Årsredovisning 2025

S1-7 – Characteristics of non-employee 
workers in the undertaking’s own workforce
As at 31 December 2025, the total number of non-
employees at Sampo Group was 3,200, representing a 
slight decrease compared to the previous year. The 
number of non-employees is reported as headcount at 
the end of the reporting period. Non-employees refer to 
individuals working in Sampo Group’s workforce who 
are not directly employed by the Group (e.g. 
consultants, freelancers, other independent contractors, 
employees employed by staffing companies). At Sampo 
Group, non-employees typically work in areas such as IT 
and contact centres.
Non-employee workers
Sampo Group
Metric 31. Dec 2025 31. Dec 2024
Number of non-employees 3,200 3,283
S1-8 – Collective bargaining coverage and 
social dialogue
As at 31 December 2025, 58.7 per cent (60.9 per cent in 
2024) of Sampo Group’s employees were covered by 
collective bargaining agreements. The small decrease 
compared to the previous year is due to an increase in 
the total number of employees in the UK. In 2025, there 
were no major changes in social dialogue coverage at 
Sampo Group compared to 2024.
The collective bargaining coverage is calculated by 
dividing the number of employees covered by collective 
bargaining agreements by the total number of 
employees, using headcount. The figure only includes 
employees who are fully covered by collective 
bargaining agreements in locations where trade unions 
are formally recognised. Nevertheless, the terms of 
these agreements apply to most employees (excluding 
top management), even if they are not formally covered 
by the agreements. Within Sampo Group’s operations in 
the European Economic Area, several collective 
bargaining agreements are in place, depending on 
geographic location and national practices. In the 
Group’s UK operations, trade unions are not formally 
recognised. However, employment terms are regularly 
benchmarked against market practices. Estimates were 
used to calculate workplace representation.
Sampo Group has no Global Framework Agreements. 
However, If has established an agreement on an 
information and consultation procedure with workers’ 
representatives, which is based on the European Works 
Councils’ stipulation. The highest level of engagement 
with workers’ representatives takes place in the 
Communication Council, chaired by the Head of HR. The 
Communication Council meets quarterly to discuss 
topics that concern more than one country or business 
area. 
Collective bargaining coverage and social dialogue
Sampo Group, 31 December 2025
Collective bargaining coverage Social dialogue
Coverage rate Employees – EEA Employees – Non-EEA
Workplace representation 
(EEA only)
0–19% - United Kingdom -
20–39% - - -
40–59% - - -
60–79% - - Denmark, Sweden
80–100% Denmark, Sweden, Finland, Norway - Finland, Norway
The table includes countries with more than 50 employees, representing over 10 per cent of total employees.
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 102

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

S1-9 – Diversity metrics
Age distribution within Sampo Group has historically 
been stable, and remained so also in 2025. The age 
distribution is calculated by headcount at year-end. 
In 2025, the definition of the top management levels 2–
4 was updated due to changes in the Group structure.
Therefore, years 2024 and 2025 are not comparable 
regarding those levels. Starting 2025, Sampo Group 
defines top management as the Sampo Group CEO 
(level 1), leaders reporting to the Group CEO (level 2), 
leaders reporting to level 2 (level 3), and leaders 
reporting to level 3 (level 4). The number of leaders on 
levels 2–4 has increased from 2024 to 2025 due to a 
change in level definitions.
As at 31 December 2025, the binary gender distribution 
at the four highest management levels of Sampo Group 
shows that there is still room for diversity at the very 
top. However, at the levels immediately below top 
management, the balance between women and men is 
more equal. 
Gender distribution at top management levels
Sampo Group
Gender
31 Dec. 2025 31 Dec. 2024
Level 1 (the Group 
CEO)
Level 2 (reporting 
to the Group CEO)
Level 3 (reporting 
to level 2)
Level 4 (reporting 
to level 3)
Level 1 (the Group 
CEO)
Level 2 (the CEOs 
of Sampo plc’s 
subsidiaries)
Level 3 (reporting 
to any of the 
CEOs)
Level 4 (reporting 
to level 3)
Female 0  0.0% 3  27.3% 18  31.6% 95  41.5% 0  0.0% 0  0.0% 9  25.7% 77  40.8% 
Male 1  100.0% 8  72.7% 39  68.4% 134  58.5% 1  100.0% 3  100.0% 26  74.3% 112  59.2% 
Sampo Group, total 1  100.0% 11  100.0% 57  100.0% 229  100.0% 1  100.0% 3  100.0% 35  100.0% 189  100.0% 
Distribution of employees by age group
Sampo Group
Age group 31 Dec. 2025 31 Dec. 2024
Under 30 years old 3,374  20.9% 3,264  20.9% 
30–50 years old 8,827  54.6% 8,730  56.0% 
Over 50 years old 3,956  24.5% 3,587  23.0% 
Sampo Group, total 16,157  100.0% 15,581  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 103

===== SIDA 104 =====

S1-10 – Adequate wages
At Sampo Group, remuneration is based on objective 
criteria such as work experience, competence, position, 
and responsibilities. All employees are paid an adequate 
wage that aligns with applicable benchmarks. Pay and 
additional benefits are not determined by, nor 
influenced by, gender or any other non-professional 
factors. Sampo Group uses, for example, structured job 
titles and job positions to ensure that employees in the 
same role are employed under consistent conditions. 
Internal and external benchmarks are also used to set 
salary ranges.
S1-11 – Social protection
All Sampo Group employees are covered by social 
protection against loss of income due to major life 
events such as sickness, unemployment, employment 
injury, acquired disability, parental leave, and 
retirement.
S1-12 – Persons with disabilities
Sampo Group does not collect data on personal 
characteristics such as disabilities due to legal 
restrictions.
S1-13 – Training and skills development 
metrics
At Sampo Group, all employees are eligible to 
participate in regular career development reviews. In 
2025, the percentage of employees who participated in 
regular performance and career development reviews 
decreased. This was due to reviews of former 
Topdanmark employees being postponed to 2026. The 
percentage of employees who participated in 
performance and career development reviews is 
calculated by dividing the number of participating 
employees by the year-end headcount, broken down by 
gender.
Sampo Group offers employees a variety of internal and 
external training opportunities. In 2025, the Group 
started strengthening its reporting processes for skills 
development and is now able to report the average 
training hours by gender for the first time. Further 
development is needed also in the coming years to 
improve reporting processes and alignment across the 
Group. Currently, the average training hours by gender 
includes mandatory internal training and leadership 
training. The training hours are calculated by dividing 
the total number of training hours with the average 
headcount.
Percentage of employees who 
participated in regular performance and 
career development reviews by gender
Sampo Group
Gender 2025 2024
Female  61.1%  66.2% 
Male  57.3%  64.0% 
Sampo Group, total  59.3%  65.1% 
Average training hours by gender
Sampo Group
Gender 2025
Female 7
Male 6
Sampo Group, total 7
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 104

===== SIDA 105 =====

S1-14 – Health and safety metrics
All Sampo Group’s employees continued to be covered 
by a health and safety management system as at 31 
December 2025. The system refers to the occupational 
healthcare services provided by the employer, which 
may be either statutory or voluntary. The percentage of 
employees in Sampo Group’s own workforce covered 
by a health and safety management system is 
calculated based on headcount.
In 2025, there were no fatalities resulting from work-
related injuries at Sampo Group, and the number of 
work-related accidents remained at the previous year's 
level. The rate of recordable work-related accidents is 
calculated by dividing the number of cases by the 
estimated total hours worked, then multiplying by one 
million. This rate represents the number of cases per 
one million hours worked. The disclosed metrics apply 
to employees in Sampo Group’s own workforce.
Sampo Group does not collect data on work-related ill 
health, fatalities due to work-related ill health, or days 
lost due to work-related ill health due to legal 
restrictions. 
Percentage of employees covered by 
health and safety management system
Sampo Group
Metric 31 Dec. 2025 31 Dec. 2024
Percentage of employees 
who are covered by health 
and safety management 
system  100.0%  100.0% 
Work-related injuries and fatalities
Sampo Group
Metric 2025 2024
Number of fatalities as a 
result of work-related 
injuries 0 0
Number of recordable work-
related accidents 47 49
Rate of recordable work-
related accidents 1.9 2.1
The number and rate of recordable work-related accidents in 
2024 were recalculated due to a clerical error in the compilation 
of data. The originally reported figures were 80 and 3.4.
S1-15 – Work-life balance metrics
At Sampo Group, all employees are entitled to family-
related leave through social policy or collective 
bargaining agreements. In 2025, the share of employees 
who took family-related leave remained stable 
compared to 2024, with a minor shift towards a more 
equal gender distribution. Family-related leave includes 
maternity, paternity, parental, carer’s and adoption 
leave. The percentage of employees who took family-
related leave is calculated by dividing the number of 
employees who were on family-related leave divided by 
year-end headcount, broken down by gender.
Percentage of employees who took 
family-related leave
Sampo Group
Gender 2025 2024
Female  9.6%  10.2% 
Male  6.8%  6.3% 
Sampo Group, total  8.3%  8.3% 
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 105

===== SIDA 106 =====

S1-16 – Remuneration metrics
In 2025, the gender pay gap remained stable. The pay 
gap is a development area in Sampo Group and 
monitored continuously through regular pay gap 
analyses. The gender pay gap describes the difference 
in actual paid compensation between men and women. 
Differences in pay can be explained by factors such as 
position in the company, job tasks, responsibilities, and 
leaves of absence. Pay gap-related metrics are 
calculated using FTE averages. 
Due to the high payment of the long-term incentive 
scheme LTI 2020, the pay of the former Group CEO was 
higher in 2025 compared to the previous year. This 
impacted the annual total remuneration ratio of the 
highest paid individual to the median annual 
remuneration. The pay data to calculate the median 
annual remuneration used in the annual total 
remuneration ratio of the highest paid individual to the 
median annual remuneration is collected from Sampo 
Group’s HR systems. The data includes annual 
contractual fixed compensation before tax and all 
variable compensation elements and bonuses. The 
median annual remuneration figure is based on the 
monthly paid employees in an employment relationship 
with Sampo Group (excluding the highest paid 
individual) at the end of the reporting year. In 2025, the 
data collection process was updated due to the 
integration of If and Topdanmark and the related 
changes in payroll systems. Therefore, the 2024 and 
2025 figures are not comparable. 
Exchange rates may have an impact on the 
remuneration figures presented in this Sustainability 
Statement. 
Gender pay gap
Sampo Group
Metric 2025 2024
Fixed remuneration  19.7%  19.8% 
Fixed and variable remuneration  24.9%  24.5% 
Annual total remuneration ratio of the 
highest paid individual to the median 
annual remuneration
Sampo Group
Metric 2025 2024
Pay ratio 111.5 89.6
S1-17 – Incidents, complaints, and severe 
human rights impacts
In 2025, no severe human rights incidents, defined as 
severe violations of human rights and labour rights 
legislation concerning Sampo Group’s own workforce, 
were reported. 19 incidents of discrimination and 
harassment were reported and corrective action was 
taken on a case-by-case basis according to internal 
processes and guidelines. The figure includes incidents 
of discrimination and harassment as defined in the 
Sampo Group Code of Conduct that have led to formal 
consequences (e.g. warning or dismissal) during the 
reporting year. None of the incidents reported during 
the year resulted in fines, penalties, or compensation for 
damages for Sampo Group.
The total number of complaints filed through Sampo 
Group’s channels for people in own workforce was 23 
(excluding incidents of discrimination and harassment 
reported above). These are complaints reported by 
employees through grievance mechanisms and 
whistleblowing channels, concerning social, human 
rights, and labour rights matters. The figure includes all 
applicable complaints filed during 2025 regardless of 
their status at the end of the reporting year.
Number of severe human rights incidents
Sampo Group
Metric 2025 2024
Number 0 0
Number of incidents of discrimination 
and harassment
Sampo Group
Metric 2025 2024
Number 19 2
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 106

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

S2 Workers in the value chain
Topic Impacts Risks and opportunities Strategy and actions
Human rights 
and labour 
practices
↓  P o t e n t i a l  n e g a t i v e  i m p a c t s  r e l a t e d  t o  h u m a n  r i g h t s  
and labour practices can occur across Sampo Group's 
entire value chain. Potential negative impacts can be 
mitigated, but due to the large number of suppliers, 
business partners, corporate customers, and investee 
companies it is not possible to completely remove the 
risk of negative impacts (e.g. related to working 
conditions and equal treatment).
↑  S a m p o  G r o u p  c a n  h a v e  a  p o t e n t i a l  p o s i t i v e  i m p a c t  o n  
the sustainability of its suppliers, business partners, 
corporate customers, and investee companies through 
its own actions, such as robust due diligence 
processes and responsible investment and 
underwriting practices. This can also improve the 
working conditions (e.g. job stability and health 
aspects) and equal treatment of its value chain 
workers.
• Time-horizon: short to medium term
• Value chain location: own operations, upstream value 
chain, downstream value chain
↓  I f  S a m p o  G r o u p ' s  s u p p l i e r s  o r  b u s i n e s s  p a r t n e r s  
exploit their employees, this may lead to legal, 
reputational, and operational risks for the supplier or 
partner in question. This could become an operational 
risk for Sampo Group, having to find a new partner or 
experience delays and poor quality in deliveries. 
↓  I f  S a m p o  G r o u p  w e r e  t o  i n v e s t  i n  o r  i n s u r e  i n d u s t r i e s  
whose operations are harmful for value chain workers, 
it could cause reputational damage and financial risks 
for the Group.
↓  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. reporting costs, possible 
fines, reputational damage).
• Time-horizon: short to medium term
• Value chain location: own operations, upstream value 
chain, downstream value chain
• Policies and guidelines (e.g. supplier codes of 
conduct, responsible investment policies, underwriting 
principles)
• Effective governance structures and processes (e.g. 
supplier risk assessments, audits, questionnaires, 
screening, engagement)
• Commitments to responsible investment and 
underwriting (e.g. PRI, SBTi)
• Internal training and competence development 
programmes
• Metrics and targets (e.g. Supplier Code of Conduct 
included in existing supplier agreements)
The table presents Sampo Group’s material impacts, risks, and opportunities related to workers in the value chain identified in the double materiality assessment and their connection to Sampo Group’s 
strategy and actions. The topic Human rights and labour practices is related to the ESRS sub-topics Working conditions, Equal treatment and opportunities for all, and Other work-related rights.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
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 107

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

Strategy
SBM-3 – Material impacts, risks, and 
opportunities and their interaction with 
strategy and business model
Sampo Group has an impact on workers in the value 
chain through its suppliers and business partners, 
corporate customers, and investee companies. For 
example, based on the double materiality assessment 
and the human rights impact assessment, the Group has 
identified that especially workers in its downstream 
value chain (e.g. workers of claims handling suppliers) 
could be negatively affected. These workers may face 
risks inherent to their roles and operating contexts. The 
risks are mitigated, amongst other things, by the 
suppliers' adherence to the required health and safety 
standards outlined in Sampo Group's supplier codes of 
conduct.
Ensuring that human and labour rights are respected by 
the suppliers is important for Sampo Group to mitigate 
financial risks and seize opportunities. Suppliers 
breaching human and labour rights may face legal, 
reputational, and operational consequences, which may, 
in turn, become an operational risk for Sampo Group. A 
stable business relationship with a responsible supplier 
is a competitive advantage and can, therefore, be seen 
as an opportunity, too.
Sampo Group develops its understanding of particularly 
vulnerable value chain workers for instance through 
self-assessment questionnaires completed by suppliers 
and engagement with investee companies, corporate 
customers, and suppliers. Examples of particularly 
vulnerable groups within Sampo Group’s value chain 
include different minorities and migrant workers.
Sampo Group includes all value chain workers who may 
be materially impacted by its operations, products, 
services, and business relationships in its disclosures. 
However, the main focus is on direct suppliers (Tier 1) 
where the Group is expected to have the largest impact. 
In addition, the impacts Sampo Group may have 
through its corporate customers and investees are also 
considered.
Sampo Group’s upstream value chain encompasses 
suppliers of office supplies and services (e.g. software 
and hardware companies), as well as providers of other 
business services (e.g. consultants, external data 
providers) that support the running of the business. The 
downstream value chain includes, for example, suppliers 
such as vehicle and property repair contractors and 
healthcare providers. Key activities related to the 
Group’s products and services that are carried out by 
suppliers include property, vehicle, and content repairs, 
health and hospital services, and travel services. Sampo 
Group acknowledges the varying levels of human and 
labour rights risks associated with different industries 
and regions connected to its business, particularly in 
sectors such as construction and vehicle repair. 
The majority of Sampo Group’s suppliers in claims 
handling are based in the Nordics, where the general 
risk for human rights violations is considered lower than 
in many other regions globally. However, value chains 
can be long and complex, and certain sectors such as 
construction, mining, transportation, and electronics are 
particularly associated with human and labour rights 
risks. Workers may be exposed to unhealthy or unsafe 
working conditions, including, for example, long hours 
and exposure to hazardous substances. Other risks 
include forced labour, child labour, discrimination, and 
violations of privacy. These risks can be considered 
systemic.
Sampo Group’s downstream value chain also includes 
the workforce and supply chains of its corporate 
customers and investee companies, through which the 
Group can impact workers beyond its own operating 
countries. This may involve risks such as forced labour, 
child labour, unsafe working conditions, or 
discrimination and harassment, as these risks can exist 
in industries or regions where corporate customers or 
investee companies operate. As these risks arise further 
down the value chain, Sampo Group’s ability to mitigate 
their impacts is limited. 
Impact, risk and opportunity 
management
S2-1 – Policies related to value chain workers
Sampo Group’s policy related to workers in the value 
chain is the Sampo Group Code of Conduct, which is 
reviewed annually and approved by Sampo’s Board of 
Directors. The Code of Conduct applies to all Sampo 
Group companies and must be personally upheld by 
every Group employee. The Code of Conduct states 
that Sampo Group complies with all applicable human 
rights, labour rights, and employment legislation. In 
addition, 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 ILO. Sampo Group also adheres to 
the principles of the UN Global Compact and follows 
internationally recognised standards on business and 
human rights, such as the UN Guiding Principles on 
Business and Human Rights and the OECD Guidelines 
for Multinational Enterprises. As such, Sampo Group is 
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 108

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

committed to fulfilling its human rights obligations and 
continuously developing related practices (e.g. human 
rights due diligence processes) that cover both its own 
operations and its value chain.	
Sampo Group has due diligence processes aligned with 
the OECD Guidelines for Multinational Enterprises. 
These processes allow the Group to identify, avoid and 
address possible adverse impacts on human rights, 
labour rights, the environment and anti-corruption 
commitments associated with its suppliers as well as 
underwriting and investment operations.  
As stated in the Code of Conduct, Sampo Group 
condemns all forms of forced and compulsory labour as 
well as child labour and modern slavery (e.g. human 
trafficking) in its own operations and value chain. In 
addition to the Group’s Code of Conduct, each Group 
company has adopted supplementary and more 
detailed policies, guidelines, and processes for its own 
purposes.
Sampo Group has not been made aware of severe 
confirmed cases of non-adherence to global standards 
for value chain workers in its upstream and downstream 
value chain during the reporting year. This includes 
direct suppliers (Tier 1), corporate customers, and direct 
investments.
Suppliers and business partners
In addition to the Sampo Group Code of Conduct, the 
Group has supplier codes of conduct that set the 
minimum requirements that suppliers are expected to 
meet on topics such as fair and equal treatment, 
privacy, employment terms, working hours, fair wages, 
health and safety, and freedom of association and 
collective bargaining. The supplier codes of conduct are 
based on the UN Global Compact and its underlying 
conventions and apply to both suppliers and sub-
suppliers. They are approved by the boards of directors 
or other governing bodies of the respective Sampo 
Group companies. The ultimate responsibility for 
implementation lies with the top management of each 
Group company. These policies are available on Sampo 
Group’s websites and are communicated to suppliers.
Sampo Group engages with its suppliers, for example, 
through dialogue, self-assessment questionnaires, 
reviews, and site visits. In the event of a breach of a 
supplier code of conduct, the Group engages with the 
supplier to promote improvements in the supplier’s 
business conduct. Sampo Group monitors the situation, 
and further actions depend on the corrective measures 
taken by the supplier. The Group may terminate the 
supplier contract if the supplier fails to take steps to 
remediate the situation within a reasonable timeframe.
Corporate customers and investee companies
Sampo Group provides insurance to corporate 
customers in accordance with its underwriting 
principles and manages its investments in line with its 
responsible investment policies. The Group reviews its 
insurance and investment-related policies annually, and 
they are approved by the boards of directors of each 
Sampo Group company. These policies include, among 
other things, guidance on how to take sustainability 
risks and criteria into account in insurance and 
investment activities.
Sampo Group conducts norm-based screening of direct 
investments and corporate customers against 
international norms and standards (e.g. the UN Global 
Compact principles, the OECD Guidelines for 
Multinational Enterprises, the ILO Tripartite Declaration 
of Principles concerning Multinational Enterprises and 
Social Policy, the Guiding Principles on Business and 
Human Rights, the Paris Climate Agreement) using 
external service providers. If Sampo Group detects a 
violation of these norms or standards, the response may 
vary depending on the severity, nature, and extent of 
the breach. Measures may include direct dialogue or 
other forms of engagement. As a last resort, the 
insurance contract may be terminated or the 
investment sold if the corporate customer or investee 
company fails to take corrective action.
In addition to norm-based screening, Sampo Group 
applies sector-based screening to its corporate 
customers and direct investments, and excludes certain 
sectors from direct investments unless pre-defined 
criteria are fulfilled. Examples of such sectors include 
tobacco, coal, and controversial weapons, due to 
potential human rights risks, labour rights risks, 
reputational risk, and/or regulatory risks.
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 109

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

S2-2 – Processes for engaging with value 
chain workers about impacts
Sampo Group does not engage directly with its value 
chain workers or their legitimate representatives or 
credible proxies. However, indirect engagement occurs 
through suppliers, corporate customers, or investee 
companies. The engagement can be part of formal due 
diligence processes or regular monitoring of business 
relationships. These processes allow Sampo Group to 
understand and manage impacts on the workers in its 
value chain. 
The frequency and method of engagement depends on 
assessed risk, which links, for example, to the type and 
size of the business partner in question. The 
effectiveness of engagement is monitored through 
follow-up meetings with suppliers and corporate 
customers or through external partners during 
engagement with investee companies, for instance. 
Different individuals are responsible for carrying out 
engagement activities, depending on which business 
unit oversees the partnership. For example, 
procurement specialists and business developers (or 
similar) handle dialogues with claims partners, while the 
investment management teams focus on investee 
companies. 
Sampo Group gains insight into the perspectives of its 
value chain workers mainly through human rights due 
diligence processes. These include, for example, 
conducting human rights impact assessments, 
evaluating suppliers' adherence to sustainability criteria, 
as well as screening corporate customers and 
investments. 
Sampo Group assesses the effectiveness of its actions 
and initiatives related to workers in its value chain by 
maintaining dialogue, continuously monitoring its 
processes, and revising practices when needed. This 
may involve, for example, updating policies or adapting 
materials (e.g. questionnaires) that are misinterpreted, 
in order to improve understanding of the conditions 
faced by value chain workers.
S2-3 – Processes to remediate negative 
impacts and channels for value chain workers 
to raise concerns
The Sampo Group Code of Conduct, supplier codes of 
conduct, and responsible underwriting and investment 
practices set clear requirements related to value chain 
workers. If non-compliance with these requirements is 
detected, Sampo Group will engage with the supplier, 
corporate customer, or investee company in question to 
rectify the situation and align their practices with the 
Group’s policies, including plans to review and follow up 
on the corrective actions. If the violation or contract 
breach is significant, or if the party is unwilling to make 
improvements within a given timeframe, the Group may 
terminate the contract or divest. 
Most of Sampo Group’s whistleblowing channels are 
available to all stakeholders, including value chain 
workers, for reporting suspected violations of legislation 
or unethical conduct. The channels are externally 
managed, and allow for anonymous reporting. In 
addition, the majority of Sampo Group’s supplier codes 
of conduct or related contracts require suppliers to 
provide channels for reporting grievances. Suppliers are 
also required to report any breaches of the principles 
outlined in the codes of conduct to Sampo Group. 
Sampo Group does not have formal processes for 
assessing value chain workers’ awareness of the 
procedures for raising concerns. However, supplier 
codes of conduct state that suppliers shall inform their 
employees about whistleblowing channels, and ensure 
that relevant policies and channels are available to value 
chain workers. Sampo Group’s reporting channels have 
been used by external stakeholders, indicating that they 
are accessible to the relevant parties. 
Incidents reported through Sampo Group’s 
whistleblowing channels are investigated promptly in 
accordance with applicable legislation. Sampo Group 
ensures the effectiveness of these channels through 
internal and external communications and training. The 
Group is also committed to further developing its 
approach. The whistleblowing channels are discussed in 
detail in the section G1 Business conduct (p. 122).
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 110

===== SIDA 111 =====

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
In 2025, based on a group-wide human rights impact 
assessment first conducted in 2024, as well as other 
sources for identifying potential human rights impacts, 
Sampo Group developed its processes to detect, 
prevent, and mitigate potential negative impacts on 
human and labour rights affecting workers in the 
Group’s value chain. Additionally, Sampo Group 
continued its regular cooperation with all relevant 
suppliers, business partners, corporate customers, and 
investees to ensure compliance with the Group’s 
policies. The Group applies continuous processes to 
assess whether engagement or other additional actions 
with a given supplier, corporate customer, or investee 
company are required to address potential negative 
impacts on value chain workers. Sampo Group’s 
policies, screening, and engagement activities also 
support the mitigation of risks and the pursuit of 
opportunities related to workers within the Group’s 
value chain. 
Sampo Group has not identified actual material 
negative impacts on its value chain workers and no 
severe human rights issues or incidents were reported 
to Sampo in the Group’s upstream or downstream value 
chain in 2025. Potential negative impacts on value chain 
workers are monitored, for example, through supplier 
self-assessment questionnaires, surveys, site visits, 
meetings, and other engagement activities. Suppliers’, 
corporate customers’ or investees’ non-compliance with 
Sampo Group’s sustainability requirements can lead to 
the termination of the business relationship. 
If any material negative impacts on value chain workers 
were to occur, Sampo Group has processes in place for 
reporting and addressing grievances, as well as for 
taking corrective action. Responsibility for managing 
such impacts is allocated to the respective departments 
within each Group company, such as Procurement, 
Investment Management, Insurance Operations (e.g. If’s 
Business Area Industrial), and Sustainability. 
Suppliers and business partners
In 2025, Sampo Group strengthened the integration of 
its supplier codes of conduct into processes, developed 
related due diligence practices, and monitored 
suppliers’ alignment with sustainability criteria. In 
addition, a process was initiated to integrate 
Topdanmark’s practices into If’s due diligence 
processes. Other actions to enhance the cooperation 
with suppliers included reviewing ESG questionnaires, 
as well as providing a digital platform and external 
consultancy to support purchasers in conducting the 
due diligence. These actions are meant to support 
Sampo Group’s work in preventing negative impacts 
and promoting positive impacts to workers across the 
value chain.
Corporate customers and investee companies
Sampo Group updated the Group’s responsible 
investment policies again during 2025. The changes 
were linked, for example, to If and Topdanmark’s 
integration, the SBTs, and sector-based screening. The 
development of the Group’s responsible investment 
practices continues during the coming years based on 
internal sustainability ambitions, external stakeholder 
feedback, and overall market development.
Sampo Group aims to engage with investee companies 
through pooled engagement with other investors, when 
it is considered an effective means of achieving a 
desired change within the investee. In 2025, the Group 
participated in nine pooled engagements regarding the 
environment, corruption, and human and labour rights-
related topics. 
During the year, Sampo Group’s investments in funds 
were managed by asset managers who are signatories 
of the UN Principles for Responsible Investment (PRI). A 
significant portion of these funds is managed by asset 
managers committed to respecting the UN Global 
Compact principles.
In 2025, Sampo Group continued to screen its direct 
investments and large corporate customers for 
breaches of the UN Global Compact principles. Based 
on the screenings, no severe and confirmed norm 
violations were identified among the Group’s corporate 
customers. Screenings of direct investments identified 
one portfolio company with a confirmed severe breach 
regarding anti-competitive practices. The situation is 
monitored continuously.
In 2025, Sampo Group continued to screen its direct 
investments for sensitive sectors to detect and manage 
any possible risks related to human and labour rights. 
The Group also initiated sector-based screening of its 
corporate customers at group level during the year. This 
internal monitoring supports the management of 
sustainability risks, including those related to human 
rights, labour rights, reputation, and/or regulation. The 
sectors used in the screening of corporate customers 
align with those monitored on the investment 
management side.
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 111

===== SIDA 112 =====

Metrics and targets
S2-5 – Targets related to managing material 
negative impacts, advancing positive 
impacts, and managing material risks and 
opportunities
For the time being, Sampo Group has not set group 
level targets for the metrics related to workers in the 
value chain. However, the Group’s long-term aim is for 
all suppliers to sign a supplier code of conduct. Sampo 
Group regularly reviews its processes for managing 
impacts, risks, and opportunities related to workers in 
the value chain. If it is assessed that an externally 
disclosed, group level target would add value, the 
decision will be revisited.
Metrics related to Supplier Code of Conduct
In order to evaluate its effectiveness in mitigating the 
risk of potential negative impacts on value chain 
workers and their human and labour rights, Sampo 
Group measures the inclusion of supplier codes of 
conduct in its supplier agreements. Tracking this 
inclusion also supports the Group in managing financial 
risks related to such negative impacts and in pursuing 
opportunities through business relationships with 
responsible partners. 
The share of suppliers that have signed a supplier code 
of conduct is calculated by dividing the number of 
suppliers that have signed one of Sampo Group’s codes 
of conduct (including those with their own codes, 
provided these have been approved by Sampo Group) 
by the total number of suppliers. Group company-
specific adjustments are made to the methodology due 
to differences in supply chain structures. This metric 
applies to both upstream suppliers (e.g. suppliers of 
office equipment as well as IT hardware and software) 
and downstream suppliers (e.g. suppliers in claims 
handling). Although supplier codes of conduct are 
implemented across the whole Group, the structures are 
not yet in place for measuring the progress in all units. 
Additionally, some suppliers, such as large IT companies 
and consultancies, are excluded from the metric. In the 
future, Sampo Group aims to improve the data quality 
to include all supplier contracts signed within the Group 
in the metric.
In 2025, the share of supplier codes of conduct included 
in existing supplier agreements increased. This was 
mainly due to the implementation of Hastings’ Supplier 
Code of Conduct in 2024, which resulted in higher 
group level inclusion of supplier codes of conduct in 
2025.  
Supplier Code of Conduct included in 
existing supplier agreements
Sampo Group
Metric 31 Dec. 2025 31 Dec. 2024
Share of suppliers  89.7%  75.6% 
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 112

===== SIDA 113 =====

S4 Consumers and end-users
Topic Impacts Risks and opportunities Strategy and actions
Customer 
health and 
safety
↑  C u s t o m e r  h e a l t h  a n d  s a f e t y  a r e  a t  t h e  c o r e  o f  t h e  
insurance business and, therefore, also at the core of 
Sampo Group’s operations. As Sampo Group’s 
strategy focuses on disciplined underwriting and 
careful risk management, the Group has an actual 
positive impact on consumers’ and end-users' health 
by providing insurance products, thereby helping its 
customers manage risks. 
• Time-horizon: short to medium term
• Value chain location: own operations, downstream 
value chain
↑  S a m p o  G r o u p  c a n  c r e a t e  f i n a n c i a l  o p p o r t u n i t i e s  b y  
offering consumers and end-users products and 
services they need and want. Opportunities can also 
be gained, for example, by cutting costs through 
digital solutions and by developing new products and 
services.
↓  F a i l i n g  t o  p r o v i d e  s u i t a b l e  p r o d u c t s  a n d  s e r v i c e s  t h a t  
meet customers' needs (e.g. insurance related to 
health and safety) can affect Sampo Group's financial 
results.*
• Time-horizon: short to medium term
• Value chain location: own operations, downstream 
value chain
• Internal policies and guidelines (e.g. codes of conduct, 
underwriting principles, risk management principles)
• Effective governance structures and processes (e.g. 
feedback channels, loss prevention, risk management)
• Internal training and competence development 
programmes
• Metrics and targets (e.g. NPS, EPSI, Trustpilot)
Sales and 
marketing 
practices
↓  S a m p o  G r o u p  c a n  h a v e  n e g a t i v e  s o c i e t a l  i m p a c t  
through possible irresponsible sales and marketing 
practices (e.g. inaccessible, discriminating, 
misleading).
↑  S a m p o  G r o u p  c a n  h a v e  a  p o s i t i v e  i m p a c t  o n  p e o p l e ' s  
health and safety through responsible sales practices 
and by providing insurance to a diverse customer 
base.*
• Time-horizon: short to medium term
• Value chain location: own operations, downstream 
value chain
↓  I r r e s p o n s i b l e  s a l e s  a n d  m a r k e t i n g  p r a c t i c e s  c a n  c a u s e  
a financial risk for Sampo Group through possible 
legislative consequences (e.g. fines) and reputational 
damage. 
• Time-horizon: short to medium term
• Value chain location: own operations, downstream 
value chain
• Internal policies and guidelines (e.g. codes of 
conduct)
• Effective governance structures and processes (e.g. 
feedback channels, quality communications, 
responsible remuneration practices)
• Internal training and competence development 
programmes
Data privacy, 
information 
security, and 
cybersecurity
↓  A s  a n  i n s u r a n c e  c o m p a n y ,  S a m p o  G r o u p  h a n d l e s  a n d  
stores large amounts of customers’ and other 
stakeholders’ personal data. Due to increasing 
digitalisation and the use of AI, there is a risk of, for 
example, information security incidents, cybersecurity 
attacks, and data breaches, leading to potential 
negative impacts on consumers and end-users. 
• Time-horizon: short to medium term
• Value chain location: own operations, downstream 
value chain
↓  S a m p o  G r o u p  i s  e x p o s e d  t o  d a t a  p r i v a c y ,  i n f o r m a t i o n  
security, and cybersecurity risks due to the high 
quantity of sensitive data the Group handles and 
processes. In the case of incidents related to privacy 
and data security, negative financial risks, such as 
fines and reputational damage, may be significant. 
• Time-horizon: short to medium term
• Value chain location: own operations, downstream 
value chain
• Internal policies and guidelines (e.g. codes of conduct, 
data privacy statement, information security 
principles, risk management principles)
• Effective governance structures and processes (e.g. 
frameworks and reporting structures, screenings, 
impact assessments, security measures, data 
processing agreements, risk analyses, continuity 
planning, quality systems and infrastructure)
• Internal training and competence development 
programmes
The table presents Sampo Group’s material impacts, risks, and opportunities related to consumers and end-users identified in the double materiality assessment and their connection to Sampo Group’s 
strategy and actions. The topic Customer health and safety is related to the ESRS sub-topic Personal safety of consumers and/or end-users. The topic Sales and marketing practises is related to the ESRS 
sub-topics Social inclusion of consumers and/or end-users. The topic Data privacy, information security, and cybersecurity is related to the ESRS sub-topic Information-related impacts for consumers and/
or end users. 
* 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 113

===== SIDA 114 =====

Strategy
SBM-3 – Material impacts, risks, and 
opportunities and their interaction with 
strategy and business model
Sampo Group provides insurance products and services 
to three main customer groups: private, commercial, 
and industrial customers, and can therefore have an 
impact on them. In addition to these groups, Sampo 
Group can have an impact on potential customers and 
end-users of insurance policies, who themselves are not 
the Group’s customers (e.g. beneficiaries). When 
assessing material impacts, Sampo Group considers all 
types of consumers and end-users who may face 
material impacts from the Group’s own operations or 
through its value chain. 
Sampo Group does not offer products or services that 
are inherently harmful to consumers or end-users’ 
health, safety, or freedom of expression. Instead, Sampo 
Group has an actual positive impact on consumers and 
end-users’ health and safety, among other things by 
providing insurance products and services, thereby 
helping customers with loss prevention, risk 
management, and in cases of loss, accident, or injury. 
Sampo Group’s sales and marketing practices can have 
a potential negative impact on consumers and end-
users, for example, through inaccessibility of products 
and services, or if the needs of underserved groups are 
not fulfilled in a satisfactory manner. As an insurance 
provider, there is also the potential for Sampo Group to 
be associated with discrimination due to risk 
assessments that can in certain cases (e.g. due to legal 
restrictions) exclude customers from accessing 
insurance protection. For example, certain insurances 
may not be available to customers with specific risk 
profiles, or carry a higher premium.
As an insurance company, Sampo Group is required to 
handle large amounts of customers' personal data and 
can therefore negatively impact consumers and end-
users through issues related to data privacy, 
information security, and cybersecurity. The privacy of 
customers can be jeopardised if Sampo Group’s data 
privacy or information security measures are breached 
as a result of a cyber attack, for instance. Due to 
digitalisation and the increasing use of AI, for instance, 
the risk of information security and cybersecurity 
attacks can increase, leading to a higher risk of potential 
negative impacts.
When offering insurance to consumers and end-users 
who can be more vulnerable to health, privacy, or 
accessibility impacts (e.g. elderly people, people with 
disabilities, people lacking financial literacy) and to 
beneficiaries who themselves are not Sampo Group’s 
customers (e.g. children), it is especially important that 
Sampo Group offers accurate and accessible 
information about their insurance policies and coverage. 
To increase understanding of which stakeholders, 
including consumers and end-users, are particularly at 
risk of harm from negative human rights impacts, 
Sampo Group has conducted a human rights impact 
assessment. In addition, the Group’s stakeholder 
dialogue and customer feedback channels serve as a 
way to engage with affected consumers and end-users 
and understand potential human rights risks.
Risks and risk management are inherent elements of 
insurance companies’ business activities and operating 
environment. At Sampo Group, the balance between 
risks, capital, and earnings requires that risks affecting 
profitability, as well as other material risks, are 
identified, assessed, and analysed. This means that 
underwriting risks are priced to reflect their inherent risk 
levels based on each individual customer’s specific risk 
profile, which may, for instance, increase the potential 
negative impact on consumers and end-users through 
sales and marketing practices. 
Impact, risk and opportunity 
management
S4-1 – Policies related to consumers and end-
users
Sampo Group has several policies to manage its 
material impacts, risks, and opportunities related to 
consumers and end-users. The group level guiding 
principles include Sampo Group’s Code of Conduct, 
Data Privacy Statement, and Information Security 
Principles. These are all reviewed annually, approved by 
Sampo’s Board of Directors, and available on Sampo’s 
website. In addition to the group level principles, Sampo 
Group has supplementary and more detailed policies 
(e.g. underwriting principles. distribution policies, data 
privacy statements), guidelines, and processes (e.g. due 
diligence) for specific purposes. The ultimate 
responsibility for the implementation of the group level 
principles and other policies lies with the management 
of each Sampo Group company. To ensure compliance 
with laws, regulations, and internal policies, the Group 
has training programmes which guide personal conduct 
and increase the competence of employees.
The Sampo Group Code of Conduct states that the 
Group complies with the International Bill of Human 
Rights, including the Universal Declaration of Human 
Rights and the two covenants, the Core Conventions of 
the ILO, the OECD Guidelines for Multinational 
Enterprises, and the UN Global Compact. The Code of 
Conduct also describes that Sampo Group is committed 
to the obligations related to human rights and the 
continuous development of related practices (e.g. 
human rights due diligence processes). Sampo Group’s 
due diligence processes cover both the Group’s own 
operations and its value chain, including consumers and 
end-users. 
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
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 114

===== SIDA 115 =====

The Code of Conduct applies to all companies 
belonging to Sampo Group and it is each employee’s 
responsibility to comply with its contents. The Code of 
Conduct obligates employees to ensure that human 
rights are respected and upheld through all operations, 
including the downstream value chain. Sampo Group 
communicates on the topics covered by the Code of 
Conduct to consumers and end-users, for example, 
through its websites, sustainability reporting, and other 
customer communication materials. The engagement 
with stakeholders is described in more detail under the 
heading SBM-2 – Interests and views of stakeholders 
(p. 65).
Sampo Group has not been made aware of any severe 
confirmed cases of non-adherence to global standards 
related to consumers and end-users in its downstream 
value chain during the reporting year.
Customer health and safety and Sales and marketing 
practices
The Sampo Group Code of Conduct sets the group level 
requirements for products and services (i.e. customer 
health and safety) at Sampo Group. The Code of 
Conduct states that Sampo Group strives to act in the 
best interest of its customers, offering products and 
services that customers need and want. The products 
and services should be fair, comprehensible, and 
designed to help meet the evolving needs of all 
customers. In addition, ESG considerations are to be 
taken into account in insurance underwriting. 
The Code of Conduct specifies that Sampo Group’s 
sales, marketing, and product information must be 
professional, comprehensive, accurate, balanced, and 
never misleading. Sampo Group takes appropriate care 
to ensure that customers are given transparent and 
easily accessible and understandable information about 
the costs, risks, and conditions relating to the product 
or service in question, as well as the reasons leading to 
an underwriting or claim decision. In addition, at Sampo 
Group all customers are to be treated fairly and no 
individual customer is given preferential treatment at 
the expense of other customers. Insurance premiums 
are only based on relevant data and not on 
discriminating factors, such as sexual orientation, 
religious belief, or ethnic background. Sampo Group 
expects its suppliers to uphold the same standards in 
their own operations.
Sampo Group has controls in place to ensure that the 
information provided to customers is accessible, 
relevant, and timely before a customer commits to any 
purchase, and that the company satisfies all regulatory 
and conduct obligations. The Group aims to clearly 
inform customers of their complaint options, as well as 
to ensure a fair and transparent complaint process. 
Possible measures to provide remedy to consumers and 
end-users depend on the nature of the impact. Sampo 
Group takes action on a case-by-case basis and 
according to established internal processes. When 
evaluating the effectiveness of mitigation approaches, 
the Group also uses information obtained through 
stakeholder dialogue. 
Data privacy, information security, and cybersecurity
Sampo Group’s policies on data privacy, information 
security, and cybersecurity lay out how the Group is 
committed to processing personal data in a lawful, fair, 
and transparent manner, while respecting human rights 
in all aspects of data management. The policies 
highlight how Sampo Group protects information and 
upholds cybersecurity. These policies also state that 
high levels of data privacy, information security, and 
cybersecurity are top priorities for the Group. 
S4-2 – Processes for engaging with 
consumers and end-users about impacts
Sampo Group has customer experience programmes 
(or similar) which are spread across the organisation 
and the different customer touchpoints. The 
programmes enable the Group to both collect customer 
data and monitor the related results. Sampo Group 
engages with consumers and end-users at several 
stages during the customer journey (i.e. before, during, 
and after a customer transaction). Customers are, for 
example, offered the possibility to leave feedback on 
the customer journey or based on a certain transaction.
Customer feedback is collected daily, weekly, or 
monthly depending on the situation and the method 
used. Feedback is reviewed and any questions or 
comments are followed up with the customer where 
relevant. Customer feedback is collected, for example, 
by phone, email, SMS, and chat. The operational 
responsibility for engagement with consumers and end-
users lies with the top management of the Sampo 
Group companies.
Sampo Group gains insight into the effectiveness of its 
engagement through multiple channels, such as 
customer satisfaction surveys (e.g. NPS, EPSI, 
Trustpilot) and customer contact points (e.g. phone, 
email, SMS, chat, meetings). Feedback can reduce the 
risk of losing the customer, and it is also used to find 
areas of improvement, for example regarding service, 
products, processes, and systems. In addition, the 
Customer Ombudsman engages with customers who 
have a complaint, and may, based on the engagement, 
suggest changes to, for example, the customer handling 
processes, claims procedures, or product terms and 
conditions. 
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 115

===== SIDA 116 =====

In addition to the channels mentioned above, Sampo 
Group gathers the perspectives of affected consumers 
and end-users through the Group’s human rights impact 
assessment. This assessment includes an analysis of 
existing data and the use of credible proxies as part of 
desktop research. Impacts on vulnerable groups are 
also considered in the assessment.
When a customer or insured is not able to manage their 
own interests due to, for example, age, sickness, injury, 
or disability, Sampo Group ensures in accordance with 
local regulatory requirements that there is a trustee or 
guardian that can look after their interests. Sampo 
Group also has guidelines on how to engage with 
customers in vulnerable situations (e.g. managing 
serious incidents with a caring attitude, ensuring privacy 
when communicating with customers with hearing 
disabilities, handling indemnities to an insured under 
guardianship).
S4-3 – Processes to remediate negative 
impacts and channels for consumers and 
end-users to raise concerns
Sampo Group offers multiple channels for customers to 
raise concerns or needs. Customers can be directly in 
contact with the company through, for example, 
customer service (e.g. phone, website, app, chat), 
customer surveys, and the company’s Customer 
Ombudsman. Indirect contact with the company is 
possible through the external Customer Ombudsman, 
whistleblowing channels, and external complaints 
boards. The whistleblowing channels are externally 
managed. 
Sampo Group encourages its suppliers, for example 
through supplier codes of conduct and contract 
discussions, to provide similar platforms for their 
customers to raise concerns. Some of Sampo Group’s 
reporting channels, such as whistleblowing channels, 
are also available for the consumers and end-users of 
suppliers and business partners.
Sampo Group monitors and measures customer 
satisfaction continuously. Both positive and negative 
feedback is carefully analysed and used to develop 
products and services and improve customer 
experience. Quality assurance based on customer 
feedback is also important. Sampo Group follows the 
customer journey to find the root causes of the 
feedback, and to restore the customer relationship, if 
needed. The insight gained is utilised in training and in 
improving processes and the overall customer journey.
By encouraging dialogue, Sampo Group can identify 
and address dissatisfaction among consumers and end-
users. To foster transparency and build trust, Sampo 
Group has a list of its most material and publicly 
available principles and policies on its website. 
Furthermore, Sampo Group upholds non-retaliation 
policies to safeguard individuals who come forward 
with concerns, ensuring they can do so without fear of 
reprisal. The mechanisms to ensure that users can trust 
the whistleblowing channels to raise concerns and are 
protected from retaliation are described in the section 
G1 Business conduct (p. 122).
Sampo Group has several processes for providing 
remedy or contributing to remedy, depending on the 
situation in question. In case of a customer complaint 
related to sales and marketing of products and 
services, the priority is to discuss with the customer to 
find a solution that is satisfactory to both parties. In 
addition, the Group has different kinds of customer 
representative functions that the customer can contact 
to submit a complaint. If a consensus cannot be 
reached, the customer is entitled to appeal to external 
complaints boards (or similar), in accordance with local 
practices in each Sampo Group country. Regardless of 
the outcome of appeal cases, Sampo Group always 
analyses how it can improve its practices.
Sampo Group has procedures for investigating 
breaches and processes for corrective actions to 
protect the personal data of consumers and end-users. 
Data breaches and information security incidents are 
analysed and handled according to fixed processes, and 
they are assessed and reported in a timely manner to 
the local authorities, when applicable. If the risk to 
consumers and end-users is considered high, they are 
notified of the incident. 
Sampo Group evaluates the effectiveness of the 
remedies it provides to ensure that negative impacts on 
consumers and end-users are addressed when needed. 
This is achieved through systematic follow-up 
procedures that include monitoring customer 
satisfaction post-resolution, analysing patterns in 
complaints and resolutions, and conducting reviews of 
remediation processes to identify areas for 
improvement. Sampo Group also follows up on every 
data breach or information security incident to assess 
how similar incidents can be avoided in the future to 
ensure the rights and freedoms of data subjects.
Board of Directors’ Report Group’s IFRS Financial Statements Sampo plc’s Financial Statements Auditor’s Report
≡
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 116

===== SIDA 117 =====

S4-4 – Taking action on material impacts on 
consumers and end-users, and approaches to 
managing material risks and pursuing 
material opportunities related to consumers 
and end-users, and effectiveness of those 
actions
Sampo Group adheres to the Code of Conduct and 
supplementary policies to prevent irresponsible sales 
and marketing practices, ensuring that all customer 
communication is clear, relevant, and timely. The Group 
regularly assesses the products for appropriateness and 
compliance with regulatory obligations, supported by 
continuous training programmes that enhance the 
conduct and competence of customer-facing teams. 
Sampo Group actively collects customer feedback, and 
has transparent complaint processes in place, with 
options for review through external complaints boards.
Sampo Group allocates resources across product and 
service development, sales and marketing, IT, and risk 
management, among other things, to further improve 
its sales and marketing practices, as well as its 
customers’ privacy, health, and safety. The Group also 
collaborates with authorities and regulators and works 
with relevant networks (e.g. related to customer 
experience, cybersecurity, and data security), industry 
associations (e.g. Finance Finland, Insurance Sweden, 
Finance Norway, Insurance and Pension Denmark, 
Association of British Insurers), and forums for 
knowledge sharing. These collaborations provide 
Sampo Group the opportunity to share knowledge and 
experiences regarding topics such as climate change 
adaptation, loss prevention, risk management, health, 
and safety.
Sampo Group ensures effective complaints handling 
and remediation processes for any material negative 
impacts on consumers and end-users by closely 
monitoring customer feedback, results of the customer 
satisfaction surveys, and cases raised with external 
complaints boards. When a negative impact originates 
from the Group’s actions, appropriate remedies are 
based on the nature of the breach. In instances where 
customers are negatively impacted, Sampo Group has 
established incident management processes to oversee 
and ensure that remediation activities are both 
appropriate to the situation and as effective as possible. 
Governance frameworks, including product reviews and 
customer forums, facilitate proactive identification of 
systemic risks.
No severe human rights issues or incidents connected 
to Sampo Group’s consumers or end-users were 
reported to the Group during the reporting year.
Customer health and safety and Sales and marketing 
practices 
During 2025, Sampo Group continued to provide loss 
prevention services to consumers and end-users. The 
main purpose of loss prevention is to prevent damage 
from occurring, but it also increases safety and reduces 
risk and economic cost. Together with an external 
partner, Sampo Group offered house assessments to 
private customers who own their house and hold top-
level coverage insurance policies. The house 
assessments provide the customers with a report that 
helps them to both plan the maintenance of the 
property and minimise the risk of unforeseen events. 
For SME customers that own residential buildings in 
Norway and Finland, Sampo Group offered building 
checks. Following a physical inspection, the customers 
receive help to identify where maintenance and fire 
safety measures are most needed, for example. Through 
the building checks and hands-on advice offered to 
larger SME customers, Sampo Group’s customers are 
made aware of risks and are provided with suggestions 
for mitigating actions. Large corporate customers 
continued to be offered on-site risk management 
services during the year.
Health insurance is an important supplement in meeting 
the increasing demand for healthcare, and through it, 
Sampo Group helps its customers across the Nordics 
when they face health issues. The Group is, for example, 
supporting corporate customers in mapping the work 
environment requirements, and by offering their 
employees preventative health services. When it comes 
to private customers, Sampo Group provides support 
not only when customers face health challenges, but 
also when preventive measures can make a difference, 
thereby contributing to improved overall wellbeing. To 
raise awareness and increase knowledge about the 
topic, If published the Nordic Health Report in 2025 for 
the third consecutive year. The report is based on a 
Nordic-wide survey and provides insights into stress, 
factors that support work-life balance, and the role of 
social insurance and healthcare systems across the 
Nordic countries.
As data from cars and car usage become more readily 
available, Sampo Group is continually looking into ways 
to incentivise safer driving. Usage-based insurance 
(UBI) programmes utilise data from cars and 
smartphones to enable the identification of 
improvement potential for each individual driver and 
may offer incentives to improve the driving behaviour. 
In the UK, Sampo Group continued to encourage safer 
driving habits through one of its car insurance policies 
during 2025. Safe drivers are rewarded with lower 
premiums and provided with personalised tips to help 
improve their driving habits.
Continuously improving the quality of its services in 
both digital and analogue channels is important to 
Sampo Group. During 2025, the Group aimed to 
enhance the ways customers communicate with the 
company through various initiatives. This included, 
among other things, further development of digital 
platforms and testing of new communication channels. 
Additionally, understanding customer experiences 
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 117

===== SIDA 118 =====

through different channels remained one of Sampo 
Group’s focus areas, as it enables the identification 
opportunities for enhancements to customer journeys 
and customer satisfaction.
Data privacy, information security, and cybersecurity
During 2025, Sampo Group took a series of measures to 
bolster data protection and ensure compliance with 
industry standards and regulations. This included, for 
example, raising awareness within the organisation 
about the importance of data privacy, information 
security, and cybersecurity, providing training to 
employees on the latest developments, new laws, and 
regulations (e.g. Digital Operational Resilience Act 
DORA), and hiring an external company to attempt to 
breach organisational defences and identify 
vulnerabilities. In addition, Sampo Group monitored the 
processing of personal data to ensure it is carried out 
transparently and with respect for individuals’ privacy. 
Key actions included Data Protection Impact 
Assessments and documentation of Records Processing 
Activities before new processing activities were 
initiated or changes to existing ones made, for instance.
In 2025, focus was directed toward the integration of 
Topdanmark into If and the need to align processes 
ensuring compliance with data protection regulations. A 
key activity was to integrate data processing activities 
in the respective Group companies in a way that 
ensures continued compliance with privacy regulations 
and mitigates the potential risks to consumers and end-
users.
Sampo Group regularly updates its policies, guidelines, 
and training materials to stay current with the evolving 
landscape of data privacy, information security, and 
cybersecurity. The Group conducted an annual policy 
review in 2025, which included, for example, 
strengthening its principles, policies, and guidelines 
related to AI. During the year, all Group employees were 
also offered training in the use of AI tools.
Sampo Group has several actions planned for 2026 to 
improve and strengthen the protection of personal 
data. These include, for example, new initiatives to 
improve procurement and monitoring of data 
processors (third-party service providers).
Metrics and targets
S4-5 – Targets related to managing material 
negative impacts, advancing positive 
impacts, and managing material risks and 
opportunities
Customer health and safety and Sales and marketing 
practices 
In accordance with the Sampo Group Code of Conduct, 
Sampo Group strives to act in the best interests of its 
customers. This means that the aim is to provide 
products and services that are fair, comprehensible, and 
designed to help meet the evolving needs of customers.
Sampo Group uses the Net Promoter Score (NPS) to 
measure customer satisfaction, which allows the Group 
to advance positive impacts on consumers and end-
users. Using NPS also supports the monitoring of 
potential negative impacts and risks and acting on 
them. The NPS is an index ranging from -100 to 100 that 
measures the willingness of customers to recommend a 
company’s products or services to others. It is used as a 
proxy for measuring the customer’s overall satisfaction 
with a company’s product or service, and the 
customer’s loyalty to the brand. Transactional Net 
Promoter Score (tNPS) is an overall metric that 
assesses the customer’s opinion on a certain business 
transaction and captures a wide range of customer 
experiences related to, for example, price, product, 
billing, brand, and marketing. The tNPS score shows 
whether customers want to recommend the company 
to others after they have been in contact with the 
company. It is calculated as the net result of the share 
of promoters (who replied 9–10) minus the share of 
detractors (who replied 0–6) on the question of to what 
extent they would recommend the company to others.
Sampo Group has set targets for customer satisfaction. 
The targets are specific to each individual Sampo Group 
company, and their scope differs between the Group 
companies due to company-specific characteristics (e.g. 
size, structure, operating countries). External 
stakeholders have not been directly involved in target 
setting. However, consumers and end-users have been 
indirectly involved, as customer-facing organisational 
units have been included in the target setting. The 
targets are presented in the table Customer satisfaction 
(tNPS) (p. 120). 
Sampo Group actively monitors and analyses the tNPS, 
and the results are regularly reported to the respective 
top managements and internal committees to assess 
overall performance. Sampo Group tracks the tNPS 
performance internally on a monthly basis and has set 
targets to ensure continuous improvement. Sampo 
Group also publishes the results and targets externally 
on a quarterly basis. Through systematic measurement 
of customer satisfaction, Sampo Group wants to both 
identify the factors that are valued by the Group’s 
customers and recognise the parts of the customer 
journey that should be improved. In addition to 
improving the customer experience in general, the 
results are used in training and in developing products, 
services, and customer-related processes. In addition to 
the tNPS, Sampo Group collects feedback through 
various other channels, including customer complaints 
and customer satisfaction surveys. The feedback not 
only contributes to tNPS but also provides deeper 
insights into the customer experience, enabling Sampo 
Group to address concerns proactively. 
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 118

===== SIDA 119 =====

Sampo Group is committed to actively addressing 
customer feedback, and low tNPS scores prompt 
engagement with customers to resolve their issues and 
inform service enhancements. Examples of 
improvements made based on customer feedback 
include clarifying terms and conditions and enhancing 
customer communications and service. These processes 
ensure consistent elevation of service quality and 
customer satisfaction.
The NPS methodology can have its limitations, such as 
oversimplification of customer sentiment, and a lack of 
detailed feedback on specific areas for improvement. 
However, follow-up with individual customers can 
provide a deeper insight into areas of potential 
development.
In 2025, If’s customer satisfaction remained high, and 
the tNPS result for the Private business area stabilised 
at a strong level, reflecting a consolidated and 
consistent trend. In 2026, the work to align If and 
Topdanmark’s customer survey set-ups will continue. In 
the UK, Hastings continued to invest in technology and 
customer service capabilities and exceeded its tNPS 
target in 2025. Examples of enhancements supporting 
positive customer sentiment included a 24/7 messenger 
channel in the mobile app and increased self-service 
functionalities.
Data privacy, information security, and cybersecurity
The goal of Sampo Group’s data privacy operations is 
to protect the employees’, customers’, and other 
stakeholders’ personal data. In addition, information 
security and cybersecurity measures ensure protection 
of all types and forms of information according to its 
sensitivity and importance to the Group, and in 
compliance with applicable rules and regulations. The 
key metrics used are the number of complaints received 
from data subjects and through data protection 
authorities (DPAs), data breaches reported to local data 
protection authorities, and information security and 
cybersecurity incidents reported to the authorities 
within the reporting year.
Complaints from data subjects are based on Sampo 
Group’s internal systems that capture complaints. 
Generally, Sampo Group’s Data Protection Officers 
(DPOs) receive complaints directly from customers and 
through DPAs. Complaints can be received via different 
channels (e.g. email, phone, post/letter) depending on 
the Group company and local legislation in question. If a 
data subject has contacted the local DPA directly, the 
complaint is forwarded to Sampo Group.
Sampo Group’s DPOs (or similar) assess whether 
internally reported data breaches require external 
reporting to local DPAs. The types of incidents that are 
deemed reportable are based on legislation (e.g. the 
General Data Protection Regulation, GDPR). According 
to the GDPR, a personal data breach is a breach of 
security leading to the accidental or unlawful 
destruction, loss, alteration, unauthorised 
disclosure of, or access to, personal data transmitted, 
stored or otherwise processed. However, there are 
regional differences in which data breaches are required 
to be reported to the local DPAs based on their 
individual guidance. In 2025, the number of reported 
data breaches decreased in Sampo Group, as the Group 
continued to further strengthen controls, and due to a 
change of reporting requirements laid down by the DPA 
in the UK.
Information security and cybersecurity incidents are 
monitored internally. Reporting on severe cases to the 
authorities is based on local legislation and is the 
responsibility of legal or information security units (or 
similar). Sampo Group experienced an information 
security incident at the beginning of 2025 when a data 
system was temporarily unavailable. The incident was 
reported to the Financial Supervisory Authority in 
accordance with applicable local regulatory 
requirements.
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 119

===== SIDA 120 =====

Customer satisfaction (tNPS)
Sampo Group
Metric Target 2025 2024
If (Business area Private) 2025: 57 57 57
Hastings 2025: 55 64 56
If’s figures are excluding Topdanmark. 
Complaints received from data subjects and through data 
protection authorities
Sampo Group 
Metric 2025 2024
Complaints received from data subjects 208 135
Complaints received through data protection authorities 9 3
Data breaches reported to local data protection authorities
Sampo Group 
Metric 2025 2024
Data breaches reported to local data protection 
authorities 109 414
Information security and cybersecurity incidents reported to the 
authorities
Sampo Group
Metric 2025 2024
Information security and cybersecurity incidents reported 
to the authorities 1 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 120

===== SIDA 121 =====

Governance information
G1 Business conduct
Topic Impacts Risks and opportunities Strategy and actions
Corruption 
and bribery
↓  S a m p o  G r o u p  c a n  h a v e  a  p o t e n t i a l  n e g a t i v e  i m p a c t  
on society, as financial institutions tend to be 
favoured channels for financial crime, corruption, and 
bribery, for example, through customer support 
functions, investments, suppliers, or business 
partners.
• Time-horizon: short to medium term
• 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  r e p u t a t i o n a l  r i s k s ,  l e g a l  r i s k s ,  
business risks, and potential costs if it fails to combat 
financial crime, corruption, and bribery in all their forms.
• Time-horizon: short to medium term
• Value chain location: own operations, upstream value 
chain, downstream value chain
• Internal policies and guidelines (e.g. codes of conduct, 
responsible investment policies)
• Effective governance structures and processes (e.g. 
general risk management measures, screening of direct 
investments and corporate customers, encouraging 
sustainability in supply chains, reporting channels)
• Internal training and competence development 
programmes
• Metrics and targets (e.g. reported incidents)
Responsible 
business 
practices
↑  A c t u a l  p o s i t i v e  i m p a c t  o c c u r s  t h r o u g h  q u a l i t y  r i s k  
management, which is at the core of Sampo Group’s 
business operations. Risk management ensures that 
the Group can provide safety and financial security 
to its customers, investors, and society in general.
↑  E m p h a s i s i n g  s u s t a i n a b i l i t y  a n d  r e s p o n s i b l e  b u s i n e s s  
practices in strategy and business operations may 
result in positive impacts across Sampo Group’s 
value chain.
↓  I f  S a m p o  G r o u p  f a i l s  t o  m a n a g e  r i s k s  e f f e c t i v e l y ,  i t  
may weaken the Group's ability to provide security 
and could therefore have a potential negative impact 
on its customers and other stakeholders.*
↓  F a i l i n g  t o  p r o t e c t  w h i s t l e b l o w e r s  c a n  h a v e  a  p o t e n t i a l  
negative impact throughout Sampo Group’s value 
chain, as it may reduce trust and maintain negative 
impacts related to people or the environment.*
• Time-horizon: short to medium term
• Value chain location: own operations, upstream value 
chain, downstream value chain
↓  F o r  a n  i n s u r a n c e  c o m p a n y  l i k e  S a m p o  G r o u p ,  r e s p o n s i b l e  
business practices and quality risk management (e.g. 
adequate management and control systems, internal 
standards and processes) are at the core of the business. 
However, due to the size of the Group and its value chain, 
it is not possible to completely eliminate the risk of 
potential negative impacts (e.g. risk of non-compliance 
due to increasing regulation or human error).
↓  I f  s u s t a i n a b i l i t y  i s  n o t  a n  i n t e g r a t e d  p a r t  o f  S a m p o  
Group’s governance and business management, it can 
cause a financial risk for the Group due to possible 
legislative consequences (e.g. fines) and reputational 
damage, for example. 
↑  I n t e g r a t i n g  s u s t a i n a b i l i t y  i n  S a m p o  G r o u p ’ s  g o v e r n a n c e  
and business operations supports preparation for future 
regulations and the sustainable development of society 
(e.g. green transformation), which may create financial 
opportunities for the Group.
• Time-horizon: short to medium term 
• Value chain location: own operations, upstream value 
chain, downstream value chain
• Internal policies and guidelines (e.g. risk management 
principles, compliance principles, codes of conduct)
• Effective governance structures and processes (e.g. 
Sampo Group steering framework, risk management 
governance framework, regulated risk management 
measures, sustainability reporting and governance 
structure, whistleblowing channels)
• Internal training and competence development 
programmes
Sustainable 
partnerships 
and supply 
chains
↓  S a m p o  G r o u p  c a n  h a v e  p o t e n t i a l  n e g a t i v e  i m p a c t s  
on suppliers and business partners if it fails to 
manage its supplier relationships according to 
agreed terms and conditions (e.g. delays in 
payments).*
• Time-horizon: short to medium term
• Value chain location: own operations, upstream value 
chain, downstream value chain
↑  H a v i n g  s t a b l e  b u s i n e s s  r e l a t i o n s h i p s  w i t h  r e s p o n s i b l e  
suppliers and business partners can be a competitive 
advantage and create financial opportunities for Sampo 
Group.*
↓  P a r t n e r i n g  w i t h  i r r e s p o n s i b l e  s u p p l i e r s  o r  b u s i n e s s  
partners can lead to increased costs (e.g. costs related to 
changing a supplier, delays, poor-quality deliveries) and 
reputational damage for Sampo Group.*
• Time-horizon: short to medium term
• Value chain location: own operations, upstream value 
chain, downstream value chain
• Internal policies and guidelines (e.g. codes of conduct, 
supplier codes of conduct, sustainability policies, 
procurement policies)
• Effective governance structures and processes (e.g. 
supplier risk assessments, audits, questionnaires, 
engagement)
• Internal training and competence development 
programmes
• Metrics and targets (e.g. supplier codes of conduct 
included in existing supplier agreements)
The table presents Sampo Group’s material impacts, risks, and opportunities related to business conduct identified in the double materiality assessment and their connection to Sampo Group’s strategy and 
actions. The topic Corruption and bribery is related to the ESRS sub-topic with the same name. The topic Responsible business practices is related to the ESRS sub-topics Corporate culture and Protection 
of whistleblowers. The topic Sustainable partnerships and supply chains is related to the ESRS sub-topic Management of relationships with suppliers including payment practices.
* 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 121

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

Impact, risk and opportunity 
management
G1-1 – Business conduct policies and 
corporate culture
The group level policy regarding business conduct and 
corporate culture is the Sampo Group Code of Conduct, 
which is reviewed annually and approved by Sampo’s 
Board of Directors. The Code states that Sampo Group 
complies with applicable legislation and the rules and 
regulations of competent authorities in all its activities. 
In addition to the Group’s Code of Conduct, Sampo 
Group has supplementary and more detailed policies, 
guidelines, and processes for specific purposes (e.g. HR 
policies, underwriting principles, responsible investment 
policies, supplier codes of conduct). Sampo Group is 
also a participant in the UN Global Compact, supporting 
its principles on human rights, labour rights, the 
environment, and anti-corruption.
The Sampo Group Code of Conduct applies to all 
companies belonging to Sampo Group. The Group 
offers regular training (e.g. e-learning, workshops) to all 
employees on the topics covered by the Code and is 
committed to communicating the topics to its 
employees (e.g. policy updates on the intranet). The 
frequency of the training varies from annual to biennial 
depending on the Group company and the topic in 
question.
Whistleblowing channels
Sampo Group has whistleblowing channels through 
which employees and relevant interest groups can 
report anonymously if they have reasonable grounds to 
suspect that somebody employed by Sampo Group has 
breached the Group’s Code of Conduct, legislation, 
regulations, or other rules that are relevant to the 
insurance industry. Material whistleblowing notifications 
reported through the whistleblowing channels are 
reported to the parent company, Sampo, as a part of 
regular compliance and sustainability reporting to 
ensure group level monitoring of these matters. In 
addition to the whistleblowing channels, Sampo Group 
encourages its employees to report other work-related 
grievances and day-to-day concerns through internal 
reporting channels. Grievances can also be reported 
directly to a leader, HR, or compliance units, for 
example.
Sampo Group has defined structures for processing 
whistleblowing notifications. The Group ensures that 
the outcomes and remedies related to whistleblowing 
systems accord with internationally recognised human 
rights. 
Information about the whistleblowing channels and 
other internal reporting channels is proactively 
communicated to employees through intranet pages, 
for example. Sampo Group also offers training to its 
own employees, including information about the 
designation and training of those reviewing the reports. 
The employees designated with this task receive 
training when they are appointed to the position (e.g. 
onboarding, on-the-job training). Maintaining objectivity 
is essential for the employees handling the reports. 
Sampo Group ensures that those handling the reports 
are separate from those whom the report concerns, and 
the investigators or investigating committees are 
separate from the chain of management involved in the 
matter.
All whistleblowing reports are investigated promptly 
and in a confidential manner, while always protecting 
the identity of the whistleblower. Sampo Group 
prohibits any form of retaliation against an employee 
who in good faith raises a concern about suspected or 
actual misconduct through any reporting channel, or 
who cooperates in an investigation of misconduct.
G1-2 – Management of relationships with 
suppliers
Sampo Group complies with applicable local legislation 
and regulations in its payment practices. In addition, the 
Group has internal guidelines in place (e.g. accounting 
instructions, claims guidelines) to ensure timely 
payment. Automated systems and digital invoicing help  
prevent late payments.
Sampo Group is a major procurer of goods and 
services, especially in claims handling and, therefore, 
has an impact on the economy, environment, and 
people. Sampo Group emphasises sustainability factors 
when working with suppliers, as sustainability issues can 
carry reputational and operational risks if not managed 
correctly. The Sampo Group Code of Conduct provides 
the group level guiding principles for sustainable supply 
chain management. According to the Code of Conduct, 
Sampo Group expects its suppliers and other business 
partners to comply with the principles of the Code of 
Conduct throughout their own operations and supply 
chains. 
Environmental and social considerations are integral to 
Sampo Group’s supplier selection process. In addition to 
the Group’s Code of Conduct, Sampo Group has 
supplementary policies (e.g. supplier codes of conduct), 
guidelines, and processes (e.g. risk assessments) that 
guide supplier selection on a more detailed level. Topics 
covered in these policies include human rights, labour 
rights, environmental considerations, and anti-
corruption. Sampo Group is committed to encouraging 
and supporting its suppliers in their efforts to use more 
sustainable methods in their operations. By actively 
requesting innovative solutions, resource efficiency, 
transparency, and responsibility from suppliers, Sampo 
Group aims to minimise its negative impact and 
stimulate sustainable production and consumption. Set 
requirements, in combination with close cooperation 
with suppliers, enable Sampo Group to develop 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 122

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

business while also contributing to sustainable 
development.
G1-3 – Prevention and detection of 
corruption and bribery
Sampo Group can be exposed to corruption and bribery 
especially through its customer support functions (e.g. 
sales, claims handling), investments, as well as suppliers 
and business partners (e.g. procurement, claims 
handling, IT). Customer support functions are at risk of 
corruption, for example due to financial transactions 
and handling of personal data. Investment operations 
can be vulnerable, for example, due to exposure to 
industries and markets with varying levels of corruption 
risk. Suppliers and business partners may face risks 
associated with the dependency on third-party 
partnerships and intricate procurement operations.
Allegations or incidents of corruption and bribery are 
generally detected through reporting channels (e.g. 
whistleblowing channels), screening of customers and 
direct investments, as well as supplier selection and risk 
assessment processes. The risks are mitigated by 
internal control systems. These include commitments to 
international initiatives (e.g. the UN Global Compact), 
policies and guidelines (e.g. codes of conduct, 
investment policies), employee training, and other 
manual and automatic control activities. 
Sampo Group’s Code of Conduct sets the overall 
guiding principles for preventing corruption and bribery 
within the Group. In addition, Sampo Group has 
supplementary policies and guidelines for specific and 
more detailed purposes. These annually updated 
guidance documents contain, for example, rules on 
gifts, participation in events, and hospitality, as well as 
information on expectations regarding employees, and 
roles and responsibilities.
The CEO of each Sampo Group company has the 
ultimate responsibility to ensure that sufficient 
resources are allocated to the prevention of corruption 
and bribery. Each Group company organises duties and 
takes other necessary and appropriate measures to 
comply with the applicable local rules and various 
sanctions regimes, which may be imposed by the UN 
and/or the EU.
Reporting on anti-corruption and anti-bribery activities, 
as well as on potential incidents, is organised in a 
manner that ensures that the applicable management 
and boards of directors within Sampo Group receive all 
material information without undue delay. All valid 
whistleblowing notifications received through the 
whistleblowing channels are reported to the parent 
company, Sampo, as part of regular compliance 
reporting. Sampo’s Risk Management organisation is 
responsible for overseeing the reporting of relevant 
incidents to Sampo’s Audit Committee and the Board of 
Directors.
Sampo Group provides training (e.g. e-learning and 
during contract discussions) on business conduct 
matters to ensure that employees, suppliers, and other 
business partners have sufficient knowledge of these 
topics. Related and relevant policies are available to all 
Group employees on intranet pages and to other 
stakeholders on the Group’s websites. 
In addition, all Sampo Group employees and top 
management (e.g. CEOs) are offered training (e.g. e-
learning) on anti-corruption and anti-bribery at least 
biennially. Hence, also all employees who work in the 
functions most at risk for negative impacts (e.g. 
customer support functions, investment management, 
supply chain management) receive training on the 
topic. Anti-corruption and anti-bribery are part of 
training programmes covering business ethics and 
conduct. In addition, employees are informed, for 
example, on the intranet pages, when related policies 
have been revised.
In 2025, Sampo Group continued its regular efforts to 
ensure that processes related to its business conduct 
remain up to date. This involved, for instance, 
conducting annual policy updates and providing 
relevant training to all employees, as well as integrating 
If and Topdanmark’s learning practices. In addition, the 
Group strengthened its internal processes by enhancing 
process descriptions and related documentation, as well 
as harmonising reporting practices.
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 123

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

Metrics and targets
G1-4 – Incidents of corruption or bribery
In 2025, Sampo Group was not convicted for incidents 
of corruption or bribery and, therefore, did not pay any 
related fines. For the same reason, the Group did not 
need to take specific actions related to breaches in 
procedures and standards of anti-corruption and anti-
bribery. In 2025, there were no public legal cases 
regarding corruption or bribery brought against Sampo 
Group either.
Incidents of corruption and bribery included in the 
reporting are confirmed incidents that the Group 
companies report to Sampo as part of regular 
sustainability and compliance and/or risk reporting. The 
Group companies receive this information through their 
established reporting channels, such as whistleblowing 
channels.
Incidents of corruption or bribery
Sampo Group
Metric 2025 2024
Confirmed incidents of corruption 
or bribery 0 0
G1-6 – Payment practices
Sampo Group is committed to fair and responsible 
payment practices. It recognises the importance of 
timely payments to suppliers and strives to ensure that 
its payment practices are transparent and equitable 
throughout its supply chain.
In 2025, the average time to pay an invoice at Sampo 
Group was 23 days. The standard payment terms and 
the share of payments aligned with the standard terms 
are presented in the table Payment practices. 85.9 per 
cent of Sampo Group’s total payments were aligned 
with the payment terms in 2025. The main reasons for 
late payments included delays in invoice review and 
approval flow, invoices arriving late to the Group, and 
challenges related to new suppliers (e.g. short payment 
terms in one-time basis purchases, time required for 
supplier validation controls, invoices sent to the wrong 
address). However, 62.8 per cent of the late payments 
were paid within seven days of the due date. 
The payment term has been calculated as the period 
between the invoice date and the due date. The 
average time to make a payment at Sampo Group has 
been calculated based on the period between the 
invoice date and the payment date. The reported 
information relates to the Group’s upstream suppliers, 
as defined by the ESRS, and has been collected for the 
entire Sampo Group, subject to minor limitations due to 
data availability.
Sampo Group’s payment terms are influenced by 
various factors, including the nature of the supplier 
relationship, the country or geographical region of 
operation, and market standards. Sampo Group is not 
able to disclose its standard payment terms by main 
category of suppliers due to the diversity of its supplier 
base and confidentiality considerations. As at 31 
December 2025, Sampo Group was not party to any 
legal proceedings due to late payments.
Payment practices
Sampo Group, 2025
Payment term
Share of total 
payments
Payments 
aligned with 
the term
Within 14 days  24.5%  70.2% 
Within 15 to 30 days  57.7%  90.7% 
Within 31 days or more  17.8%  92.2% 
Total  100.0%  85.9% 
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 124

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

Annexes
Annex 1: ESRS content index
Disclosure requirement Location
ESRS 2 General disclosures
BP-1 – General basis for preparation of the sustainability statement p. 57
BP-2 – Disclosures in relation to specific circumstances p. 57
GOV-1 – The role of the administrative, management and supervisory 
bodies p. 57
GOV-2 – Information provided to and sustainability matters addressed by 
the undertaking’s administrative, management and supervisory bodies p. 59
GOV-3 – Integration of sustainability-related performance in incentive 
schemes p. 60
GOV-4 – Statement on due diligence p. 60
GOV-5 – Risk management and internal controls over sustainability 
reporting p. 62
SBM-1 – Strategy, business model and value chain p. 62
SBM-2 – Interests and views of stakeholders p. 65
SBM-3 – Material impacts, risks, and opportunities and their interaction 
with strategy and business model
pp. 67, 78, 95, 
108, 114
IRO-1 – Description of the processes to identify and assess material 
impacts, risks, and opportunities p. 69
IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s 
sustainability statement p. 71
ESRS E1 Climate change
E1-1 – Transition plan for climate change mitigation p. 79
E1-2 – Policies related to climate change mitigation and adaptation p. 81
E1-3 – Actions and resources in relation to climate change policies p. 81
E1-4 – Targets related to climate change mitigation and adaptation p. 84
E1-6 – Gross Scopes 1, 2, 3 and total GHG emissions p. 86
ESRS E5 Resource use and circular economy
E5-1 – Policies related to resource use and circular economy p. 92
E5-2 – Actions and resources related to resource use and circular 
economy p. 92
E5-3 – Targets related to resource use and circular economy p. 93
Disclosure requirement Location
ESRS S1 Own workforce
S1-1 – Policies related to own workforce p. 95
S1-2 – Processes for engaging with own workers and workers’ 
representatives about impacts p. 96
S1-3 – Processes to remediate negative impacts and channels for own 
workers to raise concerns p. 97
S1-4 – Taking action on material impacts on own workforce, and 
approaches to mitigating material risks and pursuing material 
opportunities related to own workforce, and effectiveness of those actions p. 97
S1-5 – Targets related to managing material negative impacts, advancing 
positive impacts, and managing material risks and opportunities p. 98
S1-6 – Characteristics of the undertaking’s employees p. 100
S1-7 – Characteristics of non-employee workers in the undertaking’s own 
workforce p. 102
S1-8 – Collective bargaining coverage and social dialogue p. 102
S1-9 – Diversity metrics p. 103
S1-10 – Adequate wages p. 104
S1-11 – Social protection p. 104
S1-12– Persons with disabilities p. 104
S1-13 – Training and skills development metrics p. 104
S1-14 – Health and safety metrics p. 105
S1-15 – Work-life balance metrics p. 105
S1-16 – Remuneration metrics p. 106
S1-17 – Incidents, complaints and severe human rights impacts p. 106
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 125

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

Disclosure requirement Location
ESRS S2 Workers in the value chain
S2-1 – Policies related to value chain workers p. 108
S2-2 – Processes for engaging with value chain workers about impacts p. 110
S2-3 – Processes to remediate negative impacts and channels for value 
chain workers to raise concerns p. 110
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
S2-5 – Targets related to managing material negative impacts, advancing 
positive impacts, and managing material risks and opportunities p. 112
ESRS S4 Consumers and end-users
S4-1 – Policies related to consumers and end-users p. 114
S4-2 – Processes for engaging with consumers and end-users about 
impacts p. 115
S4-3 – Processes to remediate negative impacts and channels for 
consumers and end-users to raise concerns p. 116
S4-4 – Taking action on material impacts on consumers and end-users, 
and approaches to managing material risks and pursuing material 
opportunities related to consumers and end-users, and effectiveness of 
those actions p. 117
S4-5 – Targets related to managing material negative impacts, advancing 
positive impacts, and managing material risks and opportunities p. 118
ESRS G1 Business conduct
G1-1 – Business conduct policies and corporate culture p. 122
G1-2 – Management of relationships with suppliers p. 122
G1-3 – Prevention and detection of corruption and bribery p. 123
G1-4 – Incidents of corruption or bribery p. 124
G1-6 – Payment practices p. 124
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 126

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

Annex 2: Data points deriving from other EU legislation
Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS 2 GOV-1 Board's gender diversity 
paragraph 21 (d)
Indicator number 13 of Table 
#1 of Annex 1
Commission Delegated 
Regulation (EU) 2020/1816, 
Annex II
p. 57
ESRS 2 GOV-1 Percentage of board members 
who are independent paragraph 21 (e)
Delegated Regulation (EU) 
2020/1816, Annex II
p. 57
ESRS 2 GOV-4 Statement on due diligence 
paragraph 30
Indicator number 10 Table #3 
of Annex 1
p. 60
ESRS 2 SBM-1 Involvement in activities related 
to fossil fuel activities paragraph 40 (d) i
Indicators number 4 Table #1 
of Annex 1
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Table 1: 
Qualitative information on 
Environmental risk and Table 
2: Qualitative information on 
Social risk
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS 2 SBM-1 Involvement in activities related 
to chemical production paragraph 40 (d) ii
Indicator number 9 Table #2 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS 2 SBM-1 Involvement in activities related 
to controversial weapons paragraph 40 (d) iii
Indicator number 14 Table #1 
of Annex 1
Delegated Regulation (EU) 
2020/1818, Article 12(1) 
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS 2 SBM-1 Involvement in activities related 
to cultivation and production of tobacco 
paragraph 40 (d) iv
Delegated Regulation (EU) 
2020/1818, Article 12(1) 
Delegated Regulation (EU) 
2020/1816, Annex II
Not material
ESRS E1-1 Transition plan to reach climate 
neutrality by 2050 paragraph 14
Regulation (EU) 2021/1119, 
Article 2(1)
p. 79
ESRS E1-1 Undertakings excluded from Paris-
aligned Benchmarks paragraph 16 (g)
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 1: 
Banking book – Climate 
Change transition risk: Credit 
quality of exposures by 
sector, emissions and 
residual maturity
Delegated Regulation (EU) 
2020/1818, Article 12.1 (d) to 
(g), and Article 12.2
p. 79
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 127

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

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS E1-4 GHG emission reduction targets 
paragraph 34
Indicator number 4 Table #2 
of Annex 1
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 3: 
Banking book – Climate 
change transition risk: 
alignment metrics
Delegated Regulation (EU) 
2020/1818, Article 6
p. 84
ESRS E1-5 Energy consumption from fossil 
sources disaggregated by sources (only high 
climate impact sectors) paragraph 38
Indicator number 5 Table #1 
and Indicator no. 5 Table #2 
of Annex 1
Not material
ESRS E1-5 Energy consumption and mix 
paragraph 37
Indicator number 5 Table #1 
of Annex 1
Not material
ESRS E1-5 Energy intensity associated with 
activities in high climate impact sectors 
paragraphs 40 to 43
Indicator number 6 Table #1 
of Annex 1
Not material
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG 
emissions paragraph 44
Indicators number 1 and 2 
Table #1 of Annex 1
Article 449a; Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 1: 
Banking book – Climate 
change transition risk: Credit 
quality of exposures by 
sector, emissions and 
residual maturity
Delegated Regulation (EU) 
2020/1818, Article 5(1), 6 and 
8(1)
p. 86
ESRS E1-6 Gross GHG emissions intensity 
paragraphs 53 to 55
Indicators number 3 Table #1 
of Annex 1
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 Template 3: 
Banking book – Climate 
change transition risk: 
alignment metrics
Delegated Regulation (EU) 
2020/1818, Article 8(1)
p. 87
ESRS E1-7 GHG removals and carbon credits 
paragraph 56
Regulation (EU) 2021/1119, 
Article 2(1)
Not material
ESRS E1-9 Exposure of the benchmark 
portfolio to climate-related physical risks 
paragraph 66
Delegated Regulation (EU) 
2020/1818, Annex II 
Delegated Regulation (EU) 
2020/1816, Annex II
Phased-in
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 128

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

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS E1-9 Disaggregation of monetary 
amounts by acute and chronic physical risk 
paragraph 66 (a)
ESRS E1-9 Location of significant assets at 
material physical risk paragraph 66 (c)
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 paragraphs 
46 and 47; Template 5: 
Banking book – Climate 
change physical risk: 
Exposures subject to 
physical risk
Phased-in
ESRS E1-9 Breakdown of the carrying value of 
its real estate assets by energy-efficiency 
classes paragraph 67 (c).
Article 449a Regulation (EU) 
No 575/2013; Commission 
Implementing Regulation 
(EU) 2022/2453 paragraph 
34;Template 2:Banking book 
-Climate change transition 
risk: Loans collateralised by 
immovable property – 
Energy efficiency of the 
collateral
Phased-in
ESRS E1-9 Degree of exposure of the portfolio 
to climate-related opportunities paragraph 69
Delegated Regulation (EU) 
2020/1818, Annex II
Phased-in
ESRS E2-4 Amount of each pollutant listed in 
Annex II of the E-PRTR Regulation (European 
Pollutant Release and Transfer Register) 
emitted to air, water and soil, paragraph 28
Indicator number 8 Table #1 
of Annex 1, Indicator number 
2 Table #2 of Annex 1, 
Indicator number 1 Table #2 
of Annex 1, Indicator number 
3 Table #2 of Annex 1
Not material
ESRS E3-1 Water and marine resources 
paragraph 9
Indicator number 7 Table #2 
of Annex 1
Not material
ESRS E3-1 Dedicated policy paragraph 13 Indicator number 8 Table # 2 
of Annex 1
Not material
ESRS E3-1 Sustainable oceans and seas 
paragraph 14
Indicator number 12 Table #2 
of Annex 1
Not material
ESRS E3-4 Total water recycled and reused 
paragraph 28 (c)
Indicator number 6.2 Table 
#2 of Annex 1
Not material
ESRS E3-4 Total water consumption in m³ per 
net revenue on own operations paragraph 29
Indicator number 6.1 Table 
#2 of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (a) i Indicator number 7 Table #1 
of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (b) Indicator number 10 Table #2 
of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (c) Indicator number 14 Table #2 
of Annex 1
Not material
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 129

===== SIDA 130 =====

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS E4-2 Sustainable land / agriculture 
practices or policies paragraph 24 (b)
Indicator number 11 Table #2 
of Annex 1
Not material
ESRS E4-2 Sustainable oceans / seas 
practices or policies paragraph 24 (c)
Indicator number 12 Table #2 
of Annex 1
Not material
ESRS E4-2 Policies to address deforestation 
paragraph 24 (d)
Indicator number 15 Table #2 
of Annex 1
Not material
ESRS E5-5 Non-recycled waste paragraph 37 
(d)
Indicator number 13 Table #2 
of Annex 1
Not material
ESRS E5-5 Hazardous waste and radioactive 
waste paragraph 39
Indicator number 9 Table #1 
of Annex 1
Not material
ESRS 2 – SBM-3 - S1 Risk of incidents of 
forced labour paragraph 14 (f)
Indicator number 13 Table #3 
of Annex I
Not material
ESRS 2 – SBM-3 - S1 Risk of incidents of child 
labour paragraph 14 (g) 
Indicator number 12 Table #3 
of Annex I
Not material
ESRS S1-1 Human rights policy commitments 
paragraph 20
Indicator number 9 Table #3 
and Indicator number 11 
Table #1 of Annex I
p. 95
ESRS S1-1 Due diligence policies on issues 
addressed by the fundamental International 
Labor Organisation Conventions 1 to 8, 
paragraph 21
Delegated Regulation (EU) 
2020/1816, Annex II
p. 95
ESRS S1-1 processes and measures for 
preventing trafficking in human beings 
paragraph 22
Indicator number 11 Table #3 
of Annex I
p. 95
ESRS S1-1 workplace accident prevention 
policy or management system paragraph 23
Indicator number 1 Table #3 
of Annex I
p. 95
ESRS S1-3 grievance/complaints handling 
mechanisms paragraph 32 (c)
Indicator number 5 Table #3 
of Annex I
p. 97
ESRS S1-14 Number of fatalities and number 
and rate of work-related accidents paragraph 
88 (b) and (c)
Indicator number 2 Table #3 
of Annex I
Delegated Regulation (EU) 
2020/1816, Annex II
p. 105
ESRS S1-14 Number of days lost to injuries, 
accidents, fatalities or illness paragraph 88 (e)
Indicator number 3 Table #3 
of Annex I
Phased-in
ESRS S1-16 Unadjusted gender pay gap 
paragraph 97 (a)
Indicator number 12 Table #1 
of Annex I
Delegated Regulation (EU) 
2020/1816, Annex II
p. 106
ESRS S1-16 Excessive CEO pay ratio 
paragraph 97 (b)
Indicator number 8 Table #3 
of Annex I
p. 106
ESRS S1-17 Incidents of discrimination 
paragraph 103 (a)
Indicator number 7 Table #3 
of Annex I
p. 106
ESRS S1-17 Non-respect of UNGPs on Business 
and Human Rights and OECD paragraph 104 
(a)
Indicator number 10 Table #1 
and Indicator no. 14 Table #3 
of Annex I
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818 Art 12 (1)
p. 106
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 130

===== SIDA 131 =====

Disclosure requirement and related 
datapoint SFDR reference Pillar 3 reference
Benchmark Regulation 
reference EU Climate Law reference Location
ESRS 2 – SBM-3 – S2 Significant risk of child 
labour or forced labour in the value chain 
paragraph 11 (b)
Indicators number 12 and 13 
Table #3 of Annex I
p. 108
ESRS S2-1 Human rights policy commitments 
paragraph 17
Indicator number 9 Table #3 
and Indicator no. 11 Table #1 
of Annex 1
p. 108
ESRS S2-1 Policies related to value chain 
workers paragraph 18
Indicator number 11 and 4 
Table #3 of Annex 1
p. 108
SRS S2-1 Non-respect of UNGPs on Business 
and Human Rights principles and OECD 
guidelines paragraph 19
Indicator number 10 Table #1 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818, Art 12 (1)
p. 108
ESRS S2-1 Due diligence policies on issues 
addressed by the fundamental International 
Labor Organisation Conventions 1 to 8, 
paragraph 19
Delegated Regulation (EU) 
2020/1816, Annex II
p. 108
ESRS S2-4 Human rights issues and incidents 
connected to its upstream and downstream 
value chain paragraph 36
Indicator number 14 Table #3 
of Annex 1
p. 111
ESRS S3-1 Human rights policy commitments 
paragraph 16
Indicator number 9 Table #3 
of Annex 1 and Indicator 
number 11 Table #1 of Annex 1
Not material
ESRS S3-1 Non-respect of UNGPs on Business 
and Human Rights, ILO principles or and 
OECD guidelines paragraph 17
Indicator number 10 Table #1 
Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818, Art 12 (1)
Not material
ESRS S3-4 Human rights issues and incidents 
paragraph 36
Indicator number 14 Table #3 
of Annex 1
Not material
ESRS S4-1 Policies related to consumers and 
end-users paragraph 16
Indicator number 9 Table #3 
and Indicator number 11 
Table #1 of Annex 1
p. 114
ESRS S4-1 Non-respect of UNGPs on Business 
and Human Rights and OECD guidelines 
paragraph 17
Indicator number 10 Table #1 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II 
Delegated Regulation (EU) 
2020/1818, Art 12 (1)
p. 114
ESRS S4-4 Human rights issues and incidents 
paragraph 35
Indicator number 14 Table #3 
of Annex 1
p. 117
ESRS G1-1 United Nations Convention against 
Corruption paragraph 10 (b)
Indicator number 15 Table #3 
of Annex 1
p. 122
ESRS G1-1 Protection of whistle-blowers 
paragraph 10 (d)
Indicator number 6 Table #3 
of Annex 1
p. 122
ESRS G1-4 Fines for violation of anti-
corruption and anti-bribery laws paragraph 24 
(a)
Indicator number 17 Table #3 
of Annex 1
Delegated Regulation (EU) 
2020/1816, Annex II)
p. 124
ESRS G1-4 Standards of anti-corruption and 
anti-bribery paragraph 24 (b)
Indicator number 16 Table #3 
of Annex 1
p. 124
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 131

===== SIDA 132 =====

Key figures 
Financial highlights 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Group
Gross written premiums & brokerage income EURm  10,738  9,931  8,870  8,375  —  — 
Insurance revenue (incl. brokerage), net EURm  9,078  8,386  7,412  7,168  —  — 
Underwriting result EURm  1,485  1,316  1,164  1,031  1,314  1,282 
Net financial result EURm  1,210  636  560  1,056  —  — 
Profit before taxes EURm  2,436  1,559  1,481  1,924  1,863  3,171 
Net profit for the equity holders EURm  1,998  1,154  1,323  2,107  1,427  2,567 
Operating result EURm  1,343  1,193  1,046  —  —  — 
Risk ratio %  58.3  59.0  —  —  —  — 
Cost ratio %  25.4  25.3  —  —  —  — 
Combined ratio %  83.6  84.3  84.6  85.8  82.1  81.4 
Nordic underlying risk ratio %  63.5  63.8  —  —  —  — 
Nordic operating cost ratio %  22.6  22.7  —  —  —  — 
Solvency II ratio1 3 %  174  177  182  210  210  185 
Financial leverage %  23.6  26.9  25.3  24.4  25.6  23.8 
Return on equity own funds %  32.3  29.5  24.7  —  —  — 
Average number of staff  15,003  14,280  13,935  13,550  13,550  13,274 
Private Nordic 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Gross written premiums EURm  4,183  3,872  —  —  —  — 
Insurance revenue, net EURm  3,995  3,667  —  —  —  — 
Underwriting result EURm  715  628  —  —  —  — 
Risk ratio %  60.9  60.7  —  —  —  — 
Cost ratio %  21.2  22.2  —  —  —  — 
Combined ratio %  82.1  82.9  —  —  —  — 
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 132

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

Private UK 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Gross written premiums (incl. brokerage) EURm  2,865  2,565  —  —  —  — 
Insurance revenue (incl. brokerage), net EURm  2,000  1,659  —  —  —  — 
Underwriting result EURm  216  190  —  —  —  — 
Risk ratio %  53.6  52.3  —  —  —  — 
Cost ratio %  35.6  36.2  —  —  —  — 
Combined ratio %  89.2  88.5  —  —  —  — 
Nordic Commercial 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Gross written premiums EURm  2,391  2,173  —  —  —  — 
Insurance revenue, net EURm  2,201  2,128  —  —  —  — 
Underwriting result EURm  376  352  —  —  —  — 
Risk ratio %  58.4  58.9  —  —  —  — 
Cost ratio %  24.5  24.5  —  —  —  — 
Combined ratio %  82.9  83.5  —  —  —  — 
Nordic Industrial 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Gross written premiums EURm  1,046  1,070  —  —  —  — 
Insurance revenue, net EURm  584  657  —  —  —  — 
Underwriting result EURm  109  74  —  —  —  — 
Risk ratio %  58.4  69.2  —  —  —  — 
Cost ratio %  22.9  19.5  —  —  —  — 
Combined ratio %  81.3  88.7  —  —  —  — 
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 133

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

Per share key figures 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Earnings per share EUR  0.74  0.45  0.52  0.79  0.54  0.93 
Earnings per share, continuing operations2 EUR  0.74  0.45  0.42  0.58  —  — 
Earning per share, discontinuing operations EUR  —  —  0.10  0.22  —  — 
Operating earnings per share EUR  0.50  0.47  0.41  —  —  — 
Equity per share EUR  3.04  2.62  2.89  3.74  3.49  4.68 
Net asset value per share EUR  3.04  2.62  3.06  4.00  3.75  5.10 
Dividend per share EUR 0.36 0.34 0.36  0.52  0.52  0.82 
Total dividend EURm 956 915 903  1,321  1,321  2,186 
Dividend payout ratio %  71.2  76.7  86.4  —  —  — 
Effective dividend yield %  3.5  4.3  4.5  5.3  5.3  9.3 
Price/operating earnings ratio 20.6 16.9  —  —  —  — 
Price/earnings ratio 13.9 17.5 15.1 12.3 18.1 9.5
Number of shares at 31 Dec.5 1,000 2,661,809 2,691,239 2,508,984 2,571,847 2,571,845 2,734,060
Average number of shares5 1,000 2,684,637 2,560,572 2,529,695 2,651,481 2,651,480 2,771,585
Market capitalisation4 EURm 27,496 21,196 19,876 25,112 25,112 24,093
A shares 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Number of shares at 31 Dec.5 1,000 2,660,809 2,690,239 2,507,984 2,570,847 2,570,845 2,728,060
Average  number of shares5 1,000 2,683,637 2,559,572 2,528,695 2,650,481 2,650,480 2,765,585
Weighted average share price EUR 9.17 8.02 7.87 8.85 8.85 8.10
Adjusted share price, high4 EUR 10.36 8.47 9.04 9.99 9.99 9.47
Adjusted share price, low4 EUR 7.70 7.48 6.91 7.17 7.17 6.76
Adjusted closing price EUR 10.33 7.88 7.92 9.76 9.76 8.81
Share trading volume during the financial year 1,000 787,550 894,548 894,006 1,289,395 1,289,395 1,218,815
Relative share trading volume %  29.3  34.9  35.4  48.6  48.6  44.1 
B shares 2025 2024 2023
2022 
(restated)
2022 
(published) 2021
Number of shares at 31 Dec.5 1,000 1,000 1,000 1,000 1,000 1,000 6,000
Average number of shares5 1,000 1,000 1,000 1,000 1,000 1,000 6,000
1The Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC).
2Earnings per share on continuing operations for comparative period 2022 includes the divested operations i.e. Topdanmark Life operations.
3The solvency ratio for 2023 is pro forma figure excluding the effect of Saxo Bank on the Group SCR. 
4Share prices have been adjusted to reflect the separation of Mandatum Group in a partial demerger carried out in 2023. 
5Both the number of shares used at the reporting date and the average number of shares have been adjusted in the comparative periods to reflect the sharesplit carried out in 2025.
In calculating the key figures the tax corresponding to the result for the accounting period has been taken into account. 
In the net asset value per share, the Group valuation difference on the listed subsidiary Topdanmark has been taken into account in the comparison years prior to 2024. At the end of the financial year 2024, 
Topdanmark had been delisted.
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BOARD OF DIRECTORS’ REPORT 2025 134

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

Calculation of key figures
The key figures have been calculated in accordance with the decree issued by the Ministry of Finance and the specifying regulations and instructions of the Financial Supervisory 
Authority. The Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC) and Insurance Companies Act (521/2008).
Additional information on the Group’s alternative performance measures is on the Group’s website www.sampo.com.
Return on equity own funds, %
+ operating result (annualised) x 100 %+ unrestricted Tier 1 Own funds
(average of values 1 Jan. and the end of reporting period)
Financial leverage1
financial debt x 100%equity + financial debt
1The Group’s financial leverage includes only long-term funding. RT1 instrument 
included in financial debt (not in equity),
Insurance revenue, net
+ insurance revenue, gross
- reinsurers' share of insurance revenue
- quota share premium expense (Private UK)
insurance revenue, net
Underwriting result
+ insurance revenue, net
+ other income (Private UK)
- claims incurred
- operating expenses
underwriting result
Operating result
+ profit after tax
- non-controlling interest in P&C operations
- unrealised gains/losses on investments (excl. derivatives) in P&C 
operations- result effect from changes in discount rates in P&C operations
- non-operational amortisations in P&C operations
- non-recurring items
- adjustment on taxes
operating result
Combined ratio, %
+ claims incurred
+ operating expenses x 100%+ insurance revenue, net
+ other revenue (Private UK)
Risk ratio, %
+ claims incurred
– claims handling costs x 100%insurance revenue, net
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BOARD OF DIRECTORS’ REPORT 2025 135

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

Nordic underlying risk ratio, %
(includes Private Nordic, Nordic Commercial, Nordic Industrial and certain 
minor items from Other operations)
Risk ratio, %
– large claims, %
– severe weather, %
– prior year development, risk adjustment and other technical effects, %
– discounting effect, current year, %
underlying risk ratio, %
Cost ratio, %
+ operating expenses
+ claims handling costs x 100%insurance revenue, net
Nordic operating cost ratio, %
(includes Private Nordic, Nordic Commercial, Nordic Industrial and Other 
operations excluding internal reinsurance)
+ operating expenses
+ claims handling costs x 100 %
insurance revenue, net
Per share key figures
Earnings per share
profit for the financial period attributable to owners of the parent
adjusted average number of shares
Operating earnings per share
operating result
adjusted average number of shares
Equity per share
equity attributable to owners of the parent
adjusted number of shares at the balance sheet date
	
Net asset value per share
+ equity attributable to owners of the parent
± valuation differences on listed Group companies
adjusted number of shares at balance sheet date
Market capitalisation
number of shares at the balance sheet date x closing share price at the 
balance sheet date
Dividend payout ratio
total dividend x 100%operating result
Effective dividend yield
dividend per share x 100%adjusted closing price
Price/earnings ratio
adjusted closing price
earnings per share
Price/operating earnings ratio
adjusted closing price
operating earnings per share
Relative share trading volume
share trading volume during the financial year x 100%average number of A shares
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BOARD OF DIRECTORS’ REPORT 2025 136

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

Exchange rates used in reporting
1–12/2025 1–9/2025 1–6/2025 1–3/2025 1–12/2024
EURSEK
Income statement (average) 11.0680 11.1076 11.1000 11.2368 11.4345
Balance sheet (at end of period) 10.8215 11.0565 11.1465 10.8490 11.4590
DKKSEK
Income statement (average) 1.4827 1.4882 1.4873 1.5061 1.5327
Balance sheet (at end of period) 1.4489 1.4811 1.4940 1.4540 1.5365
NOKSEK
Income statement (average) 0.9444 0.9485 0.9516 0.9643 0.9831
Balance sheet (at end of period) 0.9137 0.9429 0.9419 0.9506 0.9715
EURDKK
Income statement (average) 7.4635 7.4617 7.4608 7.4600 7.4589
Balance sheet (at end of period) 7.4689 7.4649 7.4609 7.4613 7.4578
EURGBP
Income statement (average) 0.8569 0.8507 0.8426 0.8357 0.8467
Balance sheet (at end of period) 0.8726 0.8734 0.8555 0.8354 0.8292
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BOARD OF DIRECTORS’ REPORT 2025 137

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

Group’s IFRS Financial Statements
Statement of profit and other comprehensive income  ................................... 139
Consolidated balance sheet  ....................................................................................... 140
Statement of changes in equity      ............................................................................... 141
Statement of cash flows  .............................................................................................. 142
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FINANCIAL STATEMENTS 2025 138

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

Statement of profit and other comprehensive income
EURm Note 1-12/2025 1-12/2024
Insurance revenue  10,272  9,450 
Insurance service expenses  -8,126  -7,684 
Reinsurance result  -556  -372 
Insurance service result 1  1,590  1,394 
Net investment income 2  1,285  888 
Net finance income or expense from insurance 
contracts 3  -74  -252 
Insurance finance income or expense, gross  -180  -309 
Insurance finance income or expense, reinsurance  106  57 
Net financial result  1,210  636 
Other income 4  369  312 
Other expenses 5  -651  -685 
Finance expenses 7  -83  -103 
Share of associates' profit or loss  0  6 
Profit before taxes  2,436  1,559 
Income taxes 15,16  -439  -330 
Profit from the continuing operations  1,998  1,229 
Divested operations, net of tax  —  -26 
Net profit  1,998  1,203 
EURm Note 1-12/2025 1-12/2024
Other comprehensive income 8
Items reclassifiable to profit or loss
Exchange differences  -13  -4 
Cash flow hedges  -2  1 
Total items reclassifiable to profit or loss, net of tax  -16  -3 
Items not reclassifiable to profit or loss
Actuarial gains and losses from defined benefit 
pension plans  24  0 
Taxes  -5  0 
Total items not reclassifiable to profit or loss, net 
of tax  19  0 
Other comprehensive income total, net of tax  3  -3 
Total comprehensive income  2,001  1,200 
Profit attributable to
Owners of the parent  1,998  1,154 
Non-controlling interests  —  50 
Total comprehensive income attributable to
Owners of the parent  2,001  1,151 
Non-controlling interests  —  50 
Earnings per share (EPS), EUR  0.74  0.45 
In February 2025, Sampo carried out a share split by way of a share issue without consideration. 
The new shares were issued to shareholders in proportion to their existing holdings, so that four (4) 
new shares were issued for each existing share. Earnings per share figure for the comparison 
period has been adjusted for the share split. Previously published EPS for comparison period 
1-12/2024 was EUR 2.25.
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FINANCIAL STATEMENTS 2025 139

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

Consolidated balance sheet
EURm Note 12/2025 12/2024
Assets
Property, plant and equipment 10  301  284 
Intangible assets 11  3,492  3,637 
Investments in associates  5  4 
Financial assets 12,13,14  17,154  16,090 
Deferred income tax 15  2  2 
Reinsurance contract assets 19  2,488  2,618 
Other assets 17  962  880 
Cash and cash equivalents  1,319  962 
Total assets  25,723  24,478 
EURm Note 12/2025 12/2024
Liabilities
Insurance contract liabilities 18,19,20,21  12,760  12,286 
Subordinated debts 22  1,317  1,642 
Other financial liabilities 22  1,413  1,395 
Deferred income tax 15  553  535 
Other liabilities 23  1,589  1,562 
Total liabilities  17,631  17,419 
Equity 25
Share capital  98  98 
Reserves  3,531  3,531 
Restricted Tier 1 notes  298  — 
Retained earnings  4,927  4,176 
Other components of equity  -762  -746 
Total equity  8,092  7,059 
Total equity and liabilities  25,723  24,478 
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FINANCIAL STATEMENTS 2025 140

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

Statement of changes in equity
EURm
Share 
capital
Legal 
reserve
Invested 
unres-
tricted 
equity
Restric-
ted Tier 1 
notes5
Retained 
earnings1
Transla-
tion of 
foreign 
opera-tions
Cash flow 
hedges Total
Non- 
control-ling 
interest Total
Equity at 1 January 2024  98  4  1,527  —  6,378  -742  -1  7,263  424  7,687 
Changes in equity
Directed share issue 2  —  —  2,000  —  —  —  —  2,000  —  2,000 
Acquired non-controlling interests2  —  —  —  —  -1,666  —  —  -1,666  -334  -2,000 
Compulsory acquisition of non-controlling interests 2  —  —  —  —  -265  —  —  -265  -59  -325 
Transaction costs related to the acquisition of non-
controlling interests  —  —  —  —  -31  —  —  -31  —  -31 
Dividends3  —  —  —  —  -903  —  —  -903  -69  -972 
Acquisition of own shares  —  —  —  —  -475  —  —  -475  —  -475 
Other changes in equity  —  —  —  —  -14  —  —  -14  -11  -25 
Profit for the reporting period  —  —  —  —  1,154  —  —  1,154  50  1,203 
Other comprehensive income for the period  —  —  —  —  —  -4  1  -3  —  -3 
Total comprehensive income  —  —  —  —  1,153  -4  1  1,151  50  1,200 
Equity at 31 December 2024  98  4  3,527  —  4,176  -746  —  7,059  —  7,059 
Equity at 1 January 2025  98  4  3,527  —  4,176  -746  0  7,059  —  7,059 
Changes in equity
Dividends3  —  —  —  —  -915  —  —  -915  —  -915 
Acquisition of own shares4  —  —  —  —  -350  —  —  -350  —  -350 
Issue of Tier 1 notes  —  —  —  298  -5  —  —  293  —  293 
Other changes in equity  —  —  —  —  4  —  —  4  —  4 
Profit for the reporting period  —  —  —  —  1,998  —  —  1,998  —  1,998 
Other comprehensive income for the period  —  —  —  —  19  -13  -2  3  —  3 
Total comprehensive income  —  —  —  —  2,017  -13  -2  2,001  —  2,001 
Equity at 31 December 2025  98  4  3,527  298  4,927  -759  -3  8,092  —  8,092 
1 IAS 19 Pension benefits had a net effect of EUR 19 million (-0) on retained earnings.
2The share issue was directed at Topdanmark’s non-controlling interests. For further information, see note 28.
3Dividend per share EUR 0.36 (0.34)
4Acquisition of own shares includes the already purchased shares EUR 290 million and the liability for the remaining shares of the buyback programme EUR 60 million, recognised as a liability against equity. 
On 5 November 2025, Sampo plc cancelled 20,484,833 own shares acquired during the financial year 2025. 
5During the financial year, Sampo issued EUR 300 million of new restricted Tier 1 notes with a coupon rate of 5.25 per cent and an option of a first call date in 2035 for Sampo. The restricted Tier 1 
instrument is accounted as equity.
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FINANCIAL STATEMENTS 2025 141

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

Statement of cash flows
EURm 1–12/2025 1–12/2024
Operating activities
Profit before tax  2,436  1,533 
Adjustments
Depreciation, amortisation & impairments  211  180 
Unrealised gains and losses arising from valuation  -667  -227 
Realised gains and losses on investments  -68  -58 
Change in liabilities for insurance contracts  279  383 
Other adjustments  -383  132 
Adjustments total  -627  410 
Change (+/-) in assets of operating activities
Investments1  220  -223 
Other assets  -45  -98 
Total  176  -321 
Change (+/-) in liabilities of operating activities
Financial liabilities  201  122 
Other liabilities  75  5 
Total  276  127 
Paid taxes and interests
Paid taxes  -413  -331 
Paid interests  -89  -91 
Total  -501  -422 
Net cash from operating activities  1,759  1,327 
Investing activities
Investments in tangible and intangible assets2  -165  -142 
Divestments in equipment and intangible assets  15  17 
Net cash used in investing activities  -150  -125 
EURm 1–12/2025 1–12/2024
Financing activities
Dividends paid  -915  -903 
Dividends paid to non-controlling interests  —  -69 
Acquisition of non-controlling interests  —  -325 
Transaction costs related to acquisition of non-
controlling interests
 —  -31 
Acquisition of own shares  -290  -475 
Increase in debt securities and amounts owed to credit 
institutions3
 428  194 
Payments of debt securities in issue3  -480  -50 
Net cash used in financing activities  -1,257  -1,660 
Total cash flows  351  -458 
Cash and cash equivalents at the beginning of reporting period  962  1,415 
Effects of exchange rate changes  5  5 
Cash and cash equivalents at the end of reporting period  1,319  962 
Net change in cash and cash equivalents  351  -458 
Additional information to the cash flow statement 1–12/2025 1–12/2024
Interest income received  562  512 
Dividend income received (excl. profit sharing from funds)  42  42 
Total out-going cashflows from leases  -39  -39 
1 Investments include mainly financial assets.
2 The share of investments in tangible assets amounts to EUR -92 million (-37) and the share of 
intangibles to EUR -74 million (-105) 
3 Changes in short-term issues and repayments of debt securities are presented as net amounts.
In 2024, the profit before tax is the total of Group’s profit and the discontinued/divested 
operations’ profit before taxes. Subsequently, operating activities include EUR -26 million from 
divested activities. 
The items of the statement of cash flows cannot be directly concluded from the balance sheets due 
to e.g. exchange rate differences, and acquisitions and disposals of subsidiaries during the period.
Cash and cash equivalents include cash at bank and in hand EUR 1,091 million (682) and short-term 
deposits (max 3 months) EUR 228 million (280).
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FINANCIAL STATEMENTS 2025 142

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

Group’s notes to the financial statements 
Summary of material accounting principles   ........................................................ 144
Segment information     .................................................................................................... 159
Geographical information      ........................................................................................... 164
Other notes      ....................................................................................................................... 165
1 Insurance service result   ................................................................................................. 165
2 Net investment income ................................................................................................. 166
3 Net finance income or expense from insurance contracts      .............................. 167
4 Other income   ................................................................................................................... 167
5 Other expenses     ............................................................................................................... 167
6 Auditor's fees   ................................................................................................................... 168
7 Finance expenses   ........................................................................................................... 168
8 Components of other comprehensive income  ..................................................... 169
9 Earnings per share   ......................................................................................................... 169
10 Property, plant and equipment   ................................................................................ 170
11 Intangible assets     ............................................................................................................. 171
12 Financial assets   .............................................................................................................. 174
13 Determination and hierarchy of fair values .......................................................... 177
14 Movements in level 3 financial instruments measured at fair value    ........... 181
15 Deferred tax assets and liabilities   ............................................................................ 183
16 Taxes   .................................................................................................................................. 187
17 Other assets    .................................................................................................................... 187
18 Insurance contract liabilities  ...................................................................................... 188
19 Reconciliation of insurance contract liabilities     ................................................... 189
20 Assets for insurance acquisition cash flows  ....................................................... 192
21 Non-life claims development     .................................................................................... 192
22 Financial liabilities     ........................................................................................................ 195
23 Other liabilities     .............................................................................................................. 198
24 Employee benefits      ....................................................................................................... 199
25 Equity and reserves   ..................................................................................................... 203
26 Incentive schemes ........................................................................................................ 204
27 Investments in subsidiaries    ....................................................................................... 207
28 Acquisition of Topdanmark’s non-controlling interest  ................................... 208
29 Related party disclosures    .......................................................................................... 209
30 Contingent liabilities, commitments and legal proceedings    ........................ 210
31 Subsequent events after the balance sheet date     .............................................. 211
32 Risk Management disclosure  .................................................................................... 212
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FINANCIAL STATEMENTS 2025 143

===== SIDA 144 =====

Group’s notes to the financial statements 
Summary of material 
accounting principles
Sampo plc (business ID 0142213-3) is a Finnish public 
company listed in Helsinki Nasdaq. Sampo has a dual 
listing in Nasdaq Stockholm and in Nasdaq 
Copenhagen. It is domiciled in Helsinki and the 
headquarters are at Fabianinkatu 21, 00130 Helsinki, 
Finland. The consolidated financial statements of 
Sampo Group include Sampo plc together with its 
subsidiaries and associates as of 31 December 2025. The 
Group subsidiaries have insurance and financing 
activities in Finland, Sweden, Norway, Denmark, the 
Baltic countries, and the United Kingdom. 
A copy of the Group’s financial statements is available 
at the internet address www.sampo.com. 
Basis of preparation
Sampo Group’s consolidated financial statements are 
prepared in accordance with IFRS® Accounting 
Standards  adopted by the EU. In preparing the financial 
statements, Sampo has applied all the standards and 
interpretations relating to its business, adopted by the 
commission of the EU and effective on 31 December 
2024.
The annual improvements or other amendments to the 
standards, adopted at the beginning of 2025, had no 
material impact on the Group’s financial statements 
reporting.
In preparing the notes to the consolidated financial 
statements, attention has also been paid to the Finnish 
accounting and company legislation and applicable 
regulatory requirements.
The going concern accounting assumption has been 
assessed by the Board and used in the preparation of 
the financial statements.
The consolidated financial statements are presented in 
euro (EUR), rounded to the nearest million, unless 
otherwise stated.
The Board of Directors of Sampo plc accepted the 
financial statements for issue on 12 March 2026. In 
accordance with Limited Liability Companies Act, the 
Annual General Meeting has the right to approve or 
reject the consolidated financial statements or change 
the statements after they have been issued. 
Consolidation
Subsidiaries 
The consolidated financial statements combine the 
financial statements of Sampo plc and all its 
subsidiaries. Companies in which the Group has control 
are consolidated as subsidiaries. Control exists when the 
Group has more than half of the voting power or it has 
power over the entity together with exposure to 
variable returns from its involvement there, and the 
ability to use its power to affect the amount of these 
returns. Subsidiaries are consolidated from the date on 
which control is transferred to the Group and cease to 
be consolidated from the date that control ceases.
The acquisition method of accounting is used for the 
purchase of subsidiaries. The cost of an acquisition is 
allocated to the identifiable assets, liabilities and 
contingent liabilities, which are measured at the fair 
value of the date of the acquisition. Acquisition-related 
costs are recognised through profit or loss. Possible 
non-controlling interest of the acquired entity is 
measured either at fair value or at proportionate 
interest in the acquiree’s net assets. The acquisition-
specific choice affects both the amount of recognised 
goodwill and non-controlling interest. The excess of the 
aggregate of consideration transferred, non-controlling 
interest and possibly previously held equity interest in 
the acquiree, over the Group’s share of the fair value of 
the identifiable net assets acquired, is recognised as 
goodwill.
The accounting policies used throughout the Group for 
the purposes of consolidation are consistent with 
respect to similar business activities and other events 
taking place in similar conditions. All intra-group 
transactions and balances are eliminated upon 
consolidation.
Non-controlling interests
The technical division of profit for the financial year and 
the total comprehensive income to the owners of the 
parent and non-controlling interests is presented after 
the statement of comprehensive income. The share of 
profits is attributed to non-controlling interests even if it 
should be negative. 
Non-controlling interests are presented in the balance 
sheet separately as part of equity. 
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FINANCIAL STATEMENTS 2025 144

===== SIDA 145 =====

Non-controlling interests in an acquiree are measured 
either at fair value or as a proportionate share of net 
assets of the acquiree. The choice is made for each 
acquisition separately. 
At the end of the comparative year 2024, due to the 
acquisition of non-controlling interests in Topdanmark, 
the total equity of consolidated financial statements did 
not include the non-controlling interest share. As the 
proportion of equity held by non-controlling interests 
changed, the carrying amounts of both the equity 
owners of the parent and the non-controlling interests 
were adjusted to reflect the changes. The difference 
between the book value of the NCI and the 
consideration paid was recognised directly in equity 
(retained earnings), and attributed to the owners of the 
parent company. 
The NCI’s share of the profit was calculated as weighted 
average on their remaining share of ownership.   
Foreign currency translation
The consolidated financial statements are presented in 
euro, which is the functional and reporting currency of 
the Group and the parent company. Items included in 
the financial statements of each of the Group entities 
are measured using their functional currency, being the 
currency of the primary economic environment in which 
the Group operates. Foreign currency transactions are 
translated into the appropriate functional currency 
using the exchange rates prevailing at the dates of 
transactions or the average rate for a month. The 
balance sheet items denominated in foreign currencies 
are translated into the functional currency, at the rate 
prevailing at the balance sheet date.
Exchange differences arising from the translation of 
transactions and monetary balance sheet items 
denominated in foreign currencies into functional 
currency are recognised as translation gains and losses 
in profit or loss. 
The income statements of Group entities whose 
functional currency is other than euro are translated 
into euro at the average rate for the period, and the 
balance sheets at the rates prevailing at the balance 
sheet date. The resulting exchange differences are 
included in equity and their change in other 
comprehensive income. When a subsidiary is divested 
entirely or partially, the cumulative exchange 
differences are reclassified from equity to profit or loss 
and presented under sales gains or losses. 
Goodwill and fair value adjustments arising from an 
acquisition of a foreign entity are treated as if they were 
assets and liabilities of the foreign entity. Exchange 
differences resulting from the translation of these items 
at the exchange rate of the balance sheet date are 
included in equity, and their change in other 
comprehensive income.
Exchange rate differences arising from a monetary item, 
accounted for as Sampo’s net investment in a foreign 
operation (subsidiary), are recognised in other 
comprehensive income. 
A monetary item included in the net investment in a 
foreign operation may be denominated in the functional 
currency of Sampo (reporting entity), in the functional 
currency of the foreign operation or in a currency other 
than the functional currency of either the reporting 
entity or the foreign operation. When a foreign 
subsidiary is divested entirely or partially, the 
cumulative exchange differences are reclassified from 
equity to profit or loss. 
The following exchange rates were applied in the 
consolidated financial statements: 
1 euro (EUR) = 
Balance sheet 
date
Average 
exchange rate 
Swedish krona (SEK) 10.8215 11.0680
Danish krona (DKK) 7.4689 7.4635
Pound sterling (GBP) 0.8726 0.8569
Segment reporting
The Group’s segmentation is based on business areas 
whose risks and performance bases as well as 
regulatory environment differ from each other. The 
control and management of business and management 
reporting are organised in accordance with the business 
segments.
In February 2025, Sampo introduced new reporting 
segments to reflect its transformation into a fully-
integrated P&C insurance group following the 
acquisition of the non-controlling interest in 
Topdanmark in 2024. The Group’s business segments 
are Private Nordic, Private UK, Nordic Commercial and 
Nordic Industrial. Information presented for the 
comparative period 2024 has been restated based on 
the new segment structure. For further information on 
the new segments, see section Segment information. 
In addition to these four reporting segments, Sampo 
presents other operations, consisting mainly of the 
Group’s Baltic business but also of group eliminations 
and other internal items. Other operations are not 
considered a separate reporting segment as they do 
not fulfil the criteria for reporting segments under 
IFRS 8.
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Geographical information has been given on income 
from external customers and non-current assets. The 
reported areas are Finland, Sweden, Norway, Denmark, 
United Kingdom, and the Baltic countries.
In the inter-segment and inter-company pricing, for 
both domestic and cross border transactions, market-
based prices are applied. The pricing is based on the 
Code of Conduct on Transfer Pricing Documentation in 
the EU and OECD guidelines.
Inter-segment transactions, assets and liabilities are 
eliminated in the consolidated financial statements.
Income and expense recognition 
principles related to insurance 
contracts 
The insurance service result, comprising of insurance 
revenue, insurance service expenses, and reinsurance 
result, reflects the result relating to underwriting and 
servicing insurance policies. The net financial result 
reflects the impacts arising from financial components 
of insurance contracts.  
Insurance revenue
Insurance revenue reflects the compensation that 
Sampo receives from the policyholder in return for the 
transfer of risk (insurance contract services) on an 
earned basis. The insurance revenue recognised in the 
reporting period is based on premium receipts and 
expected premium receipts, allocated linearly over the 
underlying terms of the insurance contracts, i.e. based 
on the passage of time. The liability for remaining 
coverage is reduced with a corresponding amount as 
the insurance revenue.  
Insurance service expenses
The insurance service expenses comprise of both claims 
incurred and operating expenses. 
Claims incurred for the reporting period include claims 
payments during the period and changes in the liability 
for incurred claims. The change in liability for the 
incurred claims includes the changes in undiscounted 
best estimate, discounted risk adjustment, and the 
changes in discounting effect due to changes in 
underlying best estimate or changes in payment 
patterns. The claims incurred also include claims 
handling expenses and changes in the loss component.
Operating expenses reported in the insurance service 
result relate to administrative expenses arising from the 
handling of insurance contracts. Additionally, the 
operating expenses include the acquisition cash flows 
recognised in profit or loss, where the liability for 
remaining coverage changes with a corresponding 
amount. 
Reinsurance result 
Reinsurance result comprises both reinsurance premium 
expenses and reinsurer’s share of claims incurred. 
Reinsurance premium expenses related to reinsurance 
contracts held are recognised similarly to insurance 
revenue and reflect the premium payments attributable 
to the reporting period for the reinsurance contract 
services received. Any commissions received reduce 
the reinsurance premium expenses. The reinsurers’ 
share of claims incurred is reported consistently with 
direct insurance expenses, including changes in the risk 
of non-performance.
Insurance finance income or expense
The insurance finance income or expenses included in 
the net financial result reflect the impacts arising from 
financial components. These include changes in the 
liability for incurred claims related to changes in 
discount rates and time value of money (unwinding). 
Therefore, the effect from changes in interest rates, as 
well as interest expense, is presented in its entirety as 
insurance finance income or expenses. The effect of 
changes in indexation of annuities is also presented 
within insurance finance income or expenses. Amounts 
related to reinsurance contracts are presented 
separately. The option to present changes in 
discounting effect in other comprehensive income is not 
applied.
The change in discounting effect relating to risk 
adjustment is allocated between the insurance service 
expenses and insurance finance income and expense. 
Net investment income 
Interest and dividends
Interest income and expenses are recognised in the 
income statement using the effective interest rate 
method. This method recognises income and expenses 
on the instrument evenly in proportion to the amount 
outstanding over the period to maturity. Dividends on 
equity securities are recognised as revenue when the 
right to receive payment is established.
Fees and commissions
The fees and transaction costs of financial instruments 
measured at fair value through profit or loss are 
recognised in profit or loss when the instrument is 
initially recognised.
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Revenue from contracts with 
customers
Other income consists of income from insurance-related 
services provided, that do not involve a transfer of 
significant insurance risk, and are therefore accounted 
for under IFRS 15 Revenue from contracts with 
customers. Such income is primarily attributable to sales 
commission and services for administration, claims 
settlement, etc. in insurance contracts on behalf of 
other parties.
Furthermore, If Group’s subsidiary Viking Assistance 
Group AS provides roadside assistance. Income from 
these services is recognised when roadside assistance 
has been provided. 
The subsidiary Hastings has revenue from broker 
activities in accordance with IFRS 15 Revenue from 
Contracts with Customers. The revenue consists 
principally of fees and commissions relating to the 
arrangement of third-party underwritten insurance 
contracts and ancillary products.
Revenue from insurance brokerage activities is 
recognised at the point of sale to the customer, and 
revenue from other retail services is recognised when 
the service has been completed. Revenue arising from 
insurance broking activities is measured on an agency 
basis, net of cost, at the fair value of the income 
receivable after adjusting for any allowance for 
expected future cancellation refunds. Hastings may also 
provide contracts for the provision of other ad hoc, 
point-in-time services to customers. Such income is 
recognised when the performance obligation has been 
satisfied at the expected value of consideration. 
In the consolidated financial statements, the fees and 
commissions from external broker activities are 
included in Other income or Other expenses.
Hastings’ has also revenue from lending business in 
accordance with IFRS 15 Revenue from Contracts with 
Customers. Other income comprises of loan referral 
commission (earned from referring customers to third-
party loan providers), servicer fees and interest earned 
on cash in hand. Performance obligation related to 
referral commission is to offer the referral service to 
customers. For servicer fees the performance obligation 
is to collect payments in respect of receivables 
transferred into the securisation arrangement and 
provide other administrative services. Performance 
obligations are satisfied at a point in time. 
Financial assets and liabilities 
Initial recognition and derecognition
Financial assets and liabilities are measured at the initial 
recognition at fair value. If the acquired financial assets 
and liabilities are not measured at fair value, transaction 
costs directly attributable to acquisition or issue are 
added or deducted respectively.
Purchases and sales of financial assets at fair value 
through profit or loss are recognised and derecognised 
on the trade date, which is the date on which the Group 
commits to purchase or sell the asset. Loans and other 
receivables are recognised when cash is advanced.
Financial assets and liabilities are offset, and the net 
amount is presented in the balance sheet only when the 
Group has a legally enforceable right to set off the 
recognised amounts, and it intends to settle on a net 
basis, or to realise the asset and settle the liability 
simultaneously.
Financial assets are derecognised when the contractual 
rights to receive cash flows have expired or the Group 
has substantially transferred all the risks and rewards of 
ownership. Financial liabilities are derecognised when 
the obligation specified in the contract is discharged, 
cancelled or expired.
Classification and measurement principles of 
financial assets
Financial assets are classified as being subsequently 
measured either at amortised cost, at fair value through 
other comprehensive income (FVOCI), or at fair value 
through profit or loss (FVPL). The majority of Sampo 
Group’s financial assets are classified at fair value 
through profit or loss, and only a limited amount of 
financial assets is measured at amortised cost. No 
financial assets are classified as FVOCI.
The classification of financial assets into these 
measurement categories is based on Sampo Group’s 
business model for managing the financial assets and 
the contractual cash flow characteristics of the financial 
assets. The Group’s business model reflects how the 
portfolios of financial assets are managed to achieve 
business objectives and to generate cash flows. The 
factors considered in determining the portfolio’s 
business model include how the financial assets’ 
performance is evaluated and reported to management, 
how risks are assessed and managed, past experience 
of how the cash flows have been collected, and how 
compensation is linked to performance. 
Financial assets at fair value through profit 
or loss
Financial assets classified as at fair value through profit 
or loss include mainly investments in equity instruments 
and funds, debt instruments, and other loans. 
Equity instruments are classified and measured at fair 
value through profit or loss. 
Debt instruments, such as bonds and other interest-
bearing securities, are classified as measured at fair 
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FINANCIAL STATEMENTS 2025 147

===== SIDA 148 =====

value through profit or loss when the business model 
reflects the assets being managed and evaluated on a 
fair value basis. The instruments are initially recognised 
and subsequently measured at fair value. Transaction 
costs that are directly attributable to the issue or 
acquisition of the assets are expensed in profit or loss.
Gains and losses arising from changes in fair value, or 
realised on disposal, together with related interest 
income and dividend, are recognised in the income 
statement under net investment income.
Derivative instruments that are not designated as 
hedges and do not meet the requirements for hedge 
accounting are classified as financial assets at fair value 
through profit or loss. Derivatives are initially 
recognised at fair value. Derivative instruments are 
carried as assets when the fair value is positive and as 
liabilities when the fair value is negative. Derivative 
instruments are recognised at fair value, and gains and 
losses arising from changes in fair value, together with 
realised gains and losses, are recognised in the income 
statement under net investment income.
Financial assets measured at amortised cost
A financial asset is measured at amortised cost only if 
the objective of the business model is to hold a financial 
asset in order to collect contractual cash flows, and the 
contractual cash flows of the financial asset meet the 
SPPI criteria (solely payments of principal and interest -
criteria, SPPI), i.e. it is consistent with the basic lending 
arrangement. SPPI criteria is met when the financial 
instrument’s contractual cash flows are solely payments 
of principal and interest on the principal amount 
outstanding. Financial assets measured at amortised 
cost comprise mainly debt instruments, loans, and 
receivables. 
Financial assets measured at amortised costs are 
initially recognised at their fair value, including 
transaction costs directly attributable to the acquisition 
of the asset. Loans and other receivables are 
subsequently measured at amortised cost using the 
effective interest rate method.
Interest revenue is calculated using the effective 
interest rate method. Under IFRS 9, financial assets 
subsequently measured at amortised cost are subject to 
loss allowance, that is, expected credit losses (ECL) 
requirements.
Financial liabilities
Financial liabilities, including subordinated debt 
securities, debt securities in issue, and other financial 
liabilities, are subsequently measured at amortised cost 
using the effective interest rate method. Interest 
expenses and gains or losses on derecognition are 
recognised in the income statement.
Derivative financial liabilities are measured at fair value 
through profit or loss. 
If debt securities issued are redeemed before maturity, 
they are derecognised and the difference between the 
carrying amount and the consideration paid at 
redemption is recognised in profit or loss.
Fair value
The fair value of financial instruments is determined 
primarily by using quoted prices in active markets. 
Instruments are measured either at a bid price or at the 
last trade price, if there is an auction policy in the stock 
market of the price source. An exception are the 
syndicated loans, which are measured at a mid-price 
because of the lower liquidity. The financial derivatives 
are also measured at the last trade price. If the financial 
instrument has a counter-item that will offset its market 
risk, the same price source is used in assets and 
liabilities to that extent. If a published price quotation 
does not exist for a financial instrument in its entirety, 
but active markets exist for its component parts, the fair 
value is determined based on the relevant market prices 
of the component parts.
Fair values of financial assets are based on either 
published price quotations or valuation techniques 
based on market observable inputs, where available. If 
these are not available, the fair value is established by 
using generally accepted valuation techniques, 
including recent arm’s length market transactions 
between knowledgeable, willing parties, reference to 
the current fair value of another instrument that is 
substantially the same, discounted cash flow analysis, 
and option pricing models. For a limited amount of 
assets, the value needs to be determined using these 
other techniques. 
The carrying amount of cash and cash equivalents, as 
well as settlement receivables included in other assets is 
used as an approximation of fair value. 
The fair value of loans and other financial instruments 
which have no quoted price in active markets is based 
on discounted cash flows, using quoted market rates. 
The market’s yield curve is adjusted by other 
components of the instrument, e.g. by credit risk.
The financial instruments measured at fair value have 
been classified into three hierarchy levels in the notes, 
depending on, e.g. if the market for the instrument is 
active, or if the inputs used in the valuation technique 
are observable. For further information on the 
determination of fair value hierarchy, please see note 13.   
Impairment of financial assets
Sampo assesses, at the end of each reporting period, 
whether there is any objective evidence that a financial 
asset, other than those at fair value through profit or 
loss, may be impaired. A financial asset is impaired, and 
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impairment losses are recognised based on the 
estimated future cash flows of the financial asset if 
there is objective evidence of impairment as a result of 
one or more loss events that occurred after the initial 
recognition of the asset, and if that event has an impact 
that can be reliably estimated.
There is objective evidence of impairment if, for 
example, an issuer or debtor encounters significant 
financial difficulties that will lead to insolvency, and to 
estimation that the customer will probably not be able 
to meet the obligations to the Group. When there is 
objective evidence of impairment of a financial asset 
carried at amortised cost, the amount of the loss is 
measured as the difference between the receivable’s 
carrying amount and the present value of estimated 
future cash flows discounted at the receivable’s original 
effective interest rate. The difference is recognised as 
an impairment loss in profit or loss. In Sampo Group, the 
impairment is assessed individually for each asset.
Financial assets measured at amortised cost
In accordance with IFRS 9, Sampo applies a forward-
looking ECL model, which in Sampo Group is mainly 
applicable to financial assets measured at amortised 
cost. Impairment requirements do not apply to equity 
instruments or other financial instruments measured at 
FVPL. Expected credit losses reflect past events, i.e. 
historical loss experience, current conditions, and 
forecasts of future economic conditions.
Sampo applies a general approach for impairment in 
which a loss allowance is calculated either for 12-month 
expected credit losses or a lifetime expected credit 
losses. A three-staged model is used to determine the 
ECL at each reporting date. In stage 1, the credit risk has 
not increased significantly. Loss allowance is measured 
at an amount equal to 12-month expected credit losses. 
In stages 2 and 3, the credit risk has increased 
significantly since initial recognition and the loss 
allowance is measured at an amount equal to the 
lifetime expected credit losses. In stage 3, the financial 
asset is assessed to be credit-impaired (at default), and 
the interest is calculated on the credit-impaired amount 
instead of gross carrying amount.
In Sampo Group, the general approach is based on 
three components, namely probability of default (PD), 
loss given default (LGD), and exposure at default 
(EAD).
Derivative financial instruments 
and hedge accounting
Derivative financial instruments are classified as those 
held for trading and those held for hedging, including 
interest rate derivatives, credit risk derivatives, foreign 
exchange derivatives, equity derivatives and 
commodity derivatives. Derivative instruments are 
measured initially at fair value. All derivatives are carried 
as assets when fair value is positive, and as liabilities 
when fair value is negative.
Derivatives held for trading
Derivative instruments that are not designated as 
hedges are treated as held for trading. They are 
measured at fair value and the change in fair value, 
together with both realised gains and losses and 
interest income and expenses, is recognised in profit or 
loss.
Hedge accounting
Sampo Group may hedge its operations against interest 
rate risks, currency risks, and price risks through fair 
value hedging and cash flow hedging. Cash flow 
hedging is used as a protection against the variability of 
the future cash flows. During the financial year, cash 
flow hedging has been applied in Hastings.
Hedge accounting applies to hedges that are effective 
in relation to the hedged risk and meet the hedge 
accounting requirements of IFRS 9. The hedging 
relationship between the hedging instrument and the 
hedged item, as well as the risk management objective 
and strategy for undertaking the hedge, are 
documented at the inception of the hedge. 
Cash flow hedging
Cash flow hedging is used to hedge the interest cash 
flows of individual floating rate debt securities or other 
floating rate assets or liabilities. The hedging 
instruments used include currency forward contracts. 
Derivative instruments which are designated as hedges 
and are effective as such, are measured at fair value. 
The effective part of the change in fair value is 
recognised in other comprehensive income. 
The cumulative change in fair value is transferred from 
equity and recognised in profit or loss in the same 
period that the hedged cash flows affect profit or loss.
When a hedging instrument expires, is sold, terminated, 
or the hedge no longer meets the criteria for hedge 
accounting, the cumulative change in fair value remains 
in equity until the hedged cash flows affect profit or 
loss.
Leases
Group as lessee
All lease contracts are primarily recognised in the 
balance sheet in accordance with IFRS 16 Leases. The 
only optional exemptions include certain short-term 
contracts with a duration under 12 months or low-value 
contracts, for which the lease payments can be 
recognised as an expense on a straight-line basis over 
the lease term.
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