually renewed annually, and the investment portfolio 
can be adjusted as it consists mostly of highly liquid 
assets, such as credit bonds, money market instruments, 
government bonds, and direct equities. 
Sampo Group’s commitment to the Science Based 
Targets initiative (SBTi), the related targets, and the 
transition plan have been approved by the Group’s 
management and the Board of Directors. Sampo Group 
is committed to developing its transition plan in 
accordance with applicable regulation and frameworks, 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 79

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

and reports on the development annually as part of the 
regulatory sustainability reporting. 
Science-based targets
Sampo Group’s transition plan builds on its near-term 
SBTs, which were set in accordance with the SBTi’s 
methodology for the financial sector and validated by 
the SBTi in November 2024. The targets are compatible 
with limiting global warming to 1.5°C in line with the 
Paris Agreement. In addition to the mandatory group 
level SBTs set for the Group’s own operations (Scope 1 
and 2) and investments (Scope 3, category 15), Sampo 
Group has, on a voluntary basis, set a supplier 
engagement target on subsidiary level. 
Sampo Group initiated quarterly internal monitoring of 
its progress against the mandatory targets in 2025. 
External reporting is done annually as part of the annual 
sustainability statement. The voluntary target for 
suppliers is monitored internally regularly and reported 
on an annual basis. Sampo Group’s SBTs and progress 
against them are presented in detail in the table 
Science-based targets (p. 85).	
Sampo Group has started assessing long-term 
decarbonisation pathways aligned with the SBTi’s 
Financial Institutions Net-Zero Standard, published in 
July 2025. The aim is to ensure that possible future net-
zero targets are realistic, science-aligned, and 
supported by actionable plans. Sampo Group intends to 
formalise its plans related to net zero before the 
renewal of its current near-term targets in 2029.
Decarbonisation levers
To reach its SBTs, Sampo Group has identified relevant 
decarbonisation levers related to its own operations, 
investments, and suppliers, and actions to be taken in 
the coming years. The most important levers to achieve 
the SBTs for own operations are switching to renewable 
energy, reducing energy use in offices, and electrifying 
the car fleet. For investments, the main decarbonisation 
levers include regular monitoring using screenings, 
engagement with investee companies (e.g. direct 
dialogue, investor events, AGMs), monitoring investee 
companies' temperature scores and the percentage of 
investees who have set SBTs, development of the 
Group’s coal phase-out plan, and portfolio turnover. To 
reach its voluntary SBTs for suppliers, the key lever is 
engagement with suppliers to set SBTs. In addition to 
its existing SBTs and related decarbonisation levers that 
form the basis for Sampo Group’s transition plan, the 
Group has identified underwriting and claims handling 
operations as areas to further assess and expand when 
updating the climate transition plan in the coming years. 
The decarbonisation levers and related actions are 
described in more detail under the heading E1-3 – 
Actions and resources in relation to climate change 
policies. (p. 81).
Investments and funding
Sampo Group is committed to allocating sufficient 
resources to the development and implementation of its 
transition plan. In 2025, the Group assessed the key 
costs related to the implementation of the plan. As a 
financial company not requiring major industrial 
investments for the climate transition, Sampo Group’s 
funding needed to implement the transition plan is 
mainly related to renewable energy contracts and 
certificates, energy efficiency measures in the offices, 
and the ongoing shift away from fossil-based energy 
sources in the offices as well as the car fleet. Therefore, 
based on the current assessment, the implementation of 
the Group’s transition plan is not expected to require 
allocation of specific investments or funding beyond 
normal costs related to business development.
Sampo Group’s insurance and investment activities are 
covered by the EU Taxonomy. The Group’s Taxonomy 
disclosures, including the description of future plans, are 
presented in the section EU Taxonomy (p. 72).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 80

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

Impact, risk and opportunity 
management
E1-2 – Policies related to climate change 
mitigation and adaptation
The group level policy regarding climate change 
mitigation and adaptation is the Sampo Group Code of 
Conduct, which is reviewed annually and approved by 
Sampo’s Board of Directors. The Code of Conduct 
states that the Group complies with climate-related 
legislation, is committed to combatting climate change, 
and supports the Paris Agreement. The policy is also 
supported by Sampo Group’s commitment to the SBTi 
and involvement in various initiatives (e.g. UN Global 
Compact). The Code of Conduct covers all Sampo 
Group’s own operations. The Group also expects its 
suppliers and other business partners to comply with 
the principles of the Code of Conduct throughout their 
own operations and supply chains. 
In addition to the Group’s Code of Conduct, Sampo 
Group has supplementary policies, guidelines, and 
processes for specific purposes to guide the work 
related to climate change mitigation and adaptation on 
a more detailed level. These include, for example, 
sustainability policies, supplier codes of conduct, 
responsible investment policies, and underwriting 
principles.
The Sampo Group Code of Conduct and other policies 
address climate change mitigation and adaptation, 
energy efficiency, and renewable energy deployment. 
These matters have been incorporated into Sampo 
Group’s own operations, investment operations, 
insurance underwriting, supply chain management, 
claims handling, and loss prevention services. Through 
its own actions and engagement with its value chain, 
the Group strives to reduce the consumption of 
resources, increase reuse and recycling, and prioritise 
the use of renewable energy. The Group encourages its 
customers, investee companies, suppliers, and other 
business partners to uphold similar environmental and 
climate commitments, and consults and cooperates 
with its stakeholders on environmental and climate 
matters.
E1-3 – Actions and resources in relation to 
climate change policies
Climate change mitigation
Sampo Group has assessed that it has a negative 
impact on climate change through the GHG emissions 
of its own operations and value chain. However, the 
Group has GHG emission reduction targets and planned 
actions to reduce the emissions and mitigate the 
negative impact.
Own operations
Sampo Group has set an SBT to reduce its total Scope 1 
and 2 emissions by 42 per cent by 2030 compared to 
the 2022 base year. This corresponds to an emission 
reduction of 2,847 tCO₂e. In accordance with the SBTi’s 
methodology, the target is a combined target and does 
not have separate target levels for Scope 1 and Scope 2.
Sampo Group has identified switching to renewable 
energy, reducing energy use in offices, and electrifying 
the car fleet as the main decarbonisation levers to 
achieve the target. Key actions to be taken include 
purchasing renewable electricity, switching to biogas 
and district heating, changing to LED lighting, 
optimising the use of office space, and transitioning the 
car fleet to electric and hybrid vehicles. Sampo Group 
has estimated that switching to renewable energy in the 
offices will contribute to 68–80 per cent of the required 
emissions reductions. Reducing energy use in the 
offices and electrifying the car fleet are estimated to 
contribute to 13–22 per cent and 7–11 per cent of the 
required emissions reductions, respectively. The 
expected quantitative contributions to achieve the GHG 
emissions reduction target for Sampo Group’s own 
operations (Scope 1 and 2) were estimated using 
modelled interventions towards 2030 based on 
reduction potentials within each identified 
decarbonisation lever and assumed adoption rate to all 
emissions sources.
In 2025, Sampo Group’s climate change mitigation 
actions focused on the identified decarbonisation 
levers. During the year, several locations in the Nordics 
switched to renewable electricity and one location from 
natural gas to district heating. In addition, solar panels 
were installed in one location. The car fleet is gradually 
being electrified as leases are renewed, and as at 31 
December 2025, 87.9 per cent of Sampo Group’s 
company car fleet consisted of electric and hybrid 
vehicles. Measures related to reducing energy 
consumption in offices included, among others, 
reducing the indoor temperature, replacing windows, 
switching to LED lighting, and installing intelligent 
lighting and sensor activated taps. During 2026, Sampo 
Group will continue its emission reduction actions and 
initiatives, and monitor progress against the Scope 1 
and 2 targets.
Investments
To achieve its SBTs for investments (p. 85), Sampo 
Group has adopted a strategy that builds on strategic 
asset allocation and proactive investee engagement. 
This means that investments in companies and assets 
that offer strong financial returns and align with the 
Group’s climate objectives are prioritised. 
Decarbonisation levers related to investments include 
regular monitoring using screenings, engagement with 
investee companies, monitoring the percentage of 
investees who have set SBTs, development of the 
Group’s coal phase-out plan, and portfolio turnover. 
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BOARD OF DIRECTORS’ REPORT 2025 81

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

In 2025, Sampo Group started monitoring the 
temperature scores for its investee companies and the 
share of investees that have set SBTs validated by the 
SBTi. Through these metrics, Sampo Group can monitor 
the progress of its investment portfolio in setting 
credible GHG emission reduction targets, thereby 
contributing to the Group’s SBTs for investments. 
Sampo Group reports the percentage annually as part 
of its sustainability statement. 
During the year, Sampo Group also developed its 
engagement activities to include direct, proactive 
engagement with investee companies with no SBTs or 
other similar credible transition plans or climate goals. 
The investees Sampo Group plans to engage with were 
selected based on their significance within the 
investment portfolio and the potential to drive 
meaningful change through engagement. This direct 
engagement process will be launched in 2026. 
Information regarding pooled engagements is provided 
in this Sustainability Statement under the heading 
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. 111).
During 2025, to complement and guide each 
subsidiary’s existing responsible investment policies, 
Sampo Group introduced a group level policy that 
outlines the principles of responsible investment applied 
to the investment activities of Sampo plc and its 
subsidiaries holding investment assets. Additionally, If’s 
Responsible Investment Policy was updated to consider 
changes in its investment portfolio following the 
integration with Topdanmark.
In 2025, Sampo Group continued to perform sector-
based and norm-based screenings for its direct 
investment portfolio to identify and make decisions 
regarding investees that are involved in certain 
industries as well as investees’ adherence to 
international norms concerning environmental 
protection. In addition, to ensure quality monitoring of 
investments from a sustainability perspective going 
forward, Sampo Group reviewed its ESG data service 
providers during the year.
Share of investees with science-based 
targets
Sampo Group
Metric 31 Dec. 2025
Share of investees with SBTs  25.5% 
Calculated based on the market value (EUR) of financial assets 
(excluding Hastings’ loans to customers), and therefore also 
includes investments that are out of scope for the Group’s SBTs, 
such as sovereigns and alternative investments.
Suppliers
To reach its voluntary supplier engagement target on a 
subsidiary level (p. 85), the key decarbonisation lever is 
to engage with and encourage suppliers to set SBTs. 
Supplier engagement offers a way to influence 
decarbonisation efforts within the supply chain when 
granular emissions data is challenging to track or 
unavailable. The Group’s subsidiary level target for 
suppliers applies to all If’s suppliers. The engagement 
actions focus especially on suppliers in claims handling, 
as they represent a major part of supplier spend and 
emissions.
In 2025, If continued to monitor how many of its 
suppliers within motor and property claims have set 
SBTs or equivalent to be able to support and incentivise 
remaining suppliers to set targets going forward. If also 
developed an engagement programme to create a 
cohesive organisation-wide approach for supplier 
engagement. In 2026, If plans to launch a pilot phase 
with selected suppliers and refine engagement 
approaches before broader implementation. The pilot 
will focus on establishing assessment frameworks, 
working with procurement teams to evaluate supplier 
relationships, and initiating open dialogue with suppliers 
about potential support activities.
Underwriting
Sampo Group recognises the impact of the GHG 
emissions it enables through its underwriting activities. 
In 2025, the Group conducted a project with an external 
service provider to calculate its insurance-associated 
emissions in accordance with the standard developed 
by the Partnership for Carbon Accounting Financials 
(PCAF) to gain an understanding of the calculation 
process, data availability, and scale of emissions. 
Business lines in scope of the calculations following 
PCAF’s methodology are personal motor insurance and 
commercial insurance. Sampo Group’s insurance-
associated emissions (Scope 1 and 2) from personal 
motor insurance amounted to 723,262 tCO₂eq and from 
commercial insurance to 436,660 tCO₂eq. The 
calculations are based on insurance policies in force as 
at 31 December 2024.
Measuring insurance-associated emissions (to be 
accounted for separately from financed emissions under 
Scope 3, category 15) is a critical first step in identifying 
the carbon intensive hotspots of the Group’s 
underwriting activities and guiding decarbonisation 
efforts. Going forward, Sampo Group will develop the 
calculation process and data quality with the intent to 
report insurance-associated emissions annually. The 
Group also plans to align reporting on insurance-
associated emissions in accordance with PCAF’s 
guidance. In the coming years, Sampo Group will assess 
the possibility of defining metrics and setting targets 
based on available methodologies and standards for 
financial companies.
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BOARD OF DIRECTORS’ REPORT 2025 82

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

Claims handling
Sampo Group can contribute to climate change 
mitigation by emphasising energy and resource 
efficiency, and use of renewable energy in claims 
handling operations. This is done, for example, by 
setting additional sector-specific environmental 
requirements on vehicle and property suppliers 
covering transportation, as well as material and 
energy usage. 
In 2025, Sampo Group continued to support customers 
through its Sustainable Building module. The module, 
available in Sweden, Norway and Finland, provides 
commercial customers with concrete advice, guidance, 
and financial support for sustainable measures, such as 
the use of solar panels and energy efficiency measures, 
in the reconstruction after major damage. The module is 
based on the BREEAM certification systems.
Sampo Group also acknowledges the GHG emissions 
associated with its claims handling activities, and has 
therefore calculated emissions from vehicle and 
property claims in the Nordics. The calculations were 
conducted in 2022 using data from 2021, and the 
estimated emissions from vehicle and property repairs 
at that time amounted to a total of 88,618 tCO2eq. In 
2025, Sampo Group started a project to update the 
calculations to reflect changes in claims management 
since then, such as cost inflation, improvements in 
sustainability practices, changes in the Group structure, 
and variations in claim types. The project will be 
finalised during 2026. Going forward, the Group will 
assess the possibility to include emissions from claims 
handling in its GHG inventory (Category 11 Use of sold 
products) as reporting and data quality develop.
Climate change adaptation
Climate change will lead to severe consequences for 
society unless sufficient adaptation measures are 
implemented. Sampo Group takes actions related to 
climate change adaptation especially through its 
underwriting processes and loss prevention services.
Underwriting
Sampo Group continually develops the underwriting 
and pricing of extreme weather and climate-related 
physical risks. Pricing is typically based on historical 
claims data and portfolio results, and trends in claims 
will automatically have an effect on the price. Forward-
looking scenarios, including natural hazards scenarios, 
on a one-year basis are also part of the annual capital 
allocation process that in turn affects the pricing of all 
products. Reinsurance is used to manage the 
aggregated exposure to natural catastrophes. In 2025, 
Sampo Group further developed the climate risk pricing 
in the Nordics by exploring new data sources that 
reflect existing and future risks related to climate 
change.
Loss prevention
Sampo Group works actively with loss prevention, 
including mitigating the losses from climate-related 
events. The service offered by the Group depends on 
the customer type, insurance policy, and operating 
country. In 2025, Sampo Group continued to offer large 
corporate customers risk management services, where 
risk engineers conduct on-site risk assessments and 
identify preventive measures to avoid damage and 
enable a stable operation. Customers are advised on 
natural hazards, such as coastal flooding, tornados, 
hailstorms, and wildfires. During the year, in cooperation 
with an external partner, Sampo Group offered house 
assessments in Finland, Norway, and Sweden to private 
customers who own their house and hold top-level 
coverage insurance policies. The assessments provide 
the customer with advice on maintenance and loss 
prevention measures, including climate-related damage. 
For SME customers in Norway and Finland, Sampo 
Group continued to offer building checks. In the UK, 
Sampo Group also provided guidance to its customers 
on loss prevention during 2025, including winter car 
check reminders and recommendations on how to 
mitigate issues at home, such as frozen pipework.
Sampo Group participates in various research projects 
together with universities, research institutes, and 
customers. The aim of this work is to better understand 
risks and to support the customers in their risk 
management, but also to contribute to a more 
sustainable society. For example, If publishes extreme 
weather reports biannually in Norway, with the latest 
published in autumn 2025. The reports are prepared in 
cooperation with CICERO Center for Climate Research 
and IVL Swedish Environmental Research Institute, and 
they analyse the work conducted by Norwegian 
municipalities on climate change adaptation. In 2025, If 
published a similar report for the first time in Finland, 
together with Syke, the Finnish Environment Institute 
and IVL. The reports also identify challenges the 
municipalities are facing and showcase good examples. 
During the year, If also participated in a research project 
related to water management in Gavleån, Sweden, with 
IVL and several local actors. The project aimed at 
creating more collaboration between different public 
and private actors to prevent heavy rainfalls from 
causing flooding.
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BOARD OF DIRECTORS’ REPORT 2025 83

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

Metrics and targets
E1-4 –Targets related to climate change 
mitigation and adaptation
Sampo Group’s climate targets are aligned with the 
SBTi’s methodology, which supports the Paris 
Agreement. This approach is in line with the policy 
objectives stated in the Sampo Group Code of Conduct.
Sampo Group’s target for own operations (Scope 1 and 
2 emissions) follows the absolute contraction approach.  
The Group’s target boundary includes all Sampo Group 
companies. The market-based approach was used to 
calculate the Scope 2 GHG emissions included in the 
target.
The targets for the listed equity, corporate bond, fund, 
ETF, and corporate loan investment portfolio have been 
set using the temperature rating approach and the 
target for the commercial real estate portfolio using the 
sectoral decarbonisation approach (SDA). Sampo 
Group’s portfolio targets cover 57.9 per cent of its total 
investment and lending by total assets as of 2022. As of 
that year, required activities made up 57.9 per cent of 
Sampo Group’s total investment and lending by total 
assets, while optional activities made up 5.6 per cent 
and out-of-scope activities (e.g. sovereign bonds, 
securitised fixed income, money market instruments, 
derivatives, and cash) made up 36.5 per cent.
The above mentioned SDA, used for Sampo Group’s 
SBT for its real estate portfolio, is a method for setting 
physical intensity targets that uses convergence of 
emissions intensity. The real estate holdings represent a 
very limited portion of Sampo Group’s investment 
portfolio as their market value accounts for less than 0.5 
per cent of the total financial assets. In accordance with 
the SBTi’s methodology, the target is an emission 
intensity target and does not have separate target 
levels for absolute emissions. 
Sampo Group engaged in dialogue with several 
stakeholders when committing to the SBTi and setting 
the climate targets. These included, for example, 
investors, large corporate customers, and the 
company’s management and boards of directors. 
Progress against the Group’s targets is monitored 
internally regularly and reported externally in the 
sustainability statement published annually.
There were no changes in the group level targets during 
the reporting year. Topdanmark’s company-specific 
target related to suppliers reported in 2024 was 
discontinued due to the integration with If. The Scope 1 
and 2 GHG emissions for years 2022–2024 were 
recalculated following the merger of If and 
Topdanmark. The aim was to ensure that the 
calculations apply a common methodology as well as 
consistent assumptions across the Group and provide a 
solid base for the decarbonisation roadmap. 
Based on the recalculations, Scope 1 emissions 
increased by 679 tCO2eq in 2022 and 530 tCO2eq in 
2024 mainly due to an increase of the annual mileage, 
which is used in calculation assumptions. Scope 2 
market-based emissions increased by 115 tCO2eq in 
2022 and 88 tCO2eq in 2024 due to the availability of 
new consumption data and adjustments of emissions 
factors. Scope 2 location-based emissions increased by 
374 tCO2eq in 2022 and 710 tCO2eq in 2024. The 
changes also affected Scope 3 category 3 (Fuel and 
energy-related activities), which increased by 329 
tCO2eq in 2022 and 317 tCO2eq in 2024. In addition, 
emissions for Scope 3 category 1 (Purchased goods and 
services) were adjusted for 2024 due to improved data 
quality. Reporting on biogenic emissions has been 
updated to include only Scope 1 and 2 emissions as 
Scope 3 emissions are insignificant. Scope 3 biogenic 
emissions for 2024 have been removed for consistency 
in reporting.
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BOARD OF DIRECTORS’ REPORT 2025 84

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

Science-based targets
Sampo Group
 
Scope Target 31 Dec. 2025
Own operations 
(Scope 1 and 2) • Sampo Group commits to reduce absolute Scope 1 and 2 GHG emissions by 42 per cent by 2030 from a 2022 base year.  -55.8% 
Investments* 
(Scope 3, category 15)
• Sampo Group commits to align its Scope 1 and 2 portfolio temperature score by invested value of its listed equity, corporate bond, 
fund, ETF and corporate loan portfolio from 2.78°C in 2022 to 2.09°C by 2029. 2.00
• Sampo Group commits to align its Scope 1, 2, and 3 portfolio temperature score by invested value of its listed equity, corporate 
bond, fund, ETF and corporate loan portfolio from 2.91°C in 2022 to 2.29°C by 2029. 2.35
• Sampo Group commits to reduce its real estate direct investment and corporate loan portfolio GHG emissions by 57.7 per cent per 
square metre by 2029 from a 2022 base year.  -42.3% 
Suppliers** 
(Scope 3, category 1–14) • 30 per cent of If’s suppliers by spend, covering purchased goods and services, will have science-based targets by 2028.  23.8% 
* The CDP-WWF Temperature Scoring Methodology tool, recommended by SBTi, has generated temperature scores outside the range defined by the methodology, with values below 1.5°C and above 3.2°C. 
To ensure consistency and transparency, Sampo Group tracks two sets of targets: one based on the tool’s unadjusted calculations (as approved by the SBTi and presented in the table above) and another 
adjusted with a minimum threshold of 1.5°C. The adjusted targets and corresponding progress are detailed below:
Scope 1 and 2: The temperature score by invested value decreased from 2.85°C in 2022 to 2.26°C in 2025, showing progress toward the target of 2.12°C by 2029.
Scope 1, 2, and 3: The temperature score by invested value decreased from 2.94°C in 2022 to 2.48°C in 2025, showing progress toward the target of 2.30°C by 2029.
** Sampo Group has set SBTs in accordance with the SBTi’s sector-specific guidelines for the financial sector, which require companies to set targets for own operations (Scopes 1 and 2) and investments 
(Scope 3, category 15). In addition, Sampo Group has a voluntary climate target for its supply chain through its subsidiary If. 
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BOARD OF DIRECTORS’ REPORT 2025 85

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

E1-6 – Gross Scopes 1, 2, and 3 and total GHG emissions
Retrospective Milestones and target years
2022 
(Base year) 2024 2025 % 2025/2024 2025 2030 (2050)
Annual 
% target / 
base year
Scope 1 GHG emissions
Gross Scope 1 GHG emissions (tCO2eq) 1,876 1,412 1,569  11.1 % -42%*
Percentage of Scope 1 GHG emissions from regulated 
emission trading schemes (%) - - - -
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions (tCO2eq) 2,856 2,597 1,953  -24.8 %
Gross market-based Scope 2 GHG emissions (tCO2eq) 4,903 3,657 1,424  -61.1 % -42%*
Significant Scope 3 GHG emissions
Total gross indirect Scope 3 GHG emissions (tCO2eq) 353,383 326,634 422,945  29.5 %
1 Purchased goods and services 2,017 14,435 12,607  -12.7 %
2 Capital goods 111 2,843 5,630  98.0 %
3 Fuel and energy-related activities (not included in 
Scope 1 or Scope 2) 1,884 1,560 1,172  -24.9 %
4 Upstream transportation and distribution - 456 847  85.6 %
5 Waste generated in operations 273 260 246  -5.4 %
6 Business travelling 5,592 6,318 7,178  13.6 %
7 Employee commuting 5,141 6,860 6,849  -0.2 %
8 Upstream leased assets - - - -
9 Downstream transportation - - - -
10 Processing of sold products - - - -
11 Use of sold products - - - -
12 End-of-life treatment of sold products - - - -
13 Downstream leased assets - 41 -  -100.0 %
14 Franchises - - - -
15 Investments 338,364 293,860 388,417  32.2 %
Total GHG emissions
Total GHG emissions (location-based) (tCO2eq) 358,115 330,643 426,468  29.0 %
Total GHG emissions (market-based) (tCO2eq) 360,162 331,704 425,939  28.4 %
The figures for 2022 and 2024 were recalculated to align calculation methodologies due to the integration of If and Topdanmark.
Category 15 Investments concerns Sampo Group’s financed emissions for Scopes 1 and 2. Investment categories included in the calculations are direct equity and fixed income investments and fund 
investments. The coverage was 83.6 per cent of Sampo Group’s financial assets (including associated companies). Sampo Group’s Scope 3 financed emissions were 6,014,897 tCO2eq in 2025. 
* Sampo Group has a combined near-term target for Scope 1 and Scope 2 (market-based) emissions. Sampo Group’s emission reduction targets and results are disclosed in detail in the table Science-based 
targets (p. 85).
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BOARD OF DIRECTORS’ REPORT 2025 86

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

GHG emissions intensity (total GHG emissions per net revenue)
Sampo Group
GHG emissions intensity 2025 2024 % 2025/2024
Total GHG emissions (location-based) 
per net revenue (tCO2eq/EURm) 42 35  18.7% 
Total GHG emissions (market-based) 
per net revenue (tCO2eq/EURm) 41 35  18.1% 
The denominator used when calculating the GHG emissions intensity is the Total insurance revenue 
(Sampo Group’s Financial Statements, Statement of profit and other comprehensive income (p. 
139) and Note 1 Insurance service result (p. 165)).
Biogenic emissions
Sampo Group
Metric 2025 2024
Scope 1 (tCO2eq) 158 170
Scope 2, market-based (tCO2eq) 4,217 2,768
Total biogenic emissions 4,376 2,938
Biogenic emissions arise from direct combustion of biomass or biodegradation. In Sampo Group’s 
reporting these emissions are accounted for in Scope 1 and 2 in cases where the combusted fuel is 
assumed to have a portion of biomass. The biogenic emissions are not included in the GHG 
emissions reported on page 86.
Share of Scope 2 energy consumption covered by contractual 
instruments
Sampo Group
Metric 2025
Share of procured energy covered by bundled contractual instruments  50.6% 
Share of procured energy covered by unbundled contractual instruments  9.1% 
Share of total procured energy covered by contractual instruments  59.7% 
Bundled contractual instruments include both purchased electricity bundled with instruments (e.g. 
green tariffs proving the delivery of renewable electricity) and purchased energy (i.e. heating and 
cooling) bundled with attributes about energy generation, e.g. Guarantees of Origin (GOs). 
Unbundled contractual instruments refer to tradeable Energy Attribute Certificates (EACs) 
purchased by the company. 
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BOARD OF DIRECTORS’ REPORT 2025 87

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

Emission factors and calculation details
Sampo Group
Activity Calculation details Emission factor reference
Stationary combustion Stationary combustion includes combustion of natural gas, biogas, gas oil, and diesel at 
applicable locations. 
DESNZ, 2025
Mobile combustion Mobile combustion is calculated based on litres of fuel or kilometres driven, depending 
on the availability of data. If data is unavailable, the data is extrapolated based on the 
number and type of vehicles and annual mileage. The estimated fuel consumption per 
vehicle is based on national statistics.
DESNZ, 2025; MITECO, 2024; South Pole derived based on Swedish 
Energy Agency 2019 and 2024, Swedish EPA 2023
Refrigerants The calculation is based on the consumption of refrigerants at applicable locations. DESNZ, 2025
Electricity The calculation is based on purchased electricity (MWh). For smaller offices, the 
electricity consumption is extrapolated based on average consumption per FTE or office 
area (m2). 
DESNZ, 2025; Finland Energy, 2024; Grexel Systems, 2024; IEA, 2024;  
NVE, 2024; South Pole derived emission factors
District heating The calculation is based on purchased district heating (MWh). For smaller offices, 
district heating is extrapolated based on average consumption per FTE or office area 
(m2).
Euroheat & Power, 2023; national statistics; supplier-specific emission 
factors
District cooling The calculation is based on purchased district cooling (MWh). For smaller offices, district 
cooling is extrapolated based on average consumption per FTE or office area (m2). 
South Pole derived average based on suppliers, 2023; supplier-specific 
emission factors
Purchased goods and 
services
Purchased goods and services includes water (m3), paper (tonnes), cloud services 
(number of users), and, depending on data availability, also food services. Hastings 
reports the financial records of its purchased goods and services. 
CEDA, 2025; Cloud Carbon Footprint, 2021; DESNZ, 2023, 2024, 2025; 
ecoinvent v.3.3.8, 2021; IPCC, 2014; Amazon, 2021; Google, 2012, 2021; 
Microsoft, 2021; Salesforce, 2021
Capital goods Capital goods includes purchased IT equipment (number and model of devices) and 
larger renovations (spend).
CEDA, 2025; DESNZ, 2025; ecoinvent v. 3.11, 2024; supplier-specific 
emission factors
Fuel and energy-related 
activities
Fuel and energy-related activities are calculated with the supplier-specific method, 
average method, and hybrid method. 
DESNZ, 2025; IEA, 2024; national statistics; South Pole derived emission 
factors; supplier-specific emission factors
Upstream 
transportation and 
distribution
Upstream transportation includes letters sent to customers. The calculation is based on 
averages and spend.
CEDA, 2025; DESNZ, 2025
Waste generated in 
operations
Waste data is only available for larger offices. For smaller offices, data is extrapolated 
based on average consumption per FTE or office area (m2).
ADEME 2023; BC V8.9; DESNZ, 2025; ecoinvent v3.9.1 
Business travelling Business travelling includes travel by air, train, ferry, bus, staff cars, rental cars, and taxis, 
as well as hotel accommodation. The calculations are based on activity or spend data. 
Emissions from hotel stays are calculated with country or city-specific emission factors.
CEDA, 2025; Cornell Hotel Sustainability Benchmark Index 2024; DESNZ, 
2025; RDC flight data, 2024
Employee commuting Emissions for employee commuting are based on surveys conducted in 2024 and 2025, 
which were either sent out to all employees or targeted groups and extrapolated to 
represent all employees. The category Employee commuting also includes remote 
working.
DESNZ, 2025; South Pole derived emission factor
Downstream leased 
assets 
The lease ended in June 2024. There are no other leased assets.
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BOARD OF DIRECTORS’ REPORT 2025 88

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

Calculation principles and assumptions
Own operations
Sampo Group’s GHG emission calculations include its 
operations in the Nordics, Baltics, the UK, Gibraltar, and 
Spain. Only offices in France, Germany, the Netherlands 
and the United States have been excluded from the 
boundary as emissions from these small offices with less 
than 10 employees are deemed insignificant. An 
external service provider, South Pole, conducts the 
calculations based on data provided by Sampo Group. 
The data inventory, emission factors, and assumptions 
are based on the GHG Protocol, and include the main 
greenhouses gases CO2, CH4, N2O, SF6, HFCs, PFCs, and 
NF3 converted to CO2 equivalents. The selection of 
assumptions and emission factors follows a 
conservative approach. Where activity or spend data 
for the inventory is lacking, extrapolations and 
estimations are used.
Sampo Group purchases renewable energy through 
contractual instruments such as green tariffs and 
Guarantees of Origin (GOs). The share of purchased 
energy covered by contractual instruments is calculated 
by dividing the energy consumption (MWh) covered by 
contractual instruments with the total Scope 2 energy 
consumption (MWh). 
The data behind Sampo Group’s Scope 3 category 1–14 
emissions consists of 43.1 per cent primary data and 
56.9 per cent secondary data. Primary data includes 
data from directly reported activities (e.g. fuel 
consumption), supplier-specific data (e.g. GHG data for 
IT equipment reported by the supplier), and the 
employee commuting survey. Secondary data includes 
spend-based (e.g. services) and extrapolated data (e.g. 
office waste).
Scope 3 categories 8 Upstream leased assets, 9 
Downstream transportation, 10 Processing of sold 
products, 12 End-of-life treatment of sold products, and 
13 Downstream leased assets are not considered 
relevant for Sampo Group, as the energy use for leased 
assets (vehicles and IT equipment) is accounted for in 
Scopes 1 and 2, its operations do not include activities 
where non-paid transportation and distribution apply, 
the Group does not sell tangible products, and there are 
currently no leased assets. In the coming years, Sampo 
Group plans to further develop its Scope 3 GHG 
emission reporting, especially related to categories 1 
Purchased goods and services and 14 Franchises.
Investments
The calculation methodology for GHG emissions from 
Sampo Group’s investments follows the GHG Protocol’s 
investment-specific method. The emissions from 
investments are allocated to Sampo Group based on its 
proportional share of investments in investee 
companies. The proportional share is calculated by 
using Enterprise Value Including Cash (EVIC) to 
represent the total value of each investee company. The 
absolute GHG emissions of investee companies are 
collected using an external service provider, Bloomberg 
L.P., where the primary source used is company 
reported emissions followed by estimated emissions. 
The scope of investments' GHG emissions includes 
Sampo Group’s financial assets and investments in 
associates. Out of all investments covered by the data 
provider, 64.7 per cent is based on primary data (i.e. 
emissions reported by investees) and 35.3 per cent is 
based on secondary data (i.e. estimations).
Due to the lack of reliable data and calculation 
methodology, Sampo Group has not obtained GHG 
emissions data for its sovereign exposure, derivatives, 
and loans to customers. Moreover, the data provider 
does not cover all investment assets (e.g. some private 
companies). The data coverage for Sampo Group’s 
investments’ GHG emissions is 83.6 per cent of the 
Group’s total financial assets. The majority of financial 
assets not covered are sovereign, derivatives, and 
municipality exposures. In 2025, Sampo Group 
improved its data coverage for financed emissions 
mainly by ensuring better alignment between its 
investments and data provider records. The Group has 
not used its own estimations for financed emissions as 
the data coverage by the external data provider has 
been considered good and using estimates would 
decrease the data quality. 
The increase in financed emissions is driven by 
improved data coverage and by significant 
contributions from a small subset of investee companies 
with high emissions. Although these companies account 
for only a marginal portion of the portfolio’s market 
value, their emissions profile had a notable impact on 
the total results.
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Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 89

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

Underwriting
The calculation of insurance-associated emissions is 
based on PCAF’s Global GHG Accounting and 
Reporting Standard for the Insurance Industry. 
Emissions calculations from Sampo Group’s personal 
motor insurance include policies in the Nordics and the 
UK. Emissions from personal motor vehicles are 
calculated using activity data, such as fuel consumption 
or distance travelled and the emissions intensity of the 
vehicle multiplied with the industry attribution factor. 
The industry attribution factor supplied by PCAF 
determines the share of the vehicle’s absolute emissions 
that should be allocated to the insurer. Estimations and 
averages are used if actual emissions-related data is not 
available for the insured vehicle.
Commercial insurance includes Sampo Group’s Nordic 
Commercial and Industrial segments. Emissions for 
commercial insurance are calculated by multiplying an 
attribution factor based on PCAF’s standard with the 
reported Scope 1 and 2 emissions of the insured 
customers. The attribution factor for Sampo Group’s 
share of its customers’ emissions was calculated by 
dividing gross written premium by customer revenue. 
Emissions were estimated for customers that do not 
report their emissions.
Claims handling
Emissions from vehicle and property claims in the 
Nordics have been calculated by a third party following 
a life cycle assessment (LCA). The emissions were 
calculated for a limited number of claims and then 
extrapolated using spend to incorporate the full claims 
portfolio. The calculations do not include the former 
Topdanmark’s operations. These emissions are not 
currently included in Sampo Group’s Scope 3 inventory 
(category 11 Use of sold products) due to the level of 
uncertainty and the lack of a standardised calculation 
methodology.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 90

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

E5 Resource use and circular economy
Topic Impacts Risks and opportunities Strategy and actions
Resource use 
and circular 
economy
↓  S a m p o  G r o u p  h a s  a  n e g a t i v e  i m p a c t  o n  t h e  
environment as it uses resources, for example, in its 
claims handling operations (e.g. construction material, 
car parts). By recycling and increasing the number of 
reused parts in claims handling, the Group can limit its 
negative environmental impact.
• Time-horizon: short, medium and long term
• Value chain location: own operations, downstream 
value chain
↑  I n c r e a s i n g  c i r c u l a r  e c o n o m y - b a s e d  r e s o u r c e  f l o w  i n  
claims handling can create cost savings for Sampo 
Group, for example, through purchasing of reused 
parts instead of new ones and reselling of used 
materials instead of disposing.
↓  T h e r e  i s  a  r i s k  o f  r e p u t a t i o n a l  d a m a g e  a n d  a d d e d  
costs if Sampo Group fails to seize opportunities 
related to circular economy. This is, for example, due 
to difficulties in finding or using recycled or reused 
materials.
• Time-horizon: short, medium and long term
• Value chain location: own operations, downstream 
value chain
• Internal policies and guidelines (e.g. supplier codes of 
conduct)
• Effective governance structures and processes (e.g. 
recycling, reuse and repair in claims handling, 
sustainable supply chain management)
• Metrics and targets (e.g. reused parts, glass repairs)
The table presents Sampo Group’s material impacts, risks, and opportunities related to resource use and circular economy identified in the double materiality assessment and their connection to Sampo 
Group’s strategy and actions. The topic Resource use and circular economy is related to the ESRS sub-topic Resource inflows, including resource use.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 91

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

Impact, risk and opportunity 
management
E5-1 – Policies related to resource use and 
circular economy
The group level policy regarding resource use and 
circular economy is the Sampo Group Code of Conduct, 
which is reviewed annually and approved by Sampo’s 
Board of Directors. The Code of Conduct states that 
Sampo Group should reduce the consumption of 
resources (e.g. energy, water) and improve resource 
efficiency, as well as reduce pollution, emissions, and 
waste generated from business operations, while 
incorporating the concepts of reduction, reuse, and 
recycling. The Sampo Group Code of Conduct covers all 
of the Group’s own operations. Additionally, Sampo 
Group expects its suppliers and other business partners 
to comply with the principles of the Code of Conduct 
throughout their own operations and supply chains.
In addition to the Code of Conduct, Sampo Group has 
supplementary and more detailed policies, guidelines, 
and processes that support resource use and circular 
economy. These include, for example, sustainability 
policies to direct the work related to office space 
upgrades and supplier codes of conduct, which outline 
the expectations placed on suppliers with regards to 
environmental considerations. The boards of directors 
or other governing bodies of Sampo Group approve the 
policies, and executive management is responsible for 
the implementation.
Sampo Group’s supplier codes of conduct are publicly 
available and are based on the 10 principles of the UN 
Global Compact. The codes of conduct require 
suppliers to further the development and diffusion of 
low emission technologies that protect the 
environment, are less polluting, use resources in a more 
sustainable manner, recycle more of their waste and 
products, and handle residual waste in a more 
acceptable manner than the technologies for which 
they were substitutes. Suppliers are expected to 
continuously improve their climate and environmental 
efforts, reduce the consumption of resources and 
ensure the efficient use of these resources, and reduce 
pollution, emissions and waste from business activities. 
The supplier codes of conduct apply to suppliers with 
whom Sampo Group conducts business, including the 
suppliers’ subsidiaries and sub-suppliers. The codes also 
apply to all of the suppliers’ employees, whether 
permanent or temporary.
E5-2 – Actions and resources related to 
resource use and circular economy
The most significant impacts, risks, and opportunities 
regarding resource use and circular economy for 
Sampo Group are related to suppliers in the Group’s 
downstream value chain. Sampo Group does not 
produce, sell, or handle physical products requiring 
natural resources, but can instead affect the resource 
use in its value chain via insurance policies and claims 
handling processes. P&C insurance products and 
services affect the amount of resources used mainly 
through the policyholders’ claims related to vehicles, 
and property. Sampo Group’s suppliers and business 
partners are central to the claims handling process, and 
the Group is committed to taking environmental and 
climate considerations into account, for example, by 
encouraging and supporting circular efforts in these 
processes.
In 2025, Sampo Group cooperated with its suppliers in 
claims handling to increase material reuse, recycling, 
and repairs related to property and vehicle claims. The 
Group also focused on specific requirements it has set 
for its suppliers to promote circular economy. In the 
Nordics and Baltics, property and vehicle repair 
partners must comply with the sector-specific 
Additional Environmental Requirements (AER), which 
are incorporated into the purchasing agreements 
together with the Supplier Code of Conduct. These 
include requirements to repair instead of using new 
parts, reuse spare parts, reduce material usage, 
demolish less, increase remote work using video and 
sensors, and use materials with environmental 
certification when available. In the UK, Sampo Group 
encourages its glazing suppliers to repair rather than 
replace materials in home claims. 
In addition, Sampo Group has set expected levels of 
plastic repairs and used parts for selected vehicle repair 
contractors, and these are monitored regularly. As a 
consequence, the vehicle repair contractors reuse metal 
and plastic instead of using new materials. Within 
vehicle claims, Sampo Group works closely with the 
dismantling industry and selected partners to promote 
recycling and repair in the claims handling processes. 
This includes a focus on using spare parts for repairs, 
repairing windscreens instead of replacing them, and 
repairing bumpers. The performance of dismantling 
partners is monitored in order to obtain as many spare 
parts as possible for the claims handling. Sampo Group 
aims to steer towards the selected partners since these 
solutions reduce the material usage and GHG emissions.
In 2025, Sampo Group performed a pilot study with 
several partners in the Nordics to look into creative 
ways to decrease material use in property claims, for 
instance by repairing floors instead of installing new 
ones. The pilot results showed that the maturity levels 
and partner readiness differ between countries. Based 
on the findings, the aim is to encourage more traditional 
partners to increase repairs as well as identify potential 
claims during the reporting phase and direct them to 
partners with the necessary expertise.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 92

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

Metrics and targets
E5-3 – Targets related to resource use and 
circular economy
For the time being, Sampo Group has not set 
quantitative targets for its resource use and circular 
economy actions on a group level. The circular 
economy solutions in claims handling operations are 
developing, but continue to also be subject to several 
uncertainties and challenges, such as limited availability 
of recycled parts (e.g. the UK market for recycled parts 
is still in its early stages) and the time-sensitive nature 
of the repair work. Therefore, Sampo Group has 
evaluated that setting group level targets at this stage 
is not justifiable from an environmental or financial 
viewpoint. However, Sampo Group reviews processes 
to manage impacts, risks, and opportunities related to 
resource use and circular economy regularly, and in 
case it is assessed that a group level externally 
disclosed target is a valuable addition, the decision will 
be revisited.
Metrics related to resource use and circular 
economy
Sampo Group measures the progress of its resource use 
and circular economy efforts, for instance, with the 
metrics presented in the table Circular economy in 
claims handling (vehicle repairs). The share of reused 
parts and the share of glass repairs in vehicle repair 
claims have been selected as key metrics, as they 
reflect Sampo Group’s goals of promoting circular 
economy and reducing resource use. The Group has 
chosen to initially focus on vehicle repairs, as the 
maturity of reused parts market in this area is higher 
compared to property repairs, for instance. Sampo 
Group measures the share of reused parts and glass 
repairs based on the monetary amount spent on parts 
and the number of glass repair claims.
In 2025, Sampo Group was able to increase both the 
share of reused parts and the share of glass repairs in 
claims handling. The increase was mainly achieved by 
working together with the workshops and dismantlers 
to get more orders and deliveries of used parts in the 
Nordics. 
Circular economy in claims handling 
(vehicle repairs)
Sampo Group
Metric 2025 2024
Share of reused parts  5.0%  4.5% 
Share of glass repairs  37.3%  35.3% 
Figures are excluding the operations in the Baltics.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 93

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

Social information
S1 Own workforce
Topic Impacts Risks and opportunities Strategy and actions
Employee 
health, 
wellbeing, and 
competence
↑  T h r o u g h  S a m p o  G r o u p ’ s  w e l l b e i n g  i n i t i a t i v e s ,  t h e  
mental and physical health of its employees can be 
improved. Competence development programmes can 
have a potential positive impact on the employees’ 
motivation and facilitate their professional growth and 
skills advancement. Prioritising employee wellbeing 
and competence development helps foster motivated 
and engaged employees.
↓  S a m p o  G r o u p  c a n  h a v e  a  n e g a t i v e  i m p a c t  o n  i t s  
employees' human and labour rights related to 
working time, adequate wage, freedom of association, 
collective bargaining, and privacy. Such impacts may 
result from unethical labour practices or breaches of 
the Group’s internal policies on employment, health, 
and wellbeing, for example.
↓  F a i l i n g  t o  p r o v i d e  s u f f i c i e n t  w o r k - l i f e  b a l a n c e ,  
occupational health services, support, and 
competence development opportunities to employees 
can have a negative impact on Sampo Group's 
employees' mental and physical health, professional 
growth, competence, and motivation.*
• Time-horizon: short term
• Value chain location: own operations
↓  A  l a c k  o f  c o m p e t e n t  w o r k f o r c e  c a n  p o s e  a  f i n a n c i a l  
risk for Sampo Group. If employees are not engaged 
and see no opportunities for professional 
development, talented but dissatisfied employees 
might leave, taking their skill set with them.
↓  S a m p o  G r o u p  c a n  f a c e  a  f i n a n c i a l  r i s k  d u e  t o  
increasing and tightening legislation related to human 
rights and labour rights (e.g. possible fines, 
reputational damage).
↓  I n c r e a s e d  s i c k  l e a v e s  a n d  e m p l o y e e  t u r n o v e r ,  f o r  
instance due to inadequate work-life balance, can 
pose a financial risk for Sampo Group.
↑  E n g a g e d  a n d  c o m p e t e n t  e m p l o y e e s  c a n  c r e a t e  
opportunities for Sampo Group, as their dedication 
drives results through positive customer experiences 
every day. Investing in personnel practices and an 
empowering work environment is essential for 
sustaining strong performance.
• Time-horizon: short term
• Value chain location: own operations
• Internal policies and guidelines (e.g. codes of conduct, 
HR policies)
• Effective governance structures, processes and 
employee benefits (e.g. comprehensive occupational 
healthcare services, activities to support physical and 
mental health, workplace initiatives, quality offices, 
attractive remuneration packages)
• Internal training, competence development 
programmes, and awareness-raising
• Employee engagement (e.g. reporting channels, 
forums for dialogue, employee engagement surveys, 
freedom of association and collective bargaining)
• Metrics and targets (e.g. employee engagement 
metrics, absence due to illness, employee turnover)
Diversity, 
equity, and 
inclusion (DEI)
↑  T h r o u g h  i t s  o w n  a c t i o n s ,  S a m p o  G r o u p  c a n  h a v e  a  
positive impact on DEI in its own workforce, which can 
cultivate a sense of belonging amongst employees.
↓  F a i l i n g  t o  e n s u r e  e q u a l  t r e a t m e n t  a n d  o p p o r t u n i t i e s  
for all can have a negative impact on Sampo Group's 
employees (e.g. discrimination, harassment, neglecting 
DEI, unequal pay).*
• Time-horizon: short term
• Value chain location: own operations
↓  I f  S a m p o  G r o u p ' s  o w n  w o r k f o r c e  i s  n o t  d i v e r s e ,  t h e  
Group may not be able to serve its diverse customer 
base, which can create a financial risk through lower 
productivity or innovation, for example. 
↑  D E I  c a n  c r e a t e  f i n a n c i a l  o p p o r t u n i t i e s  f o r  S a m p o  
Group, as companies performing well in this area can 
be more innovative and profitable, and attract talent.
↓  N e w  a n d  t i g h t e n i n g  l e g i s l a t i o n  r e l a t e d  t o  D E I  ( e . g .  
related to equal pay) can increase Sampo Group's 
costs (e.g. compliance, reporting, fines) and potential 
reputational issues related to non-compliance can 
affect the Group's financial results negatively.*
• Time-horizon: short term 
• Value chain location: own operations
• Internal policies and guidelines (e.g. codes of 
conduct)
• Effective governance structures and processes (e.g. 
diversity models/programmes, employee initiatives, 
reporting channels)
• Internal training, competence development 
programmes, and awareness-raising
• Metrics and targets (e.g. related to gender diversity 
and equal pay)
The table presents Sampo Group’s material impacts, risks, and opportunities related to own workforce identified in the double materiality assessment and their connection to Sampo Group’s strategy and 
actions. The topic Employee health, wellbeing, and competence is related to the ESRS sub-topics Working conditions and Other work-related rights. The topic Diversity, equity, and inclusion is related to the 
ESRS sub-topics Equal treatment and opportunities for all.
*IRO has been added as part of the 2025 DMA review.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 94

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

Strategy
SBM-3 – Material impacts, risks, and 
opportunities and their interaction with 
strategy and business model
Engaged employees are an essential part of Sampo 
Group’s strategy and business model. The Group’s 
business activities depend on its ability to create an 
empowering work environment and on employees’ 
motivation to contribute to its goals. The dedication 
and expertise of the workforce drive customer 
satisfaction and form the foundation of the Group’s 
competitive advantage. The interests, views, and rights 
of Sampo Group’s employees inform strategic decisions 
and help shape the corporate culture.
When assessing material impacts on its own workforce, 
Sampo Group considers all types of employees who 
may be significantly affected by the Group’s own 
operations or value chain. This includes permanent, 
temporary, full-time, and part-time employees, as well 
as non-employees. For example, the double materiality 
assessment, human rights impact assessment, and 
employee engagement surveys help Sampo Group 
identify which types of employees or employee groups 
within its workforce may be particularly vulnerable to 
negative impacts. These may include underrepresented 
groups (e.g. based on ethnic background, gender, 
sexual orientation, disabilities) and employees working 
in high-pressure environments (e.g. contact centres). 
Within Sampo Group, potential negative impacts on 
employees are more likely to result from individual 
incidents rather than systemic human rights issues.
Sampo Group has identified potential business and 
operational risks stemming from a lack of diversity (e.g. 
under-representation of minority groups), 
discrimination, as well as higher illness rates and 
employee turnover in certain parts of the Group (e.g. 
contact centres). These factors may limit Sampo 
Group’s ability to serve a diverse customer base 
effectively, cause reputational damage or regulatory 
sanctions, and increase recruitment costs, and may 
therefore impact the Group’s financial performance.
Impact, risk and opportunity 
management
S1-1 – Policies related to own workforce
Sampo Group’s policy related to its own workforce is 
the Sampo Group Code of Conduct, which is reviewed 
annually and approved by the Board of Directors. The 
Code of Conduct covers topics such as human rights 
and labour practices, employee health, wellbeing, 
competence development, and DEI. It prohibits forced 
and compulsory labour, child labour, and human 
trafficking, and requires the Group companies to take 
measures to identify, avoid, and/or address such human 
rights violations in their own operations and value chain. 
When developing the Code of Conduct, Sampo Group 
consults both internal (e.g. employees, management) 
and external stakeholders (e.g. investors, rating 
agencies, authorities, external consultants), depending 
on the need. 
The Code of Conduct applies to all Sampo Group 
companies and in all countries of operation. The 
operative management in each Group company is 
responsible for its implementation, and it is the personal 
responsibility of every Sampo Group employee to 
comply with it. Sampo Group offers regular training 
(e.g. e-learning, workshops) on the topics covered by 
the Code. The Code of Conduct is available to all 
stakeholders on the Group’s website. In addition to the 
Code of Conduct, each Group company has adopted 
supplementary policies and guidelines for its own 
purposes. 
Sampo Group complies with all applicable human rights, 
labour rights, and employment legislation. In addition to 
national laws and regulations, the Group is committed 
to respecting human rights as set out in the 
International Bill of Human Rights including the 
Universal Declaration of Human Rights, the International 
Covenant on Civil and Political Rights, the International 
Covenant on Economic, Social and Cultural Rights, and 
those stated in the core conventions of the International 
Labour Organization (ILO). Sampo Group is a 
participant in the UN Global Compact and respects its 
principles related to human and labour rights.
Sampo Group’s policies and related training are part of 
its commitment to maintaining open channels of 
communication with its own workforce and to 
objectively addressing potential human rights impacts 
within its operations, ensuring the provision of suitable 
remedial actions when necessary. Remedies may 
include, for example, support from HR, employee 
representatives, and health and safety delegates, as well 
as insurance cover and rehabilitation, depending on the 
type of adverse impact and local regulations. Sampo 
Group engages with its own workforce regularly and 
has multiple channels for this purpose. More information 
is available under the headings S1-2 – Processes for 
engaging with own workers and workers’ 
representatives about impacts (p. 96) and SBM-2 – 
Interests and views of stakeholders (p. 65).
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 95

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

Employee health, wellbeing, and competence
Sampo Group has health and safety policies in place to 
address workplace accident prevention, and provides 
occupational healthcare in accordance with the 
legislation in each operating country. The Group 
investigates health and wellbeing risks regularly and 
takes preventive action to mitigate them when relevant. 
All Sampo Group companies perform risk assessments, 
and any detected incidents or risks are handled 
accordingly and reported using the appropriate incident 
reporting tools. Together with employee surveys, the 
risk assessments and incident reports provide valuable 
insights for further developing business processes and 
the work environment.
Sampo Group has work environment committees (or 
similar) in place in accordance with local legislation. 
These committees are responsible for monitoring the 
work environment, developing health and safety 
procedures, and ensuring a high quality of physical and 
psychosocial wellbeing. The duties of the committees 
can vary between the Group companies. 
Sampo Group offers a comprehensive range of learning 
opportunities to all employees, beginning with the 
onboarding process. The Group provides mandatory 
training (e.g. training required by the Insurance 
Distribution Directive), voluntary training (e.g. digital 
skills, language courses), and training delivered in 
collaboration with external partners. The available 
training options may vary depending on the employee’s 
role or part of the organisation. Some trainings, such as 
Code of Conduct, compliance, information security, and 
data privacy, are mandatory for all employees, while 
others are included in annual training cycles. In addition, 
employees have the opportunity to develop their 
expertise in various areas in line with their interests and 
the requirements of their job role.
Diversity, equity, and inclusion
Sampo Group respects each individual’s human rights 
and does not tolerate any kind of discrimination, 
bullying, harassment, or any other type of abusive 
behaviour. The Code of Conduct states that 
discrimination is strictly prohibited, for example, on the 
grounds of age, disability, national extraction or social 
origin, racial and ethnic origin, colour, family 
commitments, gender, gender identity, political opinion, 
employees’ representative activities, religion, sensitive 
medical conditions, sexual orientation, or any other 
personal characteristics. In addition, discriminatory 
practices regarding recruitment, job assignment, 
training and development, promotion, remuneration 
and other benefits, or general conduct in the workplace 
are not tolerated. Reported cases related to 
discrimination and harassment are investigated and 
corrective action is taken.
At Sampo Group, it is important that all employees feel 
included and can be themselves at work. The Group has 
DEI policies and/or programmes and has taken action 
to raise awareness and address DEI and vulnerable 
groups within its own workforce. DEI topics are 
advanced, for example, through internal employee 
communities, internal committees, setting diversity 
targets, as well as promoting DEI in recruitment and the 
leadership pipeline.
S1-2 – Processes for engaging with own 
workers and workers’ representatives about 
impacts
Sampo Group engages regularly and directly with 
employees and their representatives to gain insight into 
employees’ perspectives, gather feedback, and identify 
development needs. The CEOs of Sampo Group have 
the overall responsibility for the engagement with 
employees. Forums for dialogue include, for example, 
leader-employee discussions, work environment 
councils, meetings with union representatives, exit 
interviews, and employee engagement surveys. In 
addition, employees can raise concerns through internal 
reporting and whistleblowing channels.
The employee engagement surveys cover both the 
physical and psychosocial work environment. The 
surveys include questions related to wellbeing and DEI, 
and the results are also examined according to 
demographic groups, including minority groups. 
Aggregated survey data enables management to 
identify development areas, set targets, and measure 
the effectiveness of implemented actions. Leaders 
discuss the results with their teams, supported by HR 
when needed, and take appropriate action. In addition 
to the employee engagement surveys, Sampo Group 
seeks to gain insight into the perspectives of vulnerable 
groups through various company and employee-driven 
initiatives focused on topics, such as disabilities, women 
in the workforce, language, and the inclusion of 
different cultures and religions.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 96

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

S1-3 – Processes to remediate negative 
impacts and channels for own workers to 
raise concerns
Sampo Group strives for a constructive and trust-based 
dialogue with employees and their elected 
representatives, such as unions. The aim is to develop 
the Group and ensure the fair treatment of all 
employees. Sampo Group promotes a culture of open 
discussion, where grievances can be aired and 
addressed proactively. Employees are encouraged to 
report unethical practices or possible violations of laws, 
regulations, or internal policies directly to a leader, HR, 
employee representative, compliance units, or through 
the designated reporting channels. 
Sampo Group systematically monitors employee 
feedback received through, for example, employee 
surveys and reporting channels. The Group ensures that 
actionable insights are addressed through formalised 
HR processes and leadership reviews. In addition to 
internal reporting channels, Sampo Group has externally 
managed whistleblowing channels through which 
employees and other stakeholders can raise concerns 
anonymously. 
Any incident that breaches the Code of Conduct is 
investigated, and the need for corrective action is 
assessed on a case-by-case basis. Information about the 
various reporting channels is available on intranet pages 
and communicated to employees during onboarding 
and regularly through internal communications 
campaigns.
The effectiveness of the different channels and 
employees’ willingness to openly voice opinions or 
report misconduct can, to some extent, be assessed 
through employee engagement surveys. However, 
Sampo Group does not have formal processes to assess 
its own workforce’s awareness of the procedures for 
raising concerns. Reporting channels have, nevertheless, 
been used by the Group’s own workforce, indicating 
that they are accessible to the relevant parties. The 
processes for handling whistleblowing cases are 
discussed in the section G1 Business conduct (p. 122).
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
Through the policies and processes described earlier, 
such as the Sampo Group Code of Conduct and the 
whistleblowing procedures, Sampo Group aims to 
ensure that its employees are not subject to material 
negative impacts. If negative impacts occur, the Group’s 
remediation processes are followed. Sampo Group 
investigates all suspected breaches on a case-by-case 
basis to determine the appropriate response. The Group 
engages relevant internal stakeholders (e.g. HR, Legal, 
Compliance) in developing an action plan to address 
potential negative impacts, assess the root cause of the 
incident, and identify preventive measures to be taken 
going forward.
Sampo Group aims to be an attractive and responsible 
employer and invests in creating a corporate culture 
that promotes health and wellbeing, work-life balance, 
and career development. The Group offers, for example, 
flexible working hours and hybrid work arrangements, 
sports and volunteering opportunities, occupational 
health services, and training and career development. 
Sampo Group monitors the effectiveness of these 
measures through regular employee engagement 
surveys, turnover rates, and other health and safety 
metrics disclosed in this Sustainability Statement. The 
primary responsibility for managing material impacts 
lies with management and is enforced by HR. The aim is 
to work closely with different units to ensure that 
employees are not negatively impacted and to maintain 
or enhance positive impacts.
Employee health, wellbeing, and competence
Employee health and wellbeing remained a high priority 
for Sampo Group in 2025. The focus was primarily on 
mental health awareness and incorporated several local 
activities related to mental health, such as workshops, 
awareness raising campaigns, leader training, and 
resource groups. In 2026, Sampo Group will continue to 
raise awareness on mental health and support 
employees in building resilience to manage possible 
mental health challenges.
In 2025, the integration of Topdanmark into the If 
organisation impacted the employees of both 
companies. Employees can be adversely impacted by 
organisational changes, and mitigating this risk was a 
key priority throughout the year, for instance through 
regular communication across multiple channels. 
Leaders were trained to support employees in the 
change process and to ensure equal treatment of all 
employees. This work will continue in 2026. 
Sampo Group’s employee development programmes 
aim to provide positive impacts across its own 
workforce. In 2025, the Group’s key activities related to 
competence development included improving 
information about new learning offerings, aligning job 
profiles and learning opportunities, and arranging 
competence development days. In the UK, Sampo 
Group continued its early careers programme, offering 
apprenticeships, graduate positions, and other scheme 
opportunities. The Leadership Excellence programme 
was also delivered with department-level programmes, 
providing leaders with tools, techniques, and confidence 
to support their teams. The programme focused 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
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Corporate Governance 
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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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particularly on developing communication and 
feedback skills. In 2026, Sampo Group will continue its 
efforts to promote possibilities for employees to 
develop their knowledge and roles.
An artificial intelligence (AI) ambassador programme 
was launched in the Nordics and Baltics in 2025. The 
programme educates ambassadors around the Group in 
AI and enables them to train and support colleagues in 
AI-related matters. In addition, awareness sessions on 
responsible AI usage were held across Sampo Group 
throughout the year and supporting guidance is 
available on the intranet pages. AI was also a topic of 
mandatory and voluntary training.
In 2025, Sampo Group provided training on the topics 
covered by the Code of Conduct and other company-
specific policies to all new and existing employees. The 
aim is to ensure that all Sampo Group employees are 
aware of and act in accordance with the Group’s 
policies.
Diversity, equity, and inclusion
Sampo Group has taken several actions to reduce the 
risks of unequal treatment and to promote fair 
opportunities and good working conditions for all 
employees. During the year, the Group continued 
several projects related to equal pay, which included, 
for example, reviews of job architecture and pay grades, 
improvement of existing systems, and development of 
policies and recruitment practices. The projects aim to 
ensure Sampo Group's ability to comply with the EU 
regulation on Equal Pay for Equal Work or Work of 
Equal Value Between Men and Women in 2026. The 
Group also conducts equal pay analyses annually to 
identify, address, and prevent pay differences that may 
directly or indirectly be derived by gender.
In 2025, Sampo Group supported neurodiversity, for 
example, through training leaders and key employees 
on diversity and inclusion, and through the provision of 
resources for neurodiverse employees and their leaders. 
This reflects the increased awareness and 
understanding of neurodiversity across society. In 2026, 
the Group will work on supporting neurodiverse talents 
and increasing employees’ understanding of 
neurodiversity. 
In the UK, Hastings achieved Disability Confident 
Employer Level 2 status in 2025. This UK government 
scheme helps employers improve their processes for 
attracting, recruiting, and retaining workers with 
disabilities. As a part of this scheme, Hastings has 
introduced new and improved ways of working, 
guidance, and resources to better support employees 
with disabilities or conditions. As a Disability Confident 
Employer, Hastings guarantees that they will interview a 
fair and proportionate number of applicants with a 
disability, whose application meets the minimum criteria 
for the advertised job role. 
During the year, Sampo Group launched a new policy 
and e-learning in the UK in response to the new 
legislative requirement to prevent sexual harassment in 
the workplace. These initiatives have increased 
employees’ awareness of what constitutes harassment 
and encouraged them to speak up if they encounter it 
at work. 
Metrics and targets
S1-5 – Targets related to managing material 
negative impacts, advancing positive 
impacts, and managing material risks and 
opportunities
Sampo Group has set targets for Board diversity and 
employee engagement results to address impacts, risks, 
and opportunities related to DEI, employee health, 
wellbeing, and competencies, among other areas. These 
targets and themes align with the policy objectives 
outlined in the Sampo Group Code of Conduct and the 
Sampo plc Board Diversity Policy that aim to provide 
encouraging and rewarding working conditions, as well 
as fair and equal treatment.
The Board diversity target supports the Group’s internal 
ambitions, and reflects the Finnish Corporate 
Governance Code, and other related legislation. More 
information on the topics is available under the heading 
GOV-1 – The role of the administrative, management, 
and supervisory bodies (p. 57).
The employee engagement results are based on 
employee engagement surveys completed by 
employees to assess their experience of working at 
Sampo Group. The surveys are conducted at the 
subsidiary level, rather than the group level, to ensure 
they are suited to each Group company’s specific needs 
and characteristics. Employee engagement surveys are 
sent to all employees with an active employment 
contract at the time of the survey. They are conducted 
at least annually, and the results are reported to the 
respective management teams.
Sampo Group has set employee engagement targets 
using, for instance, internal and external benchmarking, 
as well as historical data. To assess performance, the 
Group monitors internal trends and, when possible, 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
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compares results with industry averages in its operating 
countries. Achieving the set targets is considered an 
indicator of excellent performance. 
In addition to the top management of the Sampo Group 
companies, representatives from various parts of the 
Group have been involved in drafting the employee 
engagement targets. The targets are also discussed 
with union representatives, and feedback from external 
stakeholders is considered where relevant. The results 
of the employee engagement surveys, along with other 
data related to the Group’s own workforce, are used by 
the management teams as input into the organisational 
development processes.
In H1/2025, If’s eNPS (excluding Topdanmark) declined 
following the introduction of updated hybrid work 
guidelines (i.e. a minimum requirement of three days 
per week in the office). In anticipation of the 
organisational changes related to the integration of 
Topdanmark in mid-2025, If set a slightly lower target 
for the H2/2025 survey. As expected, the eNPS result 
dropped, with notable variations between countries and 
organisational units. Going forward, the ambition is to 
reverse the negative trend. Team leaders have analysed 
the results with their teams and discussed necessary 
actions. If will follow up on the results of the H1/2026 
survey and plan further actions based on them if 
needed. In the UK, Hastings took action based on 
feedback from the 2024 employee engagement survey, 
which helped keep employee engagement stable 
throughout 2025.
Employee engagement surveys
Sampo Group
Survey Scale Target
2025 2024
H1 H2 H1 H2
If: 
HeartBeat -100–100 2025: 45 36 23 52 54
Hastings: 
Your Voice 0–100 2025: 75 80 79 77 78
Sampo plc: 
Work Life 
Survey -100–100 - - 46 - 42
The surveys are company-specific and not comparable to each 
other. Sampo’s survey is conducted annually in the autumn. For 
If and Sampo, the scale is from -100 to 100. In general, scores 
above zero can be considered good/positive, while those above 
50 can be considered excellent. However, score levels can vary 
according to industry and type of organisation, for example. For 
Hastings’ survey, results above 70 can be considered high.
If’s 2024 and H1/2025 figures are excluding Topdanmark. 
Sampo plc does not have a target related to its employee 
engagement survey.
Board diversity
Sampo plc
Gender 31 Dec. 2025 31 Dec. 2024
Female  37.5%  33.3% 
Male  62.5%  66.7% 
Total  100.0%  100.0% 
Both genders shall be represented on the Board, with a target 
that each represents at least 40 per cent of the Board’s 
members. However, some deviations may be applied if deemed 
reasonable due to the number of Board members.
Calculation principles
Metrics related to the own workforce are reported in 
accordance with the requirements of the ESRS. 
Calculations are based on either headcount or full-time 
equivalent (FTE), and the method used is disclosed with 
each metric. Hourly paid employees, summer workers, 
non-employees, and trainees are excluded from the 
headcount and FTE calculations. For FTE, working time 
is adjusted for employees on extended leave, such as 
parental leave. Year-end figures are used in reporting 
unless otherwise specified. Sampo Group collects data 
only on binary gender due to legal restrictions and 
system limitations. Therefore, reporting includes 
information on women and men only. More specific 
calculation principles are described alongside the 
metrics. There are no figures related to own workforce 
in the Sampo Group Financial Statements.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
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S1-6 – Characteristics of the undertaking’s 
employees
As at 31 December 2025, the total number of 
employees at Sampo Group was 16,157. The number of 
employees increased slightly compared to the previous 
year. In 2025, the majority of Sampo Group’s employees 
worked in the UK, Denmark, Sweden, Finland, and 
Norway. The share of women was slightly higher 
compared to men, but overall the binary gender 
balance was relatively equal. Sampo Group’s employees 
were mainly employed full-time on permanent contracts 
at the end of the year. 
Headcount is used for calculating the total number of 
employees, non-guaranteed hours employees, full and 
part-time employees, and permanent and temporary 
employees. A small number of employees work in what 
is called ‘Other countries’ in Group reporting. These 
countries have been combined in reporting due to the 
size of operations in these countries. The ‘Other 
countries’ reporting category includes Spain, Gibraltar, 
France, Germany, the Netherlands, and the United 
States. 
In 2025, Sampo Group’s turnover rate and the number 
of terminations decreased compared to the previous 
year. Turnover in ‘Other countries’ is relatively high due 
to the small number of employees in these locations. 
Even a single personnel change can have a notable 
impact on the results. The turnover rate is calculated by 
dividing the number of employees who have left Sampo 
Group during the reporting year by average headcount. 
The figure includes external voluntary and involuntary 
turnover. 
Total number of employees by gender
Sampo Group
Gender 31. Dec 2025 31. Dec 2024
Female 8,384 8,134
Male 7,773 7,447
Other - -
Not reported - -
Total employees 16,157 15,581
Total number of employees by country
Sampo Group
Country 31. Dec 2025 31. Dec 2024
United Kingdom 4,878 4,314
Denmark 2,866 2,977
Sweden 2,789 2,770
Finland 2,150 2,130
Norway 1,786 1,827
Latvia 577 573
Estonia 542 514
Spain 323 230
Lithuania 189 190
Gibraltar 34 32
Netherlands 8 8
France 7 7
Germany 7 8
United States 1 1
Total employees 16,157 15,581
Number of terminations and turnover rate 
Sampo Group
2025 2024
Country
Termi-
nations
Turnover 
rate
Termi-
nations
Turnover 
rate
United 
Kingdom 749  16.1% 776  19.9% 
Denmark 246  8.5% 416  13.7% 
Sweden 312  11.2% 312  11.4% 
Finland 151  7.1% 130  6.1% 
Norway 181  9.9% 143  8.1% 
Baltic 
countries 92  7.2% 93  7.4% 
Other 
countries 113  33.6% 102  36.8% 
Sampo 
Group, total 1,844  11.6% 1,972  13.1% 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
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Information on employees by gender
Sampo Group
31 Dec. 2025 31 Dec. 2024
Female Male Other Not disclosed Total Female Male Other Not disclosed Total
Number of 
employees 8,384 7,773 - - 16,157 8,134 7,447 - - 15,581
Number of 
permanent 
employees 8,302 7,732 - - 16,034 8,016 7,384 - - 15,400
Number of 
temporary 
employees 82 41 - - 123 118 63 - - 181
Number of non-
guaranteed hours 
employees 92 66 - - 158 168 126 - - 294
Number of full-
time employees 7,361 7,509 - - 14,870 7,125 7,170 - - 14,295
Number of part-
time employees 1,022 265 - - 1,287 1,007 279 - - 1,286
Information on employees by country
Sampo Group
31 Dec. 2025 31 Dec. 2024
United 
Kingdom Denmark Sweden Finland Norway
Baltic 
countries
Other 
countries Total
United 
Kingdom Denmark Sweden Finland Norway
Baltic 
countries
Other 
countries Total
Number of 
employees 4,878 2,866 2,789 2,150 1,786 1,308 380 16,157 4,314 2,977 2,770 2,130 1,827 1,277 286 15,581
Number of 
permanent 
employees 4,847 2,852 2,774 2,137 1,763 1,282 379 16,034 4,268 2,940 2,754 2,111 1,791 1,250 286 15,400
Number of 
temporary 
employees 31 14 15 13 23 26 1 123 46 37 16 19 36 27 0 181
Number of non-
guaranteed 
hours employees 0 15 60 0 83 0 0 158 0 142 93 0 59 0 0 294
Number of full-
time employees 4,258 2,661 2,622 1,980 1,710 1,271 368 14,870 3,741 2,766 2,576 1,955 1,736 1,245 276 14,295
Number of part-
time employees 620 205 167 170 76 37 12 1,287 573 211 194 175 91 32 10 1,286
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
Corporate Governance 
Statement 
Sustainability 
Statement
Group’s notes to 
the financial statements
Sampo plc’s notes to 
the financial statements
BOARD OF DIRECTORS’ REPORT 2025 101

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