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BOARD OF DIRECTORS’ REPORT AND FINANCIAL STATEMENTS 2024
2
Contents
Board of Directors’ Report 2024 .......................
Review of the 2024 financial year .......................
Outlook .........................................................................
Outlook for 2025 ..................................................
Dividend proposal .....................................................
Operating environment ...........................................
Business areas ............................................................
If .................................................................................
Topdanmark ...........................................................
Hastings ...................................................................
Holding ....................................................................
Financial position ......................................................
Group solvency .....................................................
Financial leverage position ...............................
Ratings .....................................................................
Other developments ................................................
Proposals for the AGM 2025 ............................
Sale of holding in Saxo Bank ...........................
Group Partial Internal Model ............................
Shares and share capital ...................................
Shareholders ..........................................................
Holdings of the Board and
Executive Management .....................................
Share buyback programmes ............................
Corporate Governance Statement ......................
Governance in Sampo plc .................................
Changes in Group structure .............................
General meeting ...................................................
Board of Directors ...............................................
Board-appointed committees .........................
Sampo Group CEO ..............................................
Remuneration ........................................................
Personnel ................................................................
Internal control in Sampo Group ....................
Sustainability Statement ...................................
General information ............................................
Environmental information ...............................
Social information ................................................
Governance information ....................................
Annexes ...................................................................
Key figures ...................................................................
Calculation of key figures .......................................
Statement of profit and other
comprehensive income ...........................................
Consolidated balance sheet ..................................
Statement of changes in equity ...........................
Statement of cash flows .........................................
Accounting principles ........................................
Segment information .........................................
Balance sheet by segment at
31 December 2024 ...............................................
Balance sheet by segment at
31 December 2023 ...............................................
Geographical information .................................
Other notes ............................................................
Sampo plc’s Financial Statements .....................
Sampo plc’s income statement ............................
Sampo plc’s balance sheet ....................................
Sampo plc’s notes to the financial
statements ..............................................................
Summary of significant
accounting policies .............................................
Notes 1–5 .................................................................
Notes 6–8 ................................................................
Note 9 ......................................................................
Notes 10-17 .............................................................
Notes 18–19 .............................................................
Note 20 ....................................................................
Auditor’s note .............................................................
Auditor’s Report .......................................................
Assurance report on the Sustainability
Statement (Translation of the Finnish
Original) ........................................................................
BOARD OF DIRECTORS’ REPORT 2024
3
Board of Directors’ Report 2024
Review of the 2024 financial year .....................
Outlook .........................................................................
Outlook for 2025 .......................................................
The major risks and uncertainties for the
Group in the near-term ...........................................
Dividend proposal ....................................................
Operating environment ..........................................
Business areas ............................................................
If .......................................................................................
Topdanmark ................................................................
Hastings ........................................................................
Holding ..........................................................................
Financial position .....................................................
Group solvency ..........................................................
Financial leverage position ....................................
Ratings ..........................................................................
Other developments ...............................................
Proposals for the AGM 2025 .................................
Sale of holding in Saxo Bank .................................
Group Partial Internal Model .................................
Shares and share capital .........................................
Shareholders ...............................................................
Holdings of the Board and Executive
Management ...............................................................
Share buyback programmes .................................
Corporate Governance Statement .....................
Governance in Sampo plc ......................................
Changes in Group structure ..................................
General meeting ........................................................
Board of Directors ....................................................
Board-appointed committees ..............................
Audit Committee ..................................................
Sampo Group CEO ...................................................
Remuneration .............................................................
Personnel ......................................................................
Internal control in Sampo Group .........................
Reporting ................................................................
Risk management ................................................
Internal audit ..........................................................
External auditor ....................................................
Sustainability Statement .......................................
General information ..................................................
Environmental information ....................................
EU Taxonomy ........................................................
Climate change .....................................................
Social information .....................................................
Own workforce .....................................................
Workers in the value chain ...............................
Consumers and end-users ................................
Governance information .........................................
Business conduct .................................................
Annexes ........................................................................
Key figures ..................................................................
Calculation of key figures .....................................
BOARD OF DIRECTORS’ REPORT 2024
4
Board of Directors’ Report 2024
Review of the 2024 financial year
Sampo Group sustained strong top-line growth in
2024, fuelled by solid performance in the Group’s
growth areas, such as the UK, personal insurance,
and digital sales. Strong growth, combined with
positive underlying trends, drove underwriting
result growth of 13 per cent.
Gross written premiums (GWP) and brokerage income
increased by 12 per cent on a currency adjusted and a
reported basis to EUR 9,931 million (8,870) in 2024. If
enjoyed 6.7 per cent currency adjusted GWP growth,
driven by high and stable retention and price actions to
mitigate claims inflation. Private saw 6.5 per cent
currency adjusted growth, as strong development in
growth areas such as personal insurance and private
property, offset slower growth in motor lines due to
weak new car sales. Commercial delivered a healthy 5.6
per cent currency adjusted growth despite sluggish
economic activity, while Industrial achieved 9.5 per cent
currency adjusted growth, supported by rate action,
increased values, and a good renewals outcome.
Topdanmark reported GWP growth of 16 per cent
driven by the acquisition of Oona Health, rate actions,
and organic growth of 8 per cent.
The Group’s UK operations had a strong year with 23
per cent GWP growth on local currency basis. The top-
line growth was driven by an increase in policy count
and higher average premiums. In total, the policy count
increased by 12 per cent to 3.9 million at the end of
2024, driven by 8 per cent growth in motor, and 34 per
cent growth in home. Policy growth in motor was
supported by strong development in new products,
such as telematics, bike and van insurance, as well as
selective growth in the core portfolio.
Claims experience was mixed in 2024 as the harsh
Nordic winter in the first quarter was followed by more
typical weather conditions and an elevated large claims
outcome, particularly in the second and third quarter. In
total, severe weather and large claims had a 3.3
percentage points negative effect on the Group
combined ratio. Nevertheless, the Group combined ratio
improved to 84.3 per cent (84.6), and combined with
strong top-line growth, led to a 13 per cent increase in
the underwriting result on a currency adjusted basis and
on a reported basis, reaching EUR 1,316 million (1,164).
Underlying margin development remained positive
throughout the year with the Group underlying
combined ratio improving by 1.5 percentage points. The
improvement was driven by particularly strong
performance in the UK, while the Nordics also
experienced a steady positive trend. If reported an
undiscounted adjusted risk ratio improvement of 0.3
percentage points year-on-year, supported by
disciplined underwriting and rate actions to cover
Nordic claims inflation, which stood at around 4 per
cent at the end of 2024. Further, If improved its cost
ratio by 0.3 percentages points, slightly ahead of the
0.2 percentage points annual ambition. In the UK, motor
prices were in a downtrend towards the end of the year,
while loss costs continued to benefit from favourable
claims frequency trends.
The net financial result amounted to EUR 636 million
(560). Net investment income declined to EUR 888
million (1,006), following weaker market performance in
the fourth quarter than in the prior year, which
benefited from exceptionally favourable market
conditions. The Group fixed income running yield was
3.9 per cent, while the mark-to-market yield amounted
to 4.2 per cent at the end of 2024. Insurance finance
income or expense (IFIE) amounted to EUR -252 million
(-446), including a negative effect from unwind of
discounting of EUR -238 million (-248). Changes in
discount rates had a negative effect of EUR -25 million
(-160) on IFIE.
Profit before taxes was EUR 1,559 million (1,481),
including non-recurring costs of around EUR 150 million
related to the Topdanmark integration. Excluding this,
profit before taxes would have been EUR 1,709 million.
Operating EPS grew 13 per cent to EUR 2.33 (2.07)
driven by increased underwriting profit. Sampo targets
more than 7 per cent operating EPS growth on average
over 2024–2026.
The Group Solvency II ratio, net of the proposed
dividend, amounted to 177 per cent at the end of 2024,
down from 182 per cent at the end of 2023. Financial
leverage stood at 26.9 per cent at the end of 2024, up
from 25.3 per cent at the end of 2023. Sampo targets a
solvency ratio of 150–190 per cent and a financial
leverage of below 30 per cent.
On 6 February 2025, Sampo plc’s Board of Directors
proposed a regular dividend of EUR 1.70 per share for
BOARD OF DIRECTORS’ REPORT 2024
5
2024 to the Annual General Meeting to be held on 23
April 2025. This represents growth of 6 per cent from
the prior year regular dividend of EUR 1.60 per share.
On 5 February 2025, the Board resolved upon a share
split so that 4 new shares will be issued for each
existing share. Adjusted for the share split, the
proposed regular dividend is EUR 0.34 per share.
On 17 June 2024, Sampo announced that Sampo and
Topdanmark have entered into a combination
agreement, pursuant to which Sampo will make a
recommended best and final public exchange offer to
acquire Topdanmark. The acquisition was successfully
completed in October 2024. The new Sampo shares
were listed on Nasdaq Copenhagen and the trading
commenced on 18 September 2024. The exchange offer
is summarised in section Other developments.
To reduce the dilution effect from the Topdanmark
exchange offer, Sampo allocated EUR 800 million to
share buybacks and the squeeze-out of Topdanmark
minority shares. As a result, EUR 475 million were used
to buybacks and EUR 325 for the squeeze-out. In total,
Sampo repurchased and cancelled 11,747,690 of its own
A shares in 2024.
In its outlook for 2025, Sampo expects the deliver
insurance revenue of EUR 8.7 - 9.0 billion, representing 
growth of 4 - 7 per cent, and an underwriting result of
EUR 1,350 - 1,450 million, implying an increase of 3 - 10
per cent. The outlook is consistent with Sampo’s
financial targets of achieving a combined ratio below 85
per cent annually and operating EPS growth of more
than 7 per cent on average over 2024-2026.
Key figures
Sampo Group, 2024
EURm
1–12/2024
1–12/2023
Change, %
Profit before taxes
1,559
1,481
5
  If
1,256
1,358
-8
  Topdanmark
137
162
-15
  Hastings
193
129
49
  Holding
-29
-160
—
Net profit for the equity holders
1,154
1,323
-13
Operating result
1,193
1,046
14
Underwriting result
1,316
1,164
13
Change, %
Earnings per share (EUR)
2.25
2.62
-14
Operating EPS (EUR)
2.33
2.07 
13
Return on equity own funds, %
29.5
24.7
—
Net profit for the equity holders and earnings per share for 2023 include result from life operations.
Financial targets
Sampo Group, 2024-2026
Target
2024
Operating EPS growth: over 7% (period average)
13%
Group combined ratio: below 85%
84.3%
Solvency ratio: 150-190%
177%
Financial leverage: below 30%
26.9%
BOARD OF DIRECTORS’ REPORT 2024
6
Outlook
Operating environment and
assumptions
The acquisition of Topdanmark in 2024 completed
Sampo’s transition into a fully integrated P&C insurance
group. Sampo has an attractive operational footprint as
the leader in the consolidated Nordic P&C insurance
market, and a leading operator in the growing digital
UK P&C insurance market, positioning the Group to
deliver both stability and growth.
Competitive dynamics remain rational across the
Group’s areas of operation going into 2025, while
demand for P&C insurance is stable despite limited
economic growth. Sampo expects claims cost to
continue to grow above the long-term trend over the
year, driven by factors including rising repair costs for
new cars and continued wage and service inflation. At
Group level, underlying claims cost is expected to see a
mid-single digit per cent increase in 2025, and the
Group remains firmly committed to conservatively
reflecting this in its pricing.
The strategic and operational investments made by
Sampo over recent years have substantially
strengthened its competitive position. The Group has
unique digital capabilities across distribution, pricing,
underwriting and claims handling that enable it to
deliver superior service and efficiency. Further, the
integration of Topdanmark into the Group is expected
to enable financial benefits through the delivery of scale
benefits and synergies.
Outlook for 2025
The outlook for Sampo Group’s 2025 financial
performance is:
• Group insurance revenue: EUR 8.7–9.0 billion,
representing growth of 4–7 per cent year-on-year.
• Group underwriting result: EUR 1,350–1,450 million,
representing growth of 3–10 per cent year-on-year.
The outlook for 2025 is consistent with Sampo’s 2024–
2026 financial targets of delivering a combined ratio
below 85 per cent annually and Operating EPS growth
of more than 7 per cent annually on average.
The outlook is subject to uncertainty related to
occurrence and estimation of the cost of P&C claims,
investment performance, foreign exchange rates and
competitive dynamics. Revenue forecasts, in particular,
are subject to competitive conditions, which may
change rapidly in some areas, such as the UK motor
insurance market. The revenue and underwriting profit
figures in the outlook are based on 31 December 2024
currency exchange rates.
A full explanation of the alternative performance
metrics used in the Outlook can be found in the section
Calculation of key figures.
The major risks and
uncertainties for the Group in
the near-term
In its current day-to-day business activities Sampo
Group is exposed to various risks and uncertainties,
mainly through its major business units. Major risks
affecting the Group companies’ profitability and its
variation are market, credit, insurance, and operational
risks. At the Group level, sources of risks are the same,
although they are not directly additive due to the
effects of diversification.
Uncertainties in the form of major unforeseen events
may have an immediate impact on the Group’s
profitability. The identification of unforeseen events is
easier than the estimation of their probabilities, timing,
and potential outcomes. Macroeconomic and financial
market developments affect Sampo Group primarily
through the market risk exposures it carries via its
insurance company investment portfolios and insurance
liabilities. Over time, adverse macroeconomic effects
could also have an impact on Sampo’s operational
business, for example, by reducing economic growth or
increasing claims costs.
BOARD OF DIRECTORS’ REPORT 2024
7
Inflation continued to fall in 2024 with euro-area
headline inflation being already close to the central
bank target. However, the fall in inflation has largely
come from lower goods inflation and a decline in
energy prices. Whereas the fall in goods inflation has
been supported by supply-chain normalisation, it may
rise if trade restrictions increase import prices, and
energy prices continue to be vulnerable to geopolitical
events. Furthermore, rapid wage growth has kept
services inflation high and could continue to keep price
pressures elevated unless labour markets loosen as
currently expected. This creates uncertainty on whether
central banks will be willing to cut interest rates as
swiftly as expected. This may lead to both a significant
slowdown in economic growth and a deterioration in
the debt service capacity of businesses, households and
governments, raising the risk of abrupt asset repricing
in financial markets. Furthermore, the potential
escalation of wars in Ukraine and the Middle East
represent a major economic risk. Combined with
historically high equity market valuations in the US in
particular, these developments are currently causing
significant uncertainties in economic and capital market
development. At the same time, rapidly evolving hybrid
threats create new challenges for states and businesses.
There are also a number of widely identified
macroeconomic, political, and other sources of
uncertainty which can, in various ways, affect the
financial services industry in a negative manner.
Sampo Group’s insurance exposures in Russia or
Ukraine are limited to certain Nordic industrial line
clients, with coverage subject to war exclusions. On the
asset side, Sampo has no material direct investments in
Russia or Ukraine. Given the limited direct exposure, the
biggest risk from the war in Ukraine to Sampo relates to
the second order capital markets and macroeconomic
effects outlined above.
Other sources of uncertainty are unforeseen structural
changes in the business environment, and already
identified trends and potential wide-impact events.
These external drivers may have a long-term impact on
how Sampo Group’s business will be conducted.
Examples of identified trends are demographic
changes, climate change, and technological
developments in areas such as artificial intelligence and
digitalisation, including threats posed by cybercrime.
BOARD OF DIRECTORS’ REPORT 2024
8
Dividend proposal
Sampo plc’s dividend policy is to pay a stable and
sustainable regular dividend that grows in line with
Sampo Group’s operating result over time. In addition
to this, excess capital is returned through share
buybacks and/or extra dividends, to the extent that it is
not utilised to support business development.
Pursuant to Sampo plc’s dividend policy applicable to
the distribution of 2024 earnings, total annual dividends
paid shall represent at least 70 per cent of Sampo
Group’s operating result for the year. The Group’s
operating result for the financial year 2024 amounted to
EUR 1,193 million. The parent company’s distributable
capital and reserves totalled EUR 7,851 million, of which
profit for the financial year 2024 was EUR 1,863 million.
Based on the policies outlined above, the Board
proposes to the Annual General Meeting that a total
dividend of EUR 1.70 per share be paid, except for any
shares held by Sampo plc on the dividend record date
of 25 April 2025. However, if the share issue without
consideration in proportion to shares owned by
shareholders (share split), as announced by Sampo plc
on 5 February 2025, is successfully carried out and
effected after the date of this proposal but prior to the
dividend record date, the proposed total dividend shall
instead be EUR 0.34 per share, except for any shares
held by Sampo plc on the dividend record date of 25
April 2025.
The Board proposal to the Annual General Meeting
corresponds to a total dividend of EUR 915 million in the
aggregate, equating to a payout ratio of 77 per cent of
the Group’s operating result for the financial year 2024.
The remainder of the distributable funds are left in the
company’s equity capital. After adjusting for the
proposed dividend, the parent company’s 2024 year-
end distributable funds amounted to approximately
EUR 6,936 million and Group Solvency II ratio to 177 per
cent. The Group’s 2024 year-end financial leverage was
26.9 per cent.
Dividend payment
The dividend is proposed to be paid to the shareholders
registered in the company’s shareholders register
maintained by Euroclear Finland Oy, as at the record
date of 25 April 2025. The Board proposes that the
dividends be paid on 6 May 2025.
The issuer of the Swedish depository receipts shall
ensure that the dividend is paid to the depository
receipt holders registered in the securities depository
and settlement register maintained by Euroclear
Sweden AB, as at the record date of 25 April 2025, with
payment made in Swedish Krona.
The dividend payment for shares registered in the form
of share entitlements book-entered in VP Securities A/S
in Denmark, as at the record date of 25 April 2025 will
be administered by VP Securities A/S subsequent to
receipt of the dividend by Euroclear Finland.
Financial position
No significant changes have taken place in the
company's financial position since the end of the
financial year. The company's liquidity position is good
and, in the view of the Board, the proposed
distributions do not jeopardise the company's ability to
fulfil its obligations.
BOARD OF DIRECTORS’ REPORT 2024
9
Operating environment
Nordic countries
During the year, the Nordic P&C industry experienced
further consolidation, which, combined with new
ambitious financial targets among major players, is
expected to strengthen existing financial discipline. The
four largest players now account for approximately 80–
90 per cent of the markets in Norway, Finland, and
Sweden, respectively. In Denmark, the top four insurers
control nearly 70 per cent of the market. Several
insurers are also established in more than one Nordic
country.
In 2024, Nordic claims inflation stabilised from the
elevated levels of recent years. Although inflation
generally declined across the Nordics, there were some
local and segment variations in claims inflation. In the
property segment, claims inflation remained moderate,
while motor claims inflation stabilised at a somewhat
elevated level, partly due to pressure from weak
currencies. For If P&C, claims inflation slowed to around
4 per cent toward the end of the year.
Throughout the year, price increases aimed at
mitigating claims inflation persisted, with some players
reporting significant hikes in areas where rate adequacy
had previously been insufficient.
The private market experienced intense competition,
while price increases continued to be generally
accepted by customers. In the corporate market, larger
players focused on select growth areas, with the SME
segment being a key priority for several. The
competitive landscape in the large corporate segment
was impacted by the withdrawal of certain local
competitors, which limited the effect of rate increases
on retention. Over recent years, substantial rate
increases have been implemented, driving significant
profitability improvements in the segment. The renewal
outcome in both the corporate and large corporate
segments at the start of 2025 appears favourable so far
with continued rate increases generally observed
throughout the market.
Historically, the Nordic P&C market has achieved higher
and more stable retention levels than other European
P&C markets with retention rates ranging between 85
and 90 per cent. Despite ongoing premium increases
throughout the year, the demand for insurance
remained broadly stable, and retention rates in 2024
continued to be strong.
In the first quarter of 2024, the Nordic countries
experienced a more extreme winter season than usual.
The increase in weather-related claims was primarily
driven by prolonged cold weather, heavy snowfall,
storms, and freeze-thaw cycles with high precipitation,
impacting both the motor and property segments. For
the remainder of the year, weather conditions were
relatively benign in the Nordics, with some localised
storms and instances of heavy rainfall.
The trend of modest new car sales continued in 2024,
with a 5 per cent decline compared to the previous
year. In Sweden, new car registrations in 2024 reached
the lowest level in ten years, driven by the economic
downturn, high interest rates, and the government's
announced policies, which did not fully stimulate
demand. Among the four Nordic countries, only Norway
saw growth in new car sales during the year.
BOARD OF DIRECTORS’ REPORT 2024
10
United Kingdom
The UK motor claims environment has been broadly
positive during 2024 with both reduced frequencies
and a lower rate of inflation than the previous year.
Claims cost inflation, whilst remaining elevated
compared to historical average trends, has continued to
reduce from the peak seen in early 2023. Claims
frequency reductions have been seen across most
heads of damage, that is accidental damage, third party
property damage, and bodily injury. This development
is partially due to driving behaviour and favourable
weather conditions in both first and fourth quarter.
As result, premiums in the competitive UK market have
softened during 2024, as insurers pass on the benefits
of these claims dynamics to consumers. Price
comparison websites (‘PCW’), Hastings’ primary
distribution channel, remain by far the largest sales
channel for UK car and home insurance customers.
Whilst consumer switching rates are now slowing in line
with falling market prices, the overall size of the PCW
market has continued to grow, with Hastings as a
beneficiary given our business model.
Government and regulatory activity has continued
across a range of topics. A government taskforce has
been created with the intention of tackling the causes
of rising motor insurance prices seen in previous
periods, and the FCA continues to be active across
many fronts. Hastings is supportive of efforts to address
the causes of high claims costs, including tackling fraud,
so that customers can benefit from lower prices.
BOARD OF DIRECTORS’ REPORT 2024
11
Business areas
If
If P&C is the leading property and casualty insurer in the Nordic region, where it
offers solutions in all major lines of business through its four business areas;
Private, Commercial, Industrial and Baltic. If P&C’s business model is based on
high customer satisfaction, best in class underwriting and leveraging the scale
benefits that its unified Nordic model offers. Excellent digital sales and service
capabilities are a core part of If’s strategy, particularly in the Private and SME
Commercial market segments.
Underwriting performance
If reported an insurance service result of EUR 890 million (842) and a combined ratio
of 83.1 per cent (83.1) in 2024. The underlying margin trend remained positive with an
undiscounted adjusted risk ratio improvement of 0.3 percentage points and a cost
ratio reduction of 0.3 percentage points year-on-year. Although the fourth quarter was
affected by some elevated large claims and severe weather claims, the impact was less
pronounced than during the same period last year.
Premium development
If reported GWP of EUR 5,860 million (5,468) in 2024. Excluding currency effects,
premiums grew by 6.7 per cent year-on-year. Growth was robust across business areas
and countries, and driven primarily by re-pricing, increased values, and stable retention
levels.
Currency adjusted GWP growth in 2024 in Private was 6.5 per cent driven mainly by
price increases covering claims inflation. The positive GWP development during the
year was supported by 12 per cent growth in personal insurance, and 6 per cent
growth in Private property insurance. Growth in the Private motor products was
dampened by low new car sales volumes and stood at 5 per cent. Geographically, all
countries contributed to growth with the Norwegian business being particularly strong.
Results
If, 2024
EURm
2024
2023
Change, %
Gross written premiums
5,860
5,468
7
Insurance revenue, net
5,258
4,996
5
Claims incurred, net
-3,267
-3,093
6
Operating expenses and claims handling costs
-1,101
-1,061
4
Insurance service result / underwriting result
890
842
6
Net investment income
652
871
-25
Insurance finance income or expense, net
-188
-331
-43
Net financial result
464
539
-14
Other items
-98
-24
315
Profit before taxes
1,256
1,358
-8
Key figures
EURm
2024
2023
Change
Combined ratio, %
83.1
83.1
-0.1
Cost ratio, %
20.9
21.2
-0.3
Risk ratio, %
62.1
61.9
0.2
Large claims
1.7
1.3
0.4
Severe weather
2.6
3.4
-0.8
Risk adjustment and other technical effects,
current year %
1.3
1.2
0.1
Prior year development, %
-5.1
-5.3
0.2
Adjusted risk ratio, current year, %
61.5
61.3
0.2
Discounting effect, current year, %
-2.8
-3.4
0.5
Undiscounted adjusted risk ratio, current year, %
64.4
64.7
-0.3
Loss ratio, %
67.6
67.6
0.0
Expense ratio, %
15.5
15.6
-0.1
All the key figures in the table above are calculated on a net basis. Key ratios are based on SEK
figures.
Large claims measured against budget but severe weather claims are reported in full; negative
figures indicate a positive outcome. Severe weather includes natural catastrophes.
Negative figures for prior year development indicate positive reserve run-off. The discounting
effect represents the impact of discounting of current year claims reserves on the risk ratio.
BOARD OF DIRECTORS’ REPORT 2024
12
In 2024, new car sales remained weak with numbers
down by 5 per cent year-on-year for the Nordics and 7
per cent for If’s largest market, Sweden. Excluding the
Swedish mobility business, currency adjusted GWP
growth in 2024 was 7.6 per cent in Private and 7.2 per
cent for If P&C.
Despite rate increases during the year, Private retention
rate was stable at 89 per cent. The development of
digital services and digital engagement in the Private
business area remained strong in 2024, following
consistent investments in this area over many years.
Digital sales increased by 10 per cent during the year,
and online claims continued to increase and stood at 64
per cent (61) at the end of the year.
Currency adjusted GWP growth in Commercial for 2024
was 5.6 per cent. The positive development was
supported by successful renewals, continuous rate
increases in line with claims inflation, and strong
retention. Throughout the year, the SME segment grew
by more than 5 percent, with growth accelerating
towards the end of the year.
In 2024, digital sales in Commercial increased by 24 per
cent year-on-year. Strong momentum in online sales
and accelerated expansion of the digital offering with
increased usage of self-service solutions contributed to
the positive development.
Industrial reported GWP growth of 9.5 per cent on a
currency adjusted basis in 2024 mainly driven by rate
actions, increased values, and a good renewals
outcome. Industrial continued to reduce exposures to
specific large property risks to ensure lower large claims
volatility.
The Baltic business delivered currency adjusted GWP
growth of 4.8 per cent in 2024. The development was
driven by repricing initiatives but impacted by rising
competition in the second half of the year.
Combined ratio development
If reported combined ratios of 83.1 per cent (83.1) for
the year 2024.
After a favourable large claims outcome in the first
quarter of the year, the subsequent quarters saw
adverse large claims development in both Industrial and
Commercial. Large claims in the year were mainly
driven by large property claims and had a 1.7
percentage points negative effect on the combined
ratio.
During the year, severe weather events had a negative
impact of 2.6 percentage points on the combined ratio.
The first quarter of the year was the most severely
affected due to an unusually harsh Nordic winter and
Storm Ingunn. If’s large claims outcome is reported as a
deviation against budget, while severe weather and
natural catastrophe effects are disclosed in full.
Prior year gains in the year stood at 5.1 per cent (5.3)
and the risk adjustment and other technical effects had
an impact of 1.3 percentage points (1.2).
The discounting effect reduced to 2.8 per cent (3.4) for
the full year as a result of lower discount rates.
In total, the risk ratio deteriorated by 0.2 percentage
points year-on-year to 62.1 per cent (61.9) in 2024. The
undiscounted adjusted risk ratio improved by 0.3
percentage points year-on-year.
The 2024 cost ratio improved to 20.9 per cent (21.2),
which is in line with If P&C’s target for 2024–2026 of a
~20 basis point yearly cost ratio reduction. Education
and development costs are included in the cost ratio.
BOARD OF DIRECTORS’ REPORT 2024
13
Combined ratio, %
Risk ratio, %
2024
2023
Change, %
2024
2023
Change, %
Private
82.2
83.1
-0.9
61.5
62.1
-0.6
Commercial
83.6
81.9
1.7
61.9
60.0
1.9
Industrial
88.7
87.3
1.5
69.2
68.3
0.9
Baltic
86.0
85.9
0.0
60.2
59.8
0.4
Sweden
81.2
83.2
-2.0
61.0
63.8
-2.8
Norway
79.9
87.2
-7.3
60.3
66.8
-6.5
Finland
81.0
75.7
5.3
59.2
53.5
5.7
Denmark
108.3
88.4
19.9
83.2
62.9
20.3
Net financial result
For 2024, If’s net financial result fell to EUR 464 million (539), as the prior year
benefited from exceptionally favourable conditions in the fourth quarter, but the mark-
to-market return on investments remained at a respectable 6.0 per cent (8.3).
At the end of December, the fixed income running yield was 4.3 per cent (4.2).
However, as a result of increased fixed income instruments’ market values, the mark-
to-market yield decreased to 4.1 per cent from 4.9 per cent at the end of 2023.
In 2024, the unwind of discounting amounted to EUR -169 million (-180) and changes
in discount rates had an impact of EUR -15 million (-136).
Profit before taxes
In total, If reported profit before taxes of EUR 1,256 million (1,358) for 2024,
representing a decrease of 8 per cent year-on-year. The profit before taxes was
supported by improved underwriting profit and a strong investment result, but offset
by lower net investment income and non-recurring costs of EUR 76 million related to
the Topdanmark integration that were booked to the fourth quarter.
BOARD OF DIRECTORS’ REPORT 2024
14
Topdanmark
Topdanmark is one of the largest P&C insurance companies in Denmark. It
focuses on the private, agricultural, and SME markets. In 2024, Sampo acquired
the remaining minority interest in Topdanmark, thereby becoming its sole
owner.
Topdanmark delivered GWP of EUR 1,553 million (1,339) in 2024, representing an
increase of 16 per cent year-on-year driven by the acquisition of Oona Health and
organic GWP growth of 8 per cent. The organic growth was driven by rate increases
across all major product areas, positive net customer inflow, and specific rate
adjustments on workers’ compensation effective from 1 July 2024 following the
implementation of new legislation affecting the calculation of awarded compensations.
The organic GWP growth rate trended positively over the year, rising to 8 in the third
quarter and 11 in the fourth quarter as several actors on the Danish P&C insurance
market increased prices to reflect higher claims costs.
The combined ratio improved to 84.2 per cent (85.0), largely as a result of weather and
large claims falling back into line with expected levels, following an adverse outcome in
the prior year. The underlying claims trend deteriorated for the full year, but turned
slightly positive in the fourth quarter as rate increases caught up with elevated motor
claims inflation, while motor claims frequency stabilised, albeit at a high level. The
insurance service result increased to EUR 233 million (194) driven by the strong growth
and an improved combined ratio. Topdanmark’s net financial result more than doubled
to EUR 60 million (27), mainly as a result of mark-to-market effects on liabilities.
The 2024 result was affected by several one-off charges, including EUR 73 million for
the integration with If and EUR 15 million of other transaction costs related to the
acquisition of Topdanmark minority interests by Sampo in October (further details
available in Other developments). Consequently, profit before taxes declined to EUR
137 million (162) despite the strong development in the insurance service and net
financial results.
Results
Topdanmark, 2024
EURm
2024
2023
Change, %
Gross written premiums
1,553
1,339
16
Insurance revenue, net
1,470
1,288
14
Claims incurred and claims handling
costs, net
-970
-862
13
Operating expenses
-267
-233
15
Insurance service result /
underwriting result
233
194
20
Net investment income
93
107
-13
Insurance finance income or
expense, net
-33
-79
-59
Net financial result
60
27
120
Other items
-155
-59
163
Profit before taxes
137
162
-15
Key figures
2024
2023
Change
Combined ratio, %
84.2
85.0
-0.8
Loss ratio, %
66.0
66.9
-0.9
Expense ratio, %
18.1
18.1
0.1
All the key figures in the table above are calculated on a net basis.
BOARD OF DIRECTORS’ REPORT 2024
15
Hastings
Hastings is one of the leading digital P&C insurance providers in the UK, serving
nearly 4 million car, van, bike, and home insurance customers, with a strong
focus on price comparison distribution, pricing and anti-fraud sophistication and
digital customer service.
Results
Hastings, 2024
EURm
2024
2023
Change, %
Gross written premiums
2,161
1,706
27
Brokerage revenue
404
357
13
Insurance revenue, net (incl.
brokerage)
1,659
1,251
33
Claims incurred and claims handling
costs, net
-938
-714
31
Operating expenses
-532
-409
30
Underwriting result
190
128
49
Net investment income
72
79
-8
Insurance finance income or
expense, net
-31
-35
-11
Net financial result
41
44
-6
Other items
-39
-42
-7
Profit before taxes
193
129
49
Key figures
2024
2023
Change
Operating ratio, %
88.5
89.8
-1.2
Live customer policies (millions)
3.9
3.5
0.4
All key figures in the table above are calculated on a net basis.
Hastings’ gross written premiums for 2024 increased by 23 per cent year-on-year on a
constant currency basis to EUR 2,161 million (1,706), reflecting higher earned premiums
from rate increases implemented mainly during 2023, alongside increases in live
customer policies (‘LCP’). Total LCP increased to 3.9 million, up 12 per cent year-on-
year, largely due to new business competitiveness. Motor LCP increased by 8 per cent
year-on-year, whilst home LCP grew by 34 per cent year-on-year.
During the year, Hastings has observed a moderate slow-down in overall claims
inflation, from around the 12 per cent level seen during 2023, to the high single digit
range. Claims frequencies in 2024 tracked below historically observed levels, reflecting
specific underwriting and claims actions taken by Hastings, alongside favourable
weather conditions and other market wide trends.
The underwriting result increased by 49 per cent to EUR 190 million (128) in 2024,
reflecting a stronger loss ratio of 61.6 per cent (63.3). Operating expenses increased in
line with revenue growth, driven by higher acquisition expenses related to new
business volume growth and by sustained investment into digital capabilities and
customer servicing initiatives. As such Hastings’ operating ratio for the period
improved to 88.5 per cent (89.8).
The net financial result decreased slightly to EUR 41 million (44), as a result of both
lower interest rates and more modest rate changes that reduced both net investment
income and the offsetting unwind of discount on insurance claim liabilities.
As a result of the higher underwriting result, Hastings’ profit before taxes increased 49
per cent to EUR 193 million (129). Included within other items is EUR 47 million (41) of
non-operational amortisation related to intangible assets identified on acquisition of
the Hastings Group by Sampo plc in 2020, without which profit before taxes would
have been EUR 239 million (171).
BOARD OF DIRECTORS’ REPORT 2024
16
Holding
Sampo plc is the parent company of Sampo Group and responsible for the
Group’s strategy and capital management activities. In addition to the Group’s
insurance subsidiaries, a small number of direct investments are held in the
holding company. 
Results
Holding, 2024
EURm
2024
2023
Change, %
Net investment income
78
-37
—
Other income
2
1
124
Other expenses
-43
-57
24
Finance expenses
-66
-66
1
Profit before taxes
-29
-160
82
Holding segment’s profit before taxes for 2024 was EUR -29 million (-160).
Net investment income increased to EUR 78 million (-37), largely due to stable interest
yields. The holding company’s investment portfolio includes short-term money market
investments and short-term bonds, as well as Sampo’s financial investments Nexi and
NOBA.
The prior year saw mark-to-market losses on holding company’s financial investments.
The holding in Saxo Bank was sold to Mandatum at EUR 302 million on a transaction
finalised in May 2024. Further details on the transaction are available in Other
developments.
BOARD OF DIRECTORS’ REPORT 2024
17
Financial position
Group solvency
Sampo Group’s Solvency II ratio, net of proposed
dividend of EUR 1.70 per share, amounted to 177 per
cent (182) at the end of 2024, based on own funds of
EUR 5,368 million (5,849) and solvency capital
requirement of EUR 3,040 million (3,217).
The decrease in own funds was driven by the capital
deployment of EUR 800 million into buybacks and
squeeze-out in connection with the Topdanmark
exchange offer. Also, the restructuring charge of
approximately EUR 150 million related to the
Topdanmark integration had a negative effect on own
funds. The decrease in solvency capital requirement, on
the other hand, was driven by the adoption of the
Group Partial Internal Model in solvency calculation as
of 30 June 2024.
Sampo targets a Solvency II ratio of 150–190 per cent.
Financial leverage position
Sampo Group’s financial leverage is calculated as Group
financial debt divided by the sum of IFRS shareholders’
equity and financial debt. The Group targets financial
leverage of below 30 per cent.
The Group’s shareholders’ equity amounted to EUR
7,059 million (7,687) and financial debt to EUR 2,596
million (2,604) at the end of 2024, translating into a
financial leverage of 26.9 per cent, up from 25.3 per
cent at the end of 2023. The increase from the prior
year was driven mainly by capital deployment of EUR
800 million into buybacks and squeeze-out in
connection with the Topdanmark exchange offer.
Financial debt remained broadly unchanged during
2024.
More information on Sampo Group’s outstanding debt
issues is available at www.sampo.com/debtfinancing.
Financial debt
Sampo Group, 31 December 2024
EURm
Sampo plc
If
Topdanmark
Hastings
Eliminations
Group total
Sub/hybrid
1,491
131
147
0
-127
1,642
Senior bonds
954
0
0
0
0
954
Total
2,445
131
147
0
-127
2,596
BOARD OF DIRECTORS’ REPORT 2024
18
Ratings
Relevant ratings for Sampo Group companies on 31 December 2024 are presented in
the table below.
Rated company
Moody’s
Standard & Poor’s
Rating
Outlook
Rating
Outlook
Sampo plc – Issuer Credit Rating
A2
Stable
A
Stable
If P&C Insurance Ltd – Insurance Financial Strength
Rating
Aa3
Stable
AA-
Stable
If P&C Insurance Holding Ltd (publ) - Issuer Credit
Rating
-
-
A
Stable
On 25 April 2024, Moody’s upgraded Sampo plc’s Issuer Credit Rating to A2 with stable outlook and If P&C
Insurance Ltd’s Insurance Financial Strength Rating to Aa3 with a stable outlook.
BOARD OF DIRECTORS’ REPORT 2024
19
Other developments
Public exchange offer for
Topdanmark
On 17 June 2024, Sampo announced that Sampo and
Topdanmark have entered into a combination
agreement, based on which Sampo made a
recommended best and final public exchange offer to
acquire all of the outstanding shares in Topdanmark not
already owned by Sampo. Under the terms of the offer,
Topdanmark shareholders received 1.25 newly issued
Sampo A shares in exchange for each share held in
Topdanmark.
On 8 July 2024, Sampo announced that all necessary
regulatory approvals had been obtained for the
exchange offer. Sampo’s Extraordinary General Meeting
(EGM), held on 9 July 2024, authorised the Board to
resolve on a share issue to acquire Topdanmark shares.
The offer period began on 9 August 2024 and expired
on 9 September 2024. Based on the final result
announced on 16 September 2024, Sampo received
acceptances representing approximately 92.6 per cent
of the entire share capital and total number of voting
rights in Topdanmark, excluding Topdanmark’s treasury
shares.
Based on the final result, the Board resolved to issue
48,198,710 new Sampo A shares to Topdanmark non-
controlling shareholders, based on the authorisation
received from Sampo EGM. The subscription price for
the new A shares was EUR 41.50 per share. The price
was determined based on the closing price for the new
A shares on Nasdaq Helsinki, at the last full trading day
prior to the Sampo Board resolving upon the directed
issuance of shares. The new Sampo shares were listed
on Nasdaq Copenhagen and the trading commenced on
18 September 2024. The Topdanmark share was
delisted from public trading on Nasdaq Copenhagen on
18 October 2024.
On 20 September 2024, Sampo commenced a
compulsory acquisition of the 6,613,865 Topdanmark
shares held by the remaining minority shareholders of
Topdanmark, in accordance with the Danish Companies
Act and the VP rule book. The compulsory acquisition
was completed on 25 October 2024, Topdanmark thus
becoming wholly-owned by Sampo plc. The total
acquisition cost of the minority shares amounted to
EUR 325 million.
The price per Topdanmark share offered in both the
exchange offer and the compulsory acquisition of the
minority shares was DKK 366.38, corresponding to 1.25
times the Sampo closing share price of EUR 39.29 on
Nasdaq Helsinki on 14 June 2024. The price thereby
reflected the valuation of the Topdanmark shares
(including the premium of 27 per cent) indicated in the
announcement published on 17 June 2024.
The total annual pre-tax run-rate cost and revenue
synergies are expected to amount to approximately
EUR 95 million, and expected to drive EPS accretion of
approximately 6 per cent, based on 2025 consensus
earnings expectations. Additional potential net savings
from lower one-off IT investments related to
Topdanmark’s ongoing digital transformation (not
included in run-rate synergies), may also be possible.
The realisation of synergies is expected to be phased in
until 2028, and one-off integration costs are estimated
at approximately EUR 150 million and expected to be
incurred upfront. Sampo will begin reporting on the
delivery of synergies from the first quarter of 2025.
As an internal transaction, Sampo plc sold its
Topdanmark shares to If P&C Insurance Holding Ltd on 1
November 2024. The sales price of EUR 4,659 million,
equivalent to approximately DKK 34.7 billion, was paid
in full by way of a loan agreement and a shareholder’s
contribution between Sampo and If P&C Insurance
Holding Ltd.
Further information on the Topdanmark transaction is
available in Appendix 28 Acquisition of Topdanmark’s
non-controlling interest and at www.sampo.com/
topdanmark.
Proposals to the AGM of
2025
On 9 December 2024, the Nomination and
Remuneration Committee of Sampo plc’s Board of
Directors made its proposals for number, members and
remuneration of the Board of Directors.
The Nomination and Remuneration Committee
proposes to the AGM, to be held on 23 April 2025, that
the number of Board members is decreased by one and
that eight members be elected to the Board. The
Committee proposes that the current members of the
Board Christian Clausen, Steve Langan, Risto Murto,
Antti Mäkinen, Markus Rauramo, Astrid Stange and
Annica Witschard be re-elected for a term continuing
until the close of the next AGM. Of the current
members, Georg Ehrnrooth and Jannica Fagerholm are
not available for re-election.
BOARD OF DIRECTORS’ REPORT 2024
20
The Committee proposes that Sara Mella be elected as
a new member to the Board. Sara Mella brings with her
more than three decades of banking experience, and
she has worked as the Head of Personal Banking and as
a member of Nordea’s Group Leadership Team since
2019.
The Committee proposes that the Board members elect
Antti Mäkinen from among its number as the Chair of
the Board and Risto Murto as the Vice Chair.
The Nomination and Remuneration Committee
proposes that the following annual fees be paid until the
close of the next AGM:
– EUR 243,000 for the Chair of the Board
(prev. EUR 235,000);
– EUR 140,000 for the Vice Chair of the Board
(prev. EUR 135,000);
– EUR 108,000 for each member of the Board
(prev. EUR 104,000);
– EUR 30,000 for the Chair of the Audit Committee as
an additional annual fee (prev. EUR 29,000);
– EUR 6,800 for each member of the Audit Committee
as an additional annual fee (prev. EUR 6,600).
A Board member must acquire Sampo plc A shares at
the price paid in public trading with 50 per cent of his/
her annual fee after the deduction of taxes, payments
and potential statutory social and pension costs.
Notwithstanding this, a Board member is not required
to purchase any additional Sampo plc A shares if the
Board member owns such amount of said shares that
their value is equivalent to twice the respective Board
member’s gross annual fee.
A Board member shall be obliged to retain the Sampo
plc A shares purchased pursuant to this proposal under
his/her ownership for two years from the purchasing
date. The disposal restriction on the Sampo shares shall,
however, be removed earlier in case the director’s
Board membership ends prior to the release of the
restricted shares, i.e. the shares will be released
simultaneously when the term of the Board membership
ends.
The proposals and the CV of Sara Mella are available at
www.sampo.com/boardproposals.
Sale of holding in Saxo Bank
On 13 May 2024, Sampo completed the sale of its 19.8
per cent stake in Saxo Bank to Mandatum, as agreed in
connection with the partial demerger completed in
2023. The transaction price was EUR 302 million,
representing the price agreed in the demerger adjusted
for dividends received. Mandatum opted to settle the
transaction in cash rather than to utilise the vendor loan
of EUR 280 million offered by Sampo.
Group Partial Internal Model
On 2 May 2024, Sampo received approval for its Group
Partial Internal Model (PIM) from the Swedish FSA
(Finansinspektionen). Sampo adopted the Group PIM in
its solvency calculation as of 30 June 2024. The Group
PIM recognises the risk profile of Sampo’s P&C
operations better than the Standard Formula and has
reduced the group-level solvency capital requirement
(SCR) by EUR 0.3 billion.
BOARD OF DIRECTORS’ REPORT 2024
21
Shares, share capital and shareholders
Shares and share capital
At the end of 2024, Sampo’s total share count stood at
538,247,772 shares, which were divided into
538,047,772 A shares and 200,000 B shares. The total
number of votes attached to the shares was
539,047,772. Each A share entitles the holder to one
vote and each B share entitles the holder to five votes
at the General Meeting of Shareholders.
During 2024, the share count increased by 36.5 million
shares, driven by new shares issued in connection with
the Topdanmark exchange offer, but partly offset by
share buybacks.
In September 2024, Sampo issued 48,198,710 new
Sampo A shares to Topdanmark shareholders. The new
shares represented approximately 8.76 per cent of all
Sampo shares and approximately 8.75 per cent of the
votes conferred by all Sampo shares immediately
following the completion of the share issue.
In December 2024, Sampo cancelled 11,747,690 of its
own A shares that were repurchased under the buyback
programme launched in June 2024.
At the end of 2024, Sampo plc’s share capital
amounted to EUR 98 million (98) and the Group’s
equity capital in total to EUR 7,059 million (7,687).
Sampo A shares have been listed on Nasdaq Helsinki
since 1988 and on Nasdaq Copenhagen since
September 2024. All of the Sampo B shares are held by
Kaleva Mutual Insurance Company. B shares can be
converted into A shares at the request of the holder.
Sampo’s Swedish Depositary Receipts (SDR) have been
traded on Nasdaq Stockholm since 2022. Helsinki-listed
A shares can be converted into SDRs and vice versa.
Approximately 2.7 million SDRs were issued at the end
of 2024.
Shareholders by the number of shares held
Sampo plc, 31 December 2024
Number of shares
Shareholders,
number
Share-
holders, %
Shares,
number
Shares, %
Voting rights,
number
Voting rights,
%
1–100
103,735
53.07
4,352,451
0.81
4,352,451
0.81
101–500
62,590
32.02
15,168,210
2.82
15,168,210
2.81
501–1,000
14,104
7.21
10,499,131
1.95
10,499,131
1.95
1,001–5,000
12,664
6.48
26,503,938
4.92
26,503,938
4.92
5,001–10,000
1,377
0.70
9,615,851
1.79
9,615,851
1.78
10,001–50,000
823
0.42
16,042,890
2.98
16,042,890
2.98
50,001–100,000
90
0.05
6,578,084
1.22
6,578,084
1.22
100,001–500,000
65
0.03
12,465,633
2.32
12,465,633
2.31
500,001–
34
0.02
437,021,584
81.19
437,821,584
81.22
Total
195,482
100
538,247,772
100
539,047,772
100
of which nominee registered
11
346,421,982
64.36
346,421,982
64.27
BOARD OF DIRECTORS’ REPORT 2024
22
Share price performance
Sampo plc, 2020–2024
Share_price_performance_Sampo-plc_2020-2024.svg
Share price performance adjusted for the partial demerger in 2023.
Monthly trading volume
Sampo plc, 2020–2024
Monthly_trading_volume_Sampo-plc_2020-2024.svg
BOARD OF DIRECTORS’ REPORT 2024
23
Shareholders
The number of Sampo’s Finnish-registered shareholders decreased during 2024 by
11,510 shareholders to 195,482, as at 31 December 2024. The holdings of nominee and
foreign shareholders increased to 64.5 per cent (60.3) of the shares, driven by the
Topdanmark exchange offer. Sampo did not hold any own shares at the end of 2024.
In 2024, Sampo received one (1) flagging notification of change in holding pursuant to
Chapter 9, Section 5 of the Securities Markets Act, according to which the total
number of Sampo A shares or related voting rights owned by BlackRock, Inc. and its
funds directly or through financial instruments is above 5 per cent of Sampo’s total
shares and voting rights. The reason for the notification by BlackRock, Inc. was the
Group restructure following the acquisition of Global Infrastructure Management LLC
(“GIP”) on 1 October 2024. The latest notifications are available at
www.sampo.com/flaggings.
Shareholders by sector
Sampo plc (A and B shares), 31 December 2024
Sector
Number of
shares
%
Corporations
18,244,564
3.39
Financial institutions and insurance corporations
15,284,027
2.84
Public institutions
71,919,043
13.36
Non-profit institutions
12,612,212
2.34
Households
72,817,450
13.53
Foreign ownership and nominee registered
347,370,476
64.54
Total
538,247,772
100
Shareholders
Sampo plc, the largest shareholders registered in Finland, 31 December 2024
A and B shares
Number of
shares
% of share
capital
% of votes
Solidium Oy
33,278,580
6.18
6.17
Varma Mutual Pension Insurance Company
22,248,420
4.13
4.13
Ilmarinen Mutual Pension Insurance Company
6,941,083
1.29
1.29
Oy Lival AB
4,220,000
0.78
0.78
Elo Mutual Pension Insurance Company
4,010,000
0.75
0.74
The State Pension Fund
2,900,000
0.54
0.54
OP Life Assurance Company Ltd
1,527,291
0.28
0.28
Svenska litteratursällskapet i Finland r.f.
1,454,150
0.27
0.27
Nordea Nordic Fund
1,270,000
0.24
0.24
Nordea Pro Finland Fund
1,174,415
0.22
0.22
OMX Helsinki 25 Exchange Traded Fund
1,114,925
0.21
0.21
Keva
1,009,300
0.19
0.19
Samfundet folkhälsan i Svenska Finland rf
864,065
0.16
0.16
Nordea Life Assurance Finland Ltd.
830,243
0.15
0.15
OP-Finland Fund
812,251
0.15
0.15
Evli Finland Select Fund
750,000
0.14
0.14
OP Finland Index Fund
743,623
0.14
0.14
Nordea Suomi
719,984
0.13
0.13
Kaleva Mutual Insurance Company
670,430
0.12
0.12
Sigrid Jusélius Foundation
664,150
0.12
0.12
Foreign and nominee registered total
347,370,476
64.54
64.44
Other total
103,674,386
19.26
19.23
Total
538,247,772
100
100
BOARD OF DIRECTORS’ REPORT 2024
24
Holdings of the Board and
Executive Management
The Board’s holdings of Sampo A shares and Group
Executive Committee’s holdings of Sampo A shares
are presented in the Corporate Governance Statement
section.
At the end of 2024, members of Sampo plc’s Board of
Directors and their close family members owned either
directly or indirectly 200,039 (197,429) Sampo A
shares. Their combined holdings constituted 0.04 per
cent (0.04) of shares and related votes.
Members of the Group Executive Committee and their
close family members owned either directly or indirectly
235,053 (227,321) Sampo A shares representing 0.04
per cent (0.04) of shares and related votes.
Share buyback programmes
In 2024, Sampo repurchased and cancelled 11,747,690
of its own A shares, corresponding to 2.1 per cent of the
total share count.
To reduce the dilution effect from the public exchange
offer for Topdanmark announced in June 2024, Sampo
allocated EUR 800 million to share buybacks and the
squeeze-out of Topdanmark minority shares, as
announced on 17 June 2024.
As the first step of this capital deployment, Sampo
launched a buyback programme of EUR 400 million,
which started on 18 June 2024. Following the
announcement of the result of the exchange offer on 16
September 2024, the programme was increased to EUR
475 million and extended to end no later than 30
November 2024 from the original end date of 31
October 2024, as the total acquisition cost the
Topdanmark minority shares amounted to EUR 325
million.
The programme was completed on 29 November 2024.
The average purchase price was EUR 40.43 per share.
All repurchased shares were cancelled on 10 December
2024.
Further details on the company’s share buyback
programmes are available at
www.sampo.com/sharebuyback.
BOARD OF DIRECTORS’ REPORT 2024
25
Events after the end of the reporting period
Share split
On 5 February 2025, the Board of Directors of Sampo
plc resolved on a share split by way of a share issue
without consideration in proportion to shares owned by
shareholders. In the share split, Sampo issued four (4)
new A shares for each existing A share and four (4) new
B shares for each existing B share to shareholders in
proportion to their existing holdings on the record day
of the share issuance on 12 February 2025. In total,
2,152,191,088 new Sampo A shares and 800,000 new
Sampo B shares were issued. Following the registration
of the new shares, Sampo’s total share count amounts
to 2,691,238,860 shares.
The resolution was based on the authorisation granted
by Annual General Meeting held on 25 April 2024. The
share split does not require any action from
shareholders nor holders of Swedish depository
receipts. Further information is available at
www.sampo.com/sharesplit.
Composition of the Sampo
Group Executive Committee
Peter Hermann, the CEO Topdanmark and Deputy CEO
of If P&C, has notified Sampo that he plans to pursue
opportunities outside the Group and that he will
therefore not join the Sampo Group Executive
Committee, as previously indicated. Mr Hermann will
continue as the CEO of Topdanmark until the planned
merger of Topdanmark and If P&C Insurance Ltd (publ)
is completed in the summer of 2025.
BOARD OF DIRECTORS’ REPORT 2024
26
Corporate Governance Statement
This Corporate Governance Statement, as provided by
Chapter 7 Section 7 of the Finnish Securities Market Act
(746/2012), has been prepared in accordance with the
Finnish Corporate Governance Code 2025 issued by the
Securities Market Association on 19 December 2024,
which became effective from 1 January 2025 (the “CG
Code”). This statement is presented as part of the
Board of Directors’ Report.
Governance in Sampo plc
Sampo plc complies with applicable legislation as well
as the Helsinki, Stockholm, and Copenhagen stock
exchange rules to issuers of shares. In addition, Sampo
plc complies, in full, with the CG Code.1 The CG Code
can be viewed in full on the website of the Finnish
Securities Market Association at www.cgfinland.fi.
Sampo’s governance is based on a clear division of
duties between general meetings, the Board of
Directors, and the executive management. The articles
of association define the general principles of division of
powers between the key corporate organs.
Sampo plc’s governance structure
25_3_1_The_general_structure_of_Sampo_plcs_corporate_governance_system.svg
1 Sampo plc complies with the CG Code of its domicile and therefore deviates in certain aspects from the Swedish Corporate Governance Code (Svensk kod för bolagsstyrning, the “Swedish Code”) and the
Danish Recommendation on Corporate Governance (Anbefalinger for god Selskabsledelse, the “Danish Code”). Applying the Swedish Code or Danish Code could lead to contradictions due to differences
between Finnish and Swedish or Danish legislation, corporate governance codes, and corporate governance practices. The main deviations from the Swedish Code relate to not having a nomination
committee comprised of members appointed by the company’s owners and to the handling of certain tasks which under the Swedish Code would belong to the nomination committee. The Swedish Code
issued by the Swedish Corporate Governance Board (Kollegiet för svensk bolagsstyrning) is available at www.corporategovernanceboard.se.
The main deviations from the Danish Code relate to the possibility for shareholders to follow general meetings through digital transmission, as well as guidelines related to take-over bids and tax practices.
Sampo plc’s Board of Directors does not include employee representatives and the members of the Board are elected in a bundle. However, the Board of If Group does include employee representatives. In
addition, Sampo deviates from the Danish Code in certain aspects of executive remuneration. The Danish Code issued by the Danish Committee on Corporate Governance (Komitéen for god
Selskabsledelse) is available at https://corporategovernance.dk/recommendations-corporate-governance. 
BOARD OF DIRECTORS’ REPORT 2024
27
Changes in Group structure
On 17 June 2024, Sampo announced that Sampo and
Topdanmark A/S have entered into a combination
agreement, pursuant to which Sampo will make a
recommended best and final public exchange offer to
acquire all of the outstanding shares in Topdanmark not
already owned by Sampo. The Board of Directors of
Topdanmark unanimously recommended Topdanmark
shareholders to accept the offer. As a result of the offer,
Sampo held approximately 92.6 per cent of the shares
in Topdanmark (excluding treasury shares) and initiated
a compulsory acquisition of the Topdanmark shares
held by the remaining minority shareholders. Following
completion of the offer in late 2024, Sampo began the
planned integration of Topdanmark’s P&C operations
into If’s pan-Nordic business organisation.
Sampo Group structure
31 December 2024
25_20_1_Group_structure_Sampo_Group_31-December-2023.svg
BOARD OF DIRECTORS’ REPORT 2024
28
Sampo Group organisation
31 December 2024
25_3_1_Organisation.svg
BOARD OF DIRECTORS’ REPORT 2024
29
General meeting
The highest decision-making body of Sampo plc is the
general meeting, where the shareholders participate in
the supervision and control of the company by using
their right to speak and vote.
The Finnish Companies Act and Sampo plc’s articles of
association determine the issues that have to be dealt
with at a general meeting (competence of a general
meeting).
Customarily, a general meeting deals with, in addition to
issues determined by law and the articles of association,
the issues presented by the Board of Directors.
Furthermore, according to the Finnish Companies Act, a
shareholder has the right to require a certain issue to be
dealt with at a general meeting, providing the issue falls
within the scope of competence of a general meeting.
The Board of Directors convenes a general meeting by
publishing a notice of the meeting on Sampo plc’s
website at least three weeks before the general meeting
and no later than nine days before the record date of
the general meeting. The notice of a general meeting
shall also be published by a stock exchange release.
Annual General Meeting
The AGM must be held within six months of the end of
the financial year on a date specified by the Board of
Directors. The AGM shall discuss matters assigned to it
in accordance with the articles of association and any
other business referred to in the notice of the meeting.
The notice and other documents of the AGM, including
the proposals of the Board of Directors and its
Committees, as well as the Financial Statements, the
Board of Directors’ Report and the Remuneration
Report for Governing Bodies, will be made available on
Sampo plc’s website at least three weeks before the
AGM.
In 2024, Sampo plc’s AGM was held on 25 April at the
Helsinki Expo and Convention Centre and a total of
3,188 shareholders representing 320,218,518 shares and
321,018,518 votes were represented at the meeting.
The Annual General Meeting decided to distribute a
dividend of EUR 1.80 per share for 2023. The record
date for the dividend payment was 29 April 2024 and
the dividend was paid to Sampo shareholders on 7 May
2024 and to Sampo SDR holders on 10 May 2024. The
Annual General Meeting adopted the financial accounts
for 2023 and discharged the Board of Directors and the
CEO from liability for the financial year. The AGM
accepted Sampo plc’s Remuneration Report for
Governing Bodies. The resolution was advisory.
The minutes of the Annual General Meeting are
available for viewing at www.sampo.com/agm and at
Sampo plc's head office at Fabianinkatu 27, Helsinki,
Finland.
Main duties of the AGM
► Receives and accepts the Financial
Statements.
► Receives the Auditor’s Report.
► Resolves on the measures occasioned by
the profit shown in the accepted Financial
Statements.
► Releases the members of the Board of
Directors and the Managing Director from
liability.
► Resolves on the number and fees of the
members of the Board of Directors.
► Resolves on the fees of the Auditor.
► Elects the members of the Board of
Directors and the Auditor.
► Deals with any other business on the
agenda, proposed by either a shareholder
or the Board of Directors.
► Provides advisory resolutions on the
Remuneration Policy for Governing Bodies
and on the acceptance of the Remuneration
Report.
BOARD OF DIRECTORS’ REPORT 2024
30
The AGM of 2024 also authorised the Board of
Directors to resolve to repurchase a maximum of
50,000,000 Sampo plc’s A shares and to resolve upon
a share issue without payment (share split) to all
shareholders in proportion to their holdings so that a
maximum of five new A shares would be issued for each
current A share and a maximum of five new B shares
would be issued for each current B share. The Board of
Directors did not resolve upon a share issue without
payment during 2024.
All resolutions of the AGM of 2024 were made without
separate voting.
Extraordinary general meeting
An Extraordinary General Meeting (the “EGM”) is
convened when considered necessary by the Board of
Directors. The Auditor, or shareholders together holding
a minimum of one tenth of all the shares in the company
may request in writing that an EGM shall be convened
to discuss a specified matter raised by them.
In 2024, Sampo plc’s EGM was held on 9 July at the
Helsinki Hall of Culture and a total of 2,923 shareholders
representing 319,844,802 shares and 320,644,802 votes
were represented at the meeting.
The Board of Directors convened the EGM to authorise
the Board of Directors to resolve upon the issuance of
shares in connection with Sampo’s recommended best
and final public exchange offer to the shareholders of
Topdanmark A/S, as announced on 17 June 2024.
The EGM of 2024 authorised the Board of Directors to
resolve on a share issue of up to maximum of
57,468,782 new Sampo A shares which corresponded
to approximately 11.5 per cent of all Sampo A shares on
the date of the EGM notice in deviation from the
shareholders’ rights (directed share issue).
Attending a shareholders’ meeting
By attending shareholders’ meetings shareholders may,
either personally or through representatives, exercise
their voting rights, request information, and participate
in the decision-making process of Sampo plc.
At a shareholders’ meeting, each Sampo plc A share
carries one vote, while each Sampo plc B share carries
five votes.
Shares and shareholders
As at 31 December 2024, the total number of Sampo
plc’s shares, including both 538,047,772 A shares and
200,000 B shares, equalled to 538,247,772 shares. Each
A share entitles its holder to one vote and each B share
to five votes at a shareholders’ meeting. The total
number of votes attached to the shares was
539,247,772.
Sampo plc’s articles of association define two different
classes of shares in the company and determine that
each A share entitles its holder to one vote and each B
share entitles its holder to five votes at a general
meeting. All of Sampo plc’s B shares are owned by a
shareholder independent from the company. Based on
Sampo plc’s articles of association, each B share can be
converted into an A share at the request of the holder
of the B share.
Moreover, subject to the Finnish Companies Act, the
general meeting may resolve upon a directed
acquisition of own shares, decide on the amendment of
the articles of association to the effect that share
classes are combined, or otherwise reduce share class
rights only provided such a proposal is supported by at
least two thirds of the votes and shares, per share class,
represented at the meeting. Thus, the authority to
decide on the combination of Sampo plc’s share classes
does not rest with the company.
As at 31 December 2024, a total number of 195,482
Finnish registered shareholders held 191,825,790 shares
representing approximately 35.7 per cent of all shares.
In addition, 11 nominee registers held 346,421,982 shares
representing approximately 64.3 per cent of all shares.
BOARD OF DIRECTORS’ REPORT 2024
31
Board of Directors
Sampo plc’s Board of Directors, elected annually by the
AGM, uses the highest decision-making power in Sampo
Group between the AGMs. Sampo plc’s Board of
Directors is responsible for the management of the
company in compliance with applicable laws, authority
regulations, Sampo plc’s articles of association, and the
decisions of the shareholders’ meetings.
Board of Directors’ duties
The working principles and main duties of the Board of
Directors have been defined in the Board’s charter. To
ensure the proper running of operations, Sampo plc’s
Board of Directors has approved internal rules
concerning general corporate governance, risk
management, remuneration, compliance, internal
control, and reporting in Sampo Group.
Main duties of the Board of Directors
► Receives group-wide reporting.
► Supervises
• the due organisation of functions and
operations
• the financial reporting systems, including the
Sustainability Statement, and the efficiency of
internal audit and risk management
• related party transactions
• the independence of and non-audit services
provided by the Auditor
• the adequacy and effectiveness of the
governance, risk management, and internal
control processes related to the Group
Internal Model.
► Resolves on
• the strategy and other major strategic or far-
reaching decisions of Sampo Group
• convening of the AGM
• group-wide and Sampo plc level principles
and policies including the Code of Conduct
and the Group Internal Audit policies
• the minimum requirements of capitalisation
and the proposal on profit distribution
• group level remuneration matters
• significant changes to the Group Internal
► Prepares
• consolidated financial statements
• proposals for the AGM.
► Appoints, discharges/removes, and decides on
the Group CEO’s, Group Executive Committee
members’, and the Group Chief Audit
Executive’s terms of service and financial
benefits within the framework of the valid
Remuneration Policy.
► Discusses the annual performance evaluation of
the Board of Directors.
BOARD OF DIRECTORS’ REPORT 2024
32
Election and term of office of
Board members
According to Sampo plc’s articles of association, the
company’s Board of Directors comprises no fewer than
three and no more than ten members elected by
shareholders at the AGM. The term of office of the
Board members ends at the close of the next AGM
following their election. The members of the Board elect
a chair and vice chair from among its members at their
first Board meeting following the AGM.
Diversity of the Board
Sampo plc’s Board Diversity Policy which was adopted
in November 2024 aims to ensure that Sampo’s Board
of Directors embodies a well-balanced mix of
knowledge, skills, diversity, and experience, fully in line
with Sampo Group’s values and Code of Conduct.
Board members are to have professional experience
and education relevant and appropriate to Sampo’s
scale and scope, including financial expertise, industry
knowledge, international experience, risk management,
strategic planning, and governance and leadership skills.
Diversity is key, with consideration given to at least age,
gender, geographical provenance, and educational and
professional background. Further, each Board member
is expected to be able to devote a sufficient time to the
Board’s work and the Board as a whole shall fulfil
independence recommendations of the CG Code. More
information on the skills and experience of the Board is
available on Sampo’s website.
To promote gender balance, both genders shall always
be represented on the Board, with a target that women
and men both shall be represented by at least 40 per
cent of the members of the Board. However, some
deviations may be applied if deemed reasonable due to
the number of Board members:
Number of Board
Members
Minimum number of both
genders on the Board
3-4
1
5-6
2
7-8
3
The number of the Directors and the composition of the
Board shall be such that they enable the Board of
Directors to see to its duties efficiently. During the past
ten years, Sampo plc’s Board of Directors has, on
average, reached its target for gender diversity and the
Board continues its endeavours to reach the new
minimum share of at least 40 per cent of the total
number of members for both genders. In 2024, the
target for each gender represented in the Board of
Directors was 37.5 per cent. As at 31 December 2024,
the share of women in Sampo plc’s Board of Directors
was 33 per cent and the share of men was 67 per cent.
Regardless of a well prepared and performed executive
search process, the proposed Board composition did
not fulfil the target according to which each gender
shall be represented by at least 37.5 per cent of the
members of the Board. This is attributable to the limited
number of suitable and available candidates. The Board
remains committed to reaching its target of having both
genders represented on the Board and will continue its
endeavours to reach the target when proposing
candidates for Board membership in the future.
Board members
As proposed by the Nomination and Remuneration
Committee, the number of Board members remained
unchanged at nine members at the AGM of 2024.
Christian Clausen , Georg Ehrnrooth, Jannica
Fagerholm, Steve Langan, Risto Murto, Antti Mäkinen,
Markus Rauramo, and Annica Witschard were re-
elected to the Board. In addition, Astrid Stange was
elected as a new member to the Board. The members of
the Board were elected for a term continuing until the
close of the next AGM. All Board members have been
determined to be independent of the company and its
major shareholders under the rules of the Finnish
Corporate Governance Code 2025.
The following persons served on Sampo plc’s Board of
Directors in 2024:
BOARD OF DIRECTORS’ REPORT 2024
33
Antti_Makinen_Report-crop.png
Antti Mäkinen
Chair of the Board
Male, born 1961, LL.M.
Finnish citizen
Chair of the Board since 17 May 2023. Also served as a
member of the Board of Directors of Sampo plc in
2018–2021.
Jannica_Fagerholm_Report-crop.png
Jannica Fagerholm
Vice Chair of the Board
Managing Director, Signe and Ane Gyllenberg
Foundation
Female, born 1961, M.Sc. (Econ.)
Finnish citizen
Positions of trust
Mandatum plc, Vice Chair
Solidium Oy, Board Member
Kesko Corporation, Board Member
Swedish Society of Literature in Finland, Board
Member
Kelonia (Private Equity holding company), Board
Member
Member of the Board of Directors of Sampo plc since
18 April 2013 and Vice Chair of the Board since
9 April 2019.
Christian_Clausen_Hires_Report-crop.png
Christian Clausen
Member of the Board
Chair for the Nordics, BlackRock
Male, born 1955, M.Sc. (Econ.), MBA
Danish citizen
Positions of trust
BW Group, Board Member
Member of the Board of Directors of Sampo plc since
21 April 2016.
Information as at 31 December 2024. The CVs of members of the Board of Directors can be viewed at www.sampo.com/board.
BOARD OF DIRECTORS’ REPORT 2024
34
Georg_Ehrnrooth_Report-crop.png
Georg Ehrnrooth
Member of the Board
Male, born 1966, Studies in agriculture and forestry
Finnish citizen
Positions of trust
eQ Oyj, Chair of the Board
Byggmästare Anders J Ahlström Holding AB (publ),
Board Member
Fennogens Investments S.A., Board Member
Topsin Investments S.A., Board Member
Geveles Ab, Chair of the Board
Neptunia Invest AB, Board Member
Louise and Göran Ehrnrooth Foundation, Chair of the
Board
Anders Wall Foundation, Board Member
Paavo Nurmi Foundation, Board Member
Member of the Board of Directors of Sampo plc since
2 June 2020.
Steve_Langan_Report-crop.png
Steve Langan
Member of the Board
Male, born 1960, Master of Arts, Medieval and Economic
History
British citizen
Positions of trust
The Kenneth Armitage Foundation, Chair
Hepworth Wakefield, Chair of the Board
Member of the Board of Directors of Sampo plc since
18 May 2022.
Risto_Murto_Report-crop.png
Risto Murto
Member of the Board
CEO and President, Varma Mutual Pension Insurance
Company
Male, born 1963, Ph.D. (Econ.)
Finnish citizen
Positions of trust
Nordea Bank Abp, Board Member
Securities Market Association, Chair of the Board
e2 Research, Chair of the Board
The Finnish Cultural Foundation, Member of the
Supervisory Board
The Finnish Pension Alliance TELA, Chair of the Board
Finnish National Opera and Ballet, Member of the
Supervisory Board
Member of the Board of Directors of Sampo plc since 16
April 2015.
Information as at 31 December 2024. The CVs of members of the Board of Directors can be viewed at www.sampo.com/board.
BOARD OF DIRECTORS’ REPORT 2024
35
Markus_Rauramo_Report-crop.png
Markus Rauramo
Member of the Board
CEO, Fortum Corporation
Male, born 1968, M.Soc.Sc.
Finnish citizen
Positions of trust
Eurelectric, Vice President
Member of the Board of Directors of Sampo plc since 19
May 2021.
Fiona Clutterbuck
Member of the Board
Born 1958, LLB (Hons)
British citizen
Member of the Board of Directors of Sampo plc
9 April 2019 - 25 April 2024
Astrid_Stange_Report-crop.png
Astrid Stange
Member of the Board
CEO, ELEMENT Insurance AG
Female, born 1965, Doctorate in Economics
German citizen
Positions of trust
Moody's Investors Service, Independent Director of the
EU/UK Supervisory Boards
Atos SE, Independent Director of the Board of Directors
Lufthansa Group, Member of the Supervisory Board
Member of the Board of Directors of Sampo plc since
25 April 2024.
Annica_Witschard_Report-crop.png
Annica Witschard
Member of the Board
Female, born 1973, M.Sc. (Business & Economics)
Swedish citizen
Positions of trust
Viaplay Group, Board Member
Member of the Board of Directors of Sampo plc since 17
May 2023.
Information as at 31 December 2024. The CVs of members of the Board of Directors can be viewed at www.sampo.com/board.
BOARD OF DIRECTORS’ REPORT 2024
36
When elected, all current Board members were independent of the company.
Furthermore, all Board members were independent of the company’s major
shareholders.
The Board convened fifteen times in 2024. The meeting attendance of Sampo plc’s
current Board members in Board meetings from 1 January–31 December 2024 is
presented in the below table:
Attendance
(%)
Meetings
attended
Antti Mäkinen (Chair of the Board)
100
14/14
Jannica Fagerholm
100
14/14
Christian Clausen
100
14/14
Fiona Clutterbuck (member until 25 April 2024)
100
4/4
Georg Ehrnrooth
100
14/14
Steve Langan
92.86
13/14
Risto Murto
100
14/14
Markus Rauramo
100
14/14
Astrid Stange (member since 25 April 2024)
90
9/10
Annica Witschard
92.86
13/14
Shares and share-based rights held by the Board
members
On 31 December 2024, the members of the Board of Directors owned, directly or
through legal entities controlled by them, Sampo plc’s A shares as follows:
Shares owned by the Board of Directors
Sampo plc, 31 December 2024 and 31 December 2023
Board of Directors
31 Dec 2024
31 Dec 2023
Antti Mäkinen
8,550
7,010
Jannica Fagerholm
8,751
8,751
Christian Clausen
38,479
38,479
Fiona Clutterbuck1
3,678
Georg Ehrnrooth
130,345
129,532
Steve Langan
2,330
1,498
Risto Murto
5,869
5,169
Markus Rauramo
3,101
2,407
Astrid Stange2
889
—
Annica Witschard
1,725
905
Total
200,039
197,429
Board of Directors ownership of shares, %
0.04
0.04
Board of Directors share of votes, %
0.04
0.04
1 Member of the Board of Directors member until 25 April 2024
2 Member of the Board of Directors since 25 April, 2024
The Board members did not have holdings in any Sampo plc share-based rights.
BOARD OF DIRECTORS’ REPORT 2024
37
The AGM decided to pay the following annual fees to
the members of the Board of Directors until the close of
the 2025 AGM:
• EUR 235,000 for the Chair of the Board
• EUR 135,000 for the Vice Chair of the Board
• EUR 104,000 for each member of the Board
• EUR 29,000 for the Chair of the Audit Committee as
an additional annual fee
• EUR 6,600 for each Audit Committee member as an
additional annual fee
A Board member shall, in accordance with the
resolution of the AGM, acquire Sampo plc A shares at
the price paid in public trading for 50 per cent of his/
her annual fee after the deduction of taxes, payments,
and potential statutory social and pension costs.
Notwithstanding this, a Board member is not required
to purchase any additional Sampo plc A shares if the
Board member owns such amount of said shares that
their value is equivalent to twice the respective Board
member’s gross annual fee. The company will pay any
possible transfer tax related to the acquisition of the
company shares.
Board-appointed committees
The Board may establish committees, executive
committees, and other permanent or temporary bodies
to deal with tasks prescribed by it. The Board confirms
the charters of the committees of Sampo plc’s Board
and the Group Executive Committee, and also the
guidelines and authorisations given to other bodies
established by the Board.
The Board has an Audit Committee and a Nomination
and Remuneration Committee, whose members it
appoints from among its members in accordance with
the charters of the respective committees. In
accordance with the Charter of Sampo plc’s Audit
Committee, matters related to risk management belong
under the scope of matters handled by Sampo plc’s
Audit Committee.
BOARD OF DIRECTORS’ REPORT 2024
38
Audit Committee
According to its charter, the Audit Committee
comprises at least three members elected from among
those Board members who do not hold executive
positions in Sampo plc and are independent of the
company and of which at least one is independent of
Sampo plc’s significant shareholders. The responsible
Auditor, Group CEO, Group CFO, Group Chief Audit
Executive, and Group Chief Risk Officer also participate
in the meetings of the Committee.
In 2024, the chair of the Audit Committee was Jannica
Fagerholm, and the other members were Fiona
Clutterbuck, Georg Ehrnrooth, Steve Langan, and
Annica Witschard until 25 April 2024 and Steve
Langan, Markus Rauramo, Astrid Stange, and Annica
Witschard thereafter. As at 31 December 2024, the
share of women in Sampo plc’s Audit Committee was
60 per cent and the share of men was 40 per cent.
The Audit Committee convened four times in 2024. The
meeting attendance of Sampo plc’s current Audit
Committee members in Committee meetings from 1
January–31 December 2024 is presented in the
following table:
Attendance
(%)
Meetings
attended
Jannica Fagerholm (Chair of
the Committee)
100
4/4
Fiona Clutterbuck (member
until 25 April 2024)
100
1/1
Georg Ehrnrooth (member
until 25 April 2024)
100
1/1
Steve Langan
100
4/4
Markus Rauramo (member
since 25 April 2024)
100
3/3
Astrid Stange (member since
25 April 2024)
67
2/3
Annica Witschard
100
4/4
Main duties of the Audit Committee
► Supervises and assesses
• Group financial and supervisory reporting
processes
• the accuracy of Group financial statements
• statutory and external audit, the independence
of the auditor, auditor’s reporting, and purchases
of non-audit services
• the capitalisation, profitability, and liquidity of
Group companies and the Group itself
• the effective operation of the risk management
system
• preparation of and compliance with risk
management policies and other related
guidelines
• the actions and processes of Sampo Group’s
compliance functions, significant litigations, and
compliance with laws and regulations
• communications with authorities
• the company’s tax position and tax risks
• the adequacy and effectiveness of the
governance, risk management, and internal
control processes related to the Group Internal
Model
► Monitors and evaluates
• the preparation of non-financial reporting
(Sustainability Statement)
• the internal audit’s reporting and approves of the
internal audit action plan and strategy
• the effectiveness and efficiency of Sampo
Group’s internal audit function
• the effectiveness of internal control and other
elements of the system of governance
• related party transactions and reporting
processes related thereto
• the Group’s risks, risk management processes,
and the quality and scope of risk management
• processes and risks regarding IT privacy and
security
• compliance with risk management principles and
other guidelines.
► Prepares proposals to the AGM concerning the
auditor’s election and its fees.
BOARD OF DIRECTORS’ REPORT 2024
39
Nomination and Remuneration
Committee
According to the Board Diversity Policy, Sampo plc’s
Nomination and Remuneration Committee shall identify,
review and recommend candidates for the Board. The
Nomination and Remuneration Committee shall take the
following factors into consideration, including such
other factors as the Board may determine:
(I) Regulatory requirements for the members of the
Board
(II) Overall Board composition, taking into
consideration the appropriate combination of
professional experience, skills, knowledge, and
variety of viewpoints and backgrounds
(III) Allocation and sufficiency of time
(IV) Other criteria (e.g. with respect to new directors,
the integrity, judgment, and available time and
with respect to current directors, their past
performance).
At the AGM, the Nomination and Remuneration
Committee gives an account of how it has conducted
its work and explains its proposals.
According to its charter, the Nomination and
Remuneration Committee comprises the chair of the
Board (who acts as the committee’s chair) and two to
three members elected from among the members of
the Board.
In 2024 the chair of the Nomination and Remuneration
Committee was Antti Mäkinen, and the other members
were Christian Clausen, Risto Murto, and Markus
Rauramo until 25 April 2024 and Christian Clausen,
Georg Ehrnrooth, and Risto Murto since 25 April 2024.
As at 31 December 2024, the share of men in the
Nomination and Remuneration Committee was 100 per
cent.
The Committee convened seven times in 2024. The
meeting attendance of Sampo plc’s Nomination and
Remuneration Committee members in Committee
meetings from 1 January–31 December 2024 is
presented in the below table:
Attendance
(%)
Meetings
attended
Antti Mäkinen (Chair of the
Committee)
100
6/6
Christian Clausen
83
5/6
Georg Ehrnrooth (member
since 25 April 2024)
100
4/4
Risto Murto
100
6/6
Markus Rauramo (member
until 25 April 2024)
100
2/2
Main duties of the Nomination and Remuneration Committee
► Monitors the implementation of the Group
remuneration in general.
► Evaluates the appropriateness of the
remuneration of the executive directors and their
remuneration structure.
► Prepares and presents proposals to the AGM on
the composition of the Board of Directors and the
remuneration of its members as well as on the
Remuneration Policy for Governing Bodies.
► Prepares and presents proposals to the Board of
Directors pertaining to
• the evaluation of independence of Board
members, composition and chair of Board
committees, and the Board Diversity Policy
• succession planning of the Board of Directors
and top management positions in Sampo Group
• the appointment of the Group CEO, the Group
Chief Audit Executive, and members of the
Group Executive Committee, including their
fitness and propriety assessments
• the remuneration and terms of employment of
the members of the GEC as well as the actual
payments to be made to the GEC members
• the launch of Sampo Group’s long-term
incentive schemes based on financial
instruments of Sampo plc and the maximum
pay-outs based on short-term programmes and
long-term incentive schemes
• Sampo Group Remuneration Principles and
Sampo Remuneration Policy for Personnel.
► Prepares the annual performance evaluation of
the Board of Directors.
BOARD OF DIRECTORS’ REPORT 2024
40
Sampo Group CEO
CEO_2024.jpg
Sampo plc has a managing director who is
simultaneously the Group CEO of Sampo Group. The
Board of Directors elects and releases the Group CEO
and decides on the terms of service and other
remuneration.
The Group CEO is in charge of the daily management of
Sampo plc, subject to the instructions and control of the
Board of Directors. The Group CEO is empowered to
take extraordinary and broad ranging actions, taking
into account the scope and nature of Sampo plc’s
operations, only upon authorisation by the Board of
Directors. The Group CEO ensures the legal compliance
of Sampo plc’s accounting and the trustworthy
organisation of asset management.
Mr. Torbjörn Magnusson, licentiate of engineering, is the
managing director of the company and the Group CEO.
His Group CEO contract is in force until further notice.
The Group CEO contract may be terminated by the
company with a notice period of 12 months, for which
period the Group CEO is entitled to receive salary. In
addition, Magnusson is, due to the terms applied in his
previous position in Sampo Group as the CEO of If P&C
Insurance Holding Ltd, entitled to a severance
compensation corresponding to a maximum of 24
months’ fixed salary, should i) Sampo plc terminate his
service contract or ii) the Group CEO terminate the
contract based on either material breach of the contract
from the company’s part, or based on material changes
in the Group CEO’s responsibilities due to significant
changes in Sampo Group structure or ownership.
BOARD OF DIRECTORS’ REPORT 2024
41
Sampo Group
Executive Committee
The Board of Directors has appointed the Sampo Group
Executive Committee to support the Group CEO in the
preparation of strategic issues relating to the Group, in
the handling of operating matters that are significant or
involve questions of principle, and in ensuring a good
internal flow of information.
The Group Executive Committee addresses especially
the following matters: Sampo Group’s strategy, profit
development, large purchases and projects, the Group’s
structure and organisation, as well as key strategic
issues pertaining to administration and personnel. In
2024, the Group Executive Committee convened 13
times at the invitation of the Group CEO.
As at 31 December 2024, the share of women in the
Group Executive Committee was 14 per cent and the
share of men was 86 per cent.
The following persons served on the Group Executive
Committee in 2024:
BOARD OF DIRECTORS’ REPORT 2024
42
Torbjorn_Magnusson_Report-crop.png
Torbjörn Magnusson
Group CEO, Sampo Group
Male, born 1963, Licentiate of Engineering
Swedish citizen
Positions of trust
Hastings Group, Board Member
If P&C Insurance Holding Ltd, Chair of the Board
Member of Sampo Group Executive Committee since
2004.
Knut_Arne_Alsaker_Report-crop.png
Knut Arne Alsaker
Group CFO, Sampo Group
Male, born 1973, M.Sc. (Econ.)
Norwegian citizen
Positions of trust
Topdanmark Forsikring A/S, Board Member
Hastings Group, Board Member
If P&C Insurance Holding Ltd, Board Member
Member of Sampo Group Executive Committee since
2014.
Ingrid_Janbu_Holthe__Report-crop.png
Ingrid Janbu Holthe
Head of BA Private, If P&C Insurance Holding Ltd
(publ)
Female, born 1982, M.Sc. (Econ.), CEMS MIM
Norwegian citizen
Positions of trust
Finance Norway (Finans Norge), Member of the
Executive Committee of P&C Insurance
Member of Sampo Group Executive Committee since
2019.
Information as at 31 December 2024. The CVs of members of the Group Executive Committee can be viewed at www.sampo.com/management.
BOARD OF DIRECTORS’ REPORT 2024
43
Klas_Svensson_Report-crop.png
Klas Svensson
Head of Business Area Commercial , If P&C Insurance
Holding Ltd (publ)
Male, born 1985, MBA
Swedish citizen
Member of Sampo Group Executive Committee since
2024.
Ville_Talasmaki_Report-crop.png
Ville Talasmäki
Group CIO, Sampo Group
Male, born 1975, M.Sc. (Econ.)
Finnish citizen
Positions of trust
Topdanmark Forsikring A/S, Board Member
Finance Finland, Board Member
Varma Mutual Pension Insurance Company, Deputy
Board Member
If P&C Insurance Holding Ltd, Board Member
If P&C Insurance Ltd, Board Member
Member of Sampo Group Executive Committee since
2023.
Morten_Thorsrud_Report-crop.png
Morten Thorsrud
President & CEO, If P&C Insurance Holding Ltd
Male, born 1971, M.Sc. (Econ.)
Norwegian citizen
Positions of trust
Topdanmark Forsikring A/S, Deputy Chair of the Board
Hastings Group, Board Member
Euronext, Member of the Supervisory Board
Finance Norway (Finans Norge), Member of the
Executive Committee
Member of Sampo Group Executive Committee since
2006.
Information as at 31 December 2024. The CVs of members of the Group Executive Committee can be viewed at www.sampo.com/management.
BOARD OF DIRECTORS’ REPORT 2024
44
Ricard_Wennerklint_Report-crop.png
Ricard Wennerklint
Chief of Strategy, Sampo Group
Male, born 1969, Executive Education, Advanced
Management Programme
Swedish citizen
Positions of trust
Topdanmark Forsikring A/S, Chair of the Board
Hastings Group, Chair of the Board
NOBA Bank Group AB (publ) (former Nordax Bank AB
(publ)), Chair of the Board
If P&C Insurance Holding Ltd, Board Member
Member of Sampo Group Executive Committee since
2005.
Information as at 31 December 2024. The CVs of members of the Group Executive Committee can be viewed at www.sampo.com/management.
BOARD OF DIRECTORS’ REPORT 2024
45
Shares and share-based rights held by the Group CEO
and the members of the Executive Committee
On 31 December 2024, the Group CEO and other members of the Executive
Committee owned, directly or through legal entities controlled by them, Sampo plc’s A
shares as follows:
Shares owned by the Group Executive Committee
Sampo plc, 31 December 2024 and 31 December 2023
Group Executive Committee
31 Dec 2024
31 Dec 2023
Torbjörn Magnusson
48,355
46,268
Knut Arne Alsaker
49,449
43,412
Ingrid Janbu Holthe
10,867
5,588
Klas Svensson
4,761
0
Ville Talasmäki
20,449
17,801
Morten Thorsrud
73,570
65,788
Ricard Wennerklint
27,602
48,464
Total
235,053
227,321
Group Executive Committee's ownership of shares, %
0.04
0.04
Group Executive Committee's share of votes, %
0.04
0.04
The Group CEO and the other members of the Executive Committee did not have
holdings in any Sampo plc share-based rights.
BOARD OF DIRECTORS’ REPORT 2024
46
Remuneration
The Board of Directors has established the Sampo
Group Remuneration Principles, which apply to all
Sampo Group companies. The Remuneration Principles
describe the remuneration structure and the principles
for setting up remuneration systems in Sampo Group.
The Remuneration Principles may apply to the Group
CEO, insofar as they do not conflict with Sampo plc’s
Remuneration Policy for Governing Bodies.
The core of the Remuneration Principles is that all
remuneration systems in Sampo Group shall safeguard
the long-term financial stability and value creation of
Sampo Group and shall comply with regulatory and
ethical standards. They shall also be aligned with the
risk management framework and thus be designed in
parallel with the risk management principles and
practices.
Remuneration mechanisms shall encourage and
stimulate employees to consistently do their best and
exceed their targets. Remuneration packages shall be
designed to reward fairly for prudent and successful
performance. At the same time, however, in order to
safeguard the interest of other stakeholders,
compensation mechanisms shall not generate conflicts
of interest and shall not entice or encourage employees
to engage in excessive or unwanted risk-taking.
The different forms of remuneration used in Sampo
Group are the following:
(a) Fixed compensation
(b) Variable compensation
(c) Pension
(d) Other benefits
Fixed compensation is the basis of an employee’s
remuneration package. Fixed salary shall support
financial stability by representing a sufficiently high
share of the total remuneration. Variable compensation
is used to ensure the competitiveness of total
remuneration packages. Variable compensation can
either be based on the contribution to the company’s
profitability and on individual performance (short-term
incentive programs) or be linked to committing
employees to Sampo Group for a longer period and
aligning the employees' interests with those of the
shareholders by linking the payout of the schemes to
key performance criteria and, if applicable, to the
positive development of Sampo’s share price (long-
term incentive schemes). The members of the Board of
Directors do not participate in any short-term incentive
programs or long-term incentive schemes.
The payment of variable compensation shall be based
on the assessment of the incurred risk exposure and the
fulfilment of solvency capital requirements. The
payment of a certain portion of the variable
compensation payable to the Senior Executive
Management and to certain key persons shall be
deferred for a defined period of time, as required in the
regulatory framework applicable to each Sampo Group
company.
After the deferral period, a retrospective risk
adjustment review shall be carried out and the Board of
Directors of each Sampo Group company shall decide
whether the deferred variable compensation shall be
paid/released in full, partly, or cancelled in whole. In
2024, a total of EUR 11 million (6.5) of short-term and
long-term incentives have been deferred.
The Board of Directors decides on the launch of long-
term incentive schemes based on financial instruments
of Sampo plc. In March 2024, the Board of Directors
decided to adopt a new performance-based long-term
incentive scheme for the Group Executive Committee
(including the Group CEO) and other senior leaders and
key employees of Sampo Group. Please refer to Sampo
plc’s 2024 Remuneration Report for Governing Bodies
for further information on the new Sampo Group long-
term incentive scheme 2024.
Moreover, the second instalment of the long-term
incentive scheme 2020:1 and the first instalment of the
long-term incentive scheme 2020:1/2 vested in 2024.
The vesting of the schemes is determined on the basis
of Sampo's share price development and dividends paid
over each instalment’s performance period, starting
from the issue of the schemes, and performance criteria
related to return on capital at risk (RoCaR) applicable
for each instalment. Both incentive schemes contain a
cap for maximum payout. The terms and conditions of
the incentive schemes are available at
www.sampo.com/incentiveterms.
A deferral rule applies to incentive rewards paid to the
Senior Executive Management and to certain key
persons. Persons subject to the deferral rule shall at
payout from the schemes acquire Sampo A shares with
a certain part of the instalment after deducting income
tax and other comparable charges. The shares are
subject to disposal restrictions for three years, after
which the Board of Directors shall decide on the
possible release.
A total of EUR 62 million (71), including social costs, was
paid as short-term incentives in January–December
2024 in Sampo Group. In the same period, a total of 43
million (38) was paid as long-term incentives. The long-
term incentive schemes in force in Sampo Group
produced a negative result impact of EUR -14 million
(-10).
BOARD OF DIRECTORS’ REPORT 2024
47
The Remuneration Report for Governing Bodies 2023 was presented to and adopted
by the Annual General Meeting in 2024. Taking into account the advance votes as well
as the advance voting instructions of the owners of nominee-registered shares and
holders of SDRs, which were delivered to Sampo before the AGM, the proposal was
supported in total by 96 per cent of votes represented at the meeting.
Sampo plc publishes the 2024 Remuneration Report for Governing Bodies in
connection with the Board of Directors’ Report at www.sampo.com/year2024. The
Remuneration Report for Governing Bodies provides information on the remuneration
of the Board of Directors and the Group CEO, and has been prepared in accordance
with the Corporate Governance Code 2025. The Corporate Governance Code 2025
can be viewed in full on the website of the Securities Market Association at
www.cgfinland.fi/en.
Sampo plc’s Remuneration Policy defines how the remuneration of the Group CEO and
the members of the company’s Board of Directors has been arranged. The
Remuneration Policy has been developed in accordance with the requirements set
forth by the amended EU Shareholders’ Rights Directive, as implemented into Finnish
legislation. Sampo plc’s Remuneration Policy was presented to the AGM in 2024. The
updated Remuneration Policy is available at www.sampo.com/agm.
Personnel
Number of personnel
Sampo Group, 2024
The average number of employees (FTE) in Sampo Group’s P&C operations in 2024
was 14,280 (13,272). On 31 December 2024, the total number of staff in the Group’s
P&C operations was 14,779 (13,450).
Sampo Group personnel
Average
personnel
(FTE) 2024
%
Average
personnel
(FTE) 2023
%
By company
If
8,070
57
7,858
59
Hastings
3,736
26
3,200
24
Topdanmark
2,412
17
2,160
16
Sampo plc
61
0.4
54
0.4
Total
14,280
100
13,272
100
By country
United Kingdom
3,710
26
3,176
24
Denmark
2,971
20,8
2,756
21
Finland
1,973
13,8
1,934
15
Sweden
2,486
17,4
2,446
18
Norway
1,680
11,8
1,613
12
Other countries
1,460
11,2
1,346
10
Total
14,280
100
13,272
100
*At the end of 2024, the total personnel (FTE) at Sampo plc amounted to 66 (58), of which 57 (49)
worked at the headquarters in Finland and 9 (9) at the branch office in Sweden.
BOARD OF DIRECTORS’ REPORT 2024
48
Internal control in
Sampo Group
The different sectors of Sampo Group’s internal control
system play a crucial role in ensuring the proper
functioning of the Group’s corporate governance
system.
Internal control means all activities which ensure that
Sampo Group’s businesses are carried out towards
desired targets in accordance with desired policies and
practices and in compliance with applicable legal and
regulatory requirements. Accordingly, the tasks of
internal control are performed by different actors within
the organisation starting from top management.
The organisation of internal control and safeguarding its
functioning and viability play a key role in the activities
of the Board of Directors of Sampo plc. In order to
ensure the proper running of operations, Sampo plc’s
Board has approved Group level policies and guidelines
concerning corporate governance, financial target
setting, risk management, remuneration, compliance,
reporting, and internal audit in conformity with and
supplementing the existing legal and regulatory
framework. With the policies and guidelines, Sampo
plc’s Board directs the Group’s activities towards
desired practices and, with appropriate control
mechanisms provided by the policies, ensures that
potential deviations are discovered without undue
delay.
Thus, a successful internal control system presumes not
only controlled steering processes for business
management, but also appropriate control mechanisms.
In Sampo Group, the internal control system includes
managing risks as an integrated part of business
activities, functions supporting the businesses, as well
as control and steering functions, which are organised
as independent from the businesses.
In addition to internal control activities within the
financial reporting process and risk management,
Sampo Group’s compliance function, with insider
administration supplementing it, together with a fully
independent internal audit function form core parts of
Sampo plc’s internal control system.
Reporting
Financial reporting
The financial reporting process aims to ensure that
Sampo plc’s Board of Directors and executive
management have timely and reliable information
supporting their decision-making, and that external
interest groups can also rely on the financial information
provided to them.
To ensure the accuracy of all reporting, the used
databases are reconciled on a monthly basis. Several
systems and analytical tools are also applied to support
efficiency and accuracy in the reporting process.
Group level financial reporting is based on information
provided by the parent company as well as the Group
companies according to formats and schedules defined
by the Group’s financial functions. Each Group company
is responsible for its respective financial reporting and
related internal controls. Consequently, the process
ensures the accuracy of the information regarding
different business segments prior to reporting to the
parent company.
Sampo Group’s financial reporting is organised under
Group Control and Group Financial Reporting functions
and it operates under the Group Chief Financial Officer.
The Group Control function prepares and follows Group
level and parent company’s financial targets and
forecasts, follows profit development and forecasts of
the Group companies, and takes care of monthly
reporting, Group level investment reporting, forecasting
of profit development of the Group, as well as
quantitative Solvency II reporting. It also produces
different types of valuations, market analyses and
reviews. The Group Control function is responsible for
the Group’s annual and quarterly quantitative
Solvency II reporting to the supervisory authorities.
The Group Financial Reporting function prepares
Sampo Group’s quarterly and annual financial reports in
accordance with International Financial Reporting
Standards (IFRS). The financial reports of the parent
company, Sampo plc, are prepared in accordance with
Finnish accounting standards (the Finnish GAAP).
Quarterly and annual reports are dealt with in the
Group’s administrative bodies in accordance with
applicable procedural rules. In addition, the Group
Financial Reporting function prepares the Group’s
monthly accounts, which form the basis of the monthly
analysis prepared by the Group Control function.
A Management Report is distributed on a monthly basis
to the members of the Group Executive Committee, and
a summary of it is delivered to the members of Sampo
plc’s Board of Directors on a regular basis.
Profit forecasts are reported quarterly to the Group
Executive Committee, the Board, and its Audit
Committee. Group solvency calculations are also
delivered on a quarterly basis to the Group Executive
Committee, the Board, and its Audit Committee.
BOARD OF DIRECTORS’ REPORT 2024
49
Non-financial reporting (Sustainability)
Sampo Group is committed to developing the
sustainability activities and related reporting of the
Group. This is in the interests of, and expected by, the
Group’s various stakeholders.
Sampo plc’s Board of Directors has the ultimate
oversight of Group level sustainability, covering the
entire range of environmental, social, and governance
(ESG) matters. The Board has assigned its Audit
Committee to monitor Sampo Group’s sustainability
reporting and activities.
The Group CFO, who is a member of the Sampo Group
Executive Committee, directs Sampo plc’s Sustainability
function. The Group CFO also ensures that adequate
reporting on sustainability matters is provided to the
Group CEO.
The Sustainability function of Sampo plc, led by the
Head of Sustainability, is responsible for the
development and coordination of sustainability at
Group level. The function prepares the Group level
sustainability reporting and the sustainability
programme, which sets the direction for the Group’s
sustainability work. In addition, the function sets
schedules, requests, and Group level guidance to the
Group companies and organises regular sustainability
meetings.
At each Group company, various business areas,
operational departments, and functions are actively
involved in the Group’s sustainability endeavours and
reporting. Group level sustainability reporting is largely
based on information provided by the Group companies
according to formats and schedules defined by Sampo
plc’s Sustainability function. Each Group company is
responsible for its respective reporting to the parent
company to ensure correctness of information.
Sampo Group’s Sustainability Statement is published
annually as a part of the Board of Directors’ Report.
Risk management
The Board of Directors of Sampo plc is responsible for
ensuring that the Group’s risks are properly managed
and controlled. The Board establishes both the risk
management principles and closely connected
remuneration principles and provides guidance on the
risk management governance structure and internal
control in the business areas. Working within the
framework of these principles and guidelines, the Group
companies tailor their risk management practices to
take account of the special features of their respective
business activities. The Board makes decisions on
strategy, return targets, and overall guidelines
regarding capital management.
The Board’s Audit Committee is responsible, on behalf
of the Board of Directors, for preparing Sampo Group’s
Risk Management Principles and related guidelines and,
in turn, the Nomination and Remuneration Committee is
responsible for preparing the Group’s Remuneration
Principles, which are closely connected with the Risk
Management Principles.
The duty of Sampo Group’s Risk Management function
is to control the effective operation of the risk
management system within the Group companies and
to monitor, review, and report on Group level risks and
risk management, including the parent company.
Risk management system
High-quality, comprehensive risk management
facilitates that Sampo plc’s executive management and
Board of Directors are constantly aware of the Group
companies’ business-related risks and their ability to
carry the financial and other risks related to business
activities.
Sampo Group’s business activities and therefore also
their corresponding risk management activities are
mainly performed in the Group’s insurance and
investment operations.
Sampo Group’s risk management system is based on
the Risk Management Principles established by the
parent company. Sampo’s business areas and insurance
entities organise their risk management activities based
on these Group level principles taking into account the
business-specific characteristics as well as local laws
and regulations.
To meet the key objectives of Sampo’s risk
management, the risk management system includes
governance structure and authorisations and a clear
division of responsibilities between business lines and
independent functions. The insurance entities in the
Group shall have prudent valuation, risk measurement
and reporting procedures, in line with the companies’
more detailed risk policies and instructions related to
risk management.
Sampo Group’s steering framework
Parent company’s guidance
The Group’s parent company steers its insurance
businesses by setting targets for their underwriting
performance and operating efficiency and by defining
the main preconditions for their operations in the form
of the group-wide principles. The parent company
assesses the adequate level of capitalisation and the
suitability of the capital structure on both Group level
and insurance entity level.
Parent company’s oversight and activities
Sampo’s risk appetite defines the boundaries for what
risk the Group is willing to accept in the pursuit of its
objectives. Sampo reviews the performance of its
business areas continuously and based on both the
Group and business area level information, the Board of
BOARD OF DIRECTORS’ REPORT 2024
50
Directors of Sampo decides on the Group’s balance
sheet targets and the parent company’s liquidity
reserve.
Activities and risk management in the business areas
Sampo’s business areas and insurance entities organise
their business activities to implement strategic
decisions made by Sampo. They make decisions on
specific risk-taking policies, capitalisation, risk limits and
the delegation of authorisations considering the specific
characteristics of their operations, within the framework
provided by approved Sampo Guidelines or otherwise
binding decisions by Sampo’s Board of Directors. The
business operations are monitored by the different
governing bodies and ultimately by the Boards of
Directors whose members are mainly in senior
management positions in Sampo or in Sampo Group
companies. The subsidiaries’ line organisations are in
charge of pricing their products and services and
organising their sales and implementation processes, for
ensuring the profitability, efficiency, quality, security,
and continuity of their operations as well as the liability
towards the clients. They are also responsible for the
management of assets and liabilities and capitalisation
on the insurance entity level.
Risk management consists of these continuous activities
that are the responsibility of the personnel involved in
business activities and being supported and controlled
by independent risk management specialists. Parties
independent of business activities provide
complementary expertise, support, monitoring, and
challenge related to the management of risk. This
includes the development, implementation, and
continuous improvement of risk management practices
at a process, system, and entity level. Although the
responsibilities of business lines and independent risk
management are clearly segregated in Sampo Group,
these functions are in continuous dialogue with each
other. Sampo Group has defined the roles and
responsibilities of different internal stakeholders in the
Internal Control Policy, which applies on a group-wide
basis.
Risk management process
The tasks included in the risk management process
include the following:
Measuring and reporting of risks, capital, and earnings:
Financial and risk management functions are explicitly
responsible for preparing the above prerequisites for
risk management and operationally they are responsible
for independent measurement and control, including
monitoring of operations in general as well as
profitability, risk, and capitalisation calculations.
Continuous analysis of opportunities and risks:
Business units and financial and risk management
functions are both active in supporting the business
with continuous analysis and assessment of
opportunities. The insurance and investment business
units assess business opportunities, especially their risk
return ratios, on a daily basis. In the financial and risk
management functions, on the other hand, a
considerable amount of time is spent on risk analysis
and reporting as well as capital planning.
Actions: Transactions representing the actual insurance
and investment operations are performed in
accordance with the given authorisations, risk policies,
and other instructions. These actions are the
responsibility of business and investment functions.
Activities related to capitalisation and liquidity positions
are included in this part of the process.
In Sampo Group, proactive profitability, risk, and capital
management actions are seen as the most important
phase in the risk and capital management processes.
Hence, risk policies, limits, and decision-making
authorisations are set up in a way that they, together
with profitability targets, facilitate business and
investment units to take carefully considered risks.
High-quality execution of the above-mentioned tasks
contributes to the achievement of the key objectives of
risk management:
1. Balance between risks, capital, and earnings:
• Risks affecting the profitability as well as other
material risks are identified, assessed, and analysed.
• Underwriting risks are priced reflecting their inherent
risk levels, expected returns of investment activities
are in balance with their risks, and consequential risks
are mitigated sufficiently.
• Capitalisation is managed in order to be adequate in
terms of current risks inherent in business activities
and business risks, taking into account the expected
profitability of the businesses.
• Risk-bearing capacity is allocated into different
business areas in accordance with the strategy.
2. Cost-efficient and high-quality processes:
• Client service processes and internal operational
processes are cost efficient, sufficiently secured and
of high quality.
• Continuity of operations is ensured and in case of
discontinuity events, recovery is fast and
comprehensive.
• Decision-making is based on accurate, adequate, and
timely information.
BOARD OF DIRECTORS’ REPORT 2024
51
3. Strategic and operational flexibility:
• External risk drivers and potential risks are identified
and assessed, and the company is in good position, in
terms of capital structure and management skills, to
react to changes in business environment.
• Corporate structure, knowledge, skills, and processes
in companies facilitate effective implementation of
changes in the business environment.
When the above targets are met, risk management is
contributing positively to return on equity and
mitigating the yearly fluctuations in profitability.
Risk management reporting and governance
framework
Sampo’s profits, risks, and capital are reported to
Sampo plc’s Board of Directors at least quarterly. In
addition to regular risk reports, Group CRO may ask
Group companies to prepare an analysis/review on
subjects that need special attention and in case of a
severe incident, companies shall inform Sampo plc
according to the defined process.
Sampo plc’s Board of Directors and the Audit
Committee, together with the boards of directors of the
Group companies, share the overall responsibility for
the Group’s risk management system. The business
units are responsible for day-to-day risk management
decisions within the framework of the provided
principles, guidelines, and authorisations (limits). The
Sampo Group Risk Committee ensures effective
communication and cooperation regarding risk
management and risk reporting within Sampo Group.
The Group Internal Model Committee is an advisory and
preparatory body to the Board of Directors and the
CEO of Sampo plc as well as for all Group companies’
Boards of Directors and CEOs using the Group Internal
Model to calculate the Solvency Capital Requirement.
In addition to these, Sampo has established a Sampo
Group Reinsurance Committee, whose purpose is to
discuss reinsurance related topics across various group
companies and align interest on group level on
reinsurance strategy and purchasing.
The risks in If and Hastings are monitored also by their
Risk Committees.
Risk management governance framework
in Sampo Group
25_3_1_Risk_management_governance_framework.svg
More detailed information on Sampo’s risk management
is available in Sampo Group’s Solvency and Financial
Condition Report 2024 which will be disclosed in May
2025 at www.sampo.com/year2024.
BOARD OF DIRECTORS’ REPORT 2024
52
Compliance
In Sampo Group, compliance is an activity supporting
business activities while being independently
administered, ensuring the compatibility with applicable
norms of all Group activities.
The starting point of the Sampo Group Compliance
Principles is that compliance with norms is an
established part of Sampo plc’s corporate culture. The
principles ensure that compliance activities are properly
organised in Group companies, and that the business
organisation is capable of responding to the changing
requirements of the business environment. The
guidance contains the perceived common
denominators of successful compliance activity – a set
of general principles that describe essential features of
effective compliance activities within the context of the
business environment in which Sampo Group
companies are operating. The principles do not,
however, limit the flexibility of each Group company
when addressing its own specific needs in relation to
compliance.
Sampo Group Compliance Principles apply to all Sampo
Group companies. It should, however, be noted that
Sampo Group companies operate in several different
jurisdictions, thus being under an obligation to abide
with local legislation as well as authority rules and
regulations. Consequently, the principles have been
defined to facilitate the deployment of a set of tools
and procedures serving best the individual needs for
each company and local operating environment, and to
ensure full compliance without jeopardising operational
efficiency. The aforesaid obviously implies that the
compliance function in each Group company must
always meet the local standards and other
requirements.
According to the approved principles all compliance
activity is designed to ensure that all business activities,
as well as the reporting of financial results and risks, are
at all times compliant with laws, authority regulations,
and internal guidelines and principles.
The compliance function also ensures that any
applicable new legislation and regulation is fully
enforced in Group companies’ guidelines and day-to-
day business activities.
According to the principles, the Group companies are
permitted to organise their compliance activities
operationally and organisationally as they deem
pertinent and effective within the framework of
applicable legislation.
Reporting of compliance activities is organised in each
Group company as deemed appropriate and sufficient
locally. Compliance matters are also regularly reported
to the parent company’s Board of Directors’ Audit
Committee, as determined in the Sampo Group
Compliance Principles. Sampo plc’s Compliance
function is responsible for overseeing the compiling of
these reports on the basis of the subgroup specific
reports provided by the Group companies.
The CEO of Sampo Group is responsible for the proper
organisation of the compliance function in the Group.
The Board of Directors of each Group company ensures
that the Group company has sufficient resources to
organise effective internal control and compliance,
while each Group company’s Managing Director is
responsible for arranging the respective Group
company’s compliance function.
BOARD OF DIRECTORS’ REPORT 2024
53
Insider administration
Given the nature of Sampo Group’s business areas,
especially bearing in mind the extensive investment
activities of Sampo Group companies, Sampo plc’s
Board of Directors has approved separate Guidelines
for Insiders that is binding on all persons employed by
Sampo Group as well as on members of Sampo plc’s
Board of Directors. In addition to current supranational
law, such as the Market Abuse Regulation (Regulation
(EU) No 596/2014 of the European Parliament and of
the Council (“MAR”)), applicable national law, including
Nasdaq Helsinki’s Guidelines for Insiders and the
Financial Supervisory Authority’s regulations, as well as
statements and interpretations, have been taken into
account in compiling the Guidelines for Insiders.
The Group Executive Committee, all Sampo plc’s
employees and other Group’s employees working with
interim statements and other financial announcements,
and other persons who have access to such documents
before publication thereof are under the following
restrictions on trading:
• persons must not conduct any transactions relating to
the financial instruments of Sampo Group during a
closed window of 30 calendar days before the
announcement of financial reports (so called
extended closed window)
• persons are prohibited from having so called short-
term positions in Sampo A shares (including
depositary receipts and share entitlements), which
refers to a situation where the period between the
acquisition and disposal or the disposal and the
acquisition of the shares is less than one month
• Group Executive Committee members and their
closely associated persons must request for prior
permission before trading in Sampo Group’s financial
instruments or in other separately defined financial
instruments.
In addition to regulatory supervision, compliance with
the obligations under the Guidelines for Insiders and the
underlying legislation is supervised by the Insider
Administration, which is a group function centralised in
Sampo plc and led by the person in charge of insider
matters.
Sampo Group’s Guidelines for Insiders is available at
www.sampo.com/insiders.
Whistleblowing
Sampo plc has a whistleblowing channel, which is based
on the MAR.
In connection with the entering into force of the MAR,
Sampo plc adopted an internal procedure for all
employees to report infringements of both internal and
external rules and regulations. All whistleblowing
notifications are investigated promptly in a confidential
manner while protecting the identity of the
whistleblower as far as possible. During 2024, no
whistleblowing notifications were reported.
Sampo Group companies have established their own
whistleblowing channels designed to serve their
personnel and relevant interest groups.
Principles for related party
transactions
Sampo Group companies may not, as a general rule,
enter into an agreement with related parties subject to
terms and conditions that differ from those Sampo plc
or its Group companies normally apply, or other
agreements that are not commercially justified, with or
for the benefit of certain individuals. All related party
transactions shall be based on written agreements in
accordance with the relevant local regulation and in the
ordinary course of business and on arm’s length terms.
Related party transactions in Sampo Group are
traditionally purchases of internal services, or other
services or products that are part of the ordinary
business of a Group company.
Sampo Group’s guidelines on related party transactions
apply to all Group companies and they set the group-
wide principles for monitoring and assessing as well as
decision-making and reporting of related party
transactions. The rules for the company level
identification, decision-making, and reporting processes
are set in the company level policies of each Group
company, as approved by the Board of Directors of
each Group company.
Related party transactions that are not part of the
company’s ordinary course of business or are made in
deviation from customary commercial terms, require a
decision of Sampo plc’s Board of Directors to carry out
the related party transaction. Such related party
transactions shall be reported to the Group Compliance
prior to entering into the transaction.
Each Sampo subgroup shall maintain a register of the
related parties linked to the company within Sampo
Group by close links and the reported related party
transactions. An accumulated list concerning the
agreements of the related parties of Sampo plc is sent
to Sampo plc’s Board of Directors or its committee
annually. The Board of Directors or its committee must
monitor and assess how agreements and other legal
acts between the company and its related parties meet
the requirements of ordinary activities and arm’s length
terms.
Additionally, in accordance with the Solvency II
regulation, Sampo Group companies must report all
significant related party transactions to the relevant
supervisory authorities.
BOARD OF DIRECTORS’ REPORT 2024
54
Internal audit
Internal Audit is a function independent of business
operations, which evaluates the efficiency and
effectiveness as well as the maturity of the internal
control system within Sampo Group. The function helps
the organisation to accomplish its objectives by a
systematic, disciplined approach to evaluate and
improve the effectiveness of the risk management,
control, and governance processes. The Group function
is organised under the Board of Directors of Sampo plc
and it reports to Sampo plc’s Board and Audit
Committee. It is managed by the Group Chief Audit
Executive, who is appointed by the Board of Directors
of Sampo plc. Internal audit functions are established in
each subgroup and legal entity as regulations demand
and approved by the respective Board of Directors or
equivalent.
The work is carried out in accordance with the Sampo
Group Internal Audit Policy, approved by the board of
directors of each Group company. According to the
Policy, the Internal Audit applies the mandatory
guidance of the Institute of Internal Auditors as
applicable.
The Internal Audit establishes an internal audit plan for
the regulated companies. A period for the audit plan
may be defined in the subgroups. The plans are
updated annually and approved by the board of
directors in the respective legal entity. The plans of the
subgroups are presented for Sampo plc’s Audit
Committee’s information. The approach is risk based
and it considers the focus areas of the business
operations. The External Audit is informed about the
internal audit plans.
The Internal Audit function reports on the audits and
follow-up activities performed to the Board of Directors
of the legal entities, and to Sampo plc’s Audit
Committee. Company-specific audit observations are
reported to the respective companies’ management.
Furthermore, the function submits audit reports to
Sampo plc’s Audit Committee and the Board of
Directors in all regulated entities at least twice a year.
These reports include any significant deficiencies
detected, including follow-up issues related to the risks
not been mitigated or remedied according to the
agreed action plans. In addition, an annual internal audit
report is issued for Sampo Group.
The Group Chief Audit Executive is responsible for
ensuring that a quality assurance and improvement
programme is established in the internal audit functions.
The results are reported to Sampo plc’s Audit
Committee.
External auditor
• Deloitte Ltd
Authorised Public Accountant Firm
• Jukka Vattulainen, APA ASA
Principally responsible auditor and sustainability
reporting assurer
Audit firm Deloitte has acted as Sampo plc’s as well as If
Group’s, Topdanmark’s and Hastings Group’s Auditor in
2024. Deloitte was elected as Topdanmark’s Auditor in
2024.
The fees paid by Sampo Group companies to audit firm
Deloitte for statutory audit services in 2024 totalled
approximately EUR 4,322,000. In addition, Sampo
Group companies paid audit firm Deloitte a total of
approximately EUR 712,000 in fees for non-audit
services, which is at most 16.5 per cent of the fees paid
by Sampo Group companies to audit firm Deloitte for
statutory audit services.
The fees paid by Sampo plc to Deloitte Ltd for statutory
audit services invoiced in 2024 totalled approximately
EUR 450,000 and approximately EUR 137,000 for
sustainability reporting assurance. In addition, Sampo
plc paid Deloitte Ltd a total of approximately EUR
204,000 in fees for non-audit services.
Sampo plc’s AGM held on 25 April 2024 elected
Deloitte Ltd to act as Sampo plc’s Auditor with APA
ASA Jukka Vattulainen as the auditor and sustainability
reporting assurer with principal responsibility. APA ASA
Jukka Vattulainen has acted as Sampo plc’s principally
responsible auditor since May 2021.
BOARD OF DIRECTORS’ REPORT 2024
55
Sustainability Statement
General information ................................................
Basis for preparation ................................................
Governance .................................................................
Strategy ........................................................................
Environmental information ...................................
EU Taxonomy .............................................................
Underwriting activities .......................................
Investment activities ...........................................
Climate change ..........................................................
Strategy ...................................................................
Impact, risk, and opportunity
management ..........................................................
Metrics and targets .............................................
Impact, risk, and opportunity
management .........................................................
Metrics and targets .............................................
Social information ....................................................
Own workforce ...........................................................
Strategy ...................................................................
Impact, risk, and opportunity
management ..........................................................
Metrics and targets .............................................
Workers in the value chain ....................................
Strategy ...................................................................
Impact, risk, and opportunity
management ..........................................................
Metrics and targets .............................................
Consumers and end-users ......................................
Strategy ...................................................................
Impact, risk, and opportunity
management ..........................................................
Metrics and targets .............................................
Governance information ........................................
Business conduct ......................................................
Impact, risk, and opportunity
management ..........................................................
Metrics and targets .............................................
Annexes ........................................................................
BOARD OF DIRECTORS’ REPORT 2024
56
General information
Basis for preparation
General basis for preparation of the
sustainability statement
This Sampo Group Sustainability Statement 2024 has
been prepared in accordance with the EU’s Corporate
Sustainability Reporting Directive (CSRD) and the
related European Sustainability Reporting Standards
(ESRS). The Statement covers Sampo plc (Sampo) and
its subsidiaries If P&C Insurance Holding Ltd (publ) (If),
including Topdanmark A/S (Topdanmark), and Hastings
Group (Consolidated) Ltd (Hastings). The consolidation
principles used in the Sustainability Statement follow
those used in Sampo Group’s financial reporting. The
Statement includes Sampo Group’s own operations as
well as upstream and downstream value chain as
described under the heading Strategy, business model
and value chain (p. 61).
Sampo Group has not used the option to omit a specific
piece of information corresponding to intellectual
property, know-how, or the results of innovation.
Neither has Sampo Group used the exemption as
provided for in articles 19a(3) and 29a(3) of Directive
2013/34/EU.
In accordance with ESRS 1 appendix C, Sampo Group
has used the phase-in options that may be used by all
reporting undertakings in the sustainability reporting for
2024.
Sampo Group has not marked this Sustainability
Statement with digital XBRL sustainability tags in
accordance with Chapter 7, Section 22 (1) (2) of the
Accounting Act, as it has not been possible to comply
with the provision due to the absence of the ESEF
Regulation or other European Union (EU) legislation.
The comparative information (figures for the year 2023)
reported in the Sustainability Statement related to the
EU Taxonomy disclosures and greenhouse gas (GHG)
emissions have not been assured by the assurance
provider of this Sustainability Statement.
Disclosures in relation to specific
circumstances
Sampo Group reports the disclosures in relation to
specific circumstances (e.g. sources of estimation,
outcome uncertainty) alongside the disclosures to
which they refer (e.g. in the calculation principles of the
respective metric), when applicable.
Governance
The role of the administrative, management,
and supervisory bodies
Composition and diversity
Sampo Group’s administrative, management and
supervisory bodies consists of nine non-executive board
members and the Group Chief Executive Officer (CEO).
Sampo’s Board of Directors does not have employee
representatives. All Board members have been
determined to be independent of the company and its
major shareholders under the rules of the Finnish
Corporate Governance Code 2025.
Sampo’s Board Diversity Policy, which was updated in
November 2024, aims to ensure that Sampo’s Board of
Directors embodies a well-balanced mix of knowledge,
skills, diversity, and experience, fully in line with Sampo
Group’s values and Code of Conduct. Board members
should have professional experience and education
relevant and appropriate to Sampo’s scale and scope,
including financial expertise, industry knowledge,
international experience, risk management and strategic
planning expertise, and governance and leadership
skills. Diversity is key, with consideration given to at
least age, gender, geographical provenance, and
educational and professional background. Further, each
Board member is expected to devote sufficient time to
the Board’s work, and the Board as a whole shall fulfil
the independence recommendations of the Corporate
Governance Code.
BOARD OF DIRECTORS’ REPORT 2024
57
To promote gender balance, both genders shall always
be represented on the Board, with a target that women
and men both shall be represented by at least 40 per
cent of the members of the Board. However, some
deviations may be applied if deemed reasonable due to
the number of Board members. The number of the
Directors and the composition of the Board shall be
such that they enable the Board of Directors to perform
its duties efficiently. During the past ten years, Sampo’s
Board of Directors has on average reached its target for
gender diversity and the Board continues its efforts to
reach the new minimum share of at least 40 per cent of
the total number of members for both genders. As at 31
December 2024, the share of women on Sampo’s Board
of Directors was 33.3 per cent and the share of men was
66.7 per cent.
Roles and responsibilities
Sampo’s Board of Directors is responsible for and has
the ultimate oversight of group level sustainability,
containing the entire range of environmental, social, and
governance (ESG) matters. The board has assigned its
Audit Committee to monitor Sampo Group’s
sustainability reporting and activities, such as reporting
in accordance with the CSRD, the double materiality
assessment, and Sampo Group’s sustainability
programme. Both the regulatory sustainability reporting
and the Group sustainability programme enable the
Board and the top management to monitor overall
sustainability work and related targets. The annually
published sustainability statement, including the double
materiality assessment, and the annually updated
Sampo Group Code of Conduct are reviewed by the
Audit Committee and approved by the Board of
Directors.
Sampo’s Board of Directors elects and releases the
Group CEO and appoints the Sampo Group Executive
Committee (GEC). The Group CEO is in charge of the
daily management of Sampo. The GEC supports the
Group CEO in the preparation of strategic issues
relating to Sampo Group, in the handling of operational
matters that are significant or involve questions of
principle, and in ensuring a good internal flow of
information.
Sampo Group’s Chief Financial Officer (CFO), who is a
member of the GEC, directs Sampo’s Sustainability unit.
The CFO also ensures that adequate reporting on
sustainability matters is provided to the Group CEO.
Sampo’s Sustainability unit is responsible for the
development and coordination of sustainability at
group level. The Group CFO and the Sustainability unit
report to the Board of Directors and the Audit
Committee on material impacts, risks, and opportunities
and associated targets, when needed.
Skills and expertise
Sampo has identified materially important areas of
expertise which have to be sufficiently covered by the
Board members’ range of skills and experience. These
include business conduct, system of governance, and
material impacts, risks, and opportunities related to the
insurance industry. Sampo has a Board skills matrix,
which shows the materially important areas of
expertise, and the number and percentage of Board
members who have strong experience in each area
(self-assessment).
Non-financial experience has also been identified as a
materially important area of expertise in the Board skills
matrix. It is defined as the ability to interpret a
company’s non-financial information (including
information related to ESG matters), identify key issues,
set appropriate controls, and take necessary measures
based on this information. In addition to the existing
expertise, the Board of Directors has access to training
on the topics identified as important, as needed. The
Board members can also leverage knowledge, for
example, through other positions they hold. Training on
the CSRD was provided to Sampo’s Board members in
February 2024.
BOARD OF DIRECTORS’ REPORT 2024
58
Sustainability organisation and reporting structure
Sampo Group
25_3_1_Sustainability_organisation_and_reporting_structure.svg
Information provided to and sustainability
matters addressed by the undertaking’s
administrative, management, and
supervisory bodies
Sampo Group’s CFO and Sampo’s Head of
Sustainability report to the Board of Directors and the
Audit Committee on sustainability matters at least twice
a year, and more frequently when deemed necessary.
During 2024, sustainability as a standalone topic was on
the agenda at Board and/or Audit Committee meetings
every quarter. The impacts, risks, and opportunities
identified in Sampo Group’s double materiality
assessment were presented to the Board and its Audit
Committee in 2024 as part of regular Board reporting.
Going forward, the assessment will be reviewed
annually, as required by the legislation.
In addition to Sampo’s Sustainability unit, other units,
such as Compliance, Risk Management, Investment
Management and Operations, and Human Resources
(HR), provide regular reporting to the Board and/or its
committees and the Group Executive Committee. This
reporting may also include sustainability matters, as
sustainability is an integral part of operations. The
Board and its committees receive meeting materials
before each Board and/or committee meeting and have
time to provide feedback. During a meeting, a
presentation on the topic in question is provided before
a decision is made.
At Sampo Group, sustainability is seen as a business risk
driver, and sustainability-related risks are a part of
Sampo Group’s overall risk management. This means
that sustainability considerations have been
incorporated into overall business and business
practices (e.g. insurance and investment operations).
Sampo’s Board of Directors is responsible for ensuring
that the Group’s risks are properly managed and
controlled, while the Audit Committee prepares Sampo
Group’s risk management principles and other
BOARD OF DIRECTORS’ REPORT 2024
59
guidelines. Additionally, the Board of Directors oversees
material impacts and opportunities related to strategy
and major transactions together with the operative
management.
A list of the material sustainability topics addressed by
Sampo’s Board of Directors is presented in this
Sustainability Statement under the heading Material
impacts, risks, and opportunities, and their interaction
with strategy and business model (p. 66). In addition,
examples of topics addressed at the Board meetings in
2024 include annual policy updates (e.g. Sampo Group
Code of Conduct), regulatory development concerning
sustainability (e.g. CSRD), sustainability reporting (e.g.
climate-related work, EU Taxonomy, employee
engagement, customer satisfaction), internal control,
and regular compliance/governance/risk reporting.
Integration of sustainability-related
performance in incentive schemes
Sampo's Board of Directors resolves all group level
remuneration matters. The Nomination and
Remuneration Committee supports the Board of
Directors by preparing the proposals to the Board on
the remuneration of the GEC members, Sampo Group's
long-term incentive schemes (LTIs), maximum pay-outs
based on short-term incentive programmes (STIs), as
well as the actual payments to be made to the members
of the GEC.
Sampo’s Remuneration Policy for Governing Bodies
states that the performance measures of the STIs and
LTIs of the Group CEO may include, for example,
shareholder value creation, financial or operative key
performance indicators (KPIs), and sustainability
performance criteria. The Board members are
independent of the companies and do not participate in
variable compensation programmes.
At Sampo Group, variable compensation is used to
ensure the competitiveness of the total remuneration
package and can be either short-term or long-term.
Sampo’s Board of Directors decides on one-year STI
programmes separately each year and on cash pay-outs
from the programmes in the following year. The Group
CEO participates in a one-year STI programme, where
the payout is triggered by an underlying performance
criterion and the outcome is determined on the basis of
key financial and non-financial performance criteria
related to Sampo Group and its subsidiaries. The
maximum amount that can be paid to the Group CEO
from the 2024 programme corresponds to 12 months'
fixed salary. Part of the payout shall be deferred for at
least three years as required in the regulatory
framework applicable to Sampo.
The Group CEO also participates in the LTI scheme
2024 for Sampo Group’s key employees. The Group
CEO has been allocated 37,909 performance incentive
units with a value equivalent to 150 per cent of his
annual base salary at the time of allocation. The number
of performance incentive units that will vest ranges
from 0–37,909 and is dependent on performance
criteria related to the development of the total
shareholder return, operational performance, and
sustainability. In addition, the performance incentive
units are subject to Sampo A share price movements
over the performance period. The scheme has a three-
year performance period and at pay-out from the 2024
scheme, the Group CEO is obliged to purchase Sampo
A shares with 50 per cent of the pay-out after
deducting income tax and other comparable charges.
The shares are subject to disposal restrictions for three
years, after which the Board of Directors shall decide on
the possible release.
Sustainability performance criteria
In 2024, 10 per cent of the reward from the STI
programme was subject to work related to
sustainability. The sustainability performance criterion
of the STI was the submission of the group level
science-based climate targets (SBTs) to the Science
Based Targets initiative (SBTi) for validation. Also, 10
per cent of the reward from the LTI scheme 2024 is
subject to the performance of Sampo Group’s work
related to sustainability. The sustainability performance
criterion consists of Group and subsidiary balanced
scorecards relating to the development,
implementation, and execution of the SBTs.
In addition to the above mentioned criteria, Sampo
Group did not factor further GHG emission reduction
targets into remuneration in 2024.
Statement on due diligence
The main aspects and steps of Sampo Group’s due
diligence process are described under the applicable
disclosure requirements in this Sustainability Statement.
The table Mapping of the main aspects and steps of the
due diligence process (p. 60) lists the reported
information.
 
BOARD OF DIRECTORS’ REPORT 2024
60
Mapping of the main aspects and steps of the due diligence process
Sampo Group
Core elements of
due diligence
Paragraphs in the Sustainability Statement
General disclosures and Governance information
Environmental information
Social information
Embedding due
diligence in
governance,
strategy, and
business model
• How sustainability matters are addressed in Sampo
Group's management ( p. 58)
• STIs, LTIs, and the ESG criteria included in
remuneration (p. 59)
• Material impacts, risks, and opportunities (IROs), and
their linkage to the Group's strategy and business
model (p. 66)
• Material IROs in relation to Business conduct (p. 115)
• STIs, LTIs and the ESG criteria-related to science-
based targets ( p. 59)
• Material IROs in relation to climate change (p. 77) and
resource use and circular economy (p. 87)
• Material IROs in relation to own workforce (p. 90),
workers in the value chain (p. 102) and consumers
and end-users (p. 107)
Engaging with
affected
stakeholders in
all key steps of
the due diligence
• How sustainability matters are addressed in Sampo
Group's management (p. 58)
• How interests and views of stakeholders are taken
into account in the Group’s strategy and business
model (p. 64)
• How the process to identify IROs and assessing
materiality is informed by the due diligence process
and includes consultation with affected stakeholders
(p. 68)
• Policies related to business conduct and corporate
culture (p. 116)
• Process to identify and assess IROs related to climate
change and resource use and circular economy,
including how affected stakeholders have been
considered (p. 68)
• Policies related to climate change (p. 80) and
resource use and circular economy (p. 88)
• How interests and views of own workforce, workers
in the value chain, and consumers and end-users are
taken into account in strategy and business model
(p. 64)
• Policies related to own workforce (p. 91), workers in
the value chain (p. 103), and consumers and end-
users (p. 108)
• Processes for engaging with own workforce (p. 92),
workers in the value chain (p. 104), and consumers
and end-users (p. 109), including grievance
mechanisms and remediation of negative impacts
Identifying and
assessing
adverse impacts
• Description of the double materiality assessment,
including specific information on the process to
identify and assess governance-related negative
impacts ( p. 68)
• Identified material IROs, as well as how negative
impacts interact with strategy and business model
(p. 66)
• Description of the double materiality assessment,
including additional description of the process to
identify and assess climate and circular economy-
related negative impacts ( p. 68)
• How negative impacts related to climate change
interact with strategy and business model as well as
additional information about climate-related risks
(p. 78)
• Description of the double materiality assessment
(p. 68)
• How negative impacts related to own workforce
(p. 91), workers in the value chain (p. 103), and
consumers and end-users (p. 108) interact with
strategy and business model
Taking actions to
address those
adverse impacts
• Management of supplier relationships and prevention
and detection of corruption and bribery (p. 116)
• Actions and resources related to climate change
(p. 80) and resource use and circular economy
(p. 88)
• Transition plan for climate change mitigation (p. 79)
• Actions and resources related to own workforce
(p. 93), workers in the value chain (p. 105), and
consumers and end-users (p. 111)
Tracking the
effectiveness of
these efforts and
communicating
• Metrics and targets related to business conduct
(p. 118)
• Metrics and targets related to climate change (p. 82)
and resource use and circular economy (p. 89)
• Metrics and targets related to own workforce (p. 95),
workers in the value chain (p. 106), and consumers
and end-users ( p. 112)
BOARD OF DIRECTORS’ REPORT 2024
61
Risk management and internal controls over
sustainability reporting
Sampo Group’s risk management and internal control
system in relation to the sustainability reporting process
are a part of Sampo Group’s overall risk management.
As part of Sampo Group's internal control framework,
the Group companies have comprehensive risk
management procedures in place to ensure the
functioning of the reporting process, including
sustainability reporting. Risk management procedures
include risk identification, assessment, measurement,
monitoring, and reporting.
Sampo Group identifies and assesses risks related to
operations on a regular basis. The process takes into
account the causes and consequences of the risks and
the existing controls. In addition to assessing the
likelihood and impact of the risk realisation, Sampo
Group assesses the need for possible additional
measures. Based on the assessment, the risks are
arranged in the order of their significance.
Risks related to the sustainability reporting process are
mainly linked to ensuring the accuracy and
completeness of the information. Sampo Group controls
these risks, for example, through internal guidelines,
well-defined responsibilities, the use of the four-eyes
principle, and other controls.
During the risk identification and assessment, an owner
is appointed for all identified risks. The owner is
responsible for taking action and developing measures
in relevant internal functions based on the findings.
The most significant risks and related mitigation
measures are regularly discussed, for example, in the
Group’s risk committees. Chief Risk Officers (CROs)
report risks to the respective senior management and
the Board of Directors.
Strategy
Strategy, business model, and value chain
Sampo Group’s strategy focuses on P&C insurance;
investing in and developing its P&C insurance
operations across the Nordic countries, the UK, and the
Baltics. The strategy is based on disciplined
underwriting, strong operational capabilities, and
customer centricity. Combined with careful risk
management, this enables Sampo Group to deliver
attractive margins and strong financial resilience, both
of which Sampo considers essential to value creation.
Sampo Group’s insurance operations are conducted
through If, Topdanmark (which is to be merged with If),
and Hastings. The subsidiaries are responsible for
pricing their products and services, organising their
sales and implementation processes, ensuring the
profitability, efficiency, quality, security, and continuity
of their operations, as well as for liabilities towards their
customers. The subsidiaries are also responsible for the
management of assets and liabilities, risks, and
capitalisation on the business area and company level.
Sampo Group provides safety to customers through its
high-quality P&C insurance products. Safety is enabled
by a detailed understanding of various risks that Sampo
Group underwrites. By pooling risks, Sampo Group
balances the various risks of the customer base and
provides insurance coverage for events that can be
complex for customers to prepare for without P&C
insurance products.
Sampo Group accomplishes the safety and value
creation through its teams of employed professionals
and through cooperation with suppliers and other
business partners. The value created for customers
flows to fair compensation to Sampo Group's
employees and suppliers, and shareholders. This safety
also benefits society at large, enabling other sectors to
continue creating value through their value chains,
which are insured for perils with Sampo Group’s P&C
insurance solutions.
Sampo Group’s activities are divided into own
operations, and an upstream and downstream value
chain. The Group’s own operations are focused on P&C
insurance operations, with an emphasis on underwriting
and managing risk, customer support, and investment
operations. Sampo Group’s upstream value chain
includes suppliers of office products and services (e.g.
ICT suppliers and external data providers) who support
the running of the business. In the downstream value
chain, Sampo Group has a large network of suppliers
and business partners, of which suppliers in claims
handling and loss prevention (e.g. vehicle and property
repair contractors), and partners in health and travel
services form a major part. The main features of Sampo
Group’s value chain are described in the figure Value
chain (p. 62).
BOARD OF DIRECTORS’ REPORT 2024
62
Value chain
Sampo Group
25_29_1_Value chain.svg
Significant groups of products, services and markets
Sampo Group’s largest customer group is private
individuals. The largest product segments for private
individuals are motor and home insurance, but Sampo
Group also offers other insurance covers, such as travel
insurance and personal accident covers. Sampo Group’s
second largest business area is commercial insurance.
While property and motor insurance risks dominate in
the commercial business area, certain liability covers are
also prominent. In addition, Sampo Group is a leading
provider of industrial lines P&C insurance in the Nordic
region through If. In the United Kingdom (UK) P&C
insurance market, Sampo Group operates through the
digital insurer Hastings, which is one of the largest retail
motor insurance providers in the UK and a challenger in
the home insurance market with a fast-growing
customer base.
Sampo Group’s operations are diversified by
geography, line of business, and customer group. The
Group’s main operating countries are Finland, Sweden,
Norway, Denmark, the UK, and the Baltic countries.
As at 31 December 2024, Sampo Group’s total
employee headcount was 15,581. The number of
employees by geographical areas is presented under
the disclosures related to own workforce (p. 96).
Sampo Group’s insurance revenue totalled EUR 9,450
million in 2024. For more information on the breakdown
of revenue in accordance with operating segments, see
Result by segment for twelve months ended 31
December 2024 in the Financial Statements.
BOARD OF DIRECTORS’ REPORT 2024
63
Sustainability programme
Sampo Group
Sustainability programme_13-02-2025.svg
Integration of sustainability into business
Sampo Group integrates sustainability into its core
business. In terms of insurance operations this means,
for example, that Sampo Group takes ESG
considerations into account in underwriting (e.g. sets
expectations for corporate clients to respect
international norms and standards as defined by the UN
Global Compact, integrates sustainability into
underwriting principles and/or other relevant policies),
provides loss prevention services (e.g. risk management
services), handles claims in a sustainable way, and
develops products and services in accordance with
relevant legal requirements (e.g. the EU Taxonomy).
Sampo Group’s sustainability-related goals apply to all
Group operations rather than to specific customer
groups and markets.
Sampo Group has a sustainability programme, which
drives group level sustainability work. The programme
consists of three strategic sustainability themes: Climate
and environment, People and communities, and
Business management and practices, which are in turn
divided into more specific topics relevant for the
Group’s sustainability work. The group level programme
is put into practice by the Sampo Group companies and
the work is monitored continuously.
Sampo Group has set general objectives for each
sustainability theme. Additionally, metrics and targets
are in place to monitor the progress in more detail.
Performance against the set targets is presented, for
example, in this Sustainability Statement. Science-based
climate targets are disclosed under the Climate change
standard, employee engagement is covered under the
Own workforce standard, customer satisfaction falls
under the Consumers and end-users standard, and
metrics related to supplier codes of conduct can be
found under the Workers in the value chain standard.
Compliance with internal policies and guidelines is
BOARD OF DIRECTORS’ REPORT 2024
64
discussed under multiple standards, as many of them
focus on describing material policies and guidelines.
In 2024, Sampo Group’s sustainability programme was
reshaped to better address the regulatory demands,
while also including areas that are critical especially for
a company operating in the P&C insurance sector. In
addition, the selected topics link to Sampo Group’s
overall business and strategy and are important to the
Group’s various stakeholders.
Interests and views of stakeholders
Sampo Group’s primary stakeholder groups are
customers, investors, employees, suppliers and other
business partners, investee companies, and local
communities. Each primary stakeholder group has
several subcategories as described in the table
Stakeholder engagement and dialogue (p. 65).
Sampo Group engages with all its stakeholder groups
through a number of forums and on multiple topics. The
intention is to engage in activities and dialogue that are
best aligned with the needs of Sampo Group and its
stakeholders. Sampo Group seeks to ensure meaningful
engagement with stakeholders, for example, by
identifying relevant stakeholders, ensuring continuous
and regular communication, and providing suitable
forums for dialogue.
The purpose of stakeholder engagement is to build
trust between Sampo Group and its stakeholders and to
seek common benefits. The stakeholder engagement
helps Sampo Group to proactively consider the needs
and wishes of its stakeholders. By focusing on
stakeholder engagement, Sampo Group can mitigate
potential risks, including uncertainty and dissatisfaction
of its key stakeholder groups. Stakeholder engagement
can help Sampo Group foster its reputation, trust, and
buy-in for the company’s key initiatives. In addition,
Sampo Group considers stakeholder engagement to be
a valuable source of information. The different
stakeholders are experts in their own fields and can
offer knowledge and expertise for the purposes of the
Group. When relevant, Sampo Group can also offer its
time and expertise to support the stakeholders.
As a result of the continuous dialogue, Sampo Group’s
key stakeholders support the Group’s chosen strategy
and business model. The views and interests of
stakeholders are considered, where possible, when
developing the strategy. As a result of stakeholder
engagement, Sampo Group aims to advance its
operations and relationship with stakeholders further.
Examples of actions taken include improved external
communications, customer service, and internal
reporting. Sampo Group’s Board of Directors is
informed about the views and interests of stakeholders
as part of regular reporting and when considered
necessary.
Engagement with own workforce, workers in the
value chain, and customers and end-users
The interests, views, and rights of Sampo Group’s own
workforce inform and support the company’s strategic
decisions. Sampo Group strives for a constructive,
trustful, and open dialogue with employees and their
elected representatives with the purpose of developing
the company and safeguarding the correct treatment of
all employees. Sampo Group recognises, for example,
the importance of workforce engagement, health,
safety, wellbeing, work-life balance, diversity, equity and
inclusion (DEI), and professional development.
Sampo Group indirectly engages with its value chain
workers on material topics through its suppliers,
investee companies and corporate customers. The
perspectives of value chain workers provide important
insights for identifying and understanding the Group’s
impacts on human rights and labour practices across its
activities and business relationships. Engagement with
value chain workers is integrated into daily business
operations, for example, through due diligence
processes.
For Sampo Group, the needs, preferences, and
wellbeing of consumers and end-users is a key input
informing strategy, and the Group’s business model is
primarily shaped based on the interests of its
customers. Sampo Group’s employees who develop and
deliver insurance products and services are constantly
monitoring and taking customers’ interests into
consideration. The recognition of the interests of
customers is complemented by the inputs and views of
Sampo Group’s employees, suppliers, and other
business partners in shaping the Group business model
and strategy.
BOARD OF DIRECTORS’ REPORT 2024
65
Stakeholder engagement and dialogue
Sampo Group
Key stakeholder group
Forum for dialogue and approximate frequency
Examples of discussion topics
Investors (current and potential shareholders and
debt investors)
• Annual General Meeting (AGM) (annual)
• Capital Markets Day (CMD) (annual or less frequent)
• Roadshows (quarterly)
• Seminars (quarterly)
• Virtual and face-to-face meetings (weekly)
• Financial performance and targets
• Strategy and Group structure
• Regulatory development
• Climate targets
• Executive remuneration
• Sustainability in general
Customers
• Regular customer contact points, e.g. website, chat, contact
centre (24/7 or daily)
• Customer feedback channels (24/7)
• Customer satisfaction surveys (24/7 or daily)
• Virtual and face-to-face meetings (daily)
• Customer Ombudsman (daily)
• Events (varying)
• Company publications, e.g. magazines (varying)
• Products and services
• Loss prevention and claims handling
• Sustainability in general
• Market situation in general
• Responsible business practices
Employees
• Employee engagement surveys (biannual/annual)
• Performance appraisals and dialogue with leaders (varying)
• Work environment committees (varying)
• Meetings with union and employee representatives (varying)
• Employee representation and consultation forums (varying)
• Employee roadshows (on a needs basis)
• Social events (varying)
• Financial performance
• Non-discrimination
• Diversity and inclusion
• Change in Group structure
• Employee engagement surveys
• Performance and development plans
• Sustainable workplace
Suppliers and other business partners (e.g.
analysts, rating agencies)
• Virtual and face-to-face meetings (daily)
• Events (varying)
• Company publications, e.g. magazines (varying)
• Financial performance
• Supply chain management (e.g. targets, performance,
sustainability considerations)
• Change in Group structure
• Future plans
• Products and services
Investee companies
• Virtual and face-to-face meetings (varying)
• AGMs of the investee companies (varying)
• Financial performance
• Market situation in general
• Regulatory development
• Sustainability in general
Local communities (e.g. regulators, supervisors,
industry associations, educational institutions,
NGOs, general public, the media)
• Virtual and face-to-face meetings (weekly)
• Events (varying)
• Company publications, e.g. magazines (varying)
• Financial performance
• Regulatory development
• Sustainability in general
• Climate change
BOARD OF DIRECTORS’ REPORT 2024
66
Material impacts, risks, and opportunities,
and their interaction with strategy and
business model
Sampo Group has conducted a double materiality
assessment as required by the CSRD. The results of the
assessment are presented in the figure Double
materiality matrix.
At Sampo Group, resilience to sustainability issues is
ensured by continuous adaptation of risk assessment
and pricing strategies to account for emerging
sustainability factors, thereby ensuring long-term
profitability and stability of the business. Adapting
strategy and business model according to sustainability
issues is critical for Sampo Group in terms of
maintaining customer confidence and reducing financial
risks, and the Group continuously invests in its people
and technology to ensure that it maintains its
competitive edge. Combined with careful risk
management, this enables Sampo Group to deliver
quality customer experience, attractive margins, and
strong financial resilience. Resilience towards material
impacts, risks, and opportunities is assessed as a part of
Sampo Group’s existing processes for sustainability
management, risk management, and strategy
development. For more information on how Sampo
Group’s strategy and business model interacts with
material impacts, risks, and opportunities, see the
Strategy section under each reported topical ESRS
standard.
Double materiality matrix
Sampo Group
25_3_1_Double materiality matrix.svg
BOARD OF DIRECTORS’ REPORT 2024
67
2024 is the first reporting year after conducting a
double materiality assessment, and as such Sampo
Group reports no changes to the material impacts, risks,
and opportunities compared to the previous year. All
the impacts, risks, and opportunities reported in the
Sustainability Statement 2024 are covered by the ESRS
disclosure requirements, as Sampo Group does not
include additional, entity-specific disclosures in the
statement. However, Sampo Group has introduced
entity-specific metrics to complement the disclosure
requirements related to the ESRS standards E5
Resource use and circular economy, S1 Own workforce,
S2 Workers in the value chain, and S4 Consumers and
end-users. Based on the identified risks and
opportunities in the double materiality assessment,
Sampo Group does not expect there to be material
adjustments within the next annual reporting period to
the carrying amounts of assets and liabilities reported in
the related financial statements.
A short summary of the material sustainability topics is
presented next. A more thorough specification of the
material topics, related impacts, risks, and opportunities,
as well as Sampo Group’s approach to managing them
is presented at the beginning of each topical ESRS
standard of this Sustainability Statement.
Climate change
The climate impact of Sampo Group’s own operations is
minor, as the direct GHG emissions are relatively low.
When considering the whole value chain, including
investments and suppliers, the negative impact of GHG
emissions is more significant. Sampo Group has
recognised both climate-related physical risks and
transition risks. Physical risks include more frequent and
severe natural disasters and changing
weather patterns, which can translate into increased
claims due to damages caused, for example, by storms
and floods. Transition risks, on the other hand, emerge
during the shift to a low-carbon economy. These risks
are driven by changes in the regulatory environment,
new technology, changing customer behaviour, and
increased interest in and concern for environmental
matters. There are also climate-related opportunities,
for example, in underwriting, and Sampo Group can
take advantage of the possibly increasing demand for
insurance products and services which provide
protection against physical risks and support climate
change adaptation.
Resource use and circular economy
Sampo Group uses resources in its business operations,
especially in claims handling. Resource use inherently
causes negative environmental impact, which Sampo
Group can mitigate by adopting and increasing circular
practices in product development and claims handling. 
Circular practices can also lead to cost reductions for
Sampo Group in the long-term due to reduced use of
virgin materials.
Own workforce
Sampo Group strives to create an engaging work
environment, which fosters creativity, innovation, and
wellbeing, promotes DEI, and encourages employees on
their career paths, thus creating positive social impact.
When employees feel like they belong in an
organisation, they are more likely to stay longer. Failing
to meet these expectations can lead to increased
employee turnover and difficulties in recruiting
competent workforce, which in turn can create a
financial risk.
Workers in the value chain
Sampo Group has an impact on workers in the value
chain especially through its downstream suppliers (e.g.
suppliers in claims operations), business partners,
corporate customers, and investees. The risk of
negative impacts related to labour practices and human
rights can be mitigated with strong policies and
governance structures, but they cannot be completely
eliminated. Due to increasing regulation and possible
reputational issues, negative impacts can also cause
financial risks.
Consumers and end-users
Through careful risk management and disciplined
underwriting, Sampo Group can have a positive impact
on consumers and end-users’ health and safety, which
provides business opportunities for the Group. Failing
to meet customer expectations related to topics such
as data privacy or sales practices can impact Sampo
Group’s customers negatively and, therefore, create
financial and reputational risks.
Business conduct
At Sampo Group, sustainable corporate governance
and solid business practices are seen as a baseline. By
promoting high standards related to topics such as anti-
corruption and bribery and risk management, Sampo
Group can contribute to the overall security of society.
 
BOARD OF DIRECTORS’ REPORT 2024
68
Impact, risk, and opportunity
management
Description of the process to identify and
assess material impacts, risks, and
opportunities
The purpose of Sampo Group’s double materiality
assessment was to identify sustainability matters, which
could trigger risks or opportunities that influence
Sampo Group’s ability to create and protect value
(financial materiality), as well as sustainability matters
related to Sampo Group’s business, which could have
positive or negative impacts on society, people, or the
environment (impact materiality). The double
materiality assessment served as a source for
identifying the information to be included in this
Sustainability Statement. The assessment was
conducted in collaboration with an external partner, and
the work and its results were presented to Sampo’s
Board and its Audit Committee during the project. The
methodology used in the double materiality assessment
follows the legislative requirements and supporting
guidance provided by the European Financial Reporting
Advisory Group (EFRAG).
The double materiality assessment started with
identifying an initial list of sustainability topics
potentially material for Sampo Group. The list was
compiled based on, for example, the ESRS standards,
GRI, SASB standard for the insurance sector, industry
benchmarking, media and megatrend analysis, Sampo
Group’s previous materiality assessment, ESG ratings
and reports, information on Sampo Group’s
investments, and investor meetings and feedback.
Representatives from Sustainability, Risk Management,
HR, Strategy, and Investor Relations functions
participated in identifying the impacts, risks, and
opportunities associated with the sustainability topics
through workshops. The identified impacts, risks, and
opportunities were mapped based on their expected
location in Sampo Group’s value chain. It was also
defined during which time-horizons (short-term: less
than 1 year, medium-term: 1–5 years, or long-term: over
5 years) it can be expected that the impacts, risks, and
opportunities would materialise.
Each Sampo Group company conducted its own double
materiality assessment in parallel with the group level
assessment, and their results were reviewed against the
group level results to ensure that all material topics are
covered and group level alignment is ensured. In Sampo
Group’s double materiality assessment, the group level
view is emphasised. Therefore, the exact results of
individual group companies’ own assessments may
deviate from the group level assessment.
In the assessment of impacts, Sampo Group utilised
regular dialogue with stakeholders, and documentation
of affected stakeholders’ perspectives collected
continuously through the Group’s existing channels.
Regarding social impacts, findings from Sampo Group’s
human rights impact assessment were utilised in order
to include perspectives from affected stakeholders.
Sampo Group’s main stakeholders and forums for
stakeholder dialogue are presented as a part of this
Sustainability Statement (p. 64).
When assessing impact materiality, each sustainability
topic was categorised based on whether its impact on
society, people, or environment is positive or negative,
and whether it is actual or potential. The criteria used
for defining the impact materiality score for each topic
were scale and scope, and for negative impacts,
irremediable character of the impact was included in
the assessment. For potential positive and negative
impacts Sampo Group estimated the likelihood of the
impact occurring.
When assessing financial materiality, each sustainability
topic was categorised based on whether it potentially
causes more risks or opportunities to the business and
value creation. The identified impacts and dependencies
of Sampo Group's business model on sustainability
topics acted as the starting point for the risk and
opportunity identification. The criteria used for defining
the financial materiality assessment for each topic were
the potential magnitude of its financial effects, and
likelihood of occurrence.
Thresholds were set based on the quantitative
assessment of severity/financial effect and likelihood,
using the expertise and perspectives of involved
stakeholders. Sampo Group set thresholds separately
for impact materiality and financial materiality. When
assessing the threshold for financial materiality, for
example, the scale of impact (whether the impact
concerns all the Group companies) as well as the
potential impact on Sampo Group’s reputation and
share price were considered. Sustainability topics were
determined to be material if the severity/financial effect
and the likelihood of the related impacts, risks, and
opportunities exceeded the threshold values.
Sampo Group assessed each applicable criterion for a
specific impact, risk, and opportunity on the same scale,
and completed the quantitative assessment by
qualitative descriptions. Impact, risk, and opportunity
assessment was discussed in workshops with internal
stakeholders, including representatives from the Sampo
Group companies. Sampo’s Board and its Audit
committee validated the final results of the double
materiality assessment as a part of the reporting on the
Sustainability Statement.
BOARD OF DIRECTORS’ REPORT 2024
69
Sustainability-related risks are a part of Sampo Group’s
overall risk management, and follow the same risk
management process as the Group’s other risks. The
sustainability risks identified as part of the overall risk
management were taken into consideration in the
double materiality assessment. Identified impacts are
considered and addressed indirectly through Sampo
Group’s risk management process when they are
related to the Group’s risks.
Sampo Group had already integrated the key risks and
opportunities identified as a part of the double
materiality assessment into the Group’s overall risk
management systems. Sampo Group’s process for
identifying, assessing, and managing sustainability
opportunities is integrated into the Group’s
management protocols, ensuring strategic alignment
with business objectives and operational decisions. 
The double materiality assessment described in this
Sustainability Statement was the first one Sampo Group
has conducted and thus there have been no changes to
how the assessment was conducted compared to
previous reporting periods. Sampo Group’s double
materiality assessment will be reviewed annually, and
any changes to the process or results will be reported in
future sustainability statements.
Additional process description related to
environmental and governance topics
Climate change
In addition to the double materiality assessment, Sampo
Group uses GHG emissions calculations, climate-related
scenario analyses, and different risk management
practices, such as internal model, price analyses, stress
tests, and sensitivity analysis, to identify and assess
climate-related impacts, risks, and opportunities. Sampo
Group has considered both its own operations and its
value chain when identifying the climate-related
impacts, risks, and opportunities.
Sampo Group assesses climate-related physical and
transition risks in its own operations and value chain as
part of the existing risk management practices. These
include, for example, group level and company-specific
stress tests and scenario analyses, in which the severity
of natural catastrophes is assumed to increase. The
scope, method, and results of the group level scenario
analysis are described in this Sustainability Statement
(p. 78). In the short term, physical climate risks arise in
the form of changes in claims frequencies and/or
severity of the climate-related events that are already
relevant in the current climate in the Nordics, such as
wind storms, floods, heavy rainfall, landslides, erosion,
and heatwaves. In the medium to long term, increased
weather-related losses will likely increase the exposure
for P&C insurers.
Climate-related transition risks are associated with
changes in the regulatory environment, new
technology, changing customer behaviour, and
increased stakeholder concern. Companies insured by
Sampo Group may be exposed to litigation under new
regulation related to climate change, leading, for
example, to increased claims costs in liability insurance.
Increased concern from stakeholders (e.g. from
investors, customers, and reinsurers) can lead to
increased costs for due diligence and a need to
discontinue business relationships with certain suppliers
and customers.
Sampo Group has noted that there are also
opportunities related to climate change, such as
underwriting opportunities and possibilities to invest in
new green technologies. Increased climate-related
physical risks can also lead to increased demand for
insurance products and services providing protection
against physical risks and supporting climate change
adaptation. Development of new products and services
is part of Sampo Group's normal business development
and innovation. Risk management services are already
part of Sampo Group’s services to both corporate and
private customers.
Pollution and Water and marine resources
Sampo Group has assessed that pollution and water
and marine resources are not among the most material
sustainability topics for a company operating in the P&C
insurance industry. Therefore, Sampo Group has not
comprehensively screened its assets, business activities,
and site locations or conducted consultations with
affected communities regarding these topics.
Biodiversity and ecosystems
Sampo Group has assessed that biodiversity and
ecosystems is not among the most material
sustainability topics for a company operating in the P&C
insurance industry. Therefore, Sampo Group has not
comprehensively screened its site locations and value
chain or conducted consultations with affected
communities regarding the topic. Sampo Group’s most
relevant impacts, dependencies, risks, and opportunities
related to biodiversity and ecosystems are linked to its
value chain, mainly underwriting and investment
operations. Sampo Group has conducted an initial
screening of its investment portfolio to assess its
exposure to sectors connected to high biodiversity
BOARD OF DIRECTORS’ REPORT 2024
70
impacts and risks. Sampo Group aims to develop its
data collection and reporting based on the findings of
the assessment.
Resource use and circular economy
The process for identifying material impacts, risks, and
opportunities related to resource use and circular
economy has focused on information already existing
within Sampo Group. Affected communities were not
specifically identified in relation to resource use and
circular economy due to Sampo Group's industry,
business model, and limited use of resources in its own
operations. Sampo Group has several channels for
dialogue with stakeholders, where topics such as
circular economy and resource use can be raised
(p. 65). Sampo Group has assessed that resource use
inherently has a negative impact on the environment,
but the severity of the impact can be mitigated through
the Group’s actions.
Business conduct
When identifying and assessing material impacts, risks,
and opportunities, Sampo Group has evaluated the
geographical context of its operations, considering the
regulatory landscape that may influence the impacts.
The nature of Sampo Group's insurance services,
including product offerings and service delivery
methods, has been reviewed to identify actual and
potential impacts. Operating within the P&C insurance
sector, Sampo Group has recognised the industry-
specific risks and opportunities.
Disclosure Requirements in ESRS covered by
the undertaking’s sustainability statement
Based on the results of the double materiality
assessment, Sampo Group reports material disclosure
requirements related to the ESRS topical standards E1
Climate change, E5 Resource use and circular economy,
S1 Own workforce, S2 Workers in the value chain, S4
Consumers and end users, and G1 Business conduct as
part of this Sustainability Statement. In addition to the
sustainability topics covered by the ESRS standards,
Sampo Group has recognised responsible underwriting
and investment management as material topics. Sampo
Group does not report entity-specific disclosures
related to these topics, but they are covered, where
applicable, under the ESRS standards E1 Climate
change, S2 Workers in the value chain, and S4
Consumers and end-users. A full list of disclosure
requirements complied with in preparing this
Sustainability Statement is presented in the ESRS
content index in Annex 1 (p. 119).
According to the double materiality assessment, Sampo
Group does not report disclosure requirements related
to the ESRS standard E4 Biodiversity and ecosystems.
Currently the topic is not amongst the most material
based on Sampo Group’s internal analysis and external
stakeholder feedback. Additionally, the disclosure
requirements laid out by the ESRS standard are in many
cases not applicable to companies in the insurance
sector. Nevertheless, biodiversity and ecosystems is a
topic Sampo Group will closely follow and work on, and
it is also connected to the Group’s climate work and
reporting. Sampo Group will re-evaluate the materiality
and reporting requirements related to the topic in the
coming years.
The disclosure requirements related to ESRS standard
S3 Affected communities were also excluded from this
Sustainability Statement. As a P&C insurance company
operating mainly in the Nordic countries, Sampo
Group’s direct impacts on topics such as adequate
housing and freedom of expression were considered
limited. However, Sampo Group reports on its
stakeholder management as part of the ESRS 2
standard, and considers topics related to affected
communities where relevant.
Sampo Group does not report disclosure requirements
related to the ESRS standards E2 Pollution and E3
Water and marine resources, as the impacts, risks, and
opportunities related to these topics are not considered
material for the Group.
BOARD OF DIRECTORS’ REPORT 2024
71
Environmental information
EU Taxonomy
The EU Taxonomy is a classification system that
translates the EU’s climate and environmental
objectives into criteria for specific economic activities
for investment purposes. The basic principle of the
Taxonomy is that for an economic activity to be
recognised as environmentally sustainable (Taxonomy-
aligned), it must make a substantial contribution to at
least one of the EU’s climate and environmental
objectives, which are climate change mitigation; climate
change adaptation; sustainable use and protection of
water and marine resources; transition to a circular
economy; pollution prevention and control; and
protection and restoration of biodiversity and
ecosystems. In addition, the economic activity cannot
significantly harm any of these objectives and must
meet the minimum safeguards criteria. The Taxonomy
Delegated Acts establish and maintain criteria (i.e.
technical screening criteria) for activities which have a
substantial positive environmental impact.
Companies are required to report on Taxonomy
eligibility (i.e. reporting on whether the economic
activity is included in the Taxonomy Climate Delegated
Act) and Taxonomy alignment (i.e. reporting on
whether the economic activity meets the technical
criteria for i) substantial contribution, ii) do no
significant harm, and iii) comply with minimum
safeguards).
Insurance companies are required to report KPIs on
sustainable underwriting activities and sustainable
investments. The first one refers to the proportion of
the non-life gross written premiums (GWP) – in relation
to total non-life GWP – corresponding to insurance
activities identified as environmentally sustainable in the
Taxonomy, and the second one to the proportion of the
insurer’s or reinsurer’s investments – in relation to total
insurer’s or reinsurer’s investments – that are directed at
or associated with funding economic activities that
qualify as environmentally sustainable.
In 2024, the weighted averages of Sampo Group’s
Taxonomy-aligned activities concerning both
underwriting and investments were 1.3 per cent
(turnover-based) and 1.3 per cent (capital expenditures-
based).
BOARD OF DIRECTORS’ REPORT 2024
72
Underwriting activities
Non-life insurance and reinsurance are recognised as
enabling economic activities that can make a
substantial contribution to the environmental objective
of climate change adaptation. At the time of writing this
statement, the EU Taxonomy does not define other
environmental objectives for insurance activities.
The non-life insurance activities listed in the Taxonomy
Delegated Acts are medical expense insurance, income
protection insurance, workers’ compensation insurance,
motor vehicle liability insurance, other motor insurance,
marine, aviation, and transport insurance, fire and other
damage to property insurance, and assistance.
Methodology
To be Taxonomy-eligible, a non-life insurance activity
must provide coverage against climate-related perils
(e.g. floods, landslides, heat stress). Sampo Group
follows in its methodology the European Commission
Notice on the interpretation of certain legal provisions
of the Disclosures Delegated Act under Article 8 of the
EU Taxonomy Regulation, published on 21 December
2023. This means that solely the share of insurance
premiums that pertain to the coverage of climate-
related perils is reported as eligible. The premiums for
which Sampo Group has not been able to obtain the
necessary data related to climate-related perils are
reported as non-eligible.
For an eligible insurance activity to be classified as
Taxonomy-aligned, it must fulfil the technical screening
criteria of:
• Substantial contribution to climate change
adaptation: 
– Leadership in modelling and pricing of climate risks
– Product design
– Innovative insurance coverage solutions
– Data sharing
– High level of service in post‐disaster situation
• Do No Significant Harm (DNSH) climate change
mitigation criteria: The activity does not include
insurance of the extraction, storage, transport, or
manufacture of fossil fuels or insurance of vehicles,
property, or other assets dedicated to such purposes.
When assessing the Taxonomy alignment, Sampo
Group has concentrated on the most relevant products
in terms of climate change adaptation, which are mainly
related to fire and other damage to property line of
business. For the products where potential alignment
with the technical screening criteria was identified, a
more thorough and granular product-level analysis (e.g.
based on a policy, country, or element) was conducted
to identify the specific premiums that are in scope for
Taxonomy-alignment. Only the part of the premiums
that pertains to the coverage of climate-related perils
was deemed to be aligned.
For assessing the DNSH-criteria, Sampo Group has used
NACE codes to extract contracts that could be related
to the extraction, storage, transport, or manufacture of
fossil fuels, and those are excluded from the Taxonomy
aligned premiums. This screening has been performed
on Sampo Group’s industrial and commercial
customers.
For an economic activity to be considered as Taxonomy-
aligned, a company carrying the activity must also meet
the minimum safeguards, which are due diligence and
remedy procedures implemented to ensure alignment
with the OECD Guidelines for Multinational Enterprises
and the UN Guiding Principles on Business and Human
Rights. Sampo Group has implemented the required
policies and taken actions to be compliant with the
safeguards. Sampo Group has, for example, conducted a
human rights impact assessment, and continues to
ensure that the adequate human rights due diligence
processes are maintained and constantly developed. As
part of the Taxonomy alignment assessment, the Group
companies have also assessed their compliance with the
minimum safeguards separately.
BOARD OF DIRECTORS’ REPORT 2024
73
Underwriting KPIs
The analysis, which is based on the above-mentioned
interpretations, shows that 3.0 per cent (2.2 in 2023) of
Sampo Group’s total non-life GWP were Taxonomy-
eligible and 1.3 per cent (1.0 in 2023) of total non-life
GWP were Taxonomy-aligned in 2024. All the
Taxonomy-aligned premiums are related to fire and
other damage to property insurance. In 2024, Sampo
Group was able to increase the share of Taxonomy-
aligned premiums due to increased alignment within If’s
property portfolio and customisation of Topdanmark’s
insurance for private houses.
Sampo Group continues to integrate the EU Taxonomy
into its business strategy and product development
processes while monitoring the market expectations
and customer needs in this area. In the coming years,
Sampo Group aims to increase the share of Taxonomy-
aligned underwriting activities in its insurance portfolio.
Taxonomy-eligible and Taxonomy-aligned non-life insurance and re-insurance activities
Sampo Group
Substantial contribution to climate change
adaptation
DNSH (Do No Significant Harm)
Economic activities
Absolute
premiums,
2024
Proportion of
premiums,
2024
Proportion of
premiums,
2023
Climate
change
mitigation
Water and
marine
resources
Circular
economy
Pollution
Biodiversity
and
ecosystems
Minimum
safeguards
(EURm)
%
%
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
A.1. Non-life insurance and reinsurance
underwriting Taxonomy-aligned
activities (environmentally sustainable)
127
1.3%
1.0%
Y
Y
Y
Y
Y
Y
A.1.1 Of which reinsured
—
—%
—%
Y
Y
Y
Y
Y
Y
A.1.2 Of which stemming from reinsurance
activity
—
—%
—%
Y
Y
Y
Y
Y
Y
A.1.2.1 Of which reinsured (retrocession)
—
—%
—%
Y
Y
Y
Y
Y
Y
A.2 Non-life insurance and reinsurance
underwriting Taxonomy-eligible but not
environmentally sustainable activities
(not Taxonomy-aligned activities)
161
1.7%
1.2%
B. Non-life insurance and reinsurance
underwriting Taxonomy-non-eligible
activities
9,216
97.0%
97.8%
Total (A.1 + A.2 + B)
9,504
100.0%
100.0%
BOARD OF DIRECTORS’ REPORT 2024
74
Investment activities
The EU Taxonomy requires insurance companies to
report the proportion of underlying investments that
are Taxonomy-eligible and -aligned. To facilitate this
type of reporting at portfolio level, all holdings need to
be screened and analysed in relation to the economic
activities of the Taxonomy. 
Methodology
Sampo Group analysed all underlying investments
according to the Taxonomy reporting requirements,
except for sovereign exposures that are to be excluded
from the Taxonomy analysis. In Sampo Group’s analysis,
exposures to municipalities were not categorised as
sovereign exposure. When analysing Taxonomy
eligibility and alignment, derivatives and investments to
undertakings not falling under the scope for publishing
non-financial information under Directive 2013/34/EU
(i.e. non-NFRD companies) were excluded from the
numerator, in line with the reporting requirements set in
the Taxonomy Disclosures Delegated Act. Reporting
requirements also obligate insurance undertakings to
distinguish the proportion of the investments held in
respect of life insurance contracts, where the
investment risk is borne by the policyholders, and the
proportion of remaining investments. Sampo Group has
no investments held in respect of life insurance
contracts where the investment risk is borne by the
policyholders.
The Taxonomy analysis of Sampo Group’s investments
was performed with the use of data from an external
data provider, ISS ESG (ISS). ISS identified companies
engaged in economic activities covered by the
Taxonomy and produced all Taxonomy indicators
directly based on the respective investee companies’
own reporting of Taxonomy eligibility and alignment.
The indicators were provided based on both underlying
companies’ revenue and capital expenditures. As
security-specific (e.g. mortgage bonds) eligibility and
alignment data is still scarce, most of the securities’
eligibility and alignment data was matched to the
issuer’s reported data. Companies’ reported eligibility
and alignment data was not modified in any way by the
data provider or by Sampo Group, and therefore it
includes some discrepancies (e.g. breakdown of
alignment to environmental objectives does not
correspond to total alignment).
The relevant investment assets were further analysed
according to the Taxonomy reporting requirements by
using both data provided by ISS and data gathered
based on each individual security's issuer. The
investments in undertakings categorised as non-NFRD
companies were identified by using data provided by
ISS. As ISS does not cover all NFRD companies, some
unidentified NFRD companies may have been included
in the assets not covered by the analysis. Investments in
undertakings from the EU and non-EU countries have
been identified using the securities' issuers' country
code. Similarly, investments in undertakings categorised
as financial and non-financial have been identified using
the securities' issuers' internal sector information to
determine the main sector the companies operate in
(e.g. NACE codes). Fund investments were analysed
using look-through data where available. Some look-
through data is updated in longer cycles and thus the
most recent available look-through data was used for
the EU Taxonomy calculations.
The underlying investments analysed also included
Sampo Group’s real assets (property, plant and
equipment as well as investment property), cash and
cash equivalents, investments in associated companies
and intangible assets and they are included in the
denominator of the Taxonomy calculations.
For Sampo Group’s real assets, no activities with EU
taxonomy eligibility or alignment were found. All
investments in associated companies were in non-NFRD
companies and thus included no EU Taxonomy
eligibility or alignment figures. Cash and cash
equivalents were analysed based on the counterparties
but due to the nature of the instruments (e.g. cash and
money market instruments), no EU Taxonomy eligibility
or alignment was reported. The intangible assets of
Sampo Group were also not found to have activities
related to the EU Taxonomy.
Investment KPIs
According to the analysis, the turnover and capital
expenditures-based Taxonomy eligibility of Sampo
Group’s covered assets as at 31 December 2024 was 3.1
per cent (3.5 in 2023) and 3.6 per cent (4.2 in 2023),
respectively and the turnover-based and capital
expenditures-based Taxonomy alignment of Sampo
Group’s covered assets was 0.7 per cent (0.7 in 2023)
and 1.0 per cent (0.9 in 2023), respectively. As
expected, the reported numbers are low, as most of the
underlying companies are not subject to mandatory
Taxonomy reporting, and reported eligibility and
alignment are low in general.
Sampo Group reports the additional KPIs related to
fossil gas and nuclear energy sectors, laid down by the
Delegated Regulation (EU) 2022/1214, regarding its
investment activities. The KPIs are presented in Annex 3
of this Sustainability Statement (p. 126). Due to minimal
exposure to those sectors in its insurance activities,
data limitations, and current market practices, Sampo
Group does not consider the additional KPIs applicable
to its underwriting activities.
BOARD OF DIRECTORS’ REPORT 2024
75
Taxonomy-eligible and Taxonomy-aligned investment activities
Sampo Group, 31 December 2024
EURm
The weighted average value of all the
investments of insurance or reinsurance
undertakings that are directed at funding, or
are associated with Taxonomy-aligned
economic activities relative to the value of
total assets covered by the KPI, with
following weights for investments in
undertakings per below:
The weighted average value of all the
investments of insurance or reinsurance
undertakings that are directed at funding, or
are associated with Taxonomy-aligned
economic activities, with following weights
for investments in undertakings per below:
Turnover-based:
0.7%
Turnover-based:
131
Capital expenditures-based:
1.0%
Capital expenditures-based:
201
The percentage of assets covered by the KPI
relative to total investments of insurance or
reinsurance undertakings (total AuM).
Excluding investments in sovereign entities.
The monetary value of assets covered by
the KPI. Excluding investments in sovereign
entities.
Coverage ratio:
94.4%
Coverage:
19,903
Additional, complementary disclosures: breakdown of denominator of the KPI
The percentage of derivatives relative to
total assets covered by the KPI:
The value in monetary amounts of
derivatives:
0.0%
1
The proportion of exposures to financial and
non-financial undertakings not subject to
Articles 19a and 29a of Directive 2013/34/
EU over total assets covered by the KPI:
Value of exposures to financial and non-
financial undertakings not subject to Articles
19a and 29a of Directive 2013/34/EU:
For non-financial
undertakings:
21.9%
For non-financial
undertakings:
4,363
For financial undertakings:
28.1%
For financial undertakings:
5,591
The proportion of exposures to financial and
non-financial undertakings from non-EU
countries not subject to Articles 19a and 29a
of Directive 2013/34/EU over total assets
covered by the KPI:
Value of exposures to financial and non-
financial undertakings from non-EU
countries not subject to Articles 19a and 29a
of Directive 2013/34/EU:
For non-financial
undertakings:
12.0%
For non-financial
undertakings:
2,390
For financial undertakings:
14.1%
For financial undertakings:
2,809
Additional, complementary disclosures: breakdown of denominator of the KPI
The proportion of exposures to financial and
non-financial undertakings subject to
Articles 19a and 29a of Directive 2013/34/
EU over total assets covered by the KPI:
Value of exposures to financial and non-
financial undertakings subject to Articles 19a
and 29a of Directive 2013/34/EU:
For non-financial
undertakings:
10.1%
For non-financial
undertakings:
2,020
For financial undertakings:
20.1%
For financial undertakings:
4,008
The proportion of exposures to other
counterparties and assets over total assets
covered by the KPI:
Value of exposures to other counterparties
and assets:
19.7%
3,921
The proportion of the insurance or
reinsurance undertaking’s investments other
than investments held in respect of life
insurance contracts where the investment
risk is borne by the policy holders, that are
directed at funding, or are associated with,
Taxonomy-aligned economic activities1:
Value of insurance or reinsurance
undertaking’s investments other than
investments held in respect of life insurance
contracts where the investment risk is borne
by the policy holders, that are directed at
funding, or are associated with, Taxonomy-
aligned economic activities1:
100.0%
19,903
The value of all the investments that are
funding economic activities that are not
Taxonomy-eligible relative to the value of
total assets covered by the KPI2 :
Value of all the investments that are funding
economic activities that are not Taxonomy-
eligible 2:
96.3%
19,158
The value of all the investments that are
funding Taxonomy-eligible economic
activities, but not Taxonomy-aligned relative
to the value of total assets covered by the
KPI3:
Value of all the investments that are funding
Taxonomy-eligible economic activities, but
not Taxonomy-aligned 3:
3.1%
614
1 The figure on the table equals the total amount of Sampo Group’s investments covered by the KPI
other than investments held in respect of life insurance contracts where the investment risk is
borne by the policy holders. The turnover-based and capital expenditures-based alignment for
these investments are 0.7 per cent and 1.0 per cent respectively.
2 Turnover-based figure is reported on the table. Capital expenditures-based figure is 95.4 per cent.
3 Turnover-based figure is reported on the table. Capital expenditures-based figure is 3.6 per cent.
BOARD OF DIRECTORS’ REPORT 2024
76
Additional, complementary disclosures: breakdown of numerator of the KPI
The proportion of Taxonomy-aligned
exposures to financial and non-financial
undertakings subject to Articles 19a and 29a
of Directive 2013/34/EU over total assets
covered by the KPI:
Value of Taxonomy-aligned exposures to
financial and non-financial undertakings
subject to Articles 19a and 29a of Directive
2013/34/EU:
For non-financial undertakings:
For non-financial undertakings:
Turnover-based:
0.6%
Turnover-based:
121
Capital expenditures-based:
0.9%
Capital expenditures-based:
185
For financial undertakings:
For financial undertakings:
Turnover-based:
0.1%
Turnover-based:
10
Capital expenditures-based:
0.1%
Capital expenditures-based:
16
The proportion of the insurance or
reinsurance undertaking’s investments other
than investments held in respect of life
insurance contracts where the investment
risk is borne by the policy holders, that are
directed at funding, or are associated with,
Taxonomy-aligned:
Value of insurance or reinsurance
undertaking’s investments other than
investments held in respect of life insurance
contracts where the investment risk is borne
by the policy holders, that are directed at
funding, or are associated with, Taxonomy-
aligned:
Turnover-based:
0.7%
Turnover-based:
131
Capital expenditures-based:
1.0%
Capital expenditures-based:
201
The proportion of Taxonomy-aligned
exposures to other counterparties and
assets in over total assets covered by the
KPI:
Value of Taxonomy-aligned exposures to
other counterparties and assets over total
assets covered by the KPI:
Turnover-based:
—%
Turnover-based:
—
Capital expenditures-based:
—%
Capital expenditures-based:
—
Breakdown of the numerator of the KPI per environmental objective
Taxonomy-aligned activities – provided ‘do-no-significant-harm’(DNSH) and social
safeguards positive assessment:
(1) Climate change
mitigation
Turnover:
0.6%
Transitional
activities:
Turnover: 
0.1%
CapEx:
0.4%
CapEx:
1.0%
Enabling
activities:
Turnover:
0.1%
CapEx:
0.5%
(2) Climate change
adaptation
Turnover:
0.0%
Enabling
activities:
Turnover:
0.0%
CapEx:
0.0%
CapEx:
0.0%
(3) The sustainable use
and protection of water
and marine resources
Turnover:
0.0%
Enabling
activities:
Turnover:
0.0%
CapEx:
0.0%
CapEx:
0.0%
(4) The transition to a
circular economy
Turnover:
0.0%
Enabling
activities:
Turnover:
0.0%
CapEx:
0.0%
CapEx:
0.0%
(5) Pollution prevention
and control
Turnover:
0.0%
Enabling
activities:
Turnover:
0.1%
CapEx:
0.0%
CapEx:
0.1%
(6) The protection and
restoration of
biodiversity and
ecosystems
Turnover:
—%
Enabling
activities:
Turnover:
—%
CapEx:
—%
CapEx:
—%
BOARD OF DIRECTORS’ REPORT 2024
77
Climate change
Topic
Impacts
Risks and opportunities
Strategy and actions
GHG emissions and
climate-related risks
↓ GHG emissions cause actual negative impact on the
environment. As an insurance company, Sampo
Group's own direct emissions are not significant, but
when considering the Group’s entire value chain,
including suppliers and investments, the impact is
more material.
Time-horizon: short, medium, and long term
↓ The increasing scale and frequency of physical
climate-related risks, such as storms, floods, heavy
rains, landslides, erosion, and heat waves, can
increase Sampo Group’s claims costs and cause
financial risks for the Group. Climate-related physical
risks are already relevant in the short term, and they
are likely to grow in the medium to long term.
↓ Sampo Group can face potential reputational risks
related to GHG emissions or not achieving the set
emission reduction targets.
↓ Sampo Group can face financial and reputational
risks arising from increasing climate-related
legislation (e.g. possible fines).
Time-horizon: short, medium, and long term
• Commitments to reduce GHG emissions (e.g. SBTi)
• Internal policies and guidelines (e.g. responsible
investment policies, underwriting principles, codes
of conduct)
• Effective governance structures and processes (e.g.
risk management, screening, engagement)
• Consideration of climate-related risks in the pricing
of the products and services and in reinsurance
• Internal training, competence development
programmes, and awareness raising
• Metrics and targets (e.g. SBTs related to own
operations, investments, and suppliers)
Product and service
offering
↑ Sampo Group has potential positive impact through
the development of climate-friendly products and
services (e.g. related to loss prevention and risk
management). Non-life insurance and reinsurance
are recognised by the EU Taxonomy as enabling
economic activities that can make a substantial
contribution to the environmental objective of
climate change adaptation.
Time-horizon: short, medium, and long term
↑ Development of sustainable products and services
can provide business opportunities for Sampo Group
(e.g. related to loss prevention, risk management,
the EU Taxonomy).
↓ Sampo Group can face potential financial risks if it is
not able to provide customers with sustainable
products and services that meet their needs.
Time-horizon: short, medium, and long term
• Development of sustainable products and services
based on customers’ needs and aligned with the EU
Taxonomy
• Climate resilience in product development and
pricing
• Loss prevention and risk management services
The table presents Sampo Group’s material impacts, risks, and opportunities related to climate change identified in the double materiality assessment and their connection to Sampo Group’s strategy and
actions. The topics are linked to the ESRS sub-topics. The topic GHG emissions and climate-related risks is related to the ESRS sub-topics climate change mitigation and climate change adaptation. The
topic Product and service offering is related to the ESRS sub-topic climate change adaptation.
BOARD OF DIRECTORS’ REPORT 2024
78
Strategy
Material impacts, risks, and opportunities
and their interaction with strategy and
business model
Sampo Group’s underwriting operations are exposed to
both physical risks and transition risks. Physical risks are
risk factors affecting the financial position and results of
Sampo Group. Physical climate-related risks include
storms, floods, heavy rains, landslides, erosion,
hailstorms, and heat waves. The scale or frequency of
these natural disasters can increase claims costs.
Transition risks, on the other hand, relate to changes in
the regulatory environment, the introduction of new
technologies, changes in customer behaviour, and
increased stakeholder concern for climate and
environmental matters, for example. The European
Insurance and Occupational Authority (EIOPA) has
identified transition risks linked to policy, legal issues,
technology, market sentiment, and reputation for non-
life insurers.
Sampo Group’s investments can also be exposed to
both physical risks and transition risks, depending on
the investment in question. Investments are particularly
exposed to physical risks in the form of losses incurred
from extreme weather events. The transition to a low-
carbon society with potentially increasing
environmental and climate regulation, more stringent
emission requirements, and changes in market
preferences could in turn cause transition risks for the
Group’s investments and possible revaluation of assets
as operating models in carbon intense sectors change.
Sampo Group’s capital planning, a forecast of own
funds and capital requirements over a three-year
planning period, and own risk and solvency assessment
(ORSA) processes include scenario analyses, stress
tests, sensitivity analyses, and reverse stress tests,
including scenarios related to natural catastrophes.
Climate scenario analysis
Sampo Group has together with the external vendor
ORTEC Finance analysed the Group’s investment
portfolio's exposure to systemic economic and financial
climate change risks in four different climate scenarios
over the next 40 years. The impact on the insurance
results was also analysed based on the impact on
macroeconomic variables as well as the potential effect
on claims related to natural catastrophes, including the
consequences for the pricing of insurance contracts.
The four scenarios analysed are the following:
• Net-Zero (NZ): This scenario describes an easy and
smooth transition where political and social
organisations act quickly and predictably to achieve
net-zero CO2 emissions by 2050.
• Net-Zero Financial Crisis (NZFC): In this scenario, the
transition to a greener economy happens in a
disorderly manner. Sudden divestments to align
portfolios to the Paris Agreement goals in 2026 have
disruptive effects on financial markets with sudden
repricing followed by stranded assets and a sentiment
shock.
• Limited Action (LA): In this scenario, policymakers
implemented limited nationally determined
contributions (NDCs) but fall short of meeting the
Paris Agreement goals. The global warming reaches
2.8°C, and this causes high physical impact.
• High Warming (HW): In this scenario, the world fails
to meet the Paris Agreement goals, and global
warming reaches 4.2°C above pre-industrial levels by
2100. Physical climate impacts cause large reductions
in economic productivity and increased impacts from
extreme weather events. This scenario focuses on
physical risk as the green transition does not happen.
The methodology used to assess systemic climate
change risks and opportunities related to Sampo
Group’s investments combines climate science with
econometric and financial modelling. The methodology
relies on the following key assumptions:
• The scenarios used are climate science informed
scenarios. Each scenario differs in terms of
assumptions about policy and technology changes,
physical risks, and pricing-in mechanisms. The
scenarios are chosen to explore a range of plausible
outcomes.
• The E3ME model by Cambridge Econometrics models
the world’s economic and energy systems and the
environment. It is a quantitative framework for
analysing the impacts of Energy-Environment-
Economy (E3) policies over the short, medium and
long term. It is widely used globally for policy
assessment as well as for forecasting and research,
and in this context, it is used to model the impact of
transition risk on the evolution of macroeconomic
variables. Currently, the E3ME model does not
explicitly account for physical risk factors and is,
therefore, complemented by methods to account for
the impact of gradual physical risks and extreme
weather events on the evolution of macroeconomic
variables.
• Stochastic financial modelling that translates shocks
to macroeconomic variables to risk-return metrics for
different geographies, sectors, and asset classes is
used in the last step to translate the climate-informed
outputs from the previous steps, i.e. the impact of
transition risks and physical risks on the evolution of
macroeconomic variables in the different scenarios. In
addition, assumptions about pricing-in and sentiment
shocks in financial markets, and how they impact
asset returns and risk for a large number of economic
and financial market variables are made.
BOARD OF DIRECTORS’ REPORT 2024
79
Impact on investment results
The climate scenario analysis was first conducted in
2023, and the results were reweighted based on the
investment allocation as at 30 September 2024. The
results of the scenario analysis form a set of data that
can be analysed from various perspectives. The results
are presented relative to a baseline that does not take
into account any specific assumptions about climate
change. Instead, the baseline relies on historical
relationships and long-term views shaped by current
market conditions.
According to the results of the climate scenario
analysis, Sampo Group’s current investment portfolio is
relatively resilient to climate change risk in all four
scenarios. This is due to the significant allocation to
fixed income instruments, which tend to be less
affected than equities, as well as the geographical
allocation towards mainly the Nordics and other
European countries where the effects of climate change
are expected to be lower than in other parts of the
world. According to the analysis, in the short run, the
main risk is related to the pricing-in shock in the NZFC
scenario. In the long run, there will be a negative impact
on the returns in all scenarios, due to increased physical
risks. In addition, returns from high GHG emitting
sectors are particularly affected in both net-zero
scenarios (NZ and NZFC).
Impact on insurance results
To assess the impact of the climate scenarios on the
insurance results, the forecasts for macro variables
(GDP and inflation) and their direct effect on insurance
results in combination with assumptions for effects on
natural catastrophe claims and repricing of insurance
contracts under the different climate scenarios were
used. The climate scenario analysis was performed for
If’s insurance portfolio (including Topdanmark), but the
results are stated on a relative basis in terms of the
insurance result and could be seen as broadly
representative for the entire Sampo Group. Also, the
business not included in the analysis, i.e. Hastings, has a
very low share of home insurance business and,
consequently, considered to have relatively low
exposure to natural catastrophes.
The sensitivity to increased physical risk was assessed
by including increased natural catastrophe claims in the
HW scenario, and separately considering re-pricing due
to increased claims cost.
According to the scenario analysis, the combined effect
of changes in GDP and inflation in the HW scenario
compared to the NZ scenario leads to a relatively
limited impact on the insurance result. This is mainly
due to offsetting effects stemming from how different
economies are affected in the Nordic region. However,
the assumed impact on natural catastrophe claims is
more material, in particular in the scenario without
repricing and the apparent offsetting effect of repricing
actions. The scenario analysis hence indicates that
although the direct impact from macroeconomic
impacts is relatively limited, increased claims costs
could materially influence the insurance results, and
appropriate repricing of the insurance contracts will be
particularly important in such a scenario. With P&C
insurance contracts almost exclusively being renewed
on a yearly basis within Sampo Group, the resilience
towards trends in claims for whatever reason is typically
high given the focus on financial control, clear financial
targets, and general underwriting focus within the
Group.
Transition plan for climate change mitigation
Sampo Group is developing its transition plan for
climate change mitigation, which is based on its SBTs.
To reach the targets, Sampo Group has identified
relevant decarbonisation levers and actions to be taken
in the coming years. Sampo Group is committed to
further develop its transition plan according to
applicable regulation and frameworks, and will report
on the development annually as part of its sustainability
reporting.
Once finalised, Sampo Group is planning to embed the
transition plan in its overall strategy and financial
planning, for example, by allocating sufficient resources
to the development and implementation of the climate
action plans in order to reach its SBTs. Currently, the
implementation of Sampo Group’s transition plan is not
expected to require allocation of specific investments or
funding beyond normal costs related to business
development. However, this will be re-evaluated while
developing the plan further.
Sampo Group has estimated that its key assets and
products do not currently contain sources for significant
locked-in emissions, as the Group does not operate in a
GHG intensive sector. Sampo Group is not excluded
from the EU Paris-aligned benchmarks.
Sampo Group’s insurance and investment activities are
covered by the EU Taxonomy. The Group’s Taxonomy
disclosures, including the description of future plans, are
presented in the section EU Taxonomy (p. 71).
BOARD OF DIRECTORS’ REPORT 2024
80
Science-based targets
Sampo Group has set SBTs in line with the SBTi’s
methodology to limit global warming to 1.5°C. Sampo
Group’s commitment to the SBTi has been approved by
the company’s management and the Board of Directors.
Sampo Group joined the SBTi in October 2023.
Mandatory group level targets for own operations and
investments were developed during 2024, and the
targets were validated by the SBTi and published in
November 2024. Sampo Group reports on progress
against the targets annually as part of the company’s
sustainability reporting starting from financial year
2025. In addition to the group level targets related to
own operations and investments, Sampo Group has set
voluntary SBTs for suppliers on a subsidiary level.
Sampo Group works towards the SBTs to reduce GHG
emissions related to its own operations, investments,
and suppliers. The Group’s actions regarding own
operations include purchasing renewable electricity,
switching to biogas and district heating, changing to
LED lighting, optimising the use of office space, and
transitioning its vehicle fleet to electric and hybrid cars.
Measures related to investments include regular
monitoring using screenings, engagement with investee
companies (e.g. investor events, AGMs), development
of the Group’s coal phase-out plan, and normal portfolio
turnover. In addition, Sampo Group engages with and
encourages its suppliers to set SBTs. Sampo Group’s
climate targets are presented in detail in the table
Science-based targets (p. 83).
Impact, risk and opportunity
management
Policies related to climate change mitigation
and adaptation
Sampo Group’s policy regarding climate change
mitigation and adaptation is the Sampo Group Code of
Conduct, which is reviewed annually and approved by
Sampo’s Board of Directors. The Code of Conduct
states that Sampo Group complies with climate-related
legislation, is committed to combatting climate change,
and supports the Paris Agreement. The policy is also
supported by Sampo Group’s commitment to the SBTi
and involvement in various initiatives (e.g. UN Global
Compact).
The Sampo Group Code of Conduct covers all Sampo
Group’s own operations. Sampo Group also expects its
suppliers and other business partners to comply with
the principles of the Code of Conduct throughout their
own operations and supply chains. In addition to the
Sampo Group Code of Conduct, each Group company
has adopted supplementary and more detailed policies,
guidelines, and processes for their own purposes, to
guide the work related to climate change mitigation and
adaptation. These include, for example, sustainability
policies, supplier codes of conduct, and responsible
investment policies.
The Sampo Group Code of Conduct together with the
company-specific policies address climate change
mitigation and adaptation, energy efficiency, and
renewable energy deployment. Sampo Group takes
ESG considerations, including climate change, into
account in product and service development, insurance
underwriting, investment operations, and supply chain
management. The Group strives to reduce the
consumption of resources (e.g. energy, water) and
improve the efficient use of those resources.
Additionally, Sampo Group is committed to reducing
emissions and waste generated from business
operations, while incorporating the concepts of
reduction, re-use, and recycling. Sampo Group also
prioritises renewable energy sources, when possible.
Sampo Group encourages its customers, investee
companies, suppliers, and other business partners to
uphold similar environmental and climate commitments,
and consults and cooperates with its stakeholders on
environmental and climate matters.
Actions and resources in relation to climate
change policies
Sampo Group has assessed that it has a negative
impact on climate change through the GHG emissions
of its own operations and value chain. However, Sampo
Group has emission reduction targets and a series of
actions to mitigate the negative impact and to reduce
the GHG emissions in line with the SBTi’s framework.
Climate change mitigation
Through its SBTs, Sampo Group is committed to
reducing its total Scope 1 and 2 emissions by 42 per
cent by 2030 compared to the 2022 base year. This
translates to an emission reduction of 2,514 tCO2eq.
Sampo Group has identified switching to renewable
energy and reducing energy use in offices and
electrifying the car fleet as the main decarbonisation
levers. Sampo Group has assessed that the majority of
the required emission reductions will be achieved by
switching to renewable energy and reducing energy use
in offices. In 2025, Sampo Group will further develop its
reporting on decarbonisation levers and their
quantitative contributions.
Sampo Group has also set SBTs for investments and
voluntary SBTs (If and Topdanmark) for suppliers. The
identified decarbonisation levers or actions related to
these Scope 3 emissions are supplier engagement,
sustainable claims handling, and responsible investment.
BOARD OF DIRECTORS’ REPORT 2024
81
Own operations
In 2024, Sampo Group’s climate change mitigation
actions focused on the decarbonisation levers that are
expected to reduce the company’s Scope 1 and 2
emissions and contribute towards the Group’s SBTs.
For the past years, Sampo Group has strived to
transition to renewable energy sources for electricity
and district heating across its locations. In 2024,
Hastings’ Bexhill and Leicester offices switched to 100
per cent renewable energy sources for both electricity
and biogas, and If had solar panels installed on the
office in Bergshamra. In addition, Sampo Group
promoted energy efficiency in 2024, for example, by
implementing environmental standards for energy
efficiency in its offices.
Sampo Group also expects emission reductions from
the shift to electric vehicles (EVs). In 2024, If started to
pay for the installation cost of EV charging outlets at
home for employees in Denmark who are entitled to a
car benefit, and Hastings upgraded the company car
parks in both Bexhill and Leicester with EV charging
stations.
In addition to aiming for Scope 1 and 2 emission
reductions from its own operations, Sampo Group
strives to better understand the extent of its Scope 3
emissions. In 2024, Sampo Group conducted an
inventory of its reported Scope 3 emissions and
assessed which Scope 3 categories are material and
need further development. As a result of the
assessment, data quality in the categories Purchased
goods and services, Capital goods, Upstream
transportation and distribution, Business travelling, and
Employee commuting was improved. In addition,
Hastings conducted a spend-based assessment of its
Purchased goods and services, leading to a large
increase in reported emissions in this category.
During 2025, Sampo Group will continue its emission
reduction actions and initiatives, and monitor progress
against the Scope 1 and 2 targets. Collectively, these
measures are expected to reduce the Group’s GHG
emissions. Regarding its Scope 3 emissions, Sampo
Group plans to further develop GHG emission reporting,
especially regarding the gaps identified in the 2024
assessment and align reporting across the Group. The
company also recognises that emissions from insurance
activities (i.e. insurance associated emissions) represent
an important part of its Scope 3 emissions and,
therefore, this category will be assessed in the coming
years.
Investments
To achieve the Group’s SBTs for investments, Sampo
Group has devised a strategy that revolves around
strategic asset allocation and proactive investee
engagement. This means that investments in companies
and assets that offer strong financial returns and align
with the Group’s climate objectives are prioritised.
During 2024, Sampo Group developed its investment
monitoring and reporting related to the SBTs, and
practices to engage with its investee companies
regarding emission reduction targets when needed.
During 2025, the plan is to continue this work and
prepare for reporting according to the SBTi’s
methodology.
In 2024, Sampo Group conducted an annual carbon
footprint analysis of its investment portfolio for
enhanced disclosure and transparency around climate-
related risks. Sampo Group also continued to perform
sector-based and norm-based screenings for its direct
investment portfolio to identify and make decisions
regarding companies that are involved in certain
industries as well as companies’ adherence to
international norms concerning environmental
protection. To support these practices and to ensure
quality monitoring of investments from a sustainability
point of view going forward, Sampo Group reviewed its
ESG data service providers during the year.
Suppliers
Sampo Group works with its suppliers on topics related
to climate change. Supplier engagement offers a way to
influence decarbonisation efforts within the supply
chain when granular emissions data is challenging to
track or unavailable. Sampo Group’s supplier
engagement targets focus on engaging a defined set of
suppliers in the near term to set their own SBTs for all
applicable scopes and categories.
In 2024, If initiated a process to assess how many of its
suppliers within motor and property claims have set
SBTs or equivalent to be able to support and incentivise
remaining suppliers to set targets going forward.
Topdanmark will apply the same approach to all
suppliers in its portfolio within purchased goods and
services.
Sustainable claims handling
Sampo Group can contribute to climate change
mitigation by emphasising energy and resource
efficiency, and use of renewable energy in claims
handling operations. For example, If has implemented a
sustainable building module as part of its most
comprehensive building insurance for commercial
buildings in Norway in 2023 and Sweden in 2024.
Through this module, which is based on BREEAM
certification systems, If provides concrete advice,
guidance, and financial support for sustainable
measures, such as the use of solar panels and energy
efficiency measures, in the reconstruction after major
damage. In 2024, Topdanmark engaged with partners in
the construction sector on the possibility of choosing
reused materials instead of new materials in the context
of building claims, while still taking cost and safety into
consideration.
BOARD OF DIRECTORS’ REPORT 2024
82
Climate change adaptation
During 2024, loss prevention remained an important
theme for Sampo Group. If and Topdanmark continued
to provide loss prevention services, such as on-site risk
assessments and house assessments, for their
customers. This is to identify specific and cost-effective
preventative measures, which can reduce the
customers’ climate-related risks. Hastings also provided
guidance to its customers on loss prevention, including
winter car check reminders and recommendations on
how to mitigate issues at home, such as freezing
pipework. In addition, in 2024, Hastings created a Geo-
Spatial Data Scientist team working to assess the value
of climate-related data enrichment, producing address-
level scores covering weather claims risk (e.g. flood,
freeze) and supporting the Underwriting team with
climate-related risk selection and accumulation
management.
Sampo Group participates in various research projects
together with universities, research institutes, and
clients. The aim of this work is to better understand
risks and to support the clients in their risk
management, but also to contribute to a more
sustainable society. For example, If has regularly
published an extreme weather report in Norway – the
previous one was published in 2023 and the next is
planned for 2025. The report is prepared together with
CICERO Center for Climate Research and IVL Swedish
Environmental Research Institute. The report
investigates how well Norwegian municipalities are
prepared for extreme weather. Topdanmark, under the
auspices of Insurance & Pension Denmark, provides
data to help the Danish municipalities identify the
largest risk areas in relation to extreme weather, such as
heavy rainfall.
Metrics and targets
Targets related to climate change mitigation
and adaptation
Sampo Group’s climate targets are aligned with the
SBTi’s methodology, which supports the Paris
Agreement. This approach is in line with the policy
objectives stated in the Sampo Group Code of Conduct.
Sampo Group’s target for own operations (Scope 1 and
2 emissions) follows the absolute contraction approach.
Sampo Group’s target boundary includes all Sampo
Group companies. Only minor offices have been
excluded from the boundary as emissions from these
are deemed insignificant. The market-based approach
was used to calculate the Scope 2 GHG emissions
included in the target.
The targets for the listed equity, corporate bond, fund,
ETF, and corporate loan investment portfolio have been
set using the temperature rating approach and the
target for the commercial real estate portfolio using the
sectoral decarbonisation approach. Sampo Group’s
portfolio targets cover 57.9 per cent of its total
investment and lending by total assets as of 2022. As of
that year, required activities made up 57.9 per cent of
Sampo Group’s total investment and lending by total
assets, while optional activities made up 5.6 per cent
and out-of-scope activities made up 36.5 per cent.
Sampo Group has had dialogue with several
stakeholders when committing to the SBTi and setting
the targets. These have included, for example, investors,
large corporate customers, and the company’s
management and boards of directors. Progress against
Sampo Group’s targets will be monitored regularly
internally and reported externally in the sustainability
statement.
There were no changes in the targets during the
reporting year. The Scope 1 and 2 GHG emissions for the
baseline year 2022 and comparative year 2023 were
recalculated to reflect changes in the reporting
boundary (e.g. Mandatum and Topdanmark Life were
excluded from the boundary). In addition, errors related
to data collection were corrected. Also, the GHG
emissions of investments (Scope 3, category 15) were
recalculated for the baseline year 2022 and
comparative year 2023 to align with other regulatory
frameworks (e.g. the EU Taxonomy).
BOARD OF DIRECTORS’ REPORT 2024
83
Science-based targets
Sampo Group
Scope
Target
2024 results
Own operations
(Scope 1 and 2)
• Sampo Group commits to reduce absolute scope 1 and 2 GHG emissions by 42
per cent by 2030 from a 2022 base year.
• Sampo Group’s SBTs were approved in November 2024. The Group will start
reporting on its progress against the targets from the year 2025 onwards.
Investments
(Scope 3, category 15)
• Sampo Group commits to align its scope 1 + 2 portfolio temperature score by
invested value of its listed equity, corporate bond, fund, ETF and corporate
loan portfolio from 2.78°C in 2022 to 2.09°C by 2029.
• Sampo Group commits to align its scope 1 + 2 + 3 portfolio temperature score
by invested value of its listed equity, corporate bond, fund, ETF and corporate
loan portfolio from 2.91°C in 2022 to 2.29°C by 2029.
• Sampo Group commits to reduce its real estate direct investment and
corporate loan portfolio GHG emissions by 57.7 per cent per square meter by
2029 from a 2022 base year.
• Sampo Group’s SBTs were approved in November 2024. The Group will start
reporting on its progress against the targets from the year 2025 onwards.
Suppliers*
(Scope 3, category 1)
• If: 30 per cent of suppliers by spend, covering purchased goods and services,
will have science-based targets by 2028.
• Topdanmark: 20 per cent of suppliers by spend, covering purchased goods and
services, will have science-based targets by 2028.
• If: 15.8 per cent
• Topdanmark: 17.1 per cent
* Sampo Group has set SBTs in accordance with the SBTi’s sector-specific guidelines for the financial sector, which require companies to set targets for own operations (Scopes 1 and 2) and investments
(Scope 3, category 15). In addition, Sampo Group has voluntary climate targets for its supply chain on a subsidiary level.
GHG emissions intensity (total GHG emissions per net revenue)
Sampo Group
GHG intensity per net revenue
2023
(Comparative)
2024
% 2024 / 2023
Total GHG emissions (location-based)
per net revenue (tCO2eq/EUR)
0.000044
0.000035
-21.5%
Total GHG emissions (market-based)
per net revenue (tCO2eq/EUR)
0.000045
0.000035
-21.6%
The denominator used when calculating the GHG emissions intensity is the Total insurance revenue
(Sampo Group’s Financial Statements, Statement of profit and other comprehensive income and
Note 1 Insurance service result).
Biogenic emissions
Sampo Group
Metric
2024
Scope 1 (tCO2eq)
170
Scope 2, market-based (tCO2eq)
2,768
Scope 3 (tCO2eq)
97
Total biogenic emissions
3,035
Biogenic emissions arise from direct combustion of biomass or biodegradation. In Sampo Group’s
reporting these emissions are accounted for in Scopes 1, 2, and 3 in cases where the combusted
fuel is assumed to have a portion of biomass. The biogenic emissions are not included in the GHG
emissions reported on page 84.
BOARD OF DIRECTORS’ REPORT 2024
84
Gross Scopes 1, 2, 3 and Total GHG emissions
Sampo Group
Retrospective
Milestones and target years
2022
(Base year)
2023
(Comparative)
2024
% 2024 / 2023
2025
2030
(2050)
Annual
% target /
base year
Scope 1 GHG emissions
Gross Scope 1 GHG emissions (tCO2eq)
1,197
1,115
883
-20.9%
-42%*
Percentage of Scope 1 GHG emissions from regulated
emission trading schemes (%)
-
-
-
-
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions (tCO2eq)
2,482
1,738
1,886
8.5%
Gross market-based Scope 2 GHG emissions (tCO2eq)
4,789
4,111
3,570
-13.2%
-42%*
Significant Scope 3 GHG emissions
Total gross indirect Scope 3 GHG emissions (tCO2eq)
353,054
370,412
326,376
-11.9%
1 Purchased goods and services
2,017
1,652
14,493
777.3%
[Optional sub-category: Cloud computing and data
centre services]
-
-
-
-
2 Capital goods
111
2,247
2,843
26.5%
3 Fuel and energy-related activities (not included in
Scope 1 or Scope 2)
1,555
1,432
1,244
-13.1%
4 Upstream transportation and distribution
-
52
456
773.3%
5 Waste generated in operations
273
232
260
12.2%
6 Business travelling
5,592
6,306
6,318
0.2%
7 Employee commuting
5,141
6,712
6,860
2.2%
8 Upstream leased assets
-
-
-
-
9 Downstream transportation
-
-
-
-
10 Processing of sold products
-
-
-
-
11 Use of sold products
-
-
-
-
12 End-of-life treatment of sold products
-
-
-
-
13 Downstream leased assets
-
139
41
-70.2%
14 Franchises
-
-
-
-
15 Investments
338,364
351,641
293,860
-16.4%
Total GHG emissions
Total GHG emissions (location-based) (tCO2eq)
356,733
373,266
329,145
-11.8%
Total GHG emissions (market-based) (tCO2eq)
359,039
375,638
330,828
-11.9%
The figures for 2022 and 2023 were recalculated to reflect changes in the reporting boundary and correct errors in data collection. For investments, the calculation method was aligned with other
regulatory frameworks (e.g. the EU Taxonomy) and the current Group structure. The increase in Sampo Group’s Scope 3 GHG emissions in 2024 was mainly due to improved data quality and calculation
methods, particularly at Hastings, and changes in emission factors.
Category 15 Investments concerns Sampo Group’s financed emissions for Scopes 1 and 2. Investment categories included in the calculations are direct equity and fixed income investments and fund
investments. The coverage was 74.2 per cent of Sampo Group’s financial assets (including associated companies). Sampo Group’s Scope 3 financed emissions were 4,020,003 tCO2eq in 2024.
* Sampo Group has a combined near-term target for Scope 1 and Scope 2 (market-based) emissions. Sampo Group’s emission reduction targets and results are disclosed in detail on page 83.
BOARD OF DIRECTORS’ REPORT 2024
85
Emission factors and calculation details
Sampo Group
Activity
Calculation details
Emission factor reference
Stationary combustion
Stationary combustion includes combustion of natural gas (If, Topdanmark, and
Hastings), biogas (Hastings), gas oil (Hastings), and fuel oil (If).
DESNZ 2024
Mobile combustion
Mobile combustion is calculated based on litres of fuel or kilometres driven,
depending on the availability of data. If data is unavailable, the data is
extrapolated based on the number and type of cars. The estimated fuel
consumption per vehicle is based on national statistics.
DESNZ 2024; South Pole derived based on Drivmedel 2022 (diesel) and
Värmeforsk 2023 (petrol)
Refrigerants
The calculation is based on the consumption of refrigerants (Hastings).
DESNZ 2024
Electricity
The calculation is based on purchased electricity (MWh). For smaller offices,
the electricity consumption is extrapolated based on average consumption per
FTE or office area (m2). The residual mix emission factors used for the market-
based method are higher than the emission factors for the location-based
method, leading to market-based emissions being higher than location-based
emissions.
AIB 2023; DESNZ 2024; Ecoinvent v3.10; EI 2023; IEA electricity emission
factors 2023; IPCC, 2014
District heating
Purchased district heating (MWh) is reported by If, Topdanmark, and Sampo.
For smaller offices, district heating is extrapolated based on average
consumption per FTE or office area (m2).
Euroheat & Power, 2023; Finnish Energy Statistics 2023; Swedenergy 2023;
supplier-specific emission factors
District cooling
Purchased district cooling (MWh) is reported by If and Sampo. For smaller
offices, district cooling is extrapolated based on average consumption per FTE
or office area (m2).
South Pole derived average based on suppliers, 2023; supplier-specific
emission factors
Purchased goods and
services
Purchased goods and services includes water (m3), paper (tonnes), and cloud
services (number of users) in all Group companies. Topdanmark reports on
some office supplies (e.g. plastic items) and Sampo on food services. Hastings
reports the financial records of its purchased goods and services. The
calculations are based on supplier-specific, hybrid, average data, and spend-
based methods.
AIB 2023; CEDA 4.01 Global; Cloud Carbon Footprint, 2021; DESNZ 2023;
Ecoinvent v.3.3.8 2021; EI 2022, Ecoinvent v.3.9.1.; Google, 2012; Amazon, 2021;
IPCC, 2014; Microsoft, 2021; SCA Ortviken 2012; Mondi, 2022
Capital goods
Capital goods includes purchased IT equipment (number and model of devices)
and larger renovations (cost).
CEDA 4.01 Global; supplier-specific emission factors
Fuel and energy-related
activities
Fuel and energy-related activities are calculated with the supplier-specific
method, average method, and hybrid method.
Ecoinvent v3.10; national statistics
Upstream transportation
and distribution
Upstream transportation includes letters sent to customers. The calculation is
based on the number of letters and the destination.
DESNZ 2024 (road and air freight); CEDA 4.01 Global
Waste generated in
operations
Waste data is only available for larger offices. For smaller offices, data is
extrapolated based on average consumption per FTE or office area (m2).
ADEME 2023 BC V8.9; DESNZ 2023 and 2024; Ecoinvent v3.9 and 3.10; World
Bank waste statistics 2024
Business travelling
Business travelling includes travel by air, train, ferry, bus, staff cars, rental cars,
and taxis, as well as hotel accommodation. The calculations are based on
activity or spend data. Emissions from hotel stays are calculated with country
or city-specific emission factors.
CEDA 4.01 Global; DESNZ 2024; Cornell Hotel Sustainability Benchmark Index
2023; RDC flight data 2024
Employee commuting
The category Employee commuting also includes remote working and is based
on a survey, which was conducted in all Group companies. The survey was
either sent out to all employees or targeted groups and the results were
extrapolated to represent all employees.
Anthesis 2021, DESNZ 2024 (WFH assumptions); IEA electricity emission
factors 2023; national statistics
Downstream leased
assets
The category Downstream leased assets is reported by Topdanmark. The
calculation is based on consumption data (electricity, natural gas) and the
actual size of the leased location during the period January–June 2024.
AIB 2023; Ecoinvent v3.10; DESNZ 2023
BOARD OF DIRECTORS’ REPORT 2024
86
Calculation principles and assumptions
Sampo Group’s GHG emission calculations include If
(Nordic and Baltic offices), Topdanmark (Danish
offices), Hastings (UK and Gibraltar offices), and Sampo
(Finnish office). An external data provider, South Pole,
conducts the calculations based on data provided by
Sampo Group. The data inventory, emission factors, and
assumptions are based on the GHG Protocol, and
include the main greenhouses gases CO2, CH4, N2O, SF6,
HFCs, PFCs, and NF3 converted to CO2 equivalents. The
selection of assumptions and emission factors follows a
conservative approach. Where activity or spend data
for the inventory is lacking, extrapolations and
estimations are used.
The data behind Sampo Group’s Scope 3 category 1–14
emissions consists of 49.0 per cent primary data and
51.0 per cent secondary data. Primary data includes
data from directly reported activities (e.g. fuel
consumption), supplier-specific data (e.g. IT equipment
reported with supplier information), and the employee
commuting survey. Secondary data includes spend-
based (e.g. services) and extrapolated data (e.g. office
waste). Regarding Scope 3 category 15 (investments),
out of all investments covered by the data provider,
66.4 per cent is based on primary data, i.e. emissions
reported by investees, and 33.6 per cent is based on
secondary data, i.e. estimations.
Emissions from vehicle and property repairs in claims
handling have been estimated using data from 2021. An
external research institute commissioned by If
calculated the emissions using the life cycle assessment
methodology (LCA) and a mix of primary and
secondary data from a representative number of vehicle
and property claims cases. Spend data from claims was
used to estimate the total emissions for vehicle and
property repairs. If’s estimated emissions for vehicle and
property repairs amounted to 88,618 tCO2eq. These
emissions are not currently included in Sampo Group’s
Scope 3 inventory (category 11 Use of sold products)
due to the level of uncertainty, but may be included in
the future as reporting and data quality develop.
Scope 3 categories 8 Upstream leased assets, 9
Downstream transportation, 10 Processing of sold
products and 12 End-of-life treatment of sold products
are not considered relevant for Sampo Group as the
energy use for leased assets (vehicles and IT
equipment) is accounted for in Scopes 1 and 2, its
operations do not include activities where non-paid
transportation and distribution apply, and the Group
does not sell tangible products. The relevance of
category 14 Franchises will be further investigated in
2025.
The calculation methodology for Sampo Group
investments’ GHG emissions follows the GHG Protocol’s
investment-specific method. The emissions from
investments are allocated to Sampo Group based on its
proportional share of investments in investee
companies. The proportional share is calculated by
using Enterprise Value Including Cash (EVIC) to
represent the total value of each investee company. The
absolute GHG emissions of investee companies are
collected using an external service provider, Bloomberg
L.P., where the primary source used is company
reported emissions followed by estimated emissions.
The scope of investments' GHG emissions includes
Sampo Group’s financial assets and investments in
associates. Due to the lack of reliable data, Sampo
Group did not obtain GHG emissions data for its
sovereign exposure and derivatives. Moreover, the data
provider does not cover all investment assets (e.g.
private companies). Due to these data gaps, the
coverage was 74.2 per cent of Sampo Group’s financial
assets (including associated companies). Sampo Group
has not used its own estimations for financed emissions
yet as the data coverage by the external data provider
has been relatively good and using estimates would
affect the data quality. Hence, Sampo Group uses the
transitional provision for not including information from
the value chain. In order to fill the gaps, Sampo Group
will evaluate the possibility to use extrapolation as a
way of estimating the missing emissions data in the
future.
The GHG emissions for the year 2024 are not validated
by an external body other than the assurance provider
of this Sustainability Statement.
BOARD OF DIRECTORS’ REPORT 2024
87
Resource use and circular economy
Topic
Impacts
Risks and opportunities
Strategy and actions
Resource use and
circular economy
↓ Sampo Group has a negative impact on the
environment as it uses resources, for example, in its
claims handling operations (e.g. construction
material, car parts). By recycling and increasing the
number of reused parts in claims handling, Sampo
Group can limit the negative environmental impact.
Time-horizon: short, medium and long term
↑ Increasing circular economy-based resource flow in
claims handling can create cost savings for Sampo
Group, for example, through purchasing of reused
parts instead of new ones and reselling of used
materials instead of disposing.
↓ There is a risk of reputational damage and added
costs if Sampo Group fails to seize opportunities
related to circular economy. This is, for example,
due to difficulties in finding or using recycled or
reused materials.
Time-horizon: short, medium and long term
• Internal policies and guidelines (e.g. supplier codes
of conduct)
• Effective governance structures and processes (e.g.
recycling, reuse and repair in claims handling,
sustainable supply chain management)
• Metrics and targets (e.g. reused parts, glass repairs)
The table presents Sampo Group’s material impacts, risks, and opportunities related to resource use and circular economy identified in the double materiality assessment and their connection to Sampo
Group’s strategy and actions. The topics are linked to the ESRS sub-topics. The topic Resource use and circular economy is related to the ESRS sub-topic Resource inflows, including resource use.
BOARD OF DIRECTORS’ REPORT 2024
88
Impact, risk, and opportunity
management
Policies related to resource use and circular
economy
The group level policy regarding resource use and
circular economy is the Sampo Group Code of Conduct,
which is reviewed annually and approved by Sampo’s
Board of Directors. The Code of Conduct states that
Sampo Group should reduce the consumption of
resources (e.g. energy, water) and improve the resource
efficiency, as well as reduce pollution, emissions, and
waste generated from business operations, while
incorporating the concepts of reduction, reuse, and
recycling. The Sampo Group Code of Conduct covers all
of the Group’s own operations. Additionally, Sampo
Group expects its suppliers and other business partners
to comply with the principles of the Code of Conduct
throughout their own operations and supply chains.
In addition to the Sampo Group Code of Conduct, each
Group company has adopted its own supplementary
and more detailed policies, guidelines, and processes to
guide the work related to resource use and circular
economy in their own operations and value chain. The
Group companies have, for example, sustainability
policies to guide the work related to office space
upgrades and supplier codes of conduct, which outline
the expectations placed on suppliers with regards to
environmental considerations. The Board of Directors or
other governing body of each Sampo Group company
approves the policies in the respective company, and
the executive management is responsible for the
implementation.
Sampo Group’s supplier codes of conduct are publicly
available and are based on the 10 principles of the UN
Global Compact. The codes of conduct require
suppliers to encourage the development and diffusion
of low emission technologies that protect the
environment, are less polluting, use resources in a more
sustainable manner, recycle more of their waste and
products, and handle residual waste in a more
acceptable manner than the technologies for which
they were substitutes. Suppliers are expected to
continuously improve their climate and environmental
efforts, reduce the consumption of resources and
ensure the efficient use of these resources, and reduce
pollution, emissions and waste from business activities.
The supplier codes of conduct apply to suppliers with
whom Sampo Group conducts business, including the
suppliers’ subsidiaries and sub-suppliers. The codes also
apply to all of the suppliers’ employees, whether
permanent or temporary.
Actions and resources related to resource
use and circular economy
The most significant impacts, risks, and opportunities
regarding resource use and circular economy for
Sampo Group are related to suppliers in the company’s
downstream value chain. Sampo Group does not
produce, sell, or handle physical products requiring
natural resources, but can instead affect the resource
use in its value chain via insurance policies and claims
handling processes. P&C insurance products and
services affect the amount of resources used mainly
through the policyholders’ claims related to vehicles,
buildings, furniture, electronics, and other property.
Sampo Group’s suppliers and business partners are
central to the claims handling process, and Sampo
Group is committed to taking environmental and
climate considerations into account, for example, by
encouraging and supporting circular efforts in these
processes.
In 2024, Sampo Group cooperated with its suppliers in
claims handling to increase material reuse, recycling,
and repairs related to property and vehicle claims.
Sampo Group also continued to focus on specific
requirements it has set for its suppliers to promote
circular economy. For instance, If’s property and vehicle
repair partners must comply with the sector-specific
Additional Environmental Requirements (AER), which
are incorporated into the purchasing agreements. These
requirements include requirements to repair instead of
using new parts, reuse spare parts and repair more,
reduce material usage, demolish less, increase remote
work using video and sensors, reduce transportation,
use material with environmental certification (when
available), and increase the use of electric and hybrid
vehicles. During the year, Sampo Group also updated
existing policies (e.g. supplier codes of conduct,
sustainability policies) regarding resource use and
circular economy. These activities will continue in 2025.
BOARD OF DIRECTORS’ REPORT 2024
89
Metrics and targets
Targets related to resource use and circular
economy
Sampo Group has not set measurable, time-bound and
outcome-oriented targets for its resource use and
circular economy actions on group level. The circular
economy solutions in claims handling operations are
developing, but continue to also be subject to several
uncertainties. Therefore, Sampo Group has evaluated
that setting group level targets at this stage is not
justifiable from an environmental or financial viewpoint.
However, Sampo Group reviews processes to manage
impacts, risks, and opportunities related to resource use
and circular economy regularly, and in case it is
assessed that a group level externally disclosed target is
a valuable addition, the decision will be revisited.
Metrics related to resource use and circular
economy
Sampo Group measures the progress of its resource use
and circular economy efforts, for instance, with the
metrics presented in the table Circular economy in
claims handling (car repairs). The share of reused parts
and the share of glass repairs in car repair claims have
been selected as key metrics, as they reflect Sampo
Group’s goals of promoting circular economy and
reducing resource use. Sampo Group has chosen to
initially focus on car repairs, as the maturity of reused
parts market in this segment is higher compared to
house repairs, for instance. Sampo Group measures the
proportion of reused parts and glass repairs based on
monetary amount spent and the number of claims.
Sampo Group’s group level progress against these
metrics has been measured starting 2024. The
measurement is not validated by an external body other
than the assurance provider of this Sustainability
Statement.
Circular economy in claims handling
(car repairs)
Sampo Group
Metric
2024
Share of reused parts
4.5%
Share of glass repairs
35.3%
BOARD OF DIRECTORS’ REPORT 2024
90
Social information
Own workforce
Topic
Impacts
Risks and opportunities
Strategy and actions
Human rights and
labour practices
↓ Sampo Group can have a negative impact on
human rights and labour rights of its own
workforce, as a result of unethical labour practices
or breaching of Sampo Group’s Code of Conduct,
for example.
Time-horizon: short term
↓ Sampo Group can face a financial risk due to
increasing and tightening legislation related to
human rights and labour rights (e.g. possible fines,
reputational damage).
Time-horizon: short term
• Internal policies and guidelines (e.g. codes of
conduct, HR policies)
• Effective governance structures and processes (e.g.
reporting channels, forums for dialogue, employee
engagement surveys, collective bargaining and
freedom of association)
• Internal training and competence development
programmes
• Metrics and targets
Employee health,
wellbeing, and
competence
↑ Through Sampo Group’s wellbeing initiatives and
competence development programmes, the mental
and physical health of employees can be improved.
This in turn can have a potential positive impact on
the employees’ motivation and facilitate their
professional growth and skills advancement.
Focusing on employee wellbeing and competence
development can result in motivated and engaged
employees.
Time-horizon: short term
↓ A lack of competent employees can pose a financial
risk for Sampo Group. If employees are not
engaged and do not feel that there are
opportunities to develop competencies, talented
and unhappy employees might leave the company,
taking their skill set with them.
↓ Increased sick leaves and employee turnover, for
instance due to inadequate work-life balance, can
pose a financial risk for Sampo Group.
↑ Engaged and competent employees can create
opportunities for Sampo Group, as dedicated
employees create results by delivering first-class
customer experiences daily. For this reason,
investing in personnel practices and an empowering
work environment makes good business sense.
Time-horizon: short term
• Internal policies and guidelines (e.g. codes of
conduct, HR policies)
• Effective governance structures and processes (e.g.
activities to support physical and mental health,
workplace initiatives, quality offices, attractive
remuneration packages)
• Internal training and competence development
programmes
• Metrics and targets (e.g. employee engagement
eNPS or similar)
Diversity, equity, and
inclusion (DEI)
↑ Sampo Group can have a positive impact on DEI in
its own workforce as a result of the actions taken
by the Group. Emphasising DEI can cultivate a
sense of belonging amongst employees.
Time-horizon: short term
↓ If Sampo Group's own workforce is not diverse, the
Group may not be able to serve its diverse
customer base, which can create a financial risk
through lower productivity or innovation, for
example.
↑ DEI can create financial opportunities for Sampo
Group, as companies performing well in this area
can be more innovative and profitable, and attract
talent.
Time-horizon: short term
• Internal policies and guidelines (e.g. codes of
conduct)
• Effective governance structures and processes (e.g.
diversity models/programmes, employee initiatives,
reporting channels)
• Internal training and competence development
programmes
• Metrics and targets (e.g. related to gender
diversity)
The table presents Sampo Group’s material impacts, risks, and opportunities related to own workforce identified in the double materiality assessment and their connection to Sampo Group’s strategy and
actions. The topics are linked to the ESRS sub-topics. The topic Human rights and labour practices is related to the ESRS sub-topics Working conditions and Other work-related rights. The topic Employee
health, wellbeing, and competence is related to the ESRS sub-topics Working conditions, Equal treatment and opportunities for all, and Other work-related rights. The topic Diversity, equity, and inclusion is
related to the ESRS sub-topics Equal treatment and opportunities for all and Other work-related rights.
BOARD OF DIRECTORS’ REPORT 2024
91
Strategy
Material impacts, risks, and opportunities
and their interaction with strategy and
business model
Engaged employees are an instrumental part of Sampo
Group’s strategy and business model. Sampo Group’s
business activities depend on the company’s ability to
create an empowering work environment and on the
employees’ motivation to contribute to the company’s
goals. The dedication and expertise of the workforce
drive customer satisfaction and are the foundation of
competitive advantage. The interests, views, and rights
of Sampo Group’s employees inform strategic decisions
and shape the corporate culture.
When assessing material impacts on its own workforce,
Sampo Group considers all types of employees who
may face significant impacts from the company’s own
operations or value chain. This encompasses
permanent, temporary, full-time, and part-time
employees, and non-employees. For example, the
double materiality assessment, human rights impact
assessment, and employee engagement surveys inform
the Group which types of employees or employee
groups in its own workforce may be at greater risk of
negative impacts. These can include underrepresented
groups (e.g. based on ethnic background, gender,
sexual orientation, disabilities) and employees working
in high pressure environments (e.g. contact centres).
Within Sampo Group, potential negative impacts
related to its own employees may be tied to individual
incidents rather than systemic human rights issues.
Sampo Group has identified potential risks stemming
from a lack of diversity (e.g. lack of representation of
minority groups), discrimination within the workforce as
well as higher illness statistics and employee turnover in
certain parts of the Group (e.g. contact centres). These
factors may limit the ability to serve a diverse customer
base in the best possible way and thus impact the
Group’s financial performance.
Impact, risk and opportunity
management
Policies related to own workforce
Sampo Group’s policy related to its own workforce is
the Sampo Group Code of Conduct, which is reviewed
annually and approved by Sampo’s Board of Directors.
The Code of Conduct covers topics such as human
rights and la bour practices, employee health, wellbeing,
and competence development, as well as DEI. The Code
of Conduct prohibits forced and compulsory labour,
child labour, and human trafficking and requires the
Group companies to take measures to identify, avoid
and/or tackle such human rights violations in their own
operations and value chain. When developing the Code
of Conduct, Sampo Group consults both internal (e.g.
employees, management) and external stakeholders
(e.g. investors, rating agencies, authorities, external
consultants), depending on need.
The Code of Conduct applies to all Sampo Group
companies and in all countries of operation. The
operative management in each Sampo Group company
is responsible for the implementation of the Code of
Conduct and it is the personal responsibility of every
Sampo Group employee to comply with the Code.
Sampo Group offers regular training (e.g. e-learning,
workshops) on the topics covered by the Code of
Conduct. The Code of Conduct is available to all
stakeholders on Sampo Group’s website. In addition to
the Code of Conduct, each Group company has
adopted supplementary policies and guidelines for their
own purposes.
Sampo Group complies with all applicable human rights,
labour rights, and employment legislation. In addition to
national laws and regulations, Sampo Group is
committed to respecting human rights as set out in the
International Bill of Human Rights including the
Universal Declaration of Human Rights, the International
Covenant on Civil and Political Rights, the International
Covenant on Economic, Social and Cultural Rights, and
those stated in the core conventions of the International
Labour Organization (ILO). Sampo Group is a
participant in the UN Global Compact, and respects the
principles related to human rights and labour rights.
Sampo Group’s policies and related training are part of
the commitment to maintain open channels of
communication with its own workforce and to
objectively address human rights impacts that could
potentially arise within the operations, ensuring the
provision of suitable remedial actions, when necessary.
Remedy may be provided, for example, in the form of
support from HR, employee representatives, and health
and safety delegates, insurance cover, and rehabilitation
depending on the type of adverse impact and local
regulations.
Sampo Group engages with its own workforce regularly
and has multiple channels for this purpose. More
information is available under the headings Processes
for engaging with own workers and workers’
representatives about impacts (p. 92) and Interests and
views of stakeholders (p. 64).
BOARD OF DIRECTORS’ REPORT 2024
92
Employee health, wellbeing, and competence
Sampo Group has health and safety policies addressing
workplace accident prevention, and the company
provides occupational health care in accordance with
the legislation in each operating country. Sampo Group
investigates health and wellbeing risks regularly and
takes preventive action to mitigate potential risks, when
considered relevant. All Sampo Group companies
perform risk assessments, and any incidents and risks
detected are handled accordingly and reported in the
relevant incident reporting tools. Along with employee
surveys, the risk assessments and incident reports
provide valuable indications to further develop the
business processes and work environment.
Sampo Group has work environment committees (or
similar) set up in accordance with local legislation.
These committees’ responsibilities include monitoring
the work environment, developing health and safety
procedures, and ensuring a high quality of physical and
psychosocial wellbeing. The duties of the work
environment committees can vary between the Group
companies.
Sampo Group has a comprehensive learning offering
available to all employees, starting from onboarding
processes. Sampo Group offers mandatory training (e.g.
the training requirements of the Insurance Distribution
Directive), voluntary training (e.g. digital skills, language
studies), and training in collaboration with external
suppliers. The training options depend on which part of
the organisation the employees work in. Some trainings
are mandatory for all employees (e.g. Code of Conduct
training, compliance training, information security and
data privacy training), and others are part of annual
training cycles.
Over the years, Sampo Group has seen a growth of
community-driven competence development
opportunities. Employees have engaged in specialist
academies, where they create their own learning paths
according to their interests and professional
competence needs.
Diversity, equity, and inclusion
Sampo Group respects each individual’s human rights
and does not tolerate any kind of discrimination,
bullying, harassment, or any other type of abusive
behaviour. The Code of Conduct states that
discrimination is strictly prohibited, for example, on the
grounds of age, disability, national extraction or social
origin, racial and ethnic origin, colour, family
commitments, gender, gender identity, political opinion,
employees’ representative activities, religion, sensitive
medical conditions, sexual orientation, or any other
personal characteristics. In addition, discriminatory
practices regarding recruitment, job assignment,
training and development, promotion, remuneration
and other benefits, or general conduct in the workplace
are not tolerated. Reported cases related to
discrimination and harassment are investigated and
corrective action is taken.
At Sampo Group, it is important that all employees feel
included and can be themselves at work. All Group
companies have DEI policies and/or programmes and
have taken action to raise awareness and address DEI
and vulnerable groups within their own workforce. DEI
topics are advanced, for example, through internal
employee communities or diversity boards, setting
company-specific diversity targets, and promoting DEI
in recruitment and the leadership pipeline.
Processes for engaging with own workers
and workers’ representatives about impacts
Sampo Group engages regularly and directly with
employees and their representatives to gain insight into
the employees’ perspectives, receive feedback, and
identify development needs. All Sampo Group
companies have decided on the highest level of
responsibility for engagement based on their respective
organisational structures. Forums for dialogue include,
for example, leader-employee dialogues, work
environment councils, meetings with union
representatives, exit interviews, and employee
engagement surveys. In addition, employees can raise
concerns through whistleblowing channels and internal
reporting channels.
The employee engagement surveys cover the physical
and psychosocial work environment. The surveys
address questions related to wellbeing and DEI, and the
results are also examined according to demographic
groups, including minority groups. Aggregated data
from the surveys allow management teams to identify
development areas, set targets, and measure the
effectiveness of implemented actions. Leaders discuss
the results with their teams, with the support of HR if
needed, and take relevant action. In addition to the
employee engagement surveys, Sampo Group aims to
gain insight into the perspectives of vulnerable groups
through different company and employee-driven
initiatives around the topics of disabilities, women in the
workforce, language, and inclusion of different cultures
and religions, for example.
BOARD OF DIRECTORS’ REPORT 2024
93
Processes to remediate negative impacts
and channels for own workers to raise
concerns
Sampo Group strives for a constructive and trustful
dialogue with employees and their elected
representatives, such as unions, with the purpose of
developing the company and safeguarding the correct
treatment of all employees. Sampo Group promotes a
culture of open discussion in which grievances can be
aired and addressed proactively. Employees are
encouraged to report unethical practices or possible
violations of laws, regulations, or internal policies
directly, for example, to a leader, HR, union
representative, compliance units, or through the
reporting channels.
Sampo Group systematically monitors employee
feedback received through, for example, employee
surveys and reporting channels. Sampo Group ensures
that actionable insights are addressed through
formalised HR processes and leadership review. In
addition to the internal reporting channels, Sampo
Group has externally managed whistleblowing channels
through which employees and other stakeholders can
raise concerns anonymously.
Any incident breaching the Code of Conduct will be
investigated and the need for corrective action
assessed on a case-by-case basis. Information about the
different channels is available on the company intranets
and communicated to employees during onboarding
and regularly through internal communications
campaigns.
The effectiveness of the different channels and the
employees’ willingness to openly voice opinions and
misconduct are assessed, for example, through the
employee engagement surveys. Processes for handling
whistleblowing cases are discussed in the section
Business conduct (p. 116).
Taking action on material impacts on own
workforce, and approaches to mitigating
material risks and pursuing material
opportunities related to own workforce, and
effectiveness of those actions
Through the policies and processes described earlier,
such as the Sampo Group Code of Conduct, Sampo
Group aims to ensure that its employees are not subject
to material negative impacts. In case of a negative
impact occurs, Sampo Group’s remediation processes
are followed. The Group investigates all suspected
breaches on a case-by-case basis to determine the
actions needed in response. Sampo Group engages with
relevant internal stakeholders (e.g. HR, Legal,
Compliance) in developing an action plan to address
potential negative impacts, as well as assessing the root
cause of the incident and preventative measures to be
taken going forward.
In 2024, Sampo Group provided training on the topics
covered by the Code of Conduct and other company-
specific policies to all new and existing employees. The
aim is to ensure that all Sampo Group employees are
aware of and act in accordance with the Group’s
policies for human rights and labour practices.
During 2024, Sampo Group conducted a human rights
impact assessment, which included an analysis of
potential human rights risks on the Group’s own
employees. The assessment covered risks related to
Sampo Group’s own operations across the Nordics, the
Baltics, and the UK, and also included non-employees,
where relevant. Based on the assessment, Sampo Group
mapped its due diligence measures in order to identify
whether appropriate processes were in place for
preventing the identified risks. The assessment is
reviewed regularly and updated based on need.
Sampo Group wants to be an attractive and responsible
employer, and invests in creating a corporate culture
which nurtures health and wellbeing, work-life balance,
and career development. Sampo Group offers, for
example, flexible working hours and hybrid work,
sports, volunteering, occupational health services, and
training and career development. Sampo Group
monitors the effectiveness of these measures, for
example, through employee engagement, turnover, and
other health and safety metrics. The main responsibility
for managing material impacts lies with the respective
HR functions who work with the business to ensure that
employees are not negatively impacted and seek to
maintain or strengthen positive impacts.
Employee health, wellbeing, and competence
In 2024, Sampo Group conducted regular employee
engagement surveys, which provide opportunities for
employees to share feedback on a range of subjects.
The surveys enable Sampo Group to identify any issues
and opportunities related to its employees. The
feedback is analysed, and Sampo Group aims to make
improvements to the most material matters. Sampo
Group tracks the effectiveness of actions taken through
analysis of future survey responses. Based on feedback
received, If, for example, paid special attention to
activities which build a strong feedback culture to
strengthen organisational, team, and personal growth
during 2024. Communication activities focused, among
other things, on building awareness and sharing good
feedback practices and tools. During the year, due to
Sampo’s acquisition of Topdanmark and the following
integration with If, Topdanmark conducted two
additional employee engagement surveys to closely
follow the employees’ mental wellbeing in times of
organisational change. These surveys helped identify
specific areas that needed attention and further
communication (e.g. fear of job loss, fear of losing close
colleagues).
BOARD OF DIRECTORS’ REPORT 2024
94
Employee health and wellbeing remained a high priority
for Sampo Group in 2024. At Sampo Group, the mental
and physical wellbeing of employees is managed by
implementing preventative measures (e.g. wellbeing
campaigns and webinars, preventative occupational
healthcare, good design of offices, financial advice),
focusing on work–life balance (e.g. workplace flexibility,
working time reduction, dependent care, special leave),
offering employees meaningful work assignments,
education, and organising team activities and sports
programmes. The actions have been directed at all
employees of the individual Group companies.
During 2024, Sampo Group continued to develop the
hybrid working model and flexible working options to
better incorporate the employees’ needs and
preferences. This was done, for instance, by investing in
IT infrastructure and equipment, redesigning office
spaces, and training leaders in remote leadership.
During the year, Sampo Group tested Microsoft 365
Copilot to learn about the product and take advantage
of the opportunities it can bring to the workforce. At
Topdanmark, the re-design of office spaces focused on
accommodating employees with neurodiverse
challenges. This meant having the right lighting and
designing workspaces to reduce visual and auditory
noise. The adaption of the physical workspace to
accommodate all employees was done to mitigate the
risk of losing skilled employees due to a lack of sense of
belonging, but also to secure the inclusion of all
employees. This work will continue in 2025.
In 2024, Sampo Group’s key activities for enabling a
positive impact on employee competence included
investments in digitalisation and development of tools
to support employees in their work, reinforcing
resources dedicated to competence development,
organising learning events, and updating employee
courses and competence development processes. For
instance, If continued to develop the mandatory
learning programme One Responsible If. The
programme deals with key ethical and practical
guidelines, such as those outlined in If’s Ethics and
Sustainability policies. In addition, it includes an e-
course on incident reporting with the aim to ensure that
all employees are aware of the channels and the types
of incidents that should be reported. Also, Hastings’
Early Careers programme continued, offering
apprenticeships, graduates, and other scheme
opportunities. A Leadership Excellence pilot
programme was also implemented at Hastings,
providing leaders and employees with skills and tools to
support their existing roles, create a consistent standard
of leadership, and develop their careers. Sampo Group’s
development programmes aim to provide positive
impacts across its own workforce. In 2025, Sampo
Group will continue its efforts to promote opportunities
for employees to develop their knowledge and roles.
For example through the above mentioned actions,
Sampo Group actively manages the financial risks
deriving from potential failure to adequately foster the
employees’ health, wellbeing, and competence
development. Having dedicated employees also allows
for better customer interactions and is thus an
opportunity for the Group. Going forward, the goal is to
further support the employees’ mental and physical
wellbeing, and allow for new professional development
opportunities.
Diversity, equity, and inclusion
In 2024, Sampo Group focused on DEI, for example,
through equal pay and equitable working conditions for
all employees. These were exhibited through different
initiatives taken by the Group.
During the year, Sampo Group initiated several projects
related to equal pay, which included, for example,
reviews of job architecture and pay grades,
improvement of existing systems, improvement of
internal reporting processes to obtain timely salary
data, and development of policies and recruitment
practices. The projects continue in 2025 to ensure the
Group's ability to comply with the new EU regulation on
Equal Pay for Equal Work or Work of Equal Value
Between Men and Women in 2026, for example.
In 2024, Sampo Group and its employees hosted DEI
events and forums (e.g. Hastings’ Inclusion Council and
DEI awareness campaigns), organised training (e.g. If
trained all leaders in competence-based interview
techniques to reduce unconscious bias), and took part
in initiatives (e.g. Hastings’ 30% Club training
programme). While aimed at creating positive impacts
on Sampo Group’s employees, these also contribute to
the management of DEI-related risks and opportunities
the Group has identified. The actions have been
directed at all employees of individual Sampo Group
companies.
Sampo Group’s DEI work is also communicated in job
advertisements, and recruitment processes are
developed to include different types of assessments,
including the use of personality tests, case
presentations, structured interview guidelines,
references, and a four-eye-principle to avoid decisions
being influenced by unconscious bias and
BOARD OF DIRECTORS’ REPORT 2024
95
discrimination. For example, If developed its existing
employer branding initiatives to incorporate more of
the company’s DEI work in 2024. In 2025, If continues
to examine the employer brand, to appeal to a more
diverse workforce, which is impacted by societal trends
such as immigration and generational values.
Going forward, Sampo Group will continue its efforts in
relation to DEI. The plan is to improve methods to
develop inclusive leadership, which contributes to
increased psychological safety. Sampo Group will also
focus on neurodiversity and disability through various
activities, which include forming communities of best
practice that can be consulted to make decisions more
inclusive. These actions aim at fostering a diverse and
inclusive culture and collecting insights to further
enhance equal treatment of employees. Furthermore,
they support Sampo Group in ensuring compliance with
its Code of Conduct and zero tolerance for
discrimination.
Metrics and targets
Targets related to managing material
negative impacts, advancing positive
impacts, and managing material risks and
opportunities
Sampo Group has set time-bound and outcome-
oriented targets for employee engagement surveys to
address impacts, risks, and opportunities related to
employee safety, wellbeing, competencies, and
diversity, for example. These themes are aligned with
the policy objectives stated in the Sampo Group Code
of Conduct, which aim at providing encouraging and
rewarding working conditions, as well as fair and equal
treatment.
The employee engagement results are based on
surveys that employees fill out to assess their
experience of working at a Sampo Group company.
Employee engagement surveys are conducted at
subsidiary level instead of group level to ensure the
suitability of the surveys for each Group company and
its individual needs and characteristics. The
engagement surveys are sent out to all employees who
have an active employment contract with Sampo Group
when the survey is conducted. The surveys are
conducted at least annually, and the results are
reported to the respective management teams.
Sampo Group has set the employee engagement
targets using internal and external benchmarking and
historical data, for example. To assess the level of
results, Sampo Group monitors trends internally and,
when possible, compares the results to industry
averages within its operating countries. Meeting the set
targets can be considered as an excellent performance.
In addition to the top management of the Sampo Group
companies, representatives from different parts of the
Group have been involved in drafting the employee
engagement targets. The targets are also discussed
with union representatives, and external stakeholders’
feedback is considered, where relevant. The results of
the employee engagement surveys and other data
related to own workforce are used by the management
teams of the Sampo Group companies as input into the
organisational development processes.
Employee engagement
Sampo Group
Survey
Scale
Target
2024
H1
H2
If: HeartBeat
-100–100
2024: 50
52
54
Topdanmark:
Ennova
Enagagement
Survey
-100–100
2025: 79
80
80
Hastings: Your
Voice
0–100
2024: 72
77
78
Sampo plc:
Work Life
Survey
-100–100
-
-
42
The surveys are company-specific and not comparable to each
other. Sampo’s survey is conducted annually in autumn. For If,
Topdanmark, and Sampo, the scale is from -100 to 100. In
general, scores above zero can be considered good/positive,
while those above 50 can be considered excellent. However,
score levels can vary according to industry and organisational
type, for example. For Hastings’ survey, results above 70 can be
considered as high.
BOARD OF DIRECTORS’ REPORT 2024
96
Calculation principles
Metrics related to own workforce are reported
according to the requirements of the ESRS standard.
The calculations are based on either headcount or full-
time equivalent (FTE) and the method used is disclosed
in conjunction with each metric. Hourly paid employees,
summer workers, non-employees, and trainees are
excluded from the headcount and FTE calculations. For
FTE, the work time is adjusted in case an employee is
on a longer leave, such as parental leave. Year-end
figures are used in reporting unless otherwise indicated.
Sampo Group only collects information on binary
gender due to legal restrictions and lack of system
support and, therefore, reporting includes data on
women and men only. More specific calculation
principles are described alongside the metrics.
The metrics for own workforce have not been validated
by an external body other than the assurance provider
of this Sustainability Statement. There are no figures
related to own workforce in the Sampo Group Financial
Statements.
Characteristics of the undertaking’s
employees
As at 31 December 2024, the total number of
employees at Sampo Group was 15,581. The number of
employees increased slightly in all Group companies
during the year. The increase was the highest at
Hastings, in the UK, due to business growth.
In 2024, the majority of Sampo Group’s employees
worked in the UK, Denmark, Sweden, Finland, and
Norway. The share of women was slightly higher
compared to men, but overall the binary gender
balance was relatively equal. Sampo Group’s employees
were mainly employed full-time on permanent contracts
at the end of the year.
Headcount is used for calculating the total number of
employees, non-guaranteed hours employees, full and
part-time employees, and permanent and temporary
employees. A small number of employees work in what
is called ‘Other countries’ in Group reporting. These
countries have been combined in reporting due to the
size of operations in these countries. ‘Other countries’
includes Spain, Gibraltar, France, Germany, the
Netherlands, and the United States.
In 2024, Sampo Group’s turnover rate and the number
of terminations remained at the same level as in
previous years. The turnover rate is calculated by
dividing the number of employees who have left Sampo
Group during the reporting year by average headcount.
The figure includes external voluntary and involuntary
turnover.
Total number of employees by gender
Sampo Group, 31 December 2024
Gender
Number of employees
Female
8,134
Male
7,447
Other
-
Not reported
-
Total employees
15,581
Total number of employees by country
Sampo Group, 31 December 2024
Country
Number of employees
United Kingdom
4,314
Denmark
2,977
Sweden
2,770
Finland
2,130
Norway
1,827
Latvia
573
Estonia
514
Spain
230
Lithuania
190
Gibraltar
32
Germany
8
Netherlands
8
France
7
United States
1
Total employees
15,581
Number of terminations and turnover
rate
Sampo Group, 2024
Country
Terminations
Turnover rate
United Kingdom
776
19.9%
Denmark
416
13.7%
Sweden
312
11.4%
Finland
130
6.1%
Norway
143
8.1%
Baltic countries
93
7.4%
Other countries
102
36.8%
Sampo Group,
total
1,972
13.1%
BOARD OF DIRECTORS’ REPORT 2024
97
Information on employees by gender
Sampo Group, 31 December 2024
Female
Male
Other
Not disclosed
Total
Number of employees
8,134
7,447
-
-
15,581
Number of permanent employees
8,016
7,384
-
-
15,400
Number of temporary employees
118
63
-
-
181
Number of non-guaranteed hours employees
168
126
-
-
294
Number of full-time employees
7,125
7,170
-
-
14,295
Number of part-time employees
1,007
279
-
-
1,286
Information on employees by country
Sampo Group, 31 December 2024
United Kingdom
Denmark
Sweden
Finland
Norway
Baltic countries
Other countries
Total
Number of employees
4,314
2,977
2,770
2,130
1,827
1,277
286
15,581
Number of permanent employees
4,268
2,940
2,754
2,111
1,791
1,250
286
15,400
Number of temporary employees
46
37
16
19
36
27
0
181
Number of non-guaranteed hours employees
0
142
93
0
59
0
0
294
Number of full-time employees
3,741
2,766
2,576
1,955
1,736
1,245
276
14,295
Number of part-time employees
573
211
194
175
91
32
10
1,286
BOARD OF DIRECTORS’ REPORT 2024
98
Characteristics of non-employee workers in
the undertaking’s own workforce
As at 31 December 2024, the total number of non-
employees at Sampo Group was 3,283. The number of
non-employees is reported as headcount. Non-
employees are employees in the company’s workforce
who are not employed by the company (e.g. self-
employed individuals or employees provided by staffing
agencies). At Sampo Group, non-employees work
within IT and in customer service centres, for example.
Collective bargaining coverage and social
dialogue
As at 31 December 2024, 60.9 per cent of Sampo
Group’s employees were covered by collective
bargaining agreements. The figure only includes
employees who are fully covered by collective
bargaining agreements in locations where trade unions
are formally recognised. Nevertheless, the agreements
apply to most employees’ (excluding top management)
terms of employment even if they are not covered by
the agreement. There are several collective bargaining
agreements within Sampo Group’s operations in the
European Economic Area, depending on the
geographic location and national practices. In Sampo
Group’s operations in the UK, trade unions are not
formally recognised, but employment terms are
compared to market practices at regular intervals.
Sampo Group has no Global Framework Agreements. If
has established an agreement on an information and
consultation procedure with the workers’
representatives, based on the European Works
Councils’ stipulation. The highest level of engagement
with workers’ representatives takes place in the
Communication Council, which is chaired by If's CEO.
The Communication Council meets quarterly to address
topics concerning more than one country or business
area.
The collective bargaining coverage is calculated by
dividing the number of employees covered by collective
bargaining agreements by the total number of
employees using headcount. Estimations were used to
calculate workplace representation.
Collective bargaining coverage and social dialogue
Sampo Group, 31 December 2024
Collective bargaining coverage
Social dialogue
Coverage rate
Employees – EEA
Employees – Non-EEA
Workplace representation
(EEA only)
0–19%
-
United Kingdom
-
20–39%
-
-
-
40–59%
-
-
-
60–79%
-
-
Denmark, Sweden
80–100%
Denmark, Sweden, Finland, Norway
-
Finland, Norway
The table includes countries with more than 50 employees, representing over 10% of total employees.
BOARD OF DIRECTORS’ REPORT 2024
99
Diversity metrics
The age distribution within Sampo Group has
historically been stable, and remained so in 2024. Age
distribution is calculated by headcount at year-end.
As at 31 December 2024, the binary gender distribution
at the four highest management levels of Sampo Group
shows that there is still room for diversity at the very
top. However, at the levels immediately below top
management, the balance between women and men is
more equal. Sampo Group defines top management as
the Sampo Group CEO (level 1), the subsidiaries’ CEOs
(level 2), executives reporting to any of the CEOs (level
3), and management level employees reporting to these
executives (level 4).
Gender distribution at top management level
Gender
Level 1 (the Group CEO)
Level 2 (the CEOs of Sampo plc’s
subsidiaries)
Level 3 (reporting to any of the CEOs)
Level 4 (reporting to level 3)
31 Dec. 2024
31 Dec. 2024
31 Dec. 2024
31 Dec. 2024
Female
0
0.0%
0
0.0%
9
25.7%
77
40.8%
Male
1
100.0%
3
100.0%
26
74.3%
112
59.2%
Sampo Group, total
1
100.0%
3
100.0%
35
100.0%
189
100.0%
Distribution of employees by age group
Age group
31 Dec. 2024
Under 30 years old
3,264
20.9%
30–50 years old
8,730
56.0%
Over 50 years old
3,587
23.0%
Sampo Group, total
15,581
100.0%
Adequate wages
At Sampo Group, remuneration is based on objective
criteria, such as work experience, competence, position,
and responsibilities, and all employees are paid an
adequate wage which is in line with applicable
benchmarks. Pay and additional benefits are not based
on or affected by gender or any other non-professional
aspect. Sampo Group has, for example, job title and job
position structures to ensure that employees in the
same position are employed under the same conditions,
and internal and external benchmarks are used in
setting the salary ranges.
Social protection
All Sampo Group employees are covered by social
protection against loss of income due to major life
events such as sickness, unemployment, employment
injury and acquired disability, parental leave, and
retirement.
Persons with disabilities
Sampo Group does not collect data on personal
characteristics, such as disabilities, due to legal
restrictions.
BOARD OF DIRECTORS’ REPORT 2024
100
Training and skills development metrics
At Sampo Group, all employees are eligible to
participate in regular career development reviews. In
2024, Sampo Group implemented new reporting
processes for career development reviews to meet the
ESRS reporting requirements. Reporting on this topic
will be further developed in 2025 to ensure data
accuracy. The percentage of employees who
participated in performance and career development
reviews is calculated by dividing the number of
employees who participated in these reviews by the
year-end headcount, broken down by gender.
Percentage of employees who
participated in regular performance and
career development reviews by gender
Gender
2024
Female
66.2%
Male
64.0%
Sampo Group, total
65.1%
Health and safety metrics
All Sampo Group’s employees were covered by a health
and safety management system on 31 December 2024.
The system refers to the occupational healthcare
services that the employer offers to employees. The
system can be either statutory or offered voluntarily.
The percentage of employees in Sampo Group’s own
workforce covered by a health and safety management
system is calculated using headcount.
During 2024, there were no fatalities as a result of work-
related injuries at Sampo Group, and the number of
work-related accidents remained stable. Sampo Group
reports the rate of recordable work-related accidents
for the first time in 2024. The rate is calculated by
dividing the number of cases by the estimated total
hours worked and multiplied by one million. The rate
represents the number of cases per one million hours
worked. The disclosed metrics concern employees in
Sampo Group’s own workforce.
Sampo Group does not collect data on work-related ill
health, fatalities due to work-related ill health, or days
lost due to work-related ill health due to legal
restrictions.
Percentage of employees covered by
health and safety management system
Sampo Group
Metric
31 Dec. 2024
Percentage of employees who are covered
by health and safety management system
100.0%
Work-related injuries and fatalities
Sampo Group
Metric
2024
Number of fatalities as a result of work-
related injuries
0
Number of recordable work-related
accidents
80
Rate of recordable work-related accidents
3.4
Work-life balance metrics
At Sampo Group, all employees are entitled to family-
related leave through social policy or collective
bargaining agreements. The percentage of employees
who took family-related leave is calculated by dividing
the number of employees who were on family-related
leave divided by year-end headcount, broken down by
gender.
Percentage of employees who took
family-related leave
Gender
2024
Female
10.2%
Male
6.3%
Sampo Group, total
8.3%
BOARD OF DIRECTORS’ REPORT 2024
101
Remuneration metrics (pay gap and total
remuneration)
The gender pay gap describes the difference in actual
paid out compensation between men and women. The
difference in pay can be explained by factors such as
position in the company, job tasks, responsibilities, and
leave of absence. The calculation principles of the
gender pay gap have been modified in 2024 to reflect
the requirements of the ESRS.
Sampo Group calculated the annual total remuneration
ratio of the highest paid individual to the median annual
remuneration for the first time in 2024. The median
remuneration data is retrieved from local payroll
systems and includes fixed net compensation, holiday
pay, bonuses, and all incentive schemes. Overtime
compensation and pensions are excluded. The median
annual remuneration figure is based on the number of
employees in an employment relationship with Sampo
Group at 31 December 2024, regardless of them being
employed a full year or not.
Pay gap related metrics are calculated using FTE
average. Exchange rates may have an impact on the
remuneration figures presented in this statement.
Gender pay gap
Sampo Group
Metric
2024
Fixed remuneration
19.8%
Fixed and variable remuneration
24.5%
Annual total remuneration ratio of the
highest paid individual to the median
annual remuneration
Sampo Group
Metric
2024
Pay ratio
89.6
Incidents, complaints, and severe human
rights impacts
In 2024, no severe human rights incidents, defined as
severe violations of human rights and labour rights
legislation concerning Sampo Group’s own workforce,
were reported. Two incidents of discrimination and
harassment were reported. These include incidents of
discrimination as defined in the Sampo Group Code of
Conduct and incidents of harassment that have led to
formal consequences (e.g. warning or dismissal). The
total number of complaints filed through Sampo
Group’s channels for people in the own workforce was
22. These are complaints reported by employees
through grievance mechanisms and whistleblowing
channels, concerning social, human rights, and labour
rights matters. The figure includes all applicable
complaints filed during 2024 regardless of their status
at the end of the reporting year. None of the incidents
or complaints reported during the year resulted in fines,
penalties, or compensation for damages.
Number of incidents of discrimination
and harassment
Sampo Group
Metric
2024
Number
2
Number of severe human rights incidents
Sampo Group
Metric
2024
Number
0
BOARD OF DIRECTORS’ REPORT 2024
102
Workers in the value chain
Topic
Impacts
Risks and opportunities
Strategy and actions
Suppliers and business
partners
↓ Sampo Group has not identified actual negative
impacts related to its suppliers and business
partners. Potential negative impacts related to
human rights and labour practices can occur across
Group's entire value chain. Potential negative
impacts can be mitigated, but due to the large
number of suppliers and business partners, it is not
possible to completely remove the risk for negative
impacts on workers in the value chain (e.g. related
to working conditions and equal treatment).
↑ Sampo Group can have a potential positive impact
on the sustainability of its suppliers and business
partners through its own actions. This can also
improve the working conditions of its suppliers’
workforce (e.g. job stability and health).
Time-horizon: short to medium term
↓ If Sampo Group's suppliers or business partners
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.
↓ Sampo Group can face a financial risk due to
increasing and tightening legislation related to
human rights and labour rights (e.g. possible fines,
reputational damage).
↑ Having stable business relationships with
responsible suppliers and business partners can be
a competitive advantage and create financial
opportunities for Sampo Group.
Time-horizon: short to medium term
• Policies and guidelines (e.g. supplier codes of
conduct)
• Effective governance structures and processes (e.g.
supplier risk assessments, audits, questionnaires,
engagement)
• Internal training and competence development
programmes
• Metrics and targets (e.g. share of suppliers signing a
code of conduct)
Underwriting and
investment
management
↑ Sampo Group can have a potential positive impact
on the entire value chain, including workers in the
value chain, by adopting responsible investment
and underwriting practices.
Time-horizon: medium to long term
↓ If Sampo Group were to invest in or insure
industries whose operations are harmful for value
chain workers, it could cause reputational damage
and financial risks for the Group.
↑ For Sampo Group, financial opportunities of
responsible investment are limited, as sustainability
is seen as a baseline. In the long run, there may be
more opportunities, as the availability of
information increases, and sustainability can also
provide reputational value.
Time-horizon: medium to long term
• Commitments to responsible investment and
underwriting (e.g. PRI, SBTi)
• Internal policies and guidelines (e.g. responsible
investment policies, underwriting principles)
• Effective governance structures and processes (e.g.
screening, engagement)
• Metrics and targets (e.g. SBTs)
The table presents Sampo Group’s material impacts, risks, and opportunities related to workers in the value chain identified in the double materiality assessment and their connection to Sampo Group’s
strategy and actions. The topics are linked to the ESRS sub-topics. The topics Suppliers and business partners and Underwriting and investment management are related to the ESRS sub-topics Working
conditions and Other work-related rights.
BOARD OF DIRECTORS’ REPORT 2024
103
Strategy
Material impacts, risks, and opportunities
and their interaction with strategy and
business model
Sampo Group has an impact on workers in the value
chain through its suppliers and business partners,
corporate customers, and investments. For example,
based on the double materiality assessment and the
human rights impact assessment, Sampo Group has
identified that especially workers in its downstream
value chain (e.g. suppliers in claims handling) could be
negatively affected. These workers may face risks
inherent to their roles and operating contexts, which are
mitigated, amongst other things, by the suppliers'
adherence to the required health and safety standards
outlined in Sampo Group's supplier codes of conduct.
Ensuring that human and labour rights are respected by
the suppliers is important for Sampo Group to mitigate
financial risks and seize opportunities. Suppliers
breaching human rights and labour rights may face
legal, reputational, and operational consequences,
which may, in turn, become an operational risk for
Sampo Group. A stable business relationship with a
responsible supplier is a competitive advantage and
can, therefore, be seen as an opportunity, too.
Sampo Group develops its understanding of particularly
vulnerable value chain workers for instance through
self-assessment questionnaires completed by suppliers
and engagement with investee companies, corporate
customers, and suppliers. Examples of particularly
vulnerable groups within Sampo Group’s value chain
include different minorities and migrant workers.
Sampo Group includes all value chain workers who may
be materially impacted by its operations, products,
services, and business relationships in its disclosures.
However, the main focus is on direct suppliers (Tier 1)
where Sampo Group is expected to have the largest
impact. In addition, impacts Sampo Group may have
through its investees and corporate customers are also
considered.
Sampo Group’s upstream value chain encompasses
suppliers of office supplies and services (e.g. software
and hardware companies) as well as providers of other
business services (e.g. consultants, external data
providers) that support the running of the business. The
downstream value chain includes, for example, suppliers
of vehicle and property repair contractors, as well as
healthcare providers. The key activities related to
Sampo Group’s products and services that are carried
out by suppliers include property, vehicle, and content
repairs, health and hospital services, and travel services.
Sampo Group acknowledges the varying levels of
human and labour rights risks associated with different
industries and regions related to its business,
particularly in sectors such as construction and vehicle
repair.
The majority of Sampo Group’s suppliers in claims
handling are based in the Nordics, where the risk for
human rights violations in general is considered lower
than in many other regions globally. However, the value
chains can be long and complex, and especially certain
sectors such as construction, mining, transportation,
and electronics are associated with risks to human
rights and labour rights. Workers may be exposed to
unhealthy or unsafe working conditions including, for
example, long hours and exposure to hazardous
substances. Risks also include forced labour and child
labour, discrimination, and violations of privacy. These
risks can be considered systemic.
Sampo Group’s downstream value chain also
encompasses the workforce and supply chains of its
investee companies and corporate customers, through
which the Group can have an impact on workers that
goes beyond its own operating countries. This could, for
example, include a risk of forced labour, unhealthy
working conditions, or discrimination and harassment,
as these risks can exist in industries or regions where
the investee companies or corporate customers
operate. As these risks materialise further down the
value chain, Sampo Group’s possibilities to limit the
impacts are limited.
Impact, risk and opportunity
management
Policies related to value chain workers
Sampo Group’s policy related to workers in the value
chain is the Sampo Group Code of Conduct, which is
reviewed annually and approved by Sampo’s Board of
Directors. The Code of Conduct is mandatory for all
Sampo Group companies and must be personally
upheld by every Group employee.
The Code of Conduct states that Sampo Group
complies with all applicable human rights, labour rights,
and employment legislation. In addition, Sampo Group
is committed to respecting human rights as set out in
the International Bill of Human Rights including the
Universal Declaration of Human Rights, the International
Covenant on Civil and Political Rights, the International
Covenant on Economic, Social and Cultural Rights, and
those stated in the core conventions of the International
Labour Organization (ILO). Sampo Group also adheres
to the principles of the UN Global Compact and follows
the internationally recognised standards on business
and human rights, such as the UN Guiding Principles on
Business and Human Rights and the OECD Guidelines
for Multinational Enterprises. Hence, Sampo Group is
committed to the obligations related to human rights
and the continuous development of related practices
(e.g. human rights due diligence processes including
BOARD OF DIRECTORS’ REPORT 2024
104
human rights impact assessments) covering both its
own operations and its value chain.
Sampo Group has due diligence processes aligned with
the OECD Guidelines for Multinational Enterprises.
These processes allow Sampo Group to identify, avoid
and address possible adverse impacts on human rights,
labour rights, the environment and anti-corruption
commitments associated with its suppliers as well as
underwriting and investment operations. 
As stated in the Code of Conduct, Sampo Group
condemns all forms of forced and compulsory labour as
well as child labour and modern slavery (e.g. human
trafficking) in the Group’s own operations and value
chain. In addition to the Sampo Group Code of Conduct,
each Group company has adopted supplementary and
more detailed policies, guidelines, and processes for
their own purposes.
Sampo Group has not been made aware of severe
confirmed cases of non-adherence to global standards
for value chain workers in its upstream and downstream
value chain during the reporting year. This includes
direct suppliers (Tier 1), direct investments, and
corporate customers.
Suppliers and business partners
The Sampo Group Code of Conduct is the group level
guidance document on supplier codes of conduct. The
Group’s company-specific supplier codes of conduct set
the minimum requirements that suppliers are expected
to meet on topics such as fair and equal treatment,
privacy, employment terms, working hours, fair wages,
health and safety, and freedom of association and
collective bargaining. The codes of conduct are based
on the UN Global Compact and its underlying
conventions, and apply to suppliers and sub-suppliers.
The supplier codes of conduct are approved by the
boards of directors or other governing bodies of the
respective Sampo Group company. The ultimate
responsibility for implementation lies with the top
management of each Group company. The policies are
available on the Group companies’ websites and they
are communicated to suppliers.
Sampo Group engages with its suppliers, for example,
through dialogue, self-assessment questionnaires,
reviews and site visits. In case of a breach against a
supplier code of conduct, Sampo Group engages with
the supplier to bring about improvements in the
supplier’s business conduct. Sampo Group monitors the
situation and actions depend on the corrective
measures taken by the supplier. Sampo Group can
terminate the supplier contract if the supplier does not
take steps to remediate the situation within a
reasonable timeframe.
Underwriting and investment management
Sampo Group provides insurance to corporate
customers in accordance with its underwriting
principles and manages its investments in accordance
with its responsible investment policies. Sampo Group
updates its policies related to insurance and investment
operations annually and they are approved by the
boards of directors of each Group company. The
policies include, among other things, descriptions on
how to take sustainability risks and sustainability criteria
into account in insurance and investment activities.
Sampo Group conducts norm-based screening of direct
investments and corporate customers against
international norms and standards (e.g. the UN Global
Compact principles, the OECD Guidelines for
Multinational Enterprises, the ILO Tripartite Declaration
of Principles concerning Multinational Enterprises and
Social Policy, the Guiding Principles on Business and
Human Rights, and the Paris Climate Agreement) using
external service providers. If Sampo Group detects a
violation of norms or standards, depending on the
severity, nature, and extent of the breach, measures
taken may consist of direct dialogue or other type of
engagement action. As a measure of last resort, the
investment can be sold or insurance contract
terminated if the investee company or corporate
customer does not take corrective action.
In addition to norm-based screening, Sampo Group
excludes certain sectors from direct investments unless
pre-defined criteria are fulfilled. Examples of such
sectors are tobacco, coal, and controversial weapons,
due to potential human rights risks, labour rights risks,
reputational risk, and/or regulatory risks.
Processes for engaging with value chain
workers about impacts
Sampo Group does not engage directly with its value
chain workers or their legitimate representatives or
credible proxies. However, indirect engagement can
occur through suppliers, investee companies, or
corporate customers. The engagement can be part of
formal due diligence processes or regular monitoring of
business relationships (e.g. meetings, self-assessment
questionnaires, business reviews). These processes
allow Sampo Group to understand and manage impacts
on the workers in its value chain.
The frequency and method of engagement depends on
assessed risk, which links, for example, to the type and
size of the business partner in question. The
effectiveness of engagement is monitored, for example,
through follow-up meetings with suppliers and
corporate customers or through external partners
during engagement with investee companies.
Sampo Group gains insight into the perspectives of its
value chain workers mainly through human rights due
diligence processes. These include, for example,
conducting human rights impact assessments,
BOARD OF DIRECTORS’ REPORT 2024
105
evaluating suppliers' adherence to sustainability criteria,
and screening investments and corporate customers.
Processes to remediate negative impacts
and channels for value chain workers to raise
concerns
The Sampo Group Code of Conduct, supplier codes of
conduct, and responsible investment and underwriting
practices set clear requirements related to value chain
workers. If non-compliance with the requirements is
detected, Sampo Group will engage with the supplier,
investee company, or corporate customer in question to
rectify the situation and align them with the Group’s
policies, with plans to review and follow up on these
actions. If the error or contract breach is major, or the
supplier, investee company, or corporate customer is
unwilling to make improvements within a given
timeframe, Sampo Group may terminate the contract or
divest.
Most of Sampo Group’s whistleblowing channels are
available to all stakeholders, including value chain
workers, for reporting suspicions of violations against
legislation or unethical conduct. The whistleblowing
channels are either internally or externally managed,
depending on the Group company, and allow
anonymous reporting. In addition, the majority of
Sampo Group’s supplier codes of conduct or related
contracts state that suppliers must provide channels for
reporting grievances. Suppliers are also required to
report any breaches against the principles of the codes
of conduct to Sampo Group. In addition to making
relevant policies and channels available to value chain
workers, Sampo Group does not specifically assess how
well they are aware of the processes to raise concerns.
Incidents reported through Sampo Group’s
whistleblowing channels are investigated promptly in
accordance with applicable legislation. Sampo Group
ensures the effectiveness of its channels through
internal and external communications and training. The
Group is also committed to develop its approaches
further. The whistleblowing channels are discussed in
detail in the section Business conduct (p. 116).
Taking action on material impacts on value
chain workers, and approaches to managing
material risks and pursuing material
opportunities related to value chain workers,
and effectiveness of those actions
In 2024, Sampo Group conducted a group-wide human
rights impact assessment, where risks related to human
rights topics across the Group’s operations and value
chain, including those related to suppliers, investments,
and corporate customers, were assessed. The
assessment covered the identification of human rights
risks in relation to Sampo Group’s own operations in the
Nordics, the Baltics, and the UK, as well as key upstream
and downstream activities and their geographies. The
work also included a plan for developing the Group’s
due diligence processes further in order to address
identified risks. During 2024, to support the group level
work, the Group companies developed, for example,
their human rights-related process descriptions,
policies, and practices (e.g. supplier codes of conduct,
human rights policies, whistleblowing channels). This
work also strengthened Sampo Group’s compliance
with the minimum safeguards of the EU Taxonomy
(p. 71).
Based on the assessment, Sampo Group develops its
processes to improve its abilities in detecting,
preventing, and mitigating potential negative impacts
on human rights and labour practices of the Group’s
value chain workers. Additionally, Sampo Group
continues its regular and on-going work with all relevant
suppliers and business partners, investees, and
corporate customers to ensure compliance with the
Group’s policies.
Sampo Group uses its continuous processes to
determine whether engagement or other additional
actions with the given supplier, corporate customer, or
investee company are needed to address any potential
negative impacts on value chain workers. Similarly,
Sampo Group’s policies, screening, and engagement
practices allow for mitigating risks and pursuing
opportunities that have been identified related to
workers within the Group’s value chain.
Sampo Group has not identified actual material
negative impacts on its value chain workers and no
severe human rights issues or incidents have been
reported to Sampo in the Group’s upstream or
downstream value chain in 2024. Potential negative
impacts on value chain workers are monitored, for
example, through supplier self-assessment
questionnaires, site visits, reviews, and potential
contract terminations, which can occur due to a
supplier’s or business partner’s non-compliance with
Sampo Group’s sustainability requirements.
In case any material negative impacts on value chain
workers were to occur, Sampo Group has processes in
place for reporting and addressing grievances and to
take corrective action. Responsibility for the
management of any material impacts on value chain
workers is allocated to each Group company’s
respective departments, such as Procurement,
Investment management, Insurance operations (e.g. If’s
Business area Industrial), and Sustainability.
BOARD OF DIRECTORS’ REPORT 2024
106
Suppliers and business partners
In 2024, Sampo Group strengthened the integration of
its supplier codes of conduct into processes, developed
due diligence practices, and monitored suppliers’
alignment with sustainability criteria. As Hastings
implemented a supplier code of conduct in 2024, all
Sampo Group companies now have a code of conduct
outlining the expectations towards suppliers, including
human and labour rights. Other actions taken to
enhance the cooperation with suppliers were reviewing
ESG questionnaires, as well as allocating training
budgets and providing digital platforms and external
consultancy support to assist in conducting the due
diligence. All of these actions are meant to support
Sampo Group’s work in preventing negative impacts to
workers across the value chain.
Sampo Group also aims to promote positive impacts
among its value chain workers. For example,
Topdanmark cooperates with its suppliers in the
building sector and engages in upskilling the key
employees at the supplier through targeted education
related to claims handling practices. In addition, Sampo
Group engaged with its suppliers to ensure alignment
with the Group’s policies and guidelines regarding
labour practices in 2024. 
Underwriting and investment management
Sampo Group updated the Group’s responsible
investment policies during 2024. The changes were
linked, for example, to the SBTs. The development of
the Group’s responsible investment practices continues
during the coming years based on internal sustainability
ambitions, external stakeholder feedback, and overall
market development.
In 2024, Sampo Group screened its direct investments
and corporate customers for breaches against the UN
Global Compact principles. Based on the screenings,
Sampo Group did not have any direct investments in
companies with confirmed norm violations and no
severe and confirmed inconsistencies were identified
among the corporate customers either. During the year,
Sampo Group also continued to screen its direct
investments for sensitive sectors to manage any
possible risks related to human and labour rights.
During the reporting year, Sampo Group’s investments
in funds were managed by asset managers who are UN
PRI signatories. A significant portion of these funds is
also managed by asset managers who have committed
to respecting the UN Global Compact principles.
Metrics and targets
Targets related to managing material
negative impacts, advancing positive
impacts, and managing material risks and
opportunities
Sampo Group’s long-term goal is that all suppliers have
signed a supplier code of conduct. However, for the
time being, Sampo Group has not set measurable, time-
bound, and outcome-oriented group level targets for
the metrics related to workers in the value chain. Sampo
Group reviews processes to manage impacts, risks, and
opportunities related to workers in the value chain
regularly. In case it is assessed that an externally
disclosed target on the group level is a valuable
addition, the decision will be revisited.
Metrics related to Supplier Code of Conduct
In order to evaluate its effectiveness in mitigating the
risk of potential negative impacts on value chain
workers and their human and labour rights, Sampo
Group measures the inclusion of supplier codes of
conduct in its supplier agreements. Tracking the
inclusion also supports Sampo Group in managing
financial risks related to any negative impacts on value
chain workers and the pursuit of opportunities from
business relationships with responsible partners.
Sampo Group started to track the inclusion of supplier
codes of conduct in supplier agreements at group level
in 2024. Performance is regularly monitored as part of
Sampo Group’s annually published sustainability
statement. Going forward, Sampo Group will monitor
the need for additional group level metrics and
implement them, if considered material.
The share of suppliers having signed a supplier code of
conduct is measured by dividing the number of
suppliers that have signed one of Sampo Group’s
supplier codes of conduct (including suppliers that have
their own code of conduct which Sampo Group has
approved) by the number of all suppliers. The metric
applies to both suppliers in Sampo Group’s upstream
(e.g. suppliers of office equipment) and downstream
value chain (e.g. suppliers in claims handling). Some
suppliers, such as large IT companies and consultancies,
are excluded from the metric. There are Group
company-specific adjustments in the methodology due
to differences in supply chain structures.
Results for the year 2024 are presented in the table
Supplier Code of Conduct included in existing supplier
agreements. The measurement of supplier codes of
conduct is not validated by an external body other than
the assurance provider of this Sustainability Statement.
Supplier Code of Conduct included in
existing supplier agreements
Sampo Group
Metric
31 Dec. 2024
Share of suppliers
75.6%
BOARD OF DIRECTORS’ REPORT 2024
107
Consumers and end-users
Topic
Impacts
Risks and opportunities
Strategy and actions
Customer health and
safety
↑ Customer health and safety is at the core of the
insurance business and, therefore, also at the core
of Sampo Group’s business. As Sampo Group’s
strategy focuses on disciplined underwriting and
careful risk management, the company has an
actual positive impact on consumers’ and end-
users' health by providing insurance products, thus
helping its customers in risk management.
Time-horizon: short to medium term
↑ Sampo Group can create financial opportunities by
offering consumers and end-users products and
services they need and want. Opportunities can also
be gained, for example, by cutting costs through
digital solutions and by developing new products
and services.
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. codes of
conduct, underwriting principles, risk management
principles)
• Effective governance structures and processes (e.g.
feedback channels, loss prevention, risk
management)
• Training and competence development
programmes
• Metrics and targets (e.g. NPS, EPSI, Trustpilot)
Sales and marketing
practices
↓ Sampo Group can have potential negative societal
impact through irresponsible sales and marketing
practices (e.g. inaccessibility, discrimination,
misleading).
Time-horizon: short to medium term
↓ Possible irresponsible sales and marketing practices
can cause a financial risk for Sampo Group through
legislative consequences (e.g. possible fines) and
reputational damage.
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. codes of
conduct)
• Effective governance structures and processes (e.g.
feedback channels, quality communications,
responsible remuneration practices)
• Training and competence development
programmes
Data privacy,
information security,
and cybersecurity
↓ As an insurance company, Sampo Group handles
and stores large amounts of customers and other
stakeholders’ personal data. Due to increasing
digitalisation and the use of AI, there is a risk of, for
example, information security breaches,
cybersecurity attacks, and data privacy incidents,
leading to potential negative impacts on consumers
and end-users.
Time-horizon: short to medium term
↓ Sampo Group is exposed to data privacy,
information security, and cybersecurity risks due to
the high quantity of sensitive data the company
handles and processes. In the case of incidents
related to privacy and data security, negative
financial risks, such as fines and reputational
damage, may be significant.
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. codes of
conduct, data privacy statement, information
security principles, risk management principles)
• Effective governance structures and processes (e.g.
frameworks and reporting structures, screenings,
impact assessments, security measures, data
processing agreements, risk analyses, continuity
planning, quality systems and infrastructure)
• Training and competence development
programmes
• Metrics and targets
The table presents Sampo Group’s material impacts, risks, and opportunities related to consumers and end-users identified in the double materiality assessment and their connection to Sampo Group’s
strategy and actions. The topics are linked to the ESRS sub-topics. The topic Customer health and safety is related to the ESRS sub-topic Personal safety of consumers and/or end-users. The topic Sales and
marketing practises is related to the ESRS sub-topics Social inclusion of consumers and/or end-users and Information-related impacts for consumers and/or end-users. The topic Data privacy, information
security, and cybersecurity is related to the ESRS sub-topic Information-related impacts for consumers and/or end-users.
BOARD OF DIRECTORS’ REPORT 2024
108
Strategy
Material impacts, risks, and opportunities
and their interaction with strategy and
business model
Sampo Group provides insurance products and services
to three main customer groups: private customers,
commercial customers (including SMEs), and industrial
customers. In addition to these groups, Sampo Group
can have an impact on potential customers and end-
users of insurance policies, who themselves are not
Sampo Group’s customers (e.g. beneficiaries). When
assessing material impacts on consumers and end-
users, Sampo Group aims to consider all types of
customers who may face material impacts from the
company’s own operations or value chain.
Sampo Group does not offer products or services that
are inherently harmful to consumers’ or end-users’
health, safety, or freedom of expression. Instead, Sampo
Group has an actual positive impact on consumers’ and
end-users’ health and safety, for example by providing
insurance products and services, thus helping
customers in loss prevention, risk management, and in
case of a claim.
Sampo Group’s sales and marketing practices can have
a potential negative impact on consumers and end-
users, for example, through inaccessibility of products
and services, or if the needs of underserved groups are
not fulfilled in a satisfactory manner. As an insurance
provider, there is also a potential for Sampo Group to
be associated with discrimination due to risk
assessments that can in certain cases (e.g. due to legal
restrictions) exclude customers from accessing
insurance protection. For example, certain insurances
may not be available to customers with specific risk
profiles, or are only available with higher premiums.
As an insurance company, Sampo Group is required to
handle large amounts of customers' personal data, and
Sampo Group can, therefore, have a negative impact on
consumers and end-users also through data privacy,
information security, and cybersecurity. The privacy of
customers can be jeopardised if Sampo Group’s data
privacy and information security measures are breached
(e.g. as a result of a cyber attack). Due to digitalisation
and AI, for instance, the risk of information security and
cybersecurity attacks can increase, leading to a higher
amount of potential negative impacts.
When offering insurance to consumers who can be
more vulnerable to health, privacy, or accessibility
impacts (e.g. elderly people, people with disabilities,
people lacking financial literacy) and to beneficiaries
who themselves are not Sampo Group’s customers (e.g.
children), it is especially important that Sampo Group
offers these consumers and end-users accurate and
accessible information about their insurance policies
and coverage. To increase understanding about which
stakeholders, including consumers and end-users, are
particularly at risk of being harmed by negative human
rights impacts, Sampo Group has conducted a human
rights impact assessment. In addition, Sampo Group’s
stakeholder dialogue and customer feedback channels
serve as a way to engage with affected consumers and
end-users and understand potential human rights risks.
Risks and risk management are inherent elements of
insurance companies’ business activities and operating
environment. At Sampo Group, the balance between
risks, capital, and earnings requires that risks affecting
profitability, as well as other material risks, are
identified, assessed, and analysed. This means that
underwriting risks are priced reflecting their inherent
risk levels based on each individual customer’s specific
risk profile, which may, for instance, increase the
potential negative impact on consumers and end-users
through sales and marketing practices.
Impact, risk and opportunity
management
Policies related to consumers and end-users
Sampo Group has several policies to manage its
material impacts, risks, and opportunities related to
consumers and end-users. These are, for example,
Sampo Group’s Code of Conduct, Data Privacy
Statement, and Information Security Principles. The
policies are all reviewed annually, approved by Sampo’s
Board of Directors, and available on Sampo’s website. In
addition, each Group company has supplementary and
more detailed policies (e.g. underwriting principles.
distribution policies, data privacy statements),
guidelines, and processes (e.g. due diligence) for their
own purposes. The ultimate responsibility for the
implementation of the group level principles and
company-specific policies lies with the management of
each individual Sampo Group company. To ensure
compliance with laws, regulations, and internal policies,
Sampo Group has training programmes which guide
personal conduct and increase the competence of
employees.
The Sampo Group Code of Conduct states that the
Group complies with the International Bill of Human
Rights, including the Universal Declaration of Human
Rights and the two covenants, the Core Conventions of
the International Labour Organization (ILO), the OECD
Guidelines for Multinational Enterprises, and the UN
Global Compact. The Code of Conduct also describes
that Sampo Group is committed to the obligations
related to human rights and the continuous
development of related practices (e.g. human rights
impact assessments, human rights due diligence
processes). Sampo Group’s due diligence processes
cover both the Group’s own operations and its value
chain, including consumers and end-users.
BOARD OF DIRECTORS’ REPORT 2024
109
The Code of Conduct applies to all companies
belonging to Sampo Group and it is each employee’s
responsibility to comply with its contents. The Code of
Conduct obligates employees to ensure that human
rights are respected and upheld through all operations,
including the downstream value chain.
Sampo Group communicates on the topics covered by
the Code of Conduct to its consumers and end-users,
for example, through company websites, sustainability
reporting, and other customer communication
materials. The engagement with stakeholders is
described in more detail under the heading Interests
and views of stakeholders (p. 64).
Sampo Group has not been made aware of any severe
legal cases of non-adherence to global standards
related to consumers and end-users in its downstream
value chain during the reporting year.
Customer health and safety and Sales and marketing
practices
The Sampo Group Code of Conduct sets the group level
requirements for products and services (i.e. customer
health and safety) at Sampo Group. The Code of
Conduct states that Sampo Group strives to act in the
best interest of its customers, offering products and
services that customers need and want. The products
and services should be fair, comprehensible, and
designed to help meet the evolving needs of all
customers. In addition, ESG considerations, including
climate change, are to be taken into account in
insurance underwriting.
The Code of Conduct specifies that Sampo Group’s
sales, marketing, and product information must be
professional, comprehensive, accurate, balanced, and
never misleading. Sampo Group takes appropriate care
to ensure that customers are given transparent and
easily accessible and understandable information about
the costs, risks, and conditions relating to the product
or service in question, as well as the reasons leading to
a decision regarding an insurance application, where
applicable. In addition, at Sampo Group all customers
are to be treated fairly and no individual customer is
given preferential treatment at the expense of other
customers. Insurance premiums are only based on
relevant data and not on discriminating factors.
Sampo Group has controls in place to ensure that the
information provided to customers is accessible,
relevant, and timely before a customer commits to any
purchase, and that the company satisfies all regulatory
and conduct obligations. Sampo Group aims to clearly
inform customers of their complaint options, as well as
to ensure a fair and transparent complaint process.
Possible measures to provide remedy to consumers and
end-users depend on the nature of the impact. Sampo
Group takes action on a case-by-case basis and
according to established internal processes. When
evaluating the effectiveness of mitigation approaches,
Sampo Group also uses information obtained through
stakeholder dialogue.
Data privacy, information security, and cybersecurity
Sampo Group’s policies on data privacy, information
security, and cybersecurity lay out how Sampo Group is
committed to processing personal data in a lawful, fair,
and transparent manner, while respecting human rights
in all aspects of data management. The policies
highlight how Sampo Group protects information and
upholds cybersecurity. These policies also state that
high levels of data privacy, information security, and
cybersecurity are top priorities for Sampo Group.
Processes for engaging with consumers and
end-users about impacts
Sampo Group has customer experience programmes
(or similar) which are spread across the organisations
and the different customer touchpoints. The
programmes enable the Group to both collect customer
data and monitor the related results. Sampo Group
engages with consumers and end-users at several
stages during the customer journey, such as before,
during, and after a customer transaction. Customers are,
for example, offered the possibility to leave feedback on
the customer journey or based on a certain transaction.
Customer feedback is collected daily, weekly, or
monthly depending on the situation. Feedback is
reviewed and any questions or comments are followed
up with the customer where relevant. Customer
feedback is collected, for example, by phone, email,
SMS, or chat. The operational responsibility for
engagement with consumers and end-users lies with
the top management of the Sampo Group companies.
Sampo Group gains insight into the effectiveness of its
engagement through multiple channels, such as
customer satisfaction surveys (e.g. NPS, EPSI,
Trustpilot) and customer contact points (e.g. email,
phone, chat, meetings). Feedback can reduce the risk of
the customer leaving, and it is also used to find areas of
improvement, for example regarding service, products,
processes, and systems. In addition, the Customer
Ombudsman engages with customers who have a
complaint, and may, based on the engagement, suggest
changes to, for example, the customer handling
processes, claims procedures, or product terms and
conditions.
Sampo Group has collected the perspectives of
affected consumers and end-users, for example,
through the Group’s human rights impact assessment.
The assessment included an analysis of Sampo Group’s
BOARD OF DIRECTORS’ REPORT 2024
110
existing data and the use of credible proxies as a part of
the desktop research. Impacts on vulnerable groups
were also considered in the assessment.
As stated in the Sampo Group Code of Conduct,
insurance premiums are only based on relevant data
and not on discriminating factors, such as sexual
orientation, religious belief, or ethnic background.
Sampo Group expects its suppliers to uphold the same
standards in their own operations.
When a customer or insured is not able to manage their
own interests due to, for example, age, sickness, injury,
or disability, Sampo Group ensures in accordance with
local regulatory requirements that there is a trustee or
guardian that can take care of their interests. Sampo
Group also has instructions and guidelines on how to
engage with customers in vulnerable situations (e.g.
managing serious incidents with a caring attitude,
ensuring privacy when communicating with customers
with hearing disabilities, handling indemnities to an
insured under guardianship).
Processes to remediate negative impacts
and channels for consumers and end-users to
raise concerns
Sampo Group offers multiple channels for customers to
raise concerns or needs. Customers can be directly in
contact with the company through, for example,
customer service (e.g. phone, website, app, chat) and
customer surveys. Indirect contact with the company is
possible through the Customer Ombudsman,
whistleblowing channels, and external complaints
boards. The whistleblowing channels are either
internally or externally managed, depending on the
Group company. Sampo Group encourages its
suppliers, for example, through supplier codes of
conduct and contract discussions, to provide similar
platforms for customers to raise concerns. Some of
Sampo Group’s reporting channels, such as
whistleblowing channels, are also available for the
consumers and end-users of suppliers and business
partners.
Sampo Group monitors and measures customer
satisfaction continuously. Both positive and negative
feedback is carefully analysed and used to further
develop products and services and improve the
customer experience. Quality assurance based on
customer feedback is also important. Sampo Group
follows the customer journey to find the root causes of
the feedback, and to restore the customer relationship,
if needed. The insight gained is utilised in training and in
improving processes and the overall customer journey.
By encouraging dialogue, Sampo Group can identify
and address any dissatisfaction among consumers and
end-users. To foster transparency and build trust,
Sampo Group has a list of its most material and publicly
available principles and policies on its website.
Furthermore, Sampo Group upholds non-retaliation
policies to safeguard individuals who come forward
with concerns, ensuring they can do so without fear of
reprisal. The mechanisms to ensure that users can trust
the whistleblowing channels to raise concerns and are
protected from retaliation are described in the section
Business conduct (p. 116).
Sampo Group has several processes for providing
remedy or contributing to remedy, depending on the
situation in question. In case of a customer complaint
related to the sales and marketing of products and
services, the priority is to discuss with the customer to
find a solution that is satisfactory to both parties. If a
consensus cannot be reached, the customer is entitled
to appeal to external complaints boards (or similar), in
accordance with local practices in each Sampo Group
country. In addition, as required by law, certain Sampo
Group companies have internal customer representative
functions that the customer can contact to submit a
complaint. Regardless of the outcome of appeal cases,
Sampo Group always analyses how it can improve its
practices.
Sampo Group has procedures for investigating
breaches and processes for corrective actions to
protect the personal data of consumers and end users.
Data privacy and information security incidents are
analysed and handled according to fixed processes, and
they are assessed and reported in a timely manner to
the local authorities, when applicable. If the risk to
consumers and end users is considered high, they are
notified of the incident.
Sampo Group evaluates the effectiveness of the
remedies it provides to ensure that any negative
impacts on consumers and end-users are addressed
when needed. This is achieved through systematic
follow-up procedures that include monitoring customer
satisfaction post-resolution, analysing patterns in
complaints and resolutions, and conducting reviews of
remediation processes to identify areas for
improvement. Sampo Group also follows up on every
data privacy or information security incident to assess
how similar incidents can be avoided in the future to
ensure the rights and freedoms of data subjects.
BOARD OF DIRECTORS’ REPORT 2024
111
Taking action on material impacts on
consumers and end-users, and approaches to
managing material risks and pursuing
material opportunities related to consumers
and end-users, and effectiveness of those
actions
Sampo Group adheres to the Code of Conduct and
supplementary policies to prevent irresponsible sales
and marketing practices, ensuring that all customer
communication is clear, relevant, and timely. Sampo
Group regularly assesses the products for
appropriateness and compliance with regulatory
obligations, supported by continuous training
programmes that enhance the conduct and
competence of customer-facing teams. Sampo Group
actively collects customer feedback, and has
transparent complaint processes in place, with options
for review through external complaints boards.
Sampo Group allocates resources across product and
service development, IT, and risk management, among
other things, to further improve its sales and marketing
practices, as well as its customers’ privacy, health, and
safety. Sampo Group also collaborates with authorities
and regulators and works with relevant networks (e.g.
related to customer experience, cybersecurity, and data
security), industry associations (e.g. Finance Finland,
Insurance Sweden, Finance Norway, Insurance and
Pension Denmark, Association of British Insurers), and
forums for knowledge sharing. These collaborations
provide Sampo Group a possibility to share knowledge
and experiences regarding topics such as climate
change adaptation, loss prevention, risk management,
health, and safety.
Sampo Group ensures effective complaints handling
and remediation processes for any material negative
impacts on customers by closely monitoring customer
feedback, results of the customer satisfaction surveys,
and cases raised with external complaints boards. When
a negative impact originates from the Group’s actions,
appropriate remedies are based on the nature of the
breach. In instances where customers are negatively
impacted, Sampo Group has established incident
management processes to oversee and ensure that
remediation activities are both appropriate to the
situation and executed as effectively as possible.
Governance frameworks, including product reviews and
customer forums, facilitate proactive identification of
systemic risks.
No severe human rights issues or incidents connected
to Sampo Group’s consumers or end-users were
reported to the Group during the reporting year.
Customer health and safety and Sales and marketing
practices
During 2024, Sampo Group continued to provide loss
prevention services to consumers and end-users. The
main purpose of loss prevention is to prevent damage
from occurring, but it also increases safety and reduces
risk and economic cost, as well as environmental
impact, as reduced damage means less need for repairs
and rebuilding. During the year, Sampo Group focused
on communicating easy-to-understand advice on loss
prevention to customers using press releases, content
marketing activities, social media, and websites. In
addition, If, together with its partners, offered house
assessments to private customers and building checks
for SMEs that own residential buildings in certain
markets. The house assessments provide the customer
with a report that helps them to both plan the
maintenance of the property and minimise the risk of
unpleasant surprises. The building checks and the
hands-on advice to larger customers within the SME
segment, whom If often meets face-to-face, help
customers to identify where maintenance and fire
safety measures are most needed. They also make
customers aware of risks and provide suggestions for
mitigating actions.
Continuously improving the quality of its services in
both digital and analogue channels is important to
Sampo Group. During 2024, the Group aimed to
enhance the way customers communicate with the
company through various initiatives. This included,
among other things, further development of digital
platforms and testing of new communication channels.
Additionally, understanding customer experiences
through different channels remained one of Sampo
Group’s focus areas, as it enables identification of
opportunities for enhancements to customer journeys
and customer satisfaction.
A part of Sampo Group’s responsible sales and
marketing practices is quality policies and processes,
and therefore, the Group conducted annual policy
reviews during the year. For example, Topdanmark
implemented the guidelines on green marketing from
the Danish Consumer Ombudsman. As a result, a key
action was to update business processes and policies
on communication on environmental initiatives,
products, and services to ensure compliance with
legislation. In addition, Sampo Group continued to
proactively contact customers to ensure that they are
correctly insured.
Data privacy, information security, and cybersecurity
During 2024, Sampo Group took a series of measures to
bolster data protection and ensure compliance with
industry standards and regulations. This included, for
example, raising awareness within the organisation
about the importance of data privacy, information
security, and cybersecurity, and providing training to
employees on the latest developments, new laws, and
regulations (e.g. Digital Operational Resilience Act
DORA).
Sampo Group regularly updates its policies, guidelines,
and training materials to stay current with the evolving
landscape of data privacy, information security, and
BOARD OF DIRECTORS’ REPORT 2024
112
cybersecurity. During 2024, this continued through
annual policy reviews conducted across the Group.
Sampo Group, for example, updated privacy notices
and ethical guidelines (or similar) to ensure artificial
intelligence (AI) is used responsibly, with a particular
focus on data security in automated and machine
learning processes. During the year, all employees of If
were instructed on the use of AI tools, for instance.
In 2024, Sampo Group monitored the processing of
personal data to ensure it is carried out transparently
and with respect for individuals’ privacy. The key
actions were the performance of data protection impact
assessments and records of processing activities before
new processing activities were initiated, as well as when
changes to existing processing activities were planned.
To ensure compliance with the regulation, Sampo
Group reviewed all new systems and applications from
a privacy perspective.
In 2024, If conducted a larger internal monitoring
activity to ensure that it accommodates all data subject
access requests according to the requirements of the
General Data Protection Regulation (GDPR). The
company continued the implementation of technical
measures to better ensure the security of personal data
in the context of electronic communication with
customers. In addition, If initiated several actions to
enable better control for customers in relation to their
personal data. In 2024, If also established a Data
Governance Committee to promote clear
responsibilities and improved guidelines for how data
can be used.
Sampo Group has several actions planned for 2025
regarding data privacy, information security, and
cybersecurity, some of them already underway. Due to
the Topdanmark transaction, one key action is to
integrate relevant activities with If in a way that ensures
continued compliance with data privacy and
information security regulations and mitigates the
potential risks for consumers and end-users. There are
also other actions planned for 2025 to improve and
strengthen the protection of personal data. These
actions address, for example, unstructured data, access
logging, privacy by design and default, as well as data
ownership structure and governance.
Metrics and targets
Targets related to managing material
negative impacts, advancing positive
impacts, and managing material risks and
opportunities
Customer health and safety and Sales and marketing
practices
In accordance with the Sampo Group Code of Conduct,
Sampo Group strives to act in the best interests of its
customers. This means that the aim is to provide
products and services that are fair, comprehensible, and
designed to help meet the evolving needs of customers.
Sampo Group uses the Net Promoter Score (NPS) to
measure customer satisfaction, which allows the Group
to advance positive impacts on consumers and end-
users. Using NPS also supports monitoring of potential
negative impacts and risks and acting on them. The NPS
is an index ranging from -100 to 100 that measures the
willingness of customers to recommend a company’s
products or services to others. It is used as a proxy for
measuring the customer’s overall satisfaction with a
company’s product or service, and the customer’s
loyalty to the brand. Transactional Net Promoter Score
(tNPS) is an overall metric that assesses the customer’s
opinion on a certain business transaction and captures a
wide range of customer experiences related to, for
example, price, product, billing, brand, and marketing.
The tNPS score shows whether customers want to
recommend the company to others after they have
been in contact with the company. It is calculated as the
net result of the share of promoters (who replied 9–10)
minus the share of detractors (who replied 0–6) on the
question of to what extent they would recommend the
company to others.
Sampo Group has set time-bound and outcome-
oriented targets for customer satisfaction. The targets
are specific to each individual Sampo Group company,
and their scope differs between the Group companies
due to company-specific characteristics (e.g. size,
structure, operating countries). External stakeholders
have not been directly involved in target setting.
However, consumers and end-users have been
indirectly involved, as customer-facing organisational
units have been included in the target setting. The
targets are presented in the table Customer satisfaction
(tNPS) (p. 114).
Sampo Group actively monitors and analyses the tNPS,
and the results are regularly reported to the respective
top managements and internal committees to assess
overall performance. Sampo Group tracks the tNPS
performance internally on a monthly basis and has set
targets to ensure continuous improvement. Sampo
Group also publishes the results and targets externally
on a quarterly basis. Through systematic measurement
of customer satisfaction, Sampo Group wants to both
identify the factors that are valued by the company’s
customers and recognise the parts of the customer
journey that should be improved. In addition to
improving the customer experience in general, the
results are used in training as well as in developing
products, services, and customer-related processes.
Additionally, Sampo Group collects feedback through
various channels, including customer complaints and
customer satisfaction surveys. The feedback not only
contributes to tNPS but also provides deeper insights
into the customer experience, enabling Sampo Group to
BOARD OF DIRECTORS’ REPORT 2024
113
address concerns proactively. Sampo Group is
committed to actively addressing customer feedback,
and low tNPS scores prompt engagement with
customers to resolve their issues and inform service
enhancements. Examples of improvements made based
on customer feedback include clarifying terms and
conditions and enhancing customer communications.
These processes ensure consistent elevation of service
quality and customer satisfaction.
The NPS methodology can have its limitations, such as
oversimplification of customer sentiment, and a lack of
detailed feedback on specific areas for improvement.
However, follow-up with individual customers can
provide a deeper insight into areas of potential
development. The measurement of customer
satisfaction is not validated by an external body other
than the assurance provider of this Sustainability
Statement.
In 2024, If’s customer satisfaction remained high, but
the tNPS result for Business area Private was somewhat
below the previous year. Topdanmark’s customer
satisfaction improved in digital channels in 2024.
However, the results related to the phone channel
decreased slightly. Hastings exceeded its tNPS target in
2024. The underlying claims journey tNPS stabilised and
results related to retail journeys continued to improve.
Data privacy, information security, and cybersecurity
The goal of Sampo Group’s data privacy operations is
to protect the employees’, customers’, and other
stakeholders’ personal data. In addition, information
security and cybersecurity measures ensure protection
of all types and forms of information according to its
sensitivity and importance to Sampo Group, and in
compliance with applicable rules and regulations. The
key metrics used are the number of complaints from
data subjects and data protection authorities (DPAs),
data privacy incidents reported to local data protection
authorities, and information security and cybersecurity
incidents reported to the authorities within the
reporting year.
Complaints from data subjects are based on Sampo
Group’s internal systems that capture complaints.
Generally, Sampo Group’s Data Protection Officers
(DPOs) receive complaints from both customers and
DPAs. Complaints can be received via different
channels (e.g. email, phone, post/letter) depending on
the Group company and local legislation in question. If a
data subject has contacted the local data protection
authorities directly, the complaint is forwarded to
Sampo Group.
Sampo Group’s DPOs (or similar) assess whether
internally reported data privacy incidents require
external reporting to local DPAs. The types of incidents
that are deemed reportable are based on legislation
(e.g. the GDPR). According to the GDPR, a personal
data breach is a breach of security leading to the
accidental or unlawful destruction, loss, alteration,
unauthorised disclosure of, or access to, personal data
transmitted, stored or otherwise processed. However,
there are regional differences in which data privacy
incidents are required to be reported to the local DPAs
based on their individual guidance. In 2024, the majority
of Sampo Group’s incidents were reported in the UK.
Information security and cybersecurity incidents are
monitored internally at Sampo Group on a subsidiary
level. Reporting on severe cases to the authorities is
based on local legislation and is the responsibility of
legal or information security units (or similar).
The measurement of the number of complaints from
data subjects and data protection authorities, data
privacy incidents reported to local data protection
authorities, and information security and cybersecurity
incidents reported to the authorities are not validated
by an external body other than the assurance provider
of this Sustainability Statement.
BOARD OF DIRECTORS’ REPORT 2024
114
Customer satisfaction (tNPS)
Sampo Group
Metric
Target
2024
If (business area Private)
2024: 60
57
Topdanmark
2025: 60
2027: 70
57
Hastings
2024: 50
56
Complaints from data subjects and data protection authorities
Sampo Group
Metric
2024
Complaints from data subjects
135
Complaints from data protection authorities
3
Data privacy incidents reported to local data protection
authorities
Sampo Group
Metric
2024
Data privacy incidents reported to local data protection authorities
414
Information security and cybersecurity incidents reported to the
authorities
Sampo Group
Metric
2024
Information security and cybersecurity incidents reported to the
authorities
0
BOARD OF DIRECTORS’ REPORT 2024
115
Governance information
Business conduct
Topic
Impacts
Risks and opportunities
Strategy and actions
Corruption and
bribery
↓ Sampo Group can have potential negative impact 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
↓ Sampo Group can face reputational risks, legal risks,
business risks, and potential costs if it fails to combat
financial crime, corruption, or bribery in all their forms.
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. codes of
conduct, responsible investment policies)
• Effective governance structures and processes (e.g.
general risk management measures, screening of
direct investments and corporate customers against
international norms and standards, encouraging
sustainability in supply chains, reporting channels)
• Training and competence development programmes
• Metrics and targets (e.g. reported incidents)
Responsible
business
practices
↑ Actual positive impact can occur through quality risk
management, which is at the core of Sampo Group’s
business operations. Risk management ensures that
Sampo Group can provide safety and financial
security to its customers, investors, and society in
general.
↑ Emphasising sustainability and responsible business
practices in strategy and business operations may
result in positive impacts across Sampo Group’s value
chain.
↓ Sampo Group can have potential negative impact 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
↓ For an insurance company like Sampo Group,
responsible business practices and quality risk
management (e.g. adequate management and control
systems, internal standards and processes) are at the
core of the business. However, due to the size of the
company and its value chain, it is not possible to
completely remove the risk for potential negative
impacts (e.g. risk of non-compliance due to increasing
regulation or human error).
↓ If sustainability is not an integrated part of governance
and business management, it can cause a financial risk
for Sampo Group due to possible legislative
consequences (e.g. fines) and reputational damage, for
example.
↑ There might be financial opportunities for Sampo
Group in the medium term, as ESG integration helps in
preparing for future regulation and the sustainable
development of society (e.g. green transformation), for
instance.
Time-horizon: short to medium term
• Internal policies and guidelines (e.g. risk
management principles, compliance principles,
codes of conduct)
• Effective governance structures and processes (e.g.
Sampo Group steering framework, risk management
governance framework, regulated risk management
measures, sustainability reporting and governance
structure)
• Training and competence development programmes
The table presents Sampo Group’s material impacts, risks, and opportunities related to business conduct identified in the double materiality assessment and their connection to Sampo Group’s strategy and
actions. The topics are linked to the ESRS sub-topics. The topic Corruption and bribery is related to the ESRS sub-topic with the same name. The topic Responsible business practices is related to the ESRS
sub-topics Corporate culture, protection of whistle-blowers, and Management of relationships with suppliers including payment practices.
BOARD OF DIRECTORS’ REPORT 2024
116
Impact, risk, and opportunity
management
Business conduct policies and corporate
culture
Sampo Group’s policy regarding business conduct and
corporate culture is the Sampo Group Code of Conduct,
which is reviewed annually and approved by Sampo’s
Board of Directors. The Code states that Sampo Group
complies with applicable legislation and the rules and
regulations of competent authorities in all its activities.
In addition to the Group’s Code of Conduct, each
Sampo Group company has its own supplementary
policies, guidelines, and processes (e.g. HR policies,
underwriting policies, responsible investment policies,
supplier codes of conduct). Sampo Group is also a
participant in the UN Global Compact supporting its
principles on human rights, labour rights, the
environment, and anti-corruption.
The Sampo Group Code of Conduct applies to all
companies belonging to Sampo Group. The Group
companies offer regular training (e.g. e-learning,
workshops) to all employees on the topics covered by
the Code and are committed to communicating the
topics to their employees (e.g. policy updates on the
intranet). The frequency of the training varies from
annual to biennial depending on the Group company
and the topic in question.
Whistleblowing channels
Sampo Group has whistleblowing channels through
which employees and relevant interest groups can
report anonymously if they have reasonable grounds to
suspect that somebody employed by Sampo Group has
breached the Sampo Group Code of Conduct,
legislation, regulations, or other rules that are relevant
to the insurance industry. Material whistleblowing
notifications reported through the whistleblowing
channels are reported to the parent company, Sampo,
as a part of regular compliance and sustainability
reporting to ensure group level monitoring of these
matters.
In addition to the whistleblowing channels, Sampo
Group encourages its employees to report grievances
related to unethical practices, as well as possible
violations of laws, regulations, or internal policies
through other internal reporting channels. Grievances
can also be reported directly to a leader, HR, or
compliance units, for example.
Sampo Group has defined structures for processing
whistleblowing notifications. The company ensures that
the outcomes and remedies related to whistleblowing
systems accord with internationally recognised human
rights.
Information about the whistleblowing channels and
other internal reporting channels is proactively
communicated to employees through the intranet, for
example. Sampo Group also offers training to its own
employees, including information about the designation
and training of those reviewing the reports. The
employees designated with this task receive training
when they are appointed to the position (e.g.
onboarding, on-the-job training). Maintaining objectivity
is essential for the employees handling the reports.
Sampo Group ensures that those handling the reports
are separate from those whom the report concerns, and
the investigators or investigating committees are
separate from the chain of management involved in the
matter.
All whistleblowing reports are investigated promptly
and in a confidential manner, while always protecting
the identity of the whistleblower. Sampo Group
prohibits any form of retaliation (e.g. physical,
psychological, economic) against an employee who in
good faith raises a concern about suspected or actual
misconduct through any reporting channel, or who
cooperates in an investigation of misconduct.
Management of relationships with suppliers
Sampo Group complies with applicable local legislation
and regulations in its payment practices. In addition,
Sampo Group has internal guidelines in place (e.g.
accounting instructions, claims guidelines) to ensure
timely payment. Automated systems and digital
invoicing help in preventing late payments.
Sampo Group is a major procurer of goods and
services, especially in claims handling and, therefore,
has an impact on the economy, environment, and
people. In addition, Sampo Group emphasises
sustainability factors when working with suppliers, as
sustainability issues can carry reputational and
operational risks if not managed correctly.
The Sampo Group Code of Conduct provides the group
level guiding principles for sustainable supply chain
management. According to the Code of Conduct,
Sampo Group expects its suppliers and other business
partners to comply with the principles of the Code of
Conduct throughout their own operations and supply
chains.
Environmental and social considerations are integral to
Sampo Group’s supplier selection process. In addition to
the Group’s Code of Conduct, each Sampo Group
company has its own supplementary policies (e.g.
supplier codes of conduct), guidelines, and processes
(e.g. risk assessments) that guide supplier selection.
Topics covered in these policies include, for example,
human rights, labor rights, environmental
considerations, and anti-corruption.
Sampo Group is committed to encouraging and
supporting the company’s suppliers in their efforts to
use more sustainable methods in their operations. By
BOARD OF DIRECTORS’ REPORT 2024
117
actively requesting innovative solutions, resource
efficiency, transparency, and responsibility from
suppliers, Sampo Group aims to minimise its negative
impact and stimulate sustainable production and
consumption. Set requirements, in combination with
close cooperation with suppliers, enable Sampo Group
to develop its business while also contributing to
sustainable development.
Prevention and detection of corruption and
bribery
Sampo Group can be exposed to corruption and bribery
especially through its customer support functions (e.g.
sales, claims handling), investments, as well as suppliers
and business partners (e.g. procurement, claims
handling, IT). Customer support functions are at risk of
corruption, for example due to financial transactions
and handling of personal data. Investment operations
can be vulnerable, for example, due to exposure to
industries and markets with varying levels of corruption
risk. Suppliers and business partners may face risks
associated with the dependency on third-party
partnerships and intricate procurement operations.
Allegations or incidents of corruption and bribery are
generally detected through reporting channels (e.g.
whistleblowing channels), screening of customers and
direct investments, and supplier selection and risk
assessment processes. The risks are mitigated by
internal control systems. This includes commitments to
international initiatives (e.g. the UN Global Compact),
policies and guidelines (e.g. codes of conduct,
investment policies), employee training, and other
manual and automatic control activities.
The Sampo Group Code of Conduct sets the overall
guiding principles on working against corruption and
bribery within Sampo Group. In addition, each Group
company has adopted supplementary policies and
guidelines for its own purposes. These annually updated
guidance documents contain, for example, rules on
gifts, participation in events, and hospitality, as well as
information on expectations regarding employees, and
roles and responsibilities.
The managing director of each company in Sampo
Group has the ultimate responsibility to ensure that
sufficient resources are allocated to the prevention of
corruption and bribery. Each Group company organises
duties and takes other necessary and appropriate
measures to comply with the applicable local rules and
various sanctions regimes, which may be imposed by
the UN and/or the EU.
Reporting on anti-corruption and anti-bribery activities,
as well as on potential incidents, is organised in a
manner that ensures that the management and the
boards of directors of relevant Group companies
receive all material information without undue delay,
and that Sampo’s Risk Management organisation is
informed of all relevant incidents.
The number of whistleblowing notifications reported
through the whistleblowing channels is reported to the
parent company, Sampo, as part of regular compliance
reporting. Sampo’s Risk Management organisation is
responsible for overseeing the reporting of relevant
incidents to Sampo’s Audit Committee and the Board of
Directors.
Sampo Group provides training (e.g. e-learning, during
contract discussions) on business conduct matters to
ensure that employees, suppliers, and other business
partners have sufficient knowledge. Related and
relevant policies are available for all Group employees
via intranet and for other stakeholders on the Group
companies’ websites.
All Sampo Group employees and top management (e.g.
CEOs) are offered training (e.g. e-learning) on anti-
corruption and anti-bribery at least biennially. Hence,
also all employees who work in the functions most at
risk for negative impacts (e.g. customer support
functions, investment management, and supply chain
management) receive training on the topic. Anti-
corruption and anti-bribery are part of training
programmes covering business ethics and conduct. In
addition, employees are informed, for example, on the
intranet, when related policies have been revised.
In 2024, Sampo Group reviewed its policies and training
material related to corruption and bribery. In addition to
annual policy updates, Sampo Group initiated projects
and raised awareness regarding the topic using several
methods. For example, If initiated an internal company-
wide project to work against organised crime, while
Hastings supplemented its existing mandatory training
on corruption and bribery by introducing a new video
series on recognising fraudulent activity and hosted a
Fraud Awareness Week for employees. In the future,
Sampo Group will continue its various activities and
training programmes, which include training on anti-
money laundering, anti-bribery, anti-corruption, and
anti-fraud.
BOARD OF DIRECTORS’ REPORT 2024
118
Metrics and targets
Incidents of corruption or bribery
In 2024, Sampo Group was not convicted for incidents
of corruption or bribery and, therefore, did not pay any
related fines. For the same reason, Sampo Group did
not need to take specific actions related to breaches in
procedures and standards of anti-corruption and anti-
bribery. In 2024, there were no public legal cases
regarding corruption or bribery brought against Sampo
Group either.
Incidents of corruption and bribery included in the
reporting are confirmed incidents that the Group
companies report to Sampo as part of regular
sustainability and compliance and/or risk reporting. The
Group companies receive this information through their
established reporting channels, such as whistleblowing
channels. The measurements related to corruption and
bribery are not validated by an external body other than
the assurance provider of this Sustainability Statement.
Incidents of corruption or bribery
Sampo Group
Metric
2024
Confirmed incidents of corruption or bribery
0
Confirmed incidents in which own workers
were dismissed or disciplined for corruption
or bribery-related incidents
0
Payment practices
Due to the complexity of Sampo Group’s payment
systems, the diversity of its supplier base, and
confidentiality considerations, Sampo Group is currently
unable to provide a specific average time for invoice
payments and information on its standard payment
terms on a group level. However, Sampo Group is
committed to fair and responsible payment practices
and is actively working to improve related reporting.
Sampo Group’s payment terms are influenced by
various factors, including the nature of the supplier
relationship, the country or geographical region of
operation, and market standards. Sampo Group
recognises the importance of timely payments to its
suppliers and aims to ensure that its payment practices
are transparent and equitable across the company’s
supply chain. Insurance companies tend to have a good
liquidity position as insurance payments provide cash
flow. As at 31 December 2024, Sampo Group was not
party to any legal proceedings due to late payments.
During 2024, Sampo Group started to investigate
reporting related to payment practices. The plan is to
develop reporting in accordance with the ESRS
guidance in the coming years.
BOARD OF DIRECTORS’ REPORT 2024
119
Annexes
Annex 1: ESRS content index
Disclosure requirement
Location
ESRS 2 General disclosures
BP-1 – General basis for preparation of the sustainability statement
BP-2 – Disclosures in relation to specific circumstances
GOV-1 – The role of the administrative, management and supervisory
bodies
p. 56
GOV-2 – Information provided to and sustainability matters addressed by
the undertaking’s administrative, management and supervisory bodies
GOV-3 – Integration of sustainability-related performance in incentive
schemes
GOV-4 – Statement on due diligence
GOV-5 – Risk management and internal controls over sustainability
reporting
SBM-1 – Strategy, business model and value chain
SBM-2 – Interests and views of stakeholders
SBM-3 – Material impacts, risks, and opportunities and their interaction
with strategy and business model
IRO-1 – Description of the processes to identify and assess material
impacts, risks, and opportunities
IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s
sustainability statement
ESRS E1 Climate change
E1-1 – Transition plan for climate change mitigation
E1-2 – Policies related to climate change mitigation and adaptation
E1-3 – Actions and resources in relation to climate change policies
E1-4 – Targets related to climate change mitigation and adaptation
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
ESRS E5 Resource use and circular economy
E5-1 – Policies related to resource use and circular economy
E5-2 – Actions and resources related to resource use and circular
economy
E5-3 – Targets related to resource use and circular economy
Disclosure requirement
Location
ESRS S1 Own workforce
S1-1 – Policies related to own workforce
S1-2 – Processes for engaging with own workers and workers’
representatives about impacts
S1-3 – Processes to remediate negative impacts and channels for own
workers to raise concerns
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
S1-5 – Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
S1-6 – Characteristics of the undertaking’s employees
S1-7 – Characteristics of non-employee workers in the undertaking’s own
workforce
S1-8 – Collective bargaining coverage and social dialogue
S1-9 – Diversity metrics
S1-10 – Adequate wages
S1-11 – Social protection
S1-12– Persons with disabilities
S1-13 – Training and skills development metrics
S1-14 – Health and safety metrics
S1-15 – Work-life balance metrics
S1-16 – Remuneration metrics (pay gap and total remuneration)
S1-17 – Incidents, complaints and severe human rights impacts
BOARD OF DIRECTORS’ REPORT 2024
120
Disclosure requirement
Location
ESRS S2 Workers in the value chain
S2-1 – Policies related to value chain workers
S2-2 – Processes for engaging with value chain workers about impacts
S2-3 – Processes to remediate negative impacts and channels for value
chain workers to raise concerns
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
S2-5 – Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
ESRS S4 Consumers and end-users
S4-1 – Policies related to consumers and end-users
S4-2 – Processes for engaging with consumers and end-users about
impacts
S4-3 – Processes to remediate negative impacts and channels for
consumers and end-users to raise concerns
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
S4-5 – Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
ESRS G1 Business conduct
G1-1 – Business conduct policies and corporate culture
G1-2 – Management of relationships with suppliers
G1-3 – Prevention and detection of corruption and bribery
G1-4 – Incidents of corruption or bribery
G1-6 – Payment practices
 
BOARD OF DIRECTORS’ REPORT 2024
121
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
ESRS 2 GOV-1 Percentage of board members
who are independent paragraph 21 (e)
Delegated Regulation (EU)
2020/1816, Annex II
ESRS 2 GOV-4 Statement on due diligence
paragraph 30
Indicator number 10 Table #3
of Annex 1
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)
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
BOARD OF DIRECTORS’ REPORT 2024
122
Disclosure requirement and related
datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law reference
Location
ESRS E1-4 GHG emission reduction targets
paragraph 34
Indicator number 4 Table #2
of Annex 1
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template 3:
Banking book – Climate
change transition risk:
alignment metrics
Delegated Regulation (EU)
2020/1818, Article 6
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)
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)
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 2024
123
Disclosure requirement and related
datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law reference
Location
ESRS E1-9 Disaggregation of monetary
amounts by acute and chronic physical risk
paragraph 66 (a)
ESRS E1-9 Location of significant assets at
material physical risk paragraph 66 (c)
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 paragraphs
46 and 47; Template 5:
Banking book – Climate
change physical risk:
Exposures subject to
physical risk
Phased-in
ESRS E1-9 Breakdown of the carrying value of
its real estate assets by energy-efficiency
classes paragraph 67 (c).
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 paragraph
34;Template 2:Banking book
-Climate change transition
risk: Loans collateralised by
immovable property –
Energy efficiency of the
collateral
Phased-in
ESRS E1-9 Degree of exposure of the portfolio
to climate-related opportunities paragraph 69
Delegated Regulation (EU)
2020/1818, Annex II
Phased-in
ESRS E2-4 Amount of each pollutant listed in
Annex II of the E-PRTR Regulation (European
Pollutant Release and Transfer Register)
emitted to air, water and soil, paragraph 28
Indicator number 8 Table #1
of Annex 1, Indicator number
2 Table #2 of Annex 1,
Indicator number 1 Table #2
of Annex 1, Indicator number
3 Table #2 of Annex 1
Not material
ESRS E3-1 Water and marine resources
paragraph 9
Indicator number 7 Table #2
of Annex 1
Not material
ESRS E3-1 Dedicated policy paragraph 13
Indicator number 8 Table # 2
of Annex 1
Not material
ESRS E3-1 Sustainable oceans and seas
paragraph 14
Indicator number 12 Table #2
of Annex 1
Not material
ESRS E3-4 Total water recycled and reused
paragraph 28 (c)
Indicator number 6.2 Table
#2 of Annex 1
Not material
ESRS E3-4 Total water consumption in m³ per
net revenue on own operations paragraph 29
Indicator number 6.1 Table
#2 of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (a) i
Indicator number 7 Table #1
of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (b)
Indicator number 10 Table #2
of Annex 1
Not material
ESRS 2 – IRO-1 - E4 paragraph 16 (c)
Indicator number 14 Table #2
of Annex 1
Not material
BOARD OF DIRECTORS’ REPORT 2024
124
Disclosure requirement and related
datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law reference
Location
ESRS E4-2 Sustainable land / agriculture
practices or policies paragraph 24 (b)
Indicator number 11 Table #2
of Annex 1
Not material
ESRS E4-2 Sustainable oceans / seas
practices or policies paragraph 24 (c)
Indicator number 12 Table #2
of Annex 1
Not material
ESRS E4-2 Policies to address deforestation
paragraph 24 (d)
Indicator number 15 Table #2
of Annex 1
Not material
ESRS E5-5 Non-recycled waste paragraph 37
(d)
Indicator number 13 Table #2
of Annex 1
Not material
ESRS E5-5 Hazardous waste and radioactive
waste paragraph 39
Indicator number 9 Table #1
of Annex 1
Not material
ESRS 2 – SBM-3 - S1 Risk of incidents of
forced labour paragraph 14 (f)
Indicator number 13 Table #3
of Annex I
Not material
ESRS 2 – SBM-3 - S1 Risk of incidents of child
labour paragraph 14 (g)
Indicator number 12 Table #3
of Annex I
Not material
ESRS S1-1 Human rights policy commitments
paragraph 20
Indicator number 9 Table #3
and Indicator number 11
Table #1 of Annex I
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
ESRS S1-1 processes and measures for
preventing trafficking in human beings
paragraph 22
Indicator number 11 Table #3
of Annex I
ESRS S1-1 workplace accident prevention
policy or management system paragraph 23
Indicator number 1 Table #3
of Annex I
ESRS S1-3 grievance/complaints handling
mechanisms paragraph 32 (c)
Indicator number 5 Table #3
of Annex I
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
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
ESRS S1-16 Excessive CEO pay ratio
paragraph 97 (b)
Indicator number 8 Table #3
of Annex I
ESRS S1-17 Incidents of discrimination
paragraph 103 (a)
Indicator number 7 Table #3
of Annex I
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)
BOARD OF DIRECTORS’ REPORT 2024
125
Disclosure requirement and related
datapoint
SFDR reference
Pillar 3 reference
Benchmark Regulation
reference
EU Climate Law reference
Location
ESRS 2 – SBM-3 – S2 Significant risk of child
labour or forced labour in the value chain
paragraph 11 (b)
Indicators number 12 and 13
Table #3 of Annex I
ESRS S2-1 Human rights policy commitments
paragraph 17
Indicator number 9 Table #3
and Indicator no. 11 Table #1
of Annex 1
ESRS S2-1 Policies related to value chain
workers paragraph 18
Indicator number 11 and 4
Table #3 of Annex 1
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)
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
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
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
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)
ESRS S4-4 Human rights issues and incidents
paragraph 35
Indicator number 14 Table #3
of Annex 1
ESRS G1-1 United Nations Convention against
Corruption paragraph 10 (b)
Indicator number 15 Table #3
of Annex 1
ESRS G1-1 Protection of whistle-blowers
paragraph 10 (d)
Indicator number 6 Table #3
of Annex 1
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)
ESRS G1-4 Standards of anti-corruption and
anti-bribery paragraph 24 (b)
Indicator number 16 Table #3
of Annex 1
BOARD OF DIRECTORS’ REPORT 2024
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Annex 3: Reporting requirements related to the Delegated Regulation (EU) 2022/1214
Template 1 Nuclear and fossil gas related activities
Row
Nuclear energy related activities
1.
The undertaking carries out, funds or has exposures to research, development,
demonstration and deployment of innovative electricity generation facilities that
produce energy from nuclear processes with minimal waste from the fuel cycle.
YES
2.
The undertaking carries out, funds or has exposures to construction and safe operation
of new nuclear installations to produce electricity or process heat, including for the
purposes of district heating or industrial processes such as hydrogen production, as
well as their safety upgrades, using best available technologies.
YES
3.
The undertaking carries out, funds or has exposures to safe operation of existing
nuclear installations that produce electricity or process heat, including for the
purposes of district heating or industrial processes such as hydrogen production from
nuclear energy, as well as their safety upgrades.
YES
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of
electricity generation facilities that produce electricity using fossil gaseous fuels.
YES
5.
The undertaking carries out, funds or has exposures to construction, refurbishment,
and operation of combined heat/cool and power generation facilities using fossil
gaseous fuels.
YES
6.
The undertaking carries out, funds or has exposures to construction, refurbishment
and operation of heat generation facilities that produce heat/cool using fossil gaseous
fuels.
YES
BOARD OF DIRECTORS’ REPORT 2024
127
Template 2 Taxonomy-aligned economic activities (denominator)
Based on turnover
EURm
Row
Economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
—
—%
—
—%
—
—%
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
4
0.0%
4
0.0%
—
—%
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
—
—%
—
—%
—
—%
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred
to in rows 1 to 6 above in the denominator of the applicable KPI
121
0.6%
121
0.6%
0
0.0%
8.
Total applicable KPI
125
0.6%
125
0.6%
0
0.0%
BOARD OF DIRECTORS’ REPORT 2024
128
Template 2 Taxonomy-aligned economic activities (denominator)
Based on CapEX
EURm
Row
Economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
—
—%
—
—%
—
—%
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
1
0.0%
1
0.0%
—
—%
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred
to in rows 1 to 6 above in the denominator of the applicable KPI
196
1.0%
195
1.0%
1
0.0%
8.
Total applicable KPI
196
1.0%
195
1.0%
1
0.0%
BOARD OF DIRECTORS’ REPORT 2024
129
Template 3 Taxonomy-aligned economic activities (numerator)
Based on turnover
EURm
Row
Economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
—
—%
—
—%
—
—%
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0.3%
0
0.3%
—
—%
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
4
3.1%
4
3.1%
—
—%
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
—
—%
—
—%
—
—%
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred
to in rows 1 to 6 above in the numerator of the applicable KPI
121
92.2%
121
92.0%
0
0.3%
8.
Total amount and proportion of taxonomy-aligned economic activities in the
numerator of the applicable KPI
125
95.6%
125
95.3%
0
0.3%
BOARD OF DIRECTORS’ REPORT 2024
130
Template 3 Taxonomy-aligned economic activities (numerator)
Based on CapEX
EURm
Row
Economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
—
—%
—
—%
—
—%
2.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
3.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
1
0.3%
1
0.3%
—
—%
4.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
5.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
6.
Amount and proportion of taxonomy-aligned economic activity referred to in Section
4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the
applicable KPI
0
0.0%
0
0.0%
—
—%
7.
Amount and proportion of other taxonomy-aligned economic activities not referred
to in rows 1 to 6 above in the numerator of the applicable KPI
196
97.2%
195
96.7%
1
0.5%
8.
Total amount and proportion of taxonomy-aligned economic activities in the
numerator of the applicable KPI
196
97.6%
195
97.1%
1
0.5%
BOARD OF DIRECTORS’ REPORT 2024
131
Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
Based on turnover
EURm
Row
Economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
—
—%
—
—%
—
—%
2.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0.0%
0
0.0%
—
—%
3.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0.0%
0
0.0%
—
—%
4.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
1
0.0%
1
0.0%
—
—%
5.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
1
0.0%
1
0.0%
—
—%
6.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0.0%
0
0.0%
—
—%
7.
Amount and proportion of other taxonomy-eligible but not taxonomy-aligned
economic activities not referred to in rows 1 to 6 above in the denominator of the
applicable KPI
480
2.4%
470
2.4%
10
0.0%
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned
economic activities in the denominator of the applicable KPI
483
2.4%
473
2.4%
10
0.0%
BOARD OF DIRECTORS’ REPORT 2024
132
Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
Based on CapEX
EURm
Row
Economic activities
Amount and proportion
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount
%
Amount
%
Amount
%
1.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
—
—%
—
—%
—
—%
2.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
—
—%
—
—%
—
—%
3.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0.0%
0
0.0%
—
—%
4.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
1
0.0%
1
0.0%
0
0.0%
5.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
1
0.0%
1
0.0%
—
—%
6.
Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic
activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation
2021/2139 in the denominator of the applicable KPI
0
0.0%
0
0.0%
—
—%
7.
Amount and proportion of other taxonomy-eligible but not taxonomy-aligned
economic activities not referred to in rows 1 to 6 above in the denominator of the
applicable KPI
610
3.1%
577
2.9%
34
0.2%
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned
economic activities in the denominator of the applicable KPI
613
3.1%
579
2.9%
34
0.2%
BOARD OF DIRECTORS’ REPORT 2024
133
Template 5 Taxonomy non-eligible economic activities
Based on turnover
EURm
Row
Economic activities
Amount
%
1.
Amount and proportion of economic activity referred to
in row 1 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
—
—%
2.
Amount and proportion of economic activity referred to
in row 2 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
7
0.0%
3.
Amount and proportion of economic activity referred to
in row 3 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
0
0.0%
4.
Amount and proportion of economic activity referred to
in row 4 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
—
—%
5.
Amount and proportion of economic activity referred to
in row 5 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
—
—%
6.
Amount and proportion of economic activity referred to
in row 6 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.31 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
—
—%
7.
Amount and proportion of other taxonomy-non-eligible
economic activities not referred to in rows 1 to 6 above
in the denominator of the applicable KPI
19,151
96.2%
8.
Total amount and proportion of taxonomy-non-eligible
economic activities in the denominator of the applicable
KPI
19,158
96.3%
Template 5 Taxonomy non-eligible economic activities
Based on CapEX
EURm
Row
Economic activities
Amount
%
1.
Amount and proportion of economic activity referred to
in row 1 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
—
—%
2.
Amount and proportion of economic activity referred to
in row 2 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
0
0.0%
3.
Amount and proportion of economic activity referred to
in row 3 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
0
0.0%
4.
Amount and proportion of economic activity referred to
in row 4 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
—
—%
5.
Amount and proportion of economic activity referred to
in row 5 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
0
0.0%
6.
Amount and proportion of economic activity referred to
in row 6 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.31 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of
the applicable KPI
—
—%
7.
Amount and proportion of other taxonomy-non-eligible
economic activities not referred to in rows 1 to 6 above
in the denominator of the applicable KPI
18,987
95.4%
8.
Total amount and proportion of taxonomy-non-eligible
economic activities in the denominator of the applicable
KPI
18,987
95.4%
BOARD OF DIRECTORS’ REPORT 2024
134
Key figures
Financial highlights
2024
2023
2022
(restated)
2022
(published)
2021
2020
Group
Gross written premiums & brokerage income
EURm
9,931
8,870
8,375
—
—
—
Insurance revenue, net
EURm
8,249
7,412
7,168
—
—
—
Insurance service result, net
EURm
1,394
1,193
1,062
—
—
—
Underwriting result
EURm
1,316
1,164
1,031
1,314
1,282
967
Net financial result
EURm
636
560
1,056
—
—
—
Profit before taxes (P&C operations)
EURm
1,559
1,481
1,924
1,863
3,171
380
Net profit for the equity holders
EURm
1,154
1,323
2,107
1,427
2,567
37
Operating result
EURm
1,193
1,046
—
—
—
—
Combined ratio
%
84.3
84.6
85.8
82.1
81.4
83.4
Undiscounted underlying combined ratio, current year, %
%
85.5
87.1
—
—
—
—
Solvency ratio1 3
%
177
182
210
210
185
176
Financial leverage
%
26.9
25.3
24.4
25.6
23.8
28.6
Return on own funds
%
21.3
18.1
—
—
—
—
Return on equity own funds
%
29.5
24.7
—
—
—
—
Return on equity
%
16.1
15.6
4.2
-1.3
26.8
3.1
Average number of staff
14,280
13,935
13,550
13,550
13,274
13,227
If
2024
2023
2022
(restated)
2022
(published)
2021
2020
Gross written premiums
EURm
5,860
5,468
5,432
—
—
—
Insurance revenue, net
EURm
5,258
4,996
5,024
—
—
—
Insurance service result/underwriting result
EURm
890
842
673
985
891
801
Net financial result
EURm
464
539
888
—
—
—
Premiums written before reinsurers' share (IFRS 4)
EURm
—
—
—
5,432
5,134
4,823
Premiums earned (IFRS 4)
EURm
—
—
—
5,002
4,772
4,484
Profit before taxes
EURm
1,256
1,358
1,550
1,217
1,077
901
Combined ratio
%
83.1
83.1
86.6
80.3
81.3
82.1
Cost ratio
%
20.9
21.2
21.6
21.1
21.4
21.5
Risk ratio
%
62.1
61.9
65.0
59.2
59.9
60.7
Adjusted risk ratio, current year, %5
%
61.5
61.3
62.3
—
—
—
Undiscounted adjusted risk ratio, current year, %6
%
64.4
64.7
65.2
—
—
—
Loss ratio
%
67.6
67.6
70.7
64.9
65.5
66.4
Expense ratio
%
15.5
15.6
15.9
15.4
15.8
15.8
Average number of staff
8,070
7,858
7,496
7,496
7,223
7,182
BOARD OF DIRECTORS’ REPORT 2024
135
Topdanmark
2024
2023
2022
(restated)
2022
(published)
2021
2020
Gross written premiums
EURm
1,553
1,339
1,308
—
—
—
Insurance revenue, net
EURm
1,470
1,288
1,255
—
—
—
Insurance service result/underwriting result
EURm
233
194
230
224
227
182
Net financial result
EURm
60
27
-28
—
—
—
Premiums written before reinsurers' share, P&C insurance (IFRS 4)
EURm
—
—
—
1,391
1,383
1,315
Premiums earned, P&C insurance (IFRS 4)
EURm
—
—
—
1,326
1,285
1,227
Profit before taxes
EURm
137
162
158
220
346
167
Combined ratio
%
84.2
85.0
81.7
83.1
82.3
85.2
Loss ratio
%
66.0
66.9
64.4
66.8
66.7
69.0
Expense ratio
%
18.1
18.1
17.2
16.3
15.6
16.2
Average number of staff
2,412
2,160
2,381
2,381
2,395
2,428
Hastings
2024
2023
2022
(restated)
2022
(published)
2021
2020
GWP & brokerage income
EURm
2,565
2,063
1,636
—
—
—
Insurance revenue, net
EURm
1,522
1,128
889
—
—
—
Insurance service result, net
EURm
268
157
159
—
—
—
Underwriting result
EURm
190
128
128
104
164
—
Net financial result
EURm
41
44
27
—
—
—
Premiums written before reinsurers' share (IFRS 4)
EURm
—
—
—
1,313
1,127
103
Net premiums written (IFRS 4)
EURm
—
—
—
727
495
137
Premiums earned (IFRS 4)
EURm
—
—
—
594
499
63
Profit before taxes
EURm
193
129
107
73
127
-16
Operating ratio
%
88.5
89.8
87.2
89.7
80.3
—
Loss ratio
%
61.6
63.3
57.2
83.7
62.2
—
Average number of staff
3,736
3,200
3,021
3,021
3,005
2,974
Holding
2024
2023
2022
(restated)
2022
(published)
2021
2020
Profit before taxes
EURm
-29
-160
146
146
1,331
-826
Average number of staff
61
54
50
50
63
67
BOARD OF DIRECTORS’ REPORT 2024
136
Per share key figures
2024
2023
2022
(restated)
2022
(published)
2021
2020
Earnings per share
EUR
2.25
2.62
3.97
2.69
4.63
0.07
Earnings per share, continuing operations2
EUR
2.25
2.12
2.88
—
—
—
Earning per share, discontinuing operations
EUR
—
0.50
1.09
—
—
—
Operational result per share
EUR
2.33
2.07
—
—
—
—
Equity per share
EUR
13.11
14.47
18.70
17.44
23.39
20.56
Net asset value per share
EUR
13.11
15.30
20.01
18.74
25.48
19.82
Market capitalisation4
EURm
21,196
19,876
25,112
25,112
24,093
19,199
Dividend per share
EUR
1.70
1.80
2.60
2.60
4.10
1.70
Dividend payout ratio
%
75.5
68.8
65.4
96.7
88.6
78.7
Effective dividend yield
%
4.3
4.5
5.3
5.3
9.3
4.9
Price/earnings ratio
17.5
15.1
12.3
18.1
9.5
16.0
Number of shares at 31 Dec.
1,000
538,248
501,797
514,369
514,369
546,812
555,352
Average number of shares
1,000
512,114
505,939
530,296
530,296
554,317
555,352
Weighted average number of shares
1,000
512,114
505,939
530,296
530,296
554,317
555,352
A shares
2024
2023
2022
2022
2021
2020
Number of shares at 31 Dec.
1,000
538,048
501,597
514,169
514,169
545,612
554,152
Average  number of shares
1,000
511,914
505,739
530,096
530,096
553,117
554,152
Weighted average number of shares
1,000
511,914
505,739
530,096
530,096
553,117
554,152
Weighted average share price
EUR
40.11
39.36
44.25
44.25
40.50
32.35
Adjusted share price, high4
EUR
42.37
45.21
49.97
49.97
47.33
42.46
Adjusted share price, low4
EUR
37.38
34.53
35.85
35.85
33.82
21.34
Adjusted closing price
EUR
39.38
39.61
48.82
48.82
44.06
34.57
Share trading volume during the financial year
1,000
178,910
178,801
257,879
257,879
243,763
376,964
Relative share trading volume
%
34.9
35.4
48.6
48.6
44.1
68.0
B shares
2024
2023
2022
2022
2021
2020
Number of shares at 31 Dec.
1,000
200
200
200
200
1,200
1,200
Average number of shares
1,000
200
200
200
200
1,200
1,200
1 The Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC).
2 Earnings per share on continuing operations for comparative period 2022 includes the divested operations i.e. Topdanmark Life operations.
3 The solvency ratio for 2023 is pro forma figure excluding the effect of Saxo Bank on the Group SCR.
4 Share prices have been adjusted to reflect the separation of Mandatum Group in the partial demerger.
5 Adjusted risk ratio illustrates the underlying underwriting performance as it excludes certain volatile effects such as large and severe weather and prior year development on risk ratio.
6Undiscounted adjusted risk ratio excludes the effect from current year discounting on adjusted risk ratio and illustrates the underlying current year underwriting performance.
The number of shares used at the reporting date was 538,247,772 and the average number during the financial period  512,114,448.
In calculating the key figures the tax corresponding to the result for the accounting period has been taken into account.
In the net asset value per share, the Group valuation difference on the listed subsidiary Topdanmark has been taken into account in the comparison year. At the end of the financial year 2024, Topdanmark
was no longer a listed company
BOARD OF DIRECTORS’ REPORT 2024
137
Calculation of key figures
The key figures have been calculated in accordance with the decree issued by the Ministry of Finance and the specifying regulations and instructions of the Financial Supervisory
Authority. The Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC) and Insurance Companies Act (521/2008).
Additional information on the Group’s alternative performance measures is on the Group’s website www.sampo.com.
Return on equity, %
+
total comprehensive income attributable to owners of the parent
x 100%
+
total equity attributable to owners of the parent
(average of values 1 Jan. and the end of reporting period)
Return on equity own funds, %
+
operating result (annualised)
x 100 %
+
Unrestricted Tier 1 Own funds
(average of values 1 Jan. and the end of reporting period)
Return on own funds, %
+
operating result (annualised)
x 100 %
+
SII own funds
(average of values 1 Jan. and the end of reporting period)
Equity/assets ratio, %
+
total equity attributable to owners of the parent
x 100%
+
balance sheet total
Financial leverage1
financial debt
x 100%
equity + financial debt
1The Group’s financial leverage includes only long-term funding.
Insurance revenue, net
+
insurance revenue, gross
-
reinsurers' share of insurance revenue
-
quota share premium expense (Hastings)
insurance revenue, net
Underwriting result
+
insurance revenue, net
+
other income (Hastings)
-
claims incurred
-
operating expenses
underwriting result
Operating result
+
P&C operations’ (incl. Sampo plc) profit after tax
-
non-controlling interest in P&C operations
-
unrealised gains/losses on investments (excl. derivatives) in P&C
operations
-
result effect from changes in discount rates in P&C operations
-
non-operational amortisations in P&C operations
-
non-recurring items
-
adjustment on taxes
operating result
Combined ratio for P&C insurance, %
+
claims incurred
+
operating expenses
x 100%
+
insurance revenue, net
+
other revenue (Hastings)
BOARD OF DIRECTORS’ REPORT 2024
138
Risk ratio for P&C insurance, %
+
claims incurred
–
claims settlement expenses
x 100%
insurance revenue, net
Cost ratio for P&C insurance, %
+
operating expenses
+
claims settlement expenses
x 100%
insurance revenue, net
Loss ratio for P&C insurance, %
+
claims incurred
x 100%
insurance revenue, net
Expense ratio for P&C insurance, %
+
operating expenses
x 100%
insurance revenue, net
Operating ratio for Hastings, %
+
claims incurred
+
acquisition costs
+
other operating expenses
+
operational depreciation and amortisation
x 100%
+
insurance revenue, net
+
other revenue
Per share key figures
Earnings per share
profit for the financial period attributable to owners of the parent
adjusted average number of shares
Operating result per share
operating result
adjusted average number of shares
Equity per share
equity attributable to owners of the parent
adjusted number of shares at the balance sheet date
Net asset value per share
+
equity attributable to owners of the parent
±
valuation differences on listed Group companies
adjusted number of shares at balance sheet date
Market capitalisation
number of shares at the balance sheet date x closing share price at the
balance sheet date
Dividend payout ratio
Dividend per share
x 100%
Earnings per share
Effective dividend yield
Dividend per share
x 100%
Adjusted closing price
Price/earnings ratio
Adjusted closing price
Earnings per share
Relative share trading volume
Share trading volume during the financial year
x 100%
Average number of A shares
BOARD OF DIRECTORS’ REPORT 2024
139
Exchange rates used in reporting
1–12/2024
1–9/2024
1–6/2024
1–3/2024
1–12/2023
EURSEK
Income statement (average)
11.4345
11.4143
11.3945
11.2814
11.4745
Balance sheet (at end of period)
11.4590
11.3000
11.3595
11.5250
11.0960
DKKSEK
Income statement (average)
1.5327
1.5300
1.5274
1.5127
1.5406
Balance sheet (at end of period)
1.5365
1.5156
1.5232
1.5453
1.4888
NOKSEK
Income statement (average)
0.9831
0.9850
0.9912
0.9880
1.0048
Balance sheet (at end of period)
0.9715
0.9605
0.9968
0.9851
0.9871
EURDKK
Income statement (average)
7.4589
7.4589
7.4579
7.4562
7.4510
Balance sheet (at end of period)
7.4578
7.4560
7.4575
7.4580
7.4529
EURGBP
Income statement (average)
0.8467
0.8514
0.8547
0.8563
0.8697
Balance sheet (at end of period)
0.8292
0.8354
0.8464
0.8551
0.8691
FINANCIAL STATEMENTS 2024
140
Group’s IFRS Financial Statements
Statement of profit and other
comprehensive income ..........................................
Consolidated balance sheet .................................
Statement of changes in equity ..........................
Statement of cash flows ........................................
FINANCIAL STATEMENTS 2024
141
Statement of profit and other comprehensive income
EURm
Note
1-12/2024
1-12/2023
Insurance revenue
9,450
8,417
Insurance service expenses
-7,684
-7,076
Reinsurance result
-372
-148
Insurance service result
1
1,394
1,193
Net investment income
2
888
1,006
Net finance income or expense from insurance
contracts
3
-252
-446
Insurance finance income or expense, gross
-309
-529
Insurance finance income or expense, reinsurance
57
83
Net financial result
636
560
Other income
4
312
277
Other expenses
5
-685
-457
Finance expenses
7
-103
-93
Share of associates' profit or loss
6
1
Profit before taxes
1,559
1,481
Income taxes
15,16
-330
-339
Profit from the continuing operations
1,229
1,142
Discontinued operations, net of tax
30
—
251
Divested operations, net of tax
-26
—
Net profit
1,203
1,393
EURm
Note
1-12/2024
1-12/2023
Other comprehensive income
8
Items reclassifiable to profit or loss
Exchange differences
-4
-1
Cash flow hedges
1
-1
Total items reclassifiable to profit or loss, net of tax
-3
-3
Items not reclassifiable to profit or loss
Actuarial gains and losses from defined pension plans
0
-6
Taxes
0
1
Total items not reclassifiable to profit or loss, net of
tax
0
-5
Other comprehensive income total, net of tax
-3
-8
Total comprehensive income
1,200
1,386
Profit attributable to
Owners of the parent
1,154
1,323
Non-controlling interests
50
70
Total comprehensive income attributable to
Owners of the parent
1,151
1,316
Non-controlling interests
50
70
Earnings per share (EPS), EUR
2.25
2.62
Earnings per share, continuing operations, EUR
2.25
2.12
In the comparative year, Mandatum segment is presented in a single line as discontinued
operations. For further information, please see note 30.
FINANCIAL STATEMENTS 2024
142
Consolidated balance sheet
EURm
Note
12/2024
12/2023
Assets
Property, plant and equipment
10
284
318
Intangible assets
11
3,637
3,637
Investments in associates
4
12
Financial assets
12,13,14
16,090
15,757
Deferred income tax
15
2
3
Reinsurance contract assets
19
2,618
2,282
Other assets
17
880
800
Cash and cash equivalents
962
1,415
Total assets
24,478
24,225
Liabilities
Insurance contract liabilities
18,19,20,21
12,286
11,716
Subordinated debts
22
1,642
1,645
Other financial liabilities
22
1,395
1,269
Deferred income tax
15
535
567
Other liabilities
23
1,562
1,342
Total liabilities
17,419
16,538
Equity
25
Share capital
98
98
Reserves
3,531
1,530
Retained earnings
4,176
6,378
Other components of equity
-746
-743
Equity attributable to owners of the parent
7,059
7,263
Non-controlling interests
—
424
Total equity
7,059
7,687
Total equity and liabilities
24,478
24,225
FINANCIAL STATEMENTS 2024
143
Statement of changes in equity
EURm
Share
capital
Legal
reserve
Invested
unres-
tricted
equity
Retained
earnings1
Transla-tion
of foreign
opera-tions
Available-
for-sale
financial
assets
Cash flow
hedges
Total
Non-
control-ling
interest
Total
Equity at 31 December 2022 (IFRS 17)
98
4
1,527
8,482
-741
248
0
9,618
560
10,178
Impact of IFRS 9 transition 1 January 2023
—
—
—
248
—
-248
—
—
—
—
Equity at 1 January 2023
98
4
1,527
8,730
-741
—
0
9,618
560
10,178
Changes in equity
Acquired non-controlling interests
—
—
—
-11
—
—
—
-11
-3
-14
Dividends 3
—
—
—
-1,321
—
—
—
-1,321
-187
-1,508
Transferred assets at fair value in the demerger
—
—
—
-1,835
—
—
—
-1,835
—
-1,835
Acquisition of own shares
—
—
—
-555
—
—
—
-555
—
-555
Other changes in equity
—
—
—
51
—
—
—
51
-15
36
Profit for the reporting period
—
—
—
1,323
—
—
—
1,323
70
1,393
Other comprehensive income for the period
—
—
—
-5
-1
—
-1
-8
—
-8
Total comprehensive income
—
—
—
1,318
-1
—
-1
1,316
70
1,386
Equity at 31 December 2023
98
4
1,527
6,378
-742
—
-1
7,263
424
7,687
Changes in equity
Directed share issue 2
—
—
2,000
—
—
—
—
2,000
—
2,000
Acquired non-controlling interests 2
—
—
—
-1,666
—
—
—
-1,666
-334
-2,000
Compulsory acquisition of non-controlling interests 2
—
—
—
-265
—
—
—
-265
-59
-325
Transaction costs related to the acquisition of non-
controlling interests
—
—
—
-31
—
—
—
-31
—
-31
Dividends 3
—
—
—
-903
—
—
—
-903
-69
-972
Acquisition of own shares
—
—
—
-475
—
—
—
-475
—
-475
Other changes in equity
—
—
—
-14
—
—
—
-14
-11
-25
Profit for the reporting period
—
—
—
1,154
—
—
—
1,154
50
1,203
Other comprehensive income for the period
—
—
—
—
-4
—
1
-3
—
-3
Total comprehensive income
—
—
—
1,153
-4
—
1
1,151
50
1,200
Equity at 31 December 2024
98
4
3,527
4,176
-746
—
—
7,059
—
7,059
1 IAS 19 Pension benefits had a net effect of EUR -0 million (-5) on retained earnings.
2 The share issue was directed at Topdanmark’s non-controlling interests.  For further information related to the acquired non-controlling interests and liability to non-controlling interests recognised in  the
reporting period, see note 28.
3 Dividend per share EUR 1.70 (2.60)
On 12 December 2024, Sampo plc cancelled 11,747,690 own shares acquired during the financial year 2024.
FINANCIAL STATEMENTS 2024
144
Statement of cash flows
EURm
1–12/2024
1–12/2023
Operating activities
Profit before tax
1,533
1,765
Adjustments
Depreciation and amortisation
180
158
Unrealised gains and losses arising from valuation
-227
-559
Realised gains and losses on investments
-58
-280
Change in liabilities for insurance and investment
contracts
383
1,146
Other adjustments
132
-537
Adjustments total
410
-72
Change (+/-) in assets of operating activities
Investments 1
-223
-86
Other assets
-98
-208
Total
-321
-294
Change (+/-) in liabilities of operating activities
Financial liabilities
122
176
Other liabilities
5
-196
Paid taxes
-331
-277
Paid interest
-91
-132
Total
-296
-429
Net cash from (or used in) operating activities
1,327
970
Investing activities
Investments in subsidiary shares
—
-247
Divestments in subsidiary shares
—
20
Investments in tangible and intangible assets
-142
0
Divestments in equipment and intangible assets
17
5
Net cash from (or used in) investing activities
-125
-223
EURm
1–12/2024
1–12/2023
Financing activities
Dividends paid
-903
-1,321
Dividends paid to non-controlling interests
-69
-187
Acquisition of non-controlling interests
-325
-14
Transaction costs related to acquisition of non-
controlling interests
-31
—
Acquisition of own shares
-475
-555
Issue of debt securities 2
194
142
Repayments of debt securities in issue 2
-50
-473
Net cash used in (or from) financing activities
-1,660
-2,407
Total cash flows
-458
-1,660
Cash and cash equivalents at the beginning of reporting period
1,415
3,073
Effects of exchange rate changes
5
3
Cash and cash equivalents at the end of reporting period
962
1,415
Net change in cash and cash equivalents
-458
-1,660
Additional information to the cash flow statement
1–12/2024
1–12/2023
Interest income received
512
751
Dividend income received (excl. profit sharing from funds)
42
92
Total out-going cashflows from leases
-39
-37
1 Investments include investment property and financial assets.
2 Changes in short-term issues and repayments of debt securities are presented as net amounts.
Both in the financial year and the comparative year, the statement of cash flows includes both
continuing and discontinued/divested operations. Profit before tax is therefore the total of Group’s
profit and the discontinued/divested operations’ profit before taxes. In the financial year,
subsequently,  operating activities include EUR -26 million from divested activities. In the
comparative year, the operating activities include EUR 173 million from the discontinued operations,
investing activities EUR 20 million and financing activities EUR -280 million. Cash flows from
financing activities include an internal dividend of EUR -150 million and a group contribution of EUR
-29 million to Sampo plc. In addition, Mandatum repaid the subordinated loan to Sampo plc EUR
100 million in September 2023.
The items of the statement of cash flows cannot be directly concluded from the balance sheets due
to e.g. exchange rate differences, and acquisitions and disposals of subsidiaries during the period.
Cash and cash equivalents include cash at bank and in hand EUR 682 million (1,081) and short-term
deposits (max 3 months) EUR 280 million (334).
FINANCIAL STATEMENTS 2024
145
Group’s notes to the financial statements
Segment information ..............................................
Result by segment for twelve months
ended 31 December 2023 .....................................
Balance sheet by segment at
31 December 2024 ...................................................
Balance sheet by segment at
31 December 2023 ...................................................
Geographical information .....................................
Other notes .................................................................
1 Insurance service result .......................................
2 Net investment income .......................................
3 Net finance income or expense from
insurance contracts ..................................................
4 Other income ..........................................................
5 Other expenses ......................................................
6 Auditor's fees ..........................................................
7 Finance expenses ..................................................
8 Components of other comprehensive
income ...........................................................................
9 Earnings per share ................................................
10 Property, plant, equipment .............................
11 Intangible assets ....................................................
12 Financial assets ....................................................
16 Taxes .......................................................................
17 Other assets ..........................................................
18 Insurance contract liabilities ..........................
19 Reconciliation of insurance contract
liabilities .......................................................................
20 Assets for insurance acquisition cash
flows ..............................................................................
21 Non-life claims development ..........................
22 Financial liabilities ..............................................
23 Other liabilities ....................................................
24 Employee benefits .............................................
25 Equity and reserves ...........................................
26 Incentive schemes .............................................
27 Investments in subsidiaries ............................
28 Acquisition of Topdanmark's
non-controlling interest .........................................
29 Related party disclosures ................................
30 Discontinued operations .................................
31 Business combinations ......................................
33 Subsequent events after the
balance sheet date ..................................................
34 Risk management disclosure .........................
FINANCIAL STATEMENTS 2024
146
Group’s notes to the financial statements
Summary of material
accounting principles
Sampo plc (business ID 0142213-3) is a Finnish public
company listed in Helsinki Nasdaq. Sampo has a dual
listing in Nasdaq Stockholm and in Nasdaq
Copenhagen. It is domiciled in Helsinki and the
headquarters are at Fabianinkatu 27, 00100 Helsinki,
Finland. The consolidated financial statements of
Sampo Group include Sampo plc together with its
subsidiaries and associates as of 31 December 2024.
The group subsidiaries have insurance and financing
activities in Finland, Sweden, Norway, Denmark, the
Baltic countries, and the United Kingdom.
A copy of the Group’s financial statements is available
at the internet address www.sampo.com.
Basis of preparation
Sampo Group has prepared the consolidated financial
statements for 2024 in compliance with the
International Financial Reporting Standards (IFRSs). In
preparing the financial statements, Sampo has applied
all the standards and interpretations relating to its
business, adopted by the commission of the EU and
effective on 31 December 2024.
The annual improvements or other amendments to the
standards, adopted at the beginning of 2024, had no
material impact on the Group’s financial statements
reporting.
In preparing the notes to the consolidated financial
statements, attention has also been paid to the Finnish
accounting and company legislation and applicable
regulatory requirements.
The going concern accounting assumption has been
assessed by the Board and used in the preparation of
the financial statements.
The consolidated financial statements are presented in
euro (EUR), rounded to the nearest million, unless
otherwise stated.
The Board of Directors of Sampo plc accepted the
financial statements for issue on 12 March 2025. In
accordance with Limited Liability Companies Act, the
Annual General Meeting has the right to approve or
reject the consolidated financial statements or change
the statements after they have been issued.
Consolidation
Subsidiaries
The consolidated financial statements combine the
financial statements of Sampo plc and all its
subsidiaries. Companies in which the Group has control
are consolidated as subsidiaries. Control exists when the
Group has more than half of the voting power or it has
power over the entity together with exposure to
variable returns from its involvement there, and the
ability to use its power to affect the amount of these
returns. Subsidiaries are consolidated from the date on
which control is transferred to the Group and cease to
be consolidated from the date that control ceases.
The acquisition method of accounting is used for the
purchase of subsidiaries. The cost of an acquisition is
allocated to the identifiable assets, liabilities and
contingent liabilities, which are measured at the fair
value of the date of the acquisition. Acquisition-related
costs are recognised through profit or loss. Possible
non-controlling interest of the acquired entity is
measured either at fair value or at proportionate
interest in the acquiree’s net assets. The acquisition-
specific choice affects both the amount of recognised
goodwill and non-controlling interest. The excess of the
aggregate of consideration transferred, non-controlling
interest and possibly previously held equity interest in
the acquiree, over the Group’s share of the fair value of
the identifiable net assets acquired, is recognised as
goodwill.
The accounting policies used throughout the Group for
the purposes of consolidation are consistent with
respect to similar business activities and other events
taking place in similar conditions. All intra-group
transactions and balances are eliminated upon
consolidation.
Non-controlling interests
The technical division of profit for the financial year and
the total comprehensive income to the owners of the
parent and non-controlling interests is presented after
the statement of comprehensive income. The share of
profits is attributed to non-controlling interests even if it
should be negative.
Non-controlling interests are presented in the balance
sheet separately as part of equity.
Non-controlling interests in an acquiree are measured
either at fair value or as a proportionate share of net
FINANCIAL STATEMENTS 2024
147
assets of the acquiree. The choice is made for each
acquisition separately.
At the end of the financial year, due to the acquisition of
non-controlling interests in Topdanmark, the total
equity of consolidated financial statements did not
include the non-controlling interest share.
At the end of financial year, as the proportion of equity
held by non-controlling interests changed, the carrying
amounts of both the equity owners of the parent and
the non-controlling interests were adjusted to reflect
the changes. The difference between the book value of
the NCI and the consideration paid was recognised
directly in equity (retained earnings), and attributed to
the owners of the parent company.
Going forward, Sampo will allocate all of Topdanmark’s
profits, after the completion of the acquisition, to the
owners of the parent company. During the financial
year, the NCI’s share of the profit was calculated as
weighted average on their remaining share of
ownership. 
Foreign currency translation
The consolidated financial statements are presented in
euro, which is the functional and reporting currency of
the Group and the parent company. Items included in
the financial statements of each of the Group entities
are measured using their functional currency, being the
currency of the primary economic environment in which
the Group operates. Foreign currency transactions are
translated into the appropriate functional currency
using the exchange rates prevailing at the dates of
transactions or the average rate for a month. The
balance sheet items denominated in foreign currencies
are translated into the functional currency, at the rate
prevailing at the balance sheet date.
Exchange differences arising from the translation of
transactions and monetary balance sheet items
denominated in foreign currencies into functional
currency are recognised as translation gains and losses
in profit or loss.
The income statements of Group entities whose
functional currency is other than euro are translated
into euro at the average rate for the period, and the
balance sheets at the rates prevailing at the balance
sheet date. The resulting exchange differences are
included in equity and their change in other
comprehensive income. When a subsidiary is divested
entirely or partially, the cumulative exchange
differences are included in the income statement under
sales gains or losses.
Goodwill and fair value adjustments arising from an
acquisition of a foreign entity are treated as if they were
assets and liabilities of the foreign entity. Exchange
differences resulting from the translation of these items
at the exchange rate of the balance sheet date are
included in equity, and their change in other
comprehensive income.
Exchange rate differences arising from a monetary item,
accounted for as Sampo’s net investment in a foreign
operation (subsidiary), are recognised in other
comprehensive income.
A monetary item included in the net investment in a
foreign operation may be denominated in the functional
currency of Sampo (reporting entity), in the functional
currency of the foreign operation or in a currency other
than the functional currency of either the reporting
entity or the foreign operation. When a foreign
subsidiary is divested entirely or partially, the
cumulative exchange differences are reclassified from
equity to profit or loss.
The following exchange rates were applied in the
consolidated financial statements:
1 euro (EUR) =
Balance sheet
date
Average
exchange rate
Swedish krona (SEK)
11.4590
11.4345
Danish krona (DKK)
7.4578
7.4589
Pound sterling (GBP)
0.8292
0.8467
Segment reporting
The Group’s segmentation is based on business areas
whose risks and performance bases as well as
regulatory environment differ from each other. The
control and management of business and management
reporting are organised in accordance with the business
segments. The Group’s business segments are If,
Topdanmark, Hastings, and Holding.
Geographical information has been given on income
from external customers and non-current assets. The
reported areas are Finland, Sweden, Norway, Denmark,
United Kingdom, and the Baltic countries.
In the inter-segment and inter-company pricing, for
both domestic and cross border transactions, market-
based prices are applied. The pricing is based on the
Code of Conduct on Transfer Pricing Documentation in
the EU and OECD guidelines.
Inter-segment transactions, assets and liabilities are
eliminated in the consolidated financial statements.
Non-current assets held for sale
and discontinued operations
Non-current assets and the assets and liabilities related
to discontinued operations are classified as held for
sale, if their carrying amount will be recovered
FINANCIAL STATEMENTS 2024
148
principally through sales transactions rather than from
continuing use. For this to be the case, the sale must be
highly probable, and the asset or disposal group must
be available for immediate sale in its present condition,
subject only to terms that are usual and customary for
sales of such assets. In addition, the management must
be committed to a plan to sell, and the sale should be
expected to qualify for recognition as a completed sale
within one year from the date of classification. The
classification, presentation, and measurement
requirements of non-current assets or disposal groups
held for sale also apply to those that are held for
distribution to owners acting in their capacity as
owners.
Assets that meet the criteria to be classified as held for
sale are measured at the lower of carrying amount and
fair value less costs to sell. Immediately before the initial
classification of the asset as held for sale, the carrying
amount of the asset shall be measured in accordance
with applicable IFRSs. If the fair value less costs to sell is
the lower, the Group recognises an impairment loss at
initial reclassification. Gains for subsequent increases in
fair value are recognised through profit or loss. Once
reclassified, any depreciation or recognition of
associates’ share of profit or loss on such assets ceases.
Income and expense recognition
principles related to insurance
contracts
The introduction of IFRS 17 changed the structure of the
statement of profit or loss to reflect the key sources of
profit. The insurance service result, comprising of
insurance revenue, insurance service expenses, and
reinsurance result, reflects the result relating to
underwriting and servicing insurance policies. The net
financial result reflects the impacts arising from financial
components of insurance contracts. 
Insurance revenue
Insurance revenue reflects the compensation that
Sampo receives from the policyholder in return for the
transfer of risk (insurance contract services) on an
earned basis. The insurance revenue recognised in the
reporting period is based on premium receipts and
expected premium receipts, allocated linearly over the
underlying terms of the insurance contracts, i.e. based
on the passage of time. The liability for remaining
coverage is reduced with a corresponding amount as
the insurance revenue.
Insurance service expenses
The insurance service expenses comprise of both claims
incurred and operating expenses.
Claims incurred for the reporting period include claims
payments during the period and changes in the liability
for incurred claims. The change in liability for the
incurred claims includes the changes in undiscounted
best estimate, discounted risk adjustment, and the
changes in discounting effect due to changes in
underlying best estimate or changes in payment
patterns. The claims incurred also include claims
handling expenses and changes in the loss component.
Operating expenses reported in the insurance service
result relate to administrative expenses arising from the
handling of insurance contracts. Additionally, the
operating expenses include the acquisition cash flows
recognised in profit or loss, where the liability for
remaining coverage changes with a corresponding
amount.
Reinsurance result
Reinsurance result comprises both reinsurance premium
expenses and reinsurer’s share of claims incurred.
Reinsurance premium expenses related to reinsurance
contracts held are recognised similarly to insurance
revenue and reflect the premium payments attributable
to the reporting period for the reinsurance contract
services received. Any commissions received reduce
the reinsurance premium expenses. The reinsurers’
share of claims incurred is reported consistently with
direct insurance expenses, including changes in the risk
of non-performance.
Insurance finance income or expense
The insurance finance income or expenses included in
the net financial result reflect the impacts arising from
financial components. These include changes in the
liability for incurred claims related to changes in
discount rates and time value of money (unwinding).
Therefore, the effect from changes in interest rates, as
well as interest expense, is presented in its entirety as
insurance finance income or expenses. The effect of
changes in indexation of annuities is also presented
within insurance finance income or expenses. Amounts
related to reinsurance contracts are presented
separately. The option to present changes in
discounting effect in other comprehensive income is not
applied.
In 2024, Sampo updated the accounting policy for the
presentation of the change in discounting effect relating
to risk adjustment. The change in discounting effect is
now allocated between the insurance service expenses
and insurance finance income and expense.
Net investment income
Interest and dividends
Interest income and expenses are recognised in the
income statement using the effective interest rate
method. This method recognises income and expenses
on the instrument evenly in proportion to the amount
outstanding over the period to maturity. Dividends on
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149
equity securities are recognised as revenue when the
right to receive payment is established.
Fees and commissions
The fees and transaction costs of financial instruments
measured at fair value through profit or loss are
recognised in profit or loss when the instrument is
initially recognised.
Revenue from contracts with
customers
Other income consists of income from insurance-related
services provided, that do not involve a transfer of
significant insurance risk, and are therefore accounted
for under IFRS 15 Revenue from contracts with
customers. Such income is primarily attributable to sales
commission and services for administration, claims
settlement, etc. in insurance contracts on behalf of
other parties.
Furthermore, If Group’s subsidiary Viking Assistance
Group AS provides roadside assistance. Income from
these services is recognised when roadside assistance
has been provided.
The subsidiary Hastings has revenue from broker
activities in accordance with IFRS 15 Revenue from
Contracts with Customers. The revenue consists
principally of fees and commissions relating to the
arrangement of third party underwritten insurance
contracts and ancillary products.
Revenue from insurance brokerage activities is
recognised at the point of sale to the customer, and
revenue from other retail services is recognised when
the service has been completed. Revenue arising from
insurance broking activities is measured on an agency
basis, net of cost, at the fair value of the income
receivable after adjusting for any allowance for
expected future cancellation refunds. Hastings may also
provide contracts for the provision of other ad hoc,
point-in-time services to customers. Such income is
recognised when the performance obligation has been
satisfied at the expected value of consideration.
In the consolidated financial statements, the fees and
commissions from external broker activities are
included in Other income or Other expenses.
Financial assets and liabilities
Initial recognition and derecognition
Financial assets and liabilities are measured at the initial
recognition at fair value. If the acquired financial assets
and liabilities are not measured at fair value, transaction
costs directly attributable to acquisition or issue are
added or deducted respectively.
Purchases and sales of financial assets at fair value
through profit or loss are recognised and derecognised
on the trade date, which is the date on which the Group
commits to purchase or sell the asset. Loans and other
receivables are recognised when cash is advanced.
Financial assets and liabilities are offset, and the net
amount is presented in the balance sheet only when the
Group has a legally enforceable right to set off the
recognised amounts, and it intends to settle on a net
basis, or to realise the asset and settle the liability
simultaneously.
Financial assets are derecognised when the contractual
rights to receive cash flows have expired or the Group
has substantially transferred all the risks and rewards of
ownership. Financial liabilities are derecognised when
the obligation specified in the contract is discharged,
cancelled or expired.
Classification and measurement principles of
financial assets
Financial assets are classified as being subsequently
measured either at amortised cost, at fair value through
other comprehensive income (FVOCI), or at fair value
through profit or loss (FVPL). The majority of Sampo
Group’s financial assets are classified at fair value
through profit or loss, and only a limited amount of
financial assets is measured at amortised cost. No
financial assets are classified as FVOCI.
The classification of financial assets into these
measurement categories is based on Sampo Group’s
business model for managing the financial assets and
the contractual cash flow characteristics of the financial
assets. The Group’s business model reflects how the
portfolios of financial assets are managed to achieve
business objectives and to generate cash flows. The
factors considered in determining the portfolio’s
business model include how the financial assets’
performance is evaluated and reported to management,
how risks are assessed and managed, past experience
of how the cash flows have been collected, and how
compensation is linked to performance.
Financial assets at fair value through profit
or loss
Financial assets classified as at fair value through profit
or loss include mainly investments in equity instruments
and funds, debt instruments, and other loans.
Equity instruments are classified and measured at fair
value through profit or loss.
Debt instruments, such as bonds and other interest-
bearing securities, are classified as measured at fair
value through profit or loss when the business model
reflects the assets being managed and evaluated on a
fair value basis. The instruments are initially recognised
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150
and subsequently measured at fair value. Transaction
costs that are directly attributable to the issue or
acquisition of the assets are expensed in profit or loss.
Gains and losses arising from changes in fair value, or
realised on disposal, together with related interest
income and dividend, are recognised in the income
statement under net investment income.
Derivative instruments that are not designated as
hedges and do not meet the requirements for hedge
accounting are classified as financial assets at fair value
through profit or loss. Derivatives are initially
recognised at fair value. Derivative instruments are
carried as assets when the fair value is positive and as
liabilities when the fair value is negative. Derivative
instruments are recognised at fair value, and gains and
losses arising from changes in fair value, together with
realised gains and losses, are recognised in the income
statement under net investment income.
Financial assets measured at amortised cost
A financial asset is measured at amortised cost only if
the objective of the business model is to hold a financial
asset in order to collect contractual cash flows, and the
contractual cash flows of the financial asset meet the
SPPI criteria (solely payments of principal and interest -
criteria, SPPI), i.e. it is consistent with the basic lending
arrangement. SPPI criteria is met when the financial
instrument’s contractual cash flows are solely payments
of principal and interest on the principal amount
outstanding. Financial assets measured at amortised
cost comprise mainly debt instruments, loans, and
receivables.
Financial assets measured at amortised costs are
initially recognised at their fair value, including
transaction costs directly attributable to the acquisition
of the asset. Loans and other receivables are
subsequently measured at amortised cost using the
effective interest rate method.
Interest revenue is calculated using the effective
interest rate method. Under IFRS 9, financial assets
subsequently measured at amortised cost are subject to
loss allowance, that is, expected credit losses (ECL)
requirements.
Financial liabilities
Financial liabilities, including subordinated debt
securities, debt securities in issue, and other financial
liabilities, are subsequently measured at amortised cost
using the effective interest rate method. Interest
expenses and gains or losses on derecognition are
recognised in the income statement.
Derivative financial liabilities are measured at fair value
through profit or loss.
If debt securities issued are redeemed before maturity,
they are derecognised and the difference between the
carrying amount and the consideration paid at
redemption is recognised in profit or loss.
Fair value
The fair value of financial instruments is determined
primarily by using quoted prices in active markets.
Instruments are measured either at a bid price or at the
last trade price, if there is an auction policy in the stock
market of the price source. An exception are the
syndicated loans, which are measured at a mid-price
because of the lower liquidity. The financial derivatives
are also measured at the last trade price. If the financial
instrument has a counter-item that will offset its market
risk, the same price source is used in assets and
liabilities to that extent. If a published price quotation
does not exist for a financial instrument in its entirety,
but active markets exist for its component parts, the fair
value is determined based on the relevant market prices
of the component parts.
Fair values of financial assets are based on either
published price quotations or valuation techniques
based on market observable inputs, where available. If
these are not available, the fair value is established by
using generally accepted valuation techniques,
including recent arm’s length market transactions
between knowledgeable, willing parties, reference to
the current fair value of another instrument that is
substantially the same, discounted cash flow analysis,
and option pricing models. For a limited amount of
assets, the value needs to be determined using these
other techniques.
The carrying amount of cash and cash equivalents, as
well as settlement receivables included in other assets is
used as an approximation of fair value.
The financial instruments measured at fair value have
been classified into three hierarchy levels in the notes,
depending on, e.g. if the market for the instrument is
active, or if the inputs used in the valuation technique
are observable.
On level 1, the measurement of the instrument is based
on quoted prices in active markets for identical assets
or liabilities.
On level 2, inputs for the measurement of the
instrument include also other than quoted prices
observable for the asset or liability, either directly or
indirectly by using valuation techniques.
On level 3, the measurement is based on other inputs
rather than observable market data.
In level 3 equity investment is valued by using the
excess return model, in which the value of a company is
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151
the sum of capital currently invested in the company
and the present value of excess returns that the
company expects to make in the future.
For private equity funds the valuation of the underlying
investments is conducted by the fund manager who has
all the relevant information required in the valuation
process. The valuation is usually updated quarterly
based on the value of the underlying assets and the
amount of debt in the fund. There are several valuation
methods, which can be based on, for example, the
acquisition value of the investments, the value of
publicly traded peer companies, the multiple based
valuation or the cash flows of the underlying
investments.
Impairment of financial assets
Sampo assesses, at the end of each reporting period,
whether there is any objective evidence that a financial
asset, other than those at fair value through profit or
loss, may be impaired. A financial asset is impaired, and
impairment losses are recognised based on the
estimated future cash flows of the financial asset if
there is objective evidence of impairment as a result of
one or more loss events that occurred after the initial
recognition of the asset, and if that event has an impact
that can be reliably estimated.
There is objective evidence of impairment, if, for
example, an issuer or debtor encounters significant
financial difficulties that will lead to insolvency, and to
estimation that the customer will probably not be able
to meet the obligations to the Group. When there is
objective evidence of impairment of a financial asset
carried at amortised cost, the amount of the loss is
measured as the difference between the receivable’s
carrying amount and the present value of estimated
future cash flows discounted at the receivable’s original
effective interest rate. The difference is recognised as
an impairment loss in profit or loss. In Sampo Group the
impairment is assessed individually for each asset.
Financial assets measured at amortised cost
In accordance with IFRS 9, Sampo applies a forward-
looking ECL model, which in Sampo Group is mainly
applicable to financial assets measured at amortised
cost. Impairment requirements do not apply to equity
instruments or other financial instruments measured at
FVPL. Expected credit losses reflect past events, i.e.
historical loss experience, current conditions, and
forecasts of future economic conditions.
Sampo applies a general approach for impairment in
which a loss allowance is calculated either for 12-month
expected credit losses or a lifetime expected credit
losses. A three-staged model is used to determine the
ECL at each reporting date. In stage 1, the credit risk has
not increased significantly. Loss allowance is measured
at an amount equal to 12-month expected credit losses.
In stages 2 and 3, the credit risk has increased
significantly since initial recognition and the loss
allowance is measured at an amount equal to the
lifetime expected credit losses. In stage 3, the financial
asset is assessed to be credit-impaired (at default), and
the interest is calculated on the credit-impaired amount
instead of gross carrying amount.
In Sampo Group, the general approach is based on
three components, namely probability of default (PD),
loss given default (LGD), and exposure at default
(EAD).
FINANCIAL STATEMENTS 2024
152
Derivative financial instruments
and hedge accounting
Derivative financial instruments are classified as those
held for trading and those held for hedging, including
interest rate derivatives, credit risk derivatives, foreign
exchange derivatives, equity derivatives and
commodity derivatives. Derivative instruments are
measured initially at fair value. All derivatives are carried
as assets when fair value is positive, and as liabilities
when fair value is negative.
Derivatives held for trading
Derivative instruments that are not designated as
hedges are treated as held for trading. They are
measured at fair value and the change in fair value,
together with both realised gains and losses and
interest income and expenses, is recognised in profit or
loss.
Hedge accounting
Sampo Group may hedge its operations against interest
rate risks, currency risks, and price risks through fair
value hedging and cash flow hedging. Cash flow
hedging is used as a protection against the variability of
the future cash flows. During the financial year, cash
flow hedging has been applied in Hastings.
Hedge accounting applies to hedges that are effective
in relation to the hedged risk and meet the hedge
accounting requirements of IFRS 9. The hedging
relationship between the hedging instrument and the
hedged item, as well as the risk management objective
and strategy for undertaking the hedge, are
documented at the inception of the hedge.
Cash flow hedging
Cash flow hedging is used to hedge the interest cash
flows of individual floating rate debt securities or other
floating rate assets or liabilities. The hedging
instruments used include currency forward contracts.
Derivative instruments which are designated as hedges
and are effective as such, are measured at fair value.
The effective part of the change in fair value is
recognised in other comprehensive income.
The cumulative change in fair value is transferred from
equity and recognised in profit or loss in the same
period that the hedged cash flows affect profit or loss.
When a hedging instrument expires, is sold, terminated,
or the hedge no longer meets the criteria for hedge
accounting, the cumulative change in fair value remains
in equity until the hedged cash flows affect profit or
loss.
Leases
Group as lessee
All lease contracts are primarily recognised in the
balance sheet in accordance with IFRS 16 Leases. The
only optional exemptions include certain short-term
contracts with a duration under 12 months or low-value
contracts, for which the lease payments can be
recognised as an expense on a straight-line basis over
the lease term.
Right-of-use assets related to lease contracts (right to
use an underlying asset) are recognised in the asset
side as part of Property, plant and equipment and the
corresponding lease liabilities in the liability side, as part
of Other liabilities. A right-of-use asset is recognised at
the commencement date of the lease and measured at
cost that includes the amount of the initial
measurement of the liability and potential prepaid rents
to the lessor. Right-of-use assets are amortised on a
straight-line basis over the lease period. Lease liability is
also recognised at the commencement date and
measured at the present value of the lease payments.
Depreciations on right-of-use assets and interests on
lease liabilities are recognised in the income statement.
Intangible assets
Goodwill
Goodwill represents the excess of the cost of an
acquisition (made after 1 January 2004) over the fair
value of the Group’s share of net identifiable assets,
liabilities, and contingent liabilities of the acquired entity
at the date of acquisition. Goodwill on acquisitions
before 1 January 2004 is accounted for in accordance
with the previous accounting standards, and the
carrying amount is used as the deemed cost in
accordance with the IFRS.
Goodwill is measured at historical cost less accumulated
impairment losses. Goodwill is not amortised. Instead, it
is tested at least annually for impairment.
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153
Other intangible assets
IT software and other intangible assets, whether
procured externally or internally generated, are
recognised in the balance sheet as intangible assets
with finite useful lives if it is probable that the expected
future economic benefits that are attributable to the
assets will flow to the Group and the cost of the assets
can be measured reliably. The cost of internally
generated intangible assets is determined as the sum of
all costs directly attributable to the assets. Research
costs are recognised as expenses in profit or loss as
they are incurred. Costs arising from the development
of new IT software or from significant improvement of
existing software are recognised only to the extent they
meet the above-mentioned requirements for being
recognised as assets in the balance sheet.
Intangible assets with finite useful lives are measured at
historical cost less accumulated amortisation and
impairment losses. Intangible assets are amortised on a
straight-line basis over the estimated useful life of the
asset. The estimated useful lives by asset class are as
follows:
• IT software 3-10 years
• Other intangible assets 3-10 years
Intangible assets with an indefinite useful life, such as
brands and trademarks acquired in business
combinations, are not amortised. Instead, they are
tested at least annually for impairment.
Amortisations and impairment losses are recognised in
the statement of profit or loss in other expenses.
Property, plant and equipment
Property, plant and equipment comprise properties
occupied for Sampo’s own activities, office equipment,
fixtures and fittings, and furniture.
Property, plant and equipment are measured at
historical cost less accumulated depreciation and
impairment losses.
Improvement costs are added to the carrying amount
of a property when it is probable that the future
economic benefits that are attributable to the asset will
flow to the Group. Costs for repairs and maintenance
are recognised as expenses in the period in which they
were incurred.
Items of property, plant and equipment are depreciated
on a straight-line basis over their estimated useful life. In
most cases, the residual value is estimated at zero. Land
is not depreciated. Estimates of useful life are reviewed
at financial year-ends and the useful life is adjusted if
the estimates change significantly. The estimated useful
lives by asset class are as follows:
• Buildings 20-50 years
• Components of buildings 15-20 years
• Property and leasehold improvements 4-10 years
• IT equipment and motor vehicles 2-5 years
• Other equipment 3-15 years
Depreciations and impairment losses are recognised in
the statement of profit or loss in other expenses.
Depreciation of property, plant or equipment will be
discontinued if the asset in question is classified as held
for sale in accordance with IFRS 5 Non-current Assets
Held for Sale and Discontinued Operations.
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154
Impairment of intangible assets
and property, plant and equipment
At each reporting date, the Group assesses whether
there is any indication that an intangible asset or an
item of property, plant or equipment may be impaired.
If any such indication exists, the Group will estimate the
recoverable amount of the asset. In addition, goodwill,
intangible assets not yet available for use, and
intangible assets with an indefinite useful life will be
tested for impairment annually, independent of any
indication of impairment. For impairment testing the
goodwill is allocated to the cash-generating units of the
Group from the date of acquisition. In the test, the
carrying amount of the cash-generating unit, including
the goodwill, is compared with its recoverable amount.
The recoverable amount is the higher of an asset’s fair
value less costs to sell and its value in use. The value in
use is calculated by estimating future net cash flows
expected to be derived from an asset or a cash-
generating unit, and by discounting them to their
present value using a pre-tax discount rate. If the
carrying amount of an asset is higher than its
recoverable amount, an impairment loss is recognised in
profit or loss. In conjunction with this, the impaired
asset’s useful life will be re-determined.
The impairment loss is reversed if there has been a
change in circumstances and the recoverable amount
has changed after the recognition of the impairment
loss, but no more than to the carrying amount that it
would have been without recognition of the impairment
loss. Impairment losses recognised for goodwill are not
reversed.
Insurance contracts
Sampo Group has applied IFRS 17 Insurance Contracts
from 1 January 2023. Sampo Group’s operations are
focused on the P&C business and Sampo primarily uses
the premium allocation approach (PAA) under IFRS 17.
The risks involved in insurance contracts are widely
elaborated in the Group’s note 34.
P&C operations
Scope
In the Group’s P&C insurance contracts, insurance risk is
considered significant. Insurance contracts issued by
third party underwriters (panel underwriters), which do
not transfer any insurance risk to the Group companies,
are not in the scope of IFRS 17 but instead accounted
for under IFRS 15 Revenue from Contracts with
Customers.
Insurance contracts containing one or more
components within the scope of different accounting
standards are accounted for separately. Sampo
evaluates the insurance contracts to identify
components from the contracts. For example, an
insurance contract may include an investment
component or a component for services other than
insurance contract services (or both).
Level of aggregation
Insurance contracts are aggregated into portfolios of
insurance contracts. The portfolios comprise contracts
with similar risks that are managed together. These
portfolios are further divided into annual cohorts, i.e.
contracts not issued more than one year apart.
In Sampo Group's P&C operations, portfolios are
determined based on a segmentation of business, or a
combination of line of business (as defined by the
management), business area and country. Portfolios are
determined separately for each legal entity or based on
product lines.
Sampo Group has identified some onerous contracts,
but, all in all, their amount is insignificant.
The carrying amount of the portfolios of insurance and
reinsurance contracts determines their presentation as
assets or liabilities in the balance sheet.
Contract boundary
The initial measurement of a group of insurance
contracts includes all future cash flows arising within
the contract boundary. In determining which cash flows
fall within the contract boundary, substantive rights and
obligations arising from the terms of the contract,
together with applicable laws and regulations, are
considered.
In Sampo Group’s P&C operations, the majority of
contracts have a one-year contract boundary, typically
until the next renewal date, i.e. the contract has one-
year coverage period during which there are
substantive rights and obligations.
Measurement
In accordance with IFRS 17, a general measurement
model (GMM) is applicable to all insurance contracts to
measure insurance contract liabilities. Under the general
measurement model, insurance contracts are measured
based on future cash flows, adjusted to reflect the time
value of money, including a risk adjustment, and a
contractual service margin (CSM).
When certain eligibility criteria are met, insurers may
apply a simplified approach, the premium allocation
approach (PAA), for the measurement of insurance
contracts. PAA is eligible for insurance contracts with a
coverage period of one year or less. This approach is
FINANCIAL STATEMENTS 2024
155
also available for contracts where the PAA would not
materially differ from the results of the GMM. In Sampo
Group's P&C operations, PAA is applied to all insurance
contracts, because the coverage period for most of the
insurance contracts is one year or less, and for longer
insurance contracts the qualifying eligibility criteria are
fulfilled.
The measurement of insurance liabilities consists of the
liability for remaining coverage (LRC) and acquisition
cash flow asset, and liability for incurred claims (LIC),
the latter including both reported but not settled claims,
as well as incurred but not reported claims (IBNR).
On the initial recognition of P&C operations’ groups of
insurance contracts, the carrying amount of LRC is
measured as the premiums initially received less
insurance acquisition cash flows. In case of onerous
contracts, a loss component is recognised.
The acquisition cash flows reducing the carrying
amount of LRC mainly include staff costs related to
sales personnel and commissions, as well as certain
costs related to selling policies through price
comparison websites. Any overhead costs are expensed
immediately. Sampo Group's P&C operations in the
private business area have elected to recognise
acquisition cash flows as an expense at the date when
they are incurred. For other business areas, the
acquisition costs are deferred over the coverage period
of the contracts, generally one year, or longer in case of
expected renewals.
Any acquisition cash flows paid relating to a group of
insurance contracts not yet recognised, are presented
as a separate acquisition cash flow asset and included in
the related portfolio’s total carrying amount.  
The liability for remaining coverage relates to the
obligation to investigate and pay valid claims that have
not yet occurred. At subsequent reporting periods, the
carrying amount of LRC is increased by premiums
received during the period and decreased by the
amount recognised as insurance revenue for services
provided in the period, which for most products is
based on the passage of time (straight line basis).
Consequently, any premium receipts pertaining to
insurance services to be provided after the closing date
remain in this liability. The carrying amount is also
increased for any premiums received in subsequent
periods, less additional insurance acquisition cash flows
paid. The carrying amount of LRC is not discounted or
adjusted with the effect of financial risk, as the time
between providing services and the related premium
due date generally is no more than a year.
For groups of onerous contracts, a loss component is
part of the liability for remaining coverage. The loss
component is calculated as the difference between the
liability measured with the general measurement model
and with the premium allocation approach.
The liability for incurred claims (LIC) is intended to
cover the future payments of all claims incurred,
including claims not yet reported to the company and
all claims handling expenses. Sampo Group measures
the liability for incurred claims (LIC) for the group of
insurance contracts at the amount of estimated
fulfilment cash flows relating to incurred claims.
Fulfilment cash flows consist of three components,
namely expected cash flows, discounting and risk
adjustment. The estimated future cash flows (best
estimate) are calculated with the aid of statistical
methods or through individual assessments of individual
claims.
Both the best estimate and risk adjustment are
discounted to present value using standard actuarial
methods and applying market-based yield curves. The
curves are constructed based on a risk-free rate and an
illiquidity premium for each of the main currencies.
Discounting
Sampo Group's P&C operations have determined the
discount rates based on a bottom-up approach. The
interest rate curve includes a risk-free rate (excluding
credit risk adjustment) and an illiquidity premium for
each currency. The illiquidity premium is mainly derived
based on a portfolio of high-rated bonds for the liquid
part of the interest rate curve. Beyond this, the curve
converges to the ultimate forward rate, consistent with
the EIOPA curves. Discount rates are constructed
separately for the main currencies applied in Sampo
Group’s subsidiaries.
The discounting effect of current-year liabilities for
incurred claims and changes in the cash flows is
recognised in the insurance service result. Unwinding of
interest rates, effect of changes in interest rates, and
other financial assumptions are presented as insurance
finance income or expense in profit or loss. Sampo
Group has elected not to apply the OCI option allowed
under IFRS 17.
Risk adjustment
In accordance with IFRS 17, an explicit risk adjustment is
included in the measurement of insurance liabilities. The
risk adjustment reflects the cost of uncertainty
associated with the amount and timing of cash flows
arising from non-financial risk and the degree of risk
aversion. The risks typically considered in P&C
operations, when assessing risk adjustment, are reserve
risk, longevity risk, inflation risk, and premium risk.
In Sampo Group, the risk adjustment is derived through
a confidence level technique whereby management
determines the appropriate quantile. The risk
adjustment is calculated at the subsidiary level and
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156
aggregated into the consolidated Sampo Group level
risk adjustment, without any diversification effects
assumed. Under the premium allocation approach, the
risk adjustment is only included in LIC, unless a group of
insurance contracts is onerous.
Reinsurance contracts
The PAA model is applied to reinsurance contracts held.
The corresponding accounting policies as for measuring
the insurance contracts issued are applied when
measuring the reinsurance contracts held. Thus,
correspondingly to insurance liabilities for issued
insurance contracts, the reinsurance assets for
reinsurance contracts held consist of asset for
remaining coverage and asset for incurred claims. The
asset for incurred claims also takes into consideration
the effect of the risk of non-performance by the issuer
of the reinsurance contract.
Investment components are included in the reinsurance
contracts held for cash flows repaid to a policyholder in
all circumstances, i.e. regardless of whether an insured
event occurs or not. Identified amounts of investment
components are excluded from recognised amounts for
reinsurance result in the statement of profit and other
comprehensive income.
Life operations
Sampo Group’s life operations were reclassified as
discontinued operations during the first quarter of
comparative period 2023.
Employee benefits
Post-employment benefits
Post-employment benefits include pensions and life
insurance.
Sampo has defined benefit plans in Sweden and
Norway, and defined contribution plans in other
countries. The most significant defined contribution
plan is that arranged through the Employees’ Pensions
Act (TyEL) in Finland.
In the defined contribution plans, the Group pays fixed
contributions to a pension insurance company and has
no legal or constructive obligation to pay further
contributions. The obligations arising from a defined
contribution plan are recognised as an expense in the
period to which the obligation relates.
In the defined benefit plans, the company still has
obligations after paying the contributions for the
financial period and bears their actuarial and/or
investment risk. The obligation is calculated separately
for each plan using the projected unit credit method. In
calculating the amount of the obligation, actuarial
assumptions are used. The pension costs are recognised
as an expense for the service period of employees.
Defined benefit plans are both funded and unfunded.
The amounts reported as pension costs during a
financial year consist of the actuarially calculated
earnings of old-age pensions during the year, calculated
straight-line, based on pensionable income at the time
of retirement. The calculated effects in the form of
interest expense for crediting/appreciating the
preceding years’ established pension obligations are
then added. The calculation of pension costs during the
financial year starts at the beginning of the year and is
based on assumptions about such factors as salary
growth and price inflation throughout the duration of
the obligation and on the current market interest rate
adjusted to take into account the duration of the
pension obligations.
The current year pension cost and the net interest of
the net liability is recognised through profit or loss in
pension costs. The actuarial gains and losses and the
return of the plan assets (excluding net interest) are
recognised as a separate item in other comprehensive
income.
The fair value of the plan assets covered by the plan is
deducted from the present value of future pension
obligations and the remaining net liability or net asset is
recognised separately in the balance sheet.
The Group has also certain voluntary defined benefit
plans, which have no material significance.
Termination benefits
An obligation based on the termination of employment
is recognised as a liability when the Group is verifiably
committed to terminating the employment of one or
more persons before the normal retirement date, or to
granting benefits payable upon termination as a result
of an offer to promote voluntary redundancy. As no
economic benefit is expected to flow to the employer
from these benefits in the future, they are recognised
immediately as expenses. Obligations maturing more
than 12 months later than the balance sheet date are
discounted. The benefits payable upon termination at
Sampo are the monetary and pension packages related
to redundancy.
Share-based payments
During the financial year, Sampo had four valid share-
based incentive schemes settled in cash (the long-term
incentive schemes 2020 I, 2020 II, 2020 III, and 2024 for
the management and key employees). 
Topdanmark had a share-based incentive scheme that
was converted to a phantom equity plan in the last
quarter of the financial year. Hastings had a share-based
incentive scheme settled in cash during the financial
year. More information on the different incentive
FINANCIAL STATEMENTS 2024
157
schemes of the Group companies can be found in
note 26 Incentive schemes.
The schemes have been measured at fair value at the
grant date and at every reporting date thereafter.
In the schemes settled in cash, the valuation is
recognised as a liability and changes are recognised
through profit or loss. In the schemes settled in shares,
the strike amounts received on the exercise of the
options are recognised in the shareholder’s equity.
The fair value of the schemes has to a large extent been
determined using the Black-Scholes-pricing model. The
fair value of the market-based part of the incentive
takes into consideration the model’s forecast
concerning the number of incentive units to be paid as
a reward. The effects of non-market-based terms are
not included in the fair value of the incentive; instead,
they are considered in the number of those incentive
units that are expected to be exercised during the
vesting period. In this respect, the Group will update the
assumption on the estimated final number of incentive
units at every interim or annual balance sheet date.
Provisions
A provision is recognised when the Group has a present
legal or constructive obligation as a result of a past
event, and when it is probable that an outflow of
resources embodying economic benefits will be
required to settle the obligation and the Group can
reliably estimate the amount of the obligation.
If it is expected that some or all of the expenditure
required to settle the provision will be reimbursed by
another party, the reimbursement will be treated as a
separate asset only when it is virtually certain that the
Group will receive it.   
Income taxes
Item Tax expenses in the income statement comprise
current and deferred tax. Tax expenses are recognised
through profit or loss, except for items recognised
directly in equity or other comprehensive income, in
which case the tax effect will also be recognised for
those items. Current tax is calculated based on the valid
tax rate of each country. Tax is adjusted for any tax
related to previous periods.
Deferred tax is calculated on all temporary differences
between the carrying amount of an asset or liability in
the balance sheet and its tax base. Deferred tax is not
recognised on non-deductible goodwill impairment, nor
is it recognised on undistributed profits of subsidiaries
to the extent that it is probable that the temporary
difference will not reverse in the foreseeable future.
Deferred tax liabilities and assets are offset in individual
companies if, and only if, they relate to income taxes
levied by the same taxation authority and the company
has a legally enforceable right of offset them.
Deferred tax is calculated using the enacted tax rates
prior to the balance sheet date. A deferred tax asset is
recognised to the extent that it is probable that future
taxable income will be available against which a
temporary difference can be utilised.
Share capital
The incremental costs directly attributable to the issue
of new shares or options or to the acquisition of a
business are included in equity as a deduction, net of
tax, from the proceeds.
Dividends are recognised in equity in the period when
they are approved by the Annual General Meeting.
When the parent company or other Group companies
purchase the parent company’s equity shares, the
consideration paid is deducted from equity as treasury
shares until they are cancelled. If such shares are
subsequently sold or reissued, any consideration
received is included in equity.
Treasury shares
The purchase price paid for the buy-back of treasury
shares (own shares) is directly deducted from equity.
No gains or losses are recognised from purchase, sale,
or cancellation of own shares. If own shares are re-
issued, the difference between purchase price and
consideration received is recognised in the premium
reserve.
Cash and cash equivalents
Cash and cash equivalents comprise cash and short-
term deposits (3 months).
Sampo presents cash flows from operating activities
using the indirect method, in which the profit (loss)
before taxation is adjusted for the effects of
transactions of a non-cash nature, deferrals and
accruals, and income and expense associated with
investing or financing cash flows.
In the cash flow statement, interest received and paid is
presented in cash flows from operating activities. In
addition, the dividends received from other than
associated companies are included in cash flows from
operating activities. Dividends received from associates
are presented in cash flows from investments.
Dividends paid are presented in cash flows from
financing.
FINANCIAL STATEMENTS 2024
158
Accounting policies requiring
management judgement and
key sources of estimation
uncertainties
Preparation of the accounts in accordance with the
IFRS requires management estimates and assumptions
that have affected the revenue, expenses, assets,
liabilities and contingent liabilities presented in the
financial statements. Judgement is also required in the
application of accounting policies. The estimates made
are based on the best information available at the
balance sheet date. The estimation is based on historical
experience and the most probable assumptions
concerning the future at the balance sheet date. The
actual outcome may deviate from results based on
estimates and assumptions. Any changes in the
estimates will be recognised in the financial year during
which the estimate is reviewed in all subsequent
periods.
Insurance contracts
Sampo Group management applies judgement
regarding the determination of discount rates and risk
adjustment.
The interest rate curve includes a risk-free rate and an
illiquidity premium determined by Management, which
in Sampo Group is mainly based on a portfolio of high-
rated bonds.
Risk adjustment is determined separately for all Sampo
Group’s companies and aggregated at the Group level.
Management considers this to reflect the compensation
that different entities would require for bearing non-
financial risk and their degree to risk aversion. The
confidence level approach is applied in the Group
companies. The confidence level applied in calculating
the risk adjustment is varying between group
companies from 75 per cent to 85 per cent. If Group
applies a confidence level of 85 per cent, and Hastings
75 per cent, respectively.
Actuarial assumptions
Evaluation of insurance liabilities always involves
uncertainty, as technical provisions are based on
estimates and assumptions concerning future claims
costs. The estimates are based on statistics on historical
claims available to the Group on the balance sheet date.
The uncertainty related to the estimates is generally
greater when estimating new insurance portfolios, or
portfolios where the clarification of a loss takes a long
time because complete claims statistics are not yet
available. In addition to historical data, estimates of
insurance liabilities take into consideration other
matters such as claims development, the amount of
unpaid claims, legislative changes, court rulings and the
general economic situation.
A substantial part of the Group’s P&C insurance
liabilities concerns statutory accident and traffic
insurance. The most significant uncertainties related to
the evaluation of these liabilities are assumptions about
inflation, mortality, discount rates and the effects of
legislative revisions and legal practices.
Defined benefit plans as intended in IAS 19, are also
estimated in accordance with actuarial principles. As
the calculation of a pension plan reserve is based on
expected future pensions, assumptions must be made
not only about discount rates, but also about matters
such as mortality, employee turnover, price inflation and
future salaries.
Determination of fair value
The fair value of any non-quoted financial assets is
determined using valuation methods that are generally
accepted in the market.
Impairment tests
Goodwill, and intangible assets with an indefinite useful
life are tested for impairment at least annually. The
recoverable amounts from cash-generating units have
mainly been determined by using calculations based on
the value in use. These require management estimates
on matters such as future cash flows, the discount rate,
and, general economic growth and inflation.
Acquisition of Topdanmark’s non-
controlling interest
On 17 June 2024, Sampo announced that Sampo and
Topdanmark had entered into a combination
agreement, based on which Sampo made  a
recommended best and final public exchange offer to
acquire all of the outstanding shares in Topdanmark not
already owned by Sampo. The transaction was
completed by the compulsory acquisition of the
remaining Topdanmark minority shares on 25 October
2024. Following the acquisition of NCI, Sampo plc sold
all the issued shares in Topdanmark A/S to If P&C
Insurance Holding Ltd. For more detailed description of
the acquisition, please see note 28.
In accordance with IFRS 10 Consolidated Financial
Statements, after the control of a subsidiary has been
gained, any subsequent change in the ownership, not
resulting in a loss of control, is treated as an equity
transaction between the non-controlling interests and
the owners of the parent company (IFRS 10.23). The
acquisition of non-controlling interest of Topdanmark
was accounted for as an equity transaction between the
FINANCIAL STATEMENTS 2024
159
NCI and the owners of the parent. Transaction costs,
which were incremental and directly related to equity
transaction, were deducted directly from equity. The
original purchase price allocation calculation (PPA),
prepared at the time of the original acquisition in 2017,
and including goodwill, remained unchanged.
Measurement of acquired Topdanmark shares
Sampo has determined that the measurement of
acquired Topdanmark A/S shares was based on the
compensation given as an exchange of those shares.
The issue price was determined based on the closing
price of the Sampo class A shares on Nasdaq Helsinki
Ltd on the last full trading day prior to the Sampo
Board resolving upon the directed issuance of shares.
For shares acquired via compulsory acquisition, the
value of acquired shares was determined based on the
compensation paid in cash.
Sale of Topdanmark A/S shares to If P&C Insurance
Holding Ltd
As the sale transaction of Topdanmark’s shares was an
intra-group transaction, all impacts, including the sales
gain of the shares, were eliminated on the Sampo Group
level. The sales gain was due to the previously owned
shares being on balance sheet at historical value. The
transaction was completed at arm’s length basis. The
intra-group sale of shares met the definition of a
common control transaction as both If P&C Insurance
Holding Ltd and Topdanmark A/S are under control of
Sampo plc before and after the acquisition.
As part of the intra-group sales transaction, Sampo
granted If P&C Insurance Holding loans denominated
partly in currencies other than functional currencies
either in Sampo or in If Group. IAS 21 The Effects of
Changes in Foreign Exchange Rates enables to
recognise exchange rate differences arising from a loan
(monetary item) in other comprehensive income when
that loan is included as part of the net investment in a
foreign operation. Sampo has assessed that in its
consolidated accounts, the long-term loan receivable
forms a part of Sampo’s net investment in foreign
operation i.e. investment in subsidiary shares in If P&C
Insurance Holding Ltd.
Segment presentation
At the end of the financial year, Sampo Group’s
business segments were If, Topdanmark, Hastings and
Holding.  Topdanmark continued to be presented as a
business segment regardless of the intra-group sale of
Topdanmark A/S shares. As Sampo presents reporting
segments unchanged for the financial year 2024
reporting, no changes have been done to the allocation
of goodwill to Topdanmark segment.
Restructuring reserve
Following the acquisition of non-controlling interests in
Topdanmark, Sampo plc sold the shares of Topdanmark
A/S to If P&C Insurance Holding Ltd for further
integration into If Group’s structure. In connection with
the acquisition and the integration of Topdanmark into
If Group, the one-off restructuring costs incurred
amounted to approximately EUR 150 million. If and
Topdanmark have estimated that requirements set in
the IAS 37 Provisions, Contingent Liabilities and
Contingent Assets for a recognition of a provision were
met at the end of the reporting period. The
restructuring provision is recognised as it is probable
that the restructuring costs will incur while carrying out
the integration. The costs relate mainly to redundancies,
decommissioning and sunsetting of systems as well as
rebranding.
On Sampo Group level, the restructuring provision
amounted to approximately EUR 150 million, of which
EUR 77 million was recognised in If’s segment and EUR
73 million in Topdanmark’s segment. In Sampo Group’s
balance sheet, the restructuring provision is presented
under other liabilities.
Pillar II
Sampo Group is within the scope of Pillar II regulations
(EU Minimum Tax Directive and OECD Safe Harbour
rules). Sampo Group companies have applied a
temporary mandatory relief from deferred tax
accounting for any potential impacts of the top-up tax
and account for it as a current tax should it occur.
Sampo Group will, as of fiscal year 2024, be subject to
the global minimum top-up tax rules either at the
ultimate parent entity level, by Sampo plc in Finland, or
domestic top-up tax in the countries where Sampo
Group companies operate and where such rules are
enacted. At the reporting date, Sampo Group has
identified that Hastings’ operations in Gibraltar are
subject to the global minimum top-up tax rules.
Discontinued operations in 2023
In order to segregate the Mandatum subgroup in the
demerger of Sampo plc, Mandatum’s assets and
liabilities were reclassified as a disposal group held for
distribution to owners and related liabilities on 31 March
2023. In the statement of profit and other
comprehensive income, the result of Mandatum is
reported as a single line item as profit from the
discontinued operations.
The partial demerger was completed on 1 October
2023, and the first trading day for Mandatum on
Nasdaq Helsinki was 2 October 2023. In the demerger,
all the shares in Mandatum Holding Ltd (a wholly owned
direct subsidiary of Sampo plc) and the related assets
and liabilities were transferred without a liquidation
procedure to Mandatum plc, a company incorporated in
the demerger on the effective date.
FINANCIAL STATEMENTS 2024
160
In addition, EUR 102 million of Sampo's general
liabilities, not allocated to any specific business
operations, were allocated to Mandatum plc. These
liabilities cannot be legally transferred due to their
nature, and therefore Sampo and Mandatum agreed on
forming an equivalent debt relationship between them
on 2 October 2023.
Application of new or revised
IFRSs and interpretations
The Group will apply new or amended standards and
interpretations related to the Group’s business in the
financial years when they become effective, or if the
effective date is other than the beginning of the
financial year, during the financial year following the
effective date. The new IFRSs coming into effect in the
financial year 2025 will not have any significant
influence on the Group's financial reporting.
FINANCIAL STATEMENTS 2024
161
Segment information
At the end of the reporting period, Sampo Group’s
business segments are If, Topdanmark, Hastings and
Holding. Topdanmark continued to be presented as a
business segment regardless of the intra-group sale of
Topdanmark A/S shares to If P&C Holding Ltd.
Segment information has been produced in accordance 
with the accounting policies adopted for preparing and
presenting the consolidated financial statements. The 
segment revenue, expense, assets and liabilities, either 
directly attributable or reasonably allocable, have been
allocated to the segments. Inter-segment pricing is
based on market prices. The transactions, assets and
liabilities between the segments are eliminated in the
consolidated financial statements on a line-by-line basis.
There was no significant income between segments
during the financial periods.
FINANCIAL STATEMENTS 2024
162
Result by segment for twelve months ended 31 December 2024
EURm
If
Topdan-
mark
Hastings
Holding
Elim.
Sampo
Group
GWP & brokerage income
5,860
1,553
2,565
—
-47
9,931
Insurance revenue, net (incl.
brokerage)
5,258
1,470
1,659
—
—
8,386
Claims incurred, net
-3,554
-970
-938
—
4
-5,459
Operating expenses
-814
-267
-532
—
—
-1,612
Underwriting result
890
233
190
—
3
1,316
Net investment income
652
93
72
78
-8
888
Insurance finance income or
expense, net
-188
-33
-31
—
—
-252
Net financial result
464
60
41
78
-8
636
Other items
-98
-155
-39
-107
8
-392
Profit before taxes
1,256
137
193
-29
3
1,559
Income taxes
-252
-48
-30
0
—
-330
Profit after taxes
1,003
90
163
-30
3
1,229
Divested operations, net of
tax
—
-26
—
—
—
-26
Net profit
1,203
Other comprehensive income
Items reclassifiable to profit
or loss
Exchange differences
-104
-1
101
—
—
-4
Cash flow hedges
—
—
1
—
—
1
Total items reclassifiable to
profit or loss, net of tax
-104
-1
102
—
—
-3
EURm
If
Topdan-
mark
Hastings
Holding
Elim.
Sampo
Group
Items not reclassifiable to
profit or loss
Actuarial gains and losses
from defined pension plans
0
—
—
—
—
0
Taxes
0
—
—
—
—
0
Total items not reclassifiable
to profit or loss, net of tax
0
—
—
—
—
0
Total other comprehensive
income, net of tax
-105
-1
102
—
—
-3
Total comprehensive income
899
63
265
-30
3
1,200
Profit attributable to
Owners of the parent
1,154
Non-controlling interests
50
Total comprehensive income
attributable to
Owners of the parent
1,151
Non-controlling interests
50
All intra-group transactions related to the sale of Topdanmark A/S shares to If P&C Insurance
Holding Ltd have been eliminated already from the segment figures. For more information on the
transaction, please see note 28.
FINANCIAL STATEMENTS 2024
163
Result by segment for twelve months ended 31 December 2023
EURm
If
Topdan-
mark
Hastings
Holding
Elim.
Sampo
Group
GWP & brokerage income
5,468
1,339
2,063
—
—
8,870
Insurance revenue, net
(incl. brokerage)
4,996
1,288
1,251
—
—
7,535
Claims incurred, net
-3,377
-862
-714
—
—
-4,953
Operating expenses
-777
-233
-409
—
—
-1,419
Underwriting result
842
194
128
—
—
1,164
Net investment income
871
107
79
-37
-13
1,006
Insurance finance income
or expense, net
-331
-79
-35
—
—
-446
Net financial result
539
27
44
-37
-13
560
Other items
-24
-59
-42
-122
4
-243
Profit before taxes
1,358
162
129
-160
-9
1,481
Income taxes
-285
-43
-11
0
—
-339
Profit from the continuing
operations
1,073
119
118
-160
-9
1,142
Discontinued operations,
net of tax 1
—
—
—
—
9
251
Net profit
1,393
Other comprehensive
income
Items reclassifiable to
profit or loss
Exchange differences
-23
-3
24
—
—
-1
Cash flow hedges
—
—
-1
—
—
-1
Total items reclassifiable
to profit or loss, net of tax
-23
-3
23
—
—
-3
EURm
If
Topdan-
mark
Hastings
Holding
Elim.
Sampo
Group
Items not reclassifiable
to profit or loss
Actuarial gains and
losses from defined
pension plans
-6
—
—
—
—
-6
Taxes
1
—
—
—
—
1
Total items not
reclassifiable to profit
or loss, net of tax
-5
—
—
—
—
-5
Total other
comprehensive income
for the continuing
operations, net of tax
-28
-3
23
—
—
-8
Total comprehensive
income
1,045
117
141
-160
-9
1,386
Profit attributable to
Owners of the parent
1,323
Non-controlling interests
70
Total comprehensive
income attributable to
Owners of the parent
1,316
Non-controlling interests
70
Mandatum Group has been presented in the comparative year in a single line as discontinued
operations, and therefore the Group total by lines do not reconcile to the segment totals.
1 The elimination totalling EUR 9 million is related to intra-segment operations between the
reportable segments and discontinued operation.
FINANCIAL STATEMENTS 2024
164
Balance sheet by segment at 31 December 2024
EURm
If
Topdanmark
Hastings
Holding
Elim.
Sampo Group
Assets
Property, plant and equipment
151
114
15
3
—
284
Intangible assets
560
1,521
1,554
1
—
3,637
Investments in associates
4
—
—
—
—
4
Financial assets
10,454
2,418
2,287
7,645
-6,713
16,090
Deferred income tax
4
1
—
0
-4
2
Reinsurance contract assets
679
73
1,896
—
-30
2,618
Other assets
593
91
167
31
-1
880
Cash and cash equivalents
273
108
333
248
—
962
Total assets
12,720
4,327
6,252
7,927
-6,748
24,478
Liabilities
Insurance contract liabilities
7,049
1,875
3,396
—
-33
12,286
Subordinated debts
131
147
—
1,491
-127
1,642
Other financial liabilities
19
43
353
979
—
1,395
Deferred income tax
358
113
64
—
—
535
Other liabilities
1,113
290
110
51
-1
1,562
Total liabilities
8,670
2,469
3,923
2,520
-162
17,419
Equity
Share capital
98
Reserves
3,531
Retained earnings
4,176
Other components of equity
-746
Equity attributable to owners of the parent
7,059
Non-controlling interests
—
Total equity
7,059
Total equity and liabilities
24,478
All intra-group transactions related to the sale of Topdanmark A/S shares to If P&C Insurance Holding Ltd have been eliminated already from the segment figures. For more information on the transaction,
please see note 28..
FINANCIAL STATEMENTS 2024
165
Balance sheet by segment at 31 December 2023
EURm
If
Topdanmark
Hastings
Holding
Elim.
Sampo Group
Assets
Property, plant and equipment
177
117
19
4
—
318
Intangible assets
579
1,545
1,512
1
—
3,637
Investments in associates
4
8
—
—
—
12
Financial assets
10,838
2,060
1,407
7,564
-6,112
15,757
Deferred income tax
4
4
—
—
-4
3
Reinsurance contract assets
563
79
1,640
—
—
2,282
Other assets
553
89
136
23
—
800
Cash and cash equivalents
197
24
448
747
—
1,415
Total assets
12,915
3,926
5,162
8,339
-6,117
24,225
Liabilities
Insurance contract liabilities
7,134
1,855
2,726
—
—
11,716
Subordinated debts
135
148
—
1,490
-127
1,645
Other financial liabilities
58
46
186
979
—
1,269
Deferred income tax
352
139
76
—
—
567
Other liabilities
1,011
162
112
58
—
1,342
Total liabilities
8,689
2,350
3,100
2,527
-128
16,538
Equity
Share capital
98
Reserves
1,530
Retained earnings
6,378
Other components of equity
-743
Equity attributable to owners of the parent
7,263
Non-controlling interests
424
Equity
7,687
Total equity and liabilities
24,225
FINANCIAL STATEMENTS 2024
166
Geographical information
EURm
2024
Finland
Sweden
Norway
Denmark
UK
Baltic
Total
Revenue from external customers
1,269 
1,954 
1,749 
2,126 
2,234 
245 
9,577 
Non-current assets
99 
433 
179 
1,639 
1,570 
6 
3,925 
EURm
2023
Finland
Sweden
Norway
Denmark
UK
Baltic
Total
Revenue from external customers
1,343 
1,801 
1,654 
1,897 
1,977 
223 
8,894 
Non-current assets
111 
454 
189 
1,675 
1,531 
7 
3,968 
Geographical information has been disclosed on income from external customers and
non-current assets. The reported areas are Finland, Sweden, Norway, Denmark, UK and
the Baltic countries.
The revenue includes insurance revenue according to the underwriting country.
Holding includes net investment income and other operating income. For Hastings,
income from broker activities has been included as well. Revenue from external
customers during the reporting period 2023 includes Mandatum’s revenue until the
date of demerger i.e. 1 October 2023.
Non-current assets comprise of intangible assets, investments in associates, property,
plant and equipment, and investment property. Mandatum’s assets were no longer
included at the end of the comparative period 2023.
FINANCIAL STATEMENTS 2024
167
Other notes
1 Insurance service result
EURm
1-12/2024
1-12/2023
Insurance revenue
Insurance contracts measured under PAA
Gross written premiums
9,527
8,513
Change in liability for remaining coverage
-343
-329
Brokerage revenue
266
233
Total insurance revenue from contracts measured under PAA
9,450
8,417
Total insurance revenue
9,450
8,417
Insurance service expenses
Expenses related to claims incurred
Claims paid and benefits
-5,827
-5,292
Claims handling expenses
-518
-468
Change in liability for incurred claims
118
-29
Change in risk adjustment
-80
-9
Change in loss component
21
-12
Insurance service expenses related to claims incurred
-6,287
-5,810
Operating expenses
-1,396
-1,266
Total insurance service expenses
-7,684
-7,076
Reinsurance result
Premiums
-909
-1,005
Claims recovered
537
857
Total reinsurance result
-372
-148
Total insurance service result
1,394
1,193
FINANCIAL STATEMENTS 2024
168
2 Net investment income
The net investment income consists of investment income and expenses from financial
assets and liabilities held by the group companies.
EURm
1-12/2024
1-12/2023
Derivative financial instruments
Interest income
4
6
Interest expense
0
-23
Net gains or losses
13
5
Derivative financial instruments, total
17
-12
Financial assets at fair value through profit or loss
Debt securities
Interest income
493
447
Net gains or losses
147
364
Equity securities
Dividend income
37
59
Net gains or losses
81
64
Funds
Distributions
6
5
Interest income
10
11
Net gains or losses
70
60
Financial assets at fair value through profit or loss, total
844
1,010
Financial assets at amortised cost
32
23
Total income or expenses from financial assets
892
1,021
Other
Expenses from asset management
-21
-19
Other income
57
34
Other expenses
-38
-26
Fee expenses
0
-1
Expenses from investment property
-3
-4
Total other
-4
-15
Total net investment income
888
1,006
Net gains or losses for debt securities include exchange differences of EUR 2 million (-3).
The amount of expected credit losses on financial assets measured at amortised cost is
presented in the note 12.
3 Net finance income or expense from
insurance contracts
EURm
1-12/2024
1-12/2023
Insurance contracts
Unwinding of discount rate
-324 
-322 
Effect of changes in interest rates and other financial
assumptions
15 
-207 
Total finance income or expenses from insurance contracts
-309 
-529 
Reinsurance contracts
Unwinding of discount rate
86 
74 
Reinsurers' share of effect of changes in interest rates and
other financial assumptions
-29 
9 
Total finance income or expenses from reinsurance contracts
57 
83 
Net finance result insurance and reinsurance contracts
-252 
-446 
FINANCIAL STATEMENTS 2024
169
4 Other income
EURm
1-12/2024
1-12/2023
Other income
300 
265 
Income related to broker activities
12 
12 
Total other income
312 
277 
If’s other operating income includes approximately EUR 144 million (144) income from
insurance operations without a transfer of insurance risk. Such income is primarily
attributable, e.g. to sales commission and services for administration and claims
settlement in insurance contracts on behalf of other parties. This operating income is
accounted for under IFRS 15 Revenue from Contracts with Customers. In addition,
other operating income includes income from roadside assistance services provided by
If’s subsidiary Viking Assistance Group AS, recognised when roadside assistance has
been provided.
Hastings’ operating income includes total of EUR 134 million (115) revenue recognised
under IFRS 15 and consisting of fees and commission on panel providers, ancillary
product income, and other retail income. Income related to broker activities is also
accounted for under IFRS 15 if there is no insurance risk transferred to Hastings.
5 Other expenses
EURm
1-12/2024
1-12/2023
Other expenses
-465 
-300 
Depreciation and amortisation
-119 
-99 
Salaries and other staff costs
-100 
-57 
Total other expenses
-685 
-457 
Expenses by nature
As Sampo presents expenses by function in the statement of profit or loss, the
following table provides additional information on the nature of the expenses,
including the total of depreciation, amortisation, and employee benefit expense.
EURm
1-12/2024
1-12/2023
Staff costs
Salaries and wages
-967
-893
Cash-settled share-based payments
-22
-4
Share-settled share-based payments
-7
-2
Pension costs
Pension expenses - defined contribution plans
-101
-99
Pension expenses - defined benefit plans
-9
-15
Other social security costs
-188
-168
Depreciations
Depreciation on plant and equipment
-17
-15
Depreciation IFRS 16
-34
-33
Amortisations
Amortisation on customer relations
-72
-64
Amortisation on other intangibles
-57
-46
Rental expenses
-35
-34
IT costs
-243
-244
Marketing expenses
-75
-62
Other
-824
-654
Total expenses split by nature
-2,653 
-2,335 
The comparative year includes Mandatum Group’s figures.
The main items in line Other include commissions of EUR 146 million (138), other
technical expenses of EUR 228 million (132), acquisition costs of EUR 125 million (92),
and levies EUR 47 million (48).
FINANCIAL STATEMENTS 2024
170
6 Auditor's fees
EUR thousand
1-12/2024
1-12/2023
Auditing fees
-4,322 
-4,666 
Deloitte
-4,322 
-4,032 
KPMG
— 
-634 
Other fees
-712 
-612 
Deloitte
-712 
-460 
KPMG
— 
-152 
Total
-5,034 
-5,278 
7 Finance expenses
EURm
1-12/2024
1-12/2023
Interest expense on financial liabilities
-21 
-24 
Interest expense on subordinated loans
-52 
-48 
Other items
-30 
-22 
Total finance expenses
-103 
-93 
8 Components of other comprehensive
income
EURm
1-12/2024
1-12/2023
Other comprehensive income
Items reclassifiable to profit or loss
Exchange differences
-25
-1
Exchange differences arising from net investment in foreign
operation
21
—
Cashflow hedges
1
-1
Total items reclassifiable to profit or loss, net of tax
-3
-3
Items not reclassifiable to profit or loss
Actuarial gains and losses from defined pension plans
0
-6
Taxes
0
1
Total items not reclassifiable to profit or loss, net of tax
0
-5
Other comprehensive income total, net of tax
-3
-8
On 1 November 2024, Sampo plc sold all the issued shares in Topdanmark A/S to If
P&C Insurance Holding Ltd. As part of the arrangement, Sampo plc granted a loan to If
P&C Insurance Holding Ltd, amounting to EUR 1,724 million divided in principle
amounts of DKK 6,432 million and EUR 862 million. The loan is considered to form a
part of Sampo’s net investment in a foreign operation (subsidiary) and therefore any
exchange rate gains or losses are recognised in other comprehensive income. The net
exchange rate differences are accumulated in the equity in the translation of foreign
operations reserve.
For more information on the transaction, please see note 28 Acquisition of
Topdanmark’s non-controlling interest and note 29 Related party disclosures.
FINANCIAL STATEMENTS 2024
171
9 Earnings per share
EURm
1-12/2024
1-12/2023
Profit or loss attributable to the equity holders of the parent
company
1,154 
1,323 
Weighted average number of shares outstanding during the
financial year*
512 
506 
Earnings per share (EUR per share)
2.25 
2.62 
Earnings per share, continuing operations
2.25 
2.12 
Earning per share, discontinuing operations
— 
0.50 
* The weighted average number of treasury shares during the financial year has been taken into
account in the number of shares. There were no other share-related transactions during the
financial year.
FINANCIAL STATEMENTS 2024
172
10 Property, plant and equipment
2024
EURm
Right-of-
use assets1
Land and
buildings
Plant and
equipment2
Total
At 1 January
Cost
286
114
182
582
Accumulated depreciation
-126
-9
-130
-264
Net carrying amount at 1 January
160
106
52
318
Carrying amount at 1 January
Additions
14
2
17
33
Disposals
-4
-7
-1
-12
Depreciation
-34
0
-17
-51
Exchange differences
-4
0
0
-4
Other changes
1
-1
—
—
Carrying amount at 31 December
134
100
51
284
At 31 December
Cost
294
108
197
599
Accumulated depreciation
-160
-9
-147
-315
Net carrying amount at 31
December
134
100
51
284
2023
EURm
Right-of-
use assets1
Land and
buildings
Plant and
equipment2
Total
At 1 January
Cost
289
119
162
570
Accumulated depreciation
-92
-8
-115
-216
Net carrying amount at 1 January
197
111
47
355
Carrying amount at 1 January
Business acquisitions
—
1
0
1
Additions
19
1
25
45
Disposals
-20
-4
-5
-29
Depreciation
-32
0
-14
-46
Exchange differences
-4
0
-1
-4
Other changes
—
-3
—
-3
Carrying amount at 31 December
160
106
52
318
At 31 December
Cost
286
114
182
582
Accumulated depreciation
-126
-9
-130
-264
Net carrying amount at 31
December
160
106
52
318
1 The Group acts as a lessee in various leases of office premises, vehicles, and office equipment.
Right-of-use assets relate to lease contracts for large office premises. The Group leases premises
mainly for its own use. The expected lease term varies from 2 to 12 years. Most contracts include an
option to extend the contract at the term end. Some lease contracts have an option to terminate
the contract before the term end. Variable lease payments are generally linked to consumer price
indexes.
More information on leases is in note 23 Other liabilities.
2 Equipment in different segments comprise IT equipment and furniture.
The disposals in the comparative year include the PP&E of Mandatum Group,
separated from Sampo on 1 October 2023.
FINANCIAL STATEMENTS 2024
173
11 Intangible assets
2024
EURm
Goodwill
Customer
relations
Trademark
Work in
progress
Other
intangible
assets
Total
At 1 January
Cost
2,469
726
233
91
722
4,241
Accumulated
amortisation
—
-282
0
-1
-321
-604
Net carrying amount at
1 January
2,469
443
233
90
401
3,637
Net carrying amount at
1 January
Additions
—
—
—
96
5
101
Disposals
-5
-13
-6
—
-1
-25
Amortisation
—
-72
—
—
-57
-129
Impairment losses
—
—
—
-2
—
-2
Transfers from WIP
—
—
—
-36
36
—
Exchange differences
26
7
6
0
14
54
Net carrying amount at
31 December
2,490
365
233
149
399
3,637
At 31 December
Cost
2,490
719
234
151
777
4,371
Accumulated
amortisation
—
-354
—
-1
-378
-733
Accumulated
impairment losses
—
—
—
-2
—
-2
Net carrying amount at
31 December
2,490
365
233
149
399
3,637
2023
EURm
Goodwill
Customer
relations
Trademark
Work in
progress
Other
intangible
assets
Total
At 1 January
Cost
2,385
679
224
72
625
3,985
Accumulated
amortisation
—
-216
—
—
-275
-492
Net carrying amount
at 1 January
2,385
463
224
72
350
3,494
Net carrying amount
at 1 January
Business acquisitions
238
72
7
—
8
325
Additions
—
—
—
102
4
106
Disposals
-163
-31
—
-2
-4
-200
Amortisation
—
-65
0
-1
-44
-109
Transfers from WIP
—
—
—
-81
81
—
Exchange differences
10
3
3
0
5
21
Net carrying amount
at 31 December
2,469
443
233
90
401
3,637
At 31 December
Cost
2,469
726
233
91
722
4,241
Accumulated
amortisation
—
-282
0
-1
-321
-604
Net carrying amount
at 31 December
2,469
443
233
90
401
3,637
The disposals in the comparative year include the intangibles of Mandatum Group,
separated from Sampo on 1 October 2023. 
FINANCIAL STATEMENTS 2024
174
Goodwill is split between the segments as follows:
2024
2023
If
537 
556 
Topdanmark
1,036 
1,038 
Hastings
918 
876 
Total
2,490 
2,469 
The useful life for customer relations in the Group is 3–10 years. They are amortised
using the straight-line method. The useful life of trademark is deemed indefinite and it
will not be amortised.
Other intangible assets in all segments comprise mainly IT software. Amortisations and
impairment losses are included in the income statement item Other expenses.
Testing goodwill for impairment
Goodwill is annually tested for impairment in accordance with IAS 36 Impairment of
assets. No impairment losses have been recognised based on these tests.
For the purpose of testing goodwill for impairment, Sampo determines the recoverable
amount of its cash-generating units, to which goodwill has been allocated, on the basis
of value in use. Sampo has defined these cash-generating units as If Group,
Topdanmark Group, and Hastings Group.
The recoverable amounts for If and Hastings have been determined by using a
discounted cash flow model. The model is based on the best estimates of companies’
management of both historical evidence and financial conditions such as premiums,
claims, reinsurance, margins, interest rates, capital structure, and income and cost
development. The derived cash flows were discounted at the pre-tax rate of the cost
of equity which for If was 9.2 per cent and for Hastings 11.1 per cent. The cost of capital
is defined based on the CAPM model from external sources to reflect the risk of each
company relative to the market.
Financial plans for If and Hastings, approved by the management and the boards,
cover the years 2025–2027. The cash flows beyond that have been extrapolated using
a 2 per cent growth rate.
For Hastings, the recoverable amount exceeds its carrying amount by some EUR 600
million. With the calculation method used, e.g. an increase of about 2 percentage
points in the cost of equity could lead to a situation where the recoverable amount of
the entity would equal its carrying amount.
As for If Group, management believes that any reasonably possible change in any of
the key assumptions would not cause the aggregate carrying amount to exceed the
aggregate recoverable amount.
Sampo acquired the non-controlling interests of Topdanmark at a market price during
H2/2024. Management has not identified any indicators of impairment as per 31
December 2024.
Sensitivity analysis
Impact on the present value from the following changes (EURbn)
2024
If
Long-term Combined ratio +2.5 p.p.
-1.4
Long-term Combined ratio -2.5 p.p.
2.0
Long-term growth rate -1 p.p.
-1.9
Long-term growth rate +1 p.p.
2.7
Cost of equity +1 p.p.
-2.3
Cost of equity -1 p.p.
3.2
Hastings
Long-term growth rate -1 p.p.
-0.2
Long-term growth rate +1 p.p.
0.3
Cost of Equity +1 p.p.
-0.4
Cost of Equity -1 p.p.
0.5
FINANCIAL STATEMENTS 2024
175
12 Financial assets
EURm
12/2024
12/2023
Financial assets
Derivative financial instruments
26
38
Financial assets at fair value through profit or loss
Debt securities
13,325
12,925
Equity securities
1,288
1,640
Funds
823
662
Deposits and other
—
40
Total financial assets at fair value through profit or loss
15,436
15,267
Financial assets measured at amortised cost
Loans
272
276
Loans and advances to customers
356
175
Deposits
1
1
Total financial assets measured at amortised cost
629
452
Total financial assets
16,090
15,757
Loans and advances to customers consist of Hastings’ loans to customers.
Loans measured at amortised cost also include a loan receivable from Mandatum plc
amounting to 101 million (101 million). The loan receivable was recognised in the
allocation of general liabilities, as part of the partial demerger of 1 October 2023.
During 2024, Sampo completed the sale of its 19.8 per cent stake in Saxo Bank to
Mandatum, as agreed in connection with the partial demerger completed in 2023. The
transaction price was EUR 302 million, representing the price agreed in the demerger,
adjusted for dividends received.
Financial assets measured at amortised cost by stages
The financial assets measured at amortised cost are in the scope of impairment. The
impairment model is based on a forward-looking expected credit loss model (ECL).
The expected credit loss model has a three-stage approach based on changes in credit
risk. A 12-month ECL (Stage 1) applies to all items, unless there is a significant increase
in credit risk since initial recognition. For items where there is a significant increase in
credit risk (Stage 2), or in default (Stage 3), lifetime ECL applies.
FINANCIAL STATEMENTS 2024
176
The determination of expected credit losses is
described in detail in the section Accounting principles.
The next table presents the gross amounts of financial
assets measured at amortised cost and loss allowance
by stages.
2024
EURm
Stage 1 -
12-month ECL
Stage 2 -
Lifetime ECL -
not credit-
impaired
Stage 3 -
Lifetime ECL -
credit-impaired
Total
Financial assets at amortised cost
Loans
273
—
—
273
Loans and advances to customers
347
16
14
377
Deposits
1
—
—
1
Loss allowance
-8
-3
-11
-23
Total
613
13
3
629
2023
EURm
Stage 1 -
12-month ECL
Stage 2 -
Lifetime ECL -
not credit-
impaired
Stage 3 -
Lifetime ECL -
credit-impaired
Total
Financial assets at amortised cost
Loans
278
—
2
280
Loans and advances to customers
173
8
5
186
Deposits
1
—
—
1
Loss allowance
-9
-1
-5
-16
Total
442
6
2
451
FINANCIAL STATEMENTS 2024
177
The gross carrying amounts of the financial assets
measured at amortised cost was EUR 651 million (EUR
468  million) and loss allowance was EUR -23 million
(EUR -16 million).
During the reporting period, the expected credit losses
recognised in the income statement was EUR -7 million
and in the comparative period EUR -10 million.
Derivative financial instruments
2024
Fair value
2023
Fair value
EURm
Contract/
Notional
Amount
Assets
Liabilities
Contract/
Notional
Amount
Assets
Liabilities
Derivatives held for
trading
Interest rate
derivatives
OTC derivatives
Interest rate swaps
456
2
49
340
3
44
Inflation cover
211
13
18
211
16
12
Total interest rate
derivatives
667
15
68
551
18
56
Foreign exchange
derivatives
OTC derivatives
Currency forwards
2,760
10
19
3,032
18
57
Currency options,
bought and sold
24
1
0
53
1
1
Total foreign exchange
derivatives
2,784
11
20
3,085
20
58
Total derivatives held
for trading
3,451
26
87
3,636
38
114
2024
Fair value
2023
Fair value
EURm
Contract/
Notional
Amount
Assets
Liabilities
Contract/
Notional
Amount
Assets
Liabilities
Derivatives held for
hedging
Cash flow hedges
Currency forwards
5
0
—
—
—
—
Interest rate swaps
576
—
1
228
—
2
Total cash flow hedges
581
0
1
228
—
2
Total derivatives held
for hedging
581
0
1
228
—
2
Group financial
derivatives, total
4,032
26
88
3,864
38
116
FINANCIAL STATEMENTS 2024
178
13 Determination and
hierarchy of fair values
A majority of Sampo Group's financial assets are valued
at fair value. The valuation is based on either published
price quotations or valuation techniques based on
market observable inputs, where available. For a limited
amount of assets, the value needs to be determined
using other techniques. The financial instruments
measured at fair value have been classified into three
hierarchy levels in the notes, depending on, for example,
whether the market for the instrument is active, or if the
inputs used in the valuation technique are observable. 
The classification of financial assets into hierarchy levels
is assessed quarterly.
The fair value of the derivative instruments is assessed
using quoted market prices in active markets,
discounting method, or option pricing models.
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.
Fair values are "clean" fair values, i.e. less interest
accruals.
On level 1, the measurement of the instrument is based
on quoted prices in active markets for identical assets
or liabilities. Quoted prices in active markets are
considered to represent the best estimate of fair value
for related financial assets. On an active market quoted
prices are easily and regularly available and represent
actual and regularly occurring transactions at arm’s
length distance.
On level 2, inputs for the measurement of the
instrument also include other than quoted prices
observable for the asset or liability, either directly or
indirectly by using valuation techniques.
On level 3, the measurement is based on other inputs
rather than observable market data. Sampo Group’s
level 3 assets consist mainly of a few larger equity
investments and investments in private equity and
alternative funds.
In level 3 equity investment is valued by using excess
return model, in which value of a company is sum of
capital invested currently in the company and the
present value of excess returns that the company
expects to make in the future.
For private equity funds, the valuation of the underlying
investments is conducted by the fund manager who has
all the relevant information required in the valuation
process. The valuation is usually updated quarterly
based on the value of the underlying assets and the
amount of debt in the fund. There are several valuation
methods, which can be based on, for example, the
acquisition value of the investments, the value of
publicly traded peer companies, the multiple-based
valuation or the cash flows of the underlying
investments.
The carrying amounts and fair values of financial assets
and financial liabilities, including their fair value
hierarchy levels, are presented in the following table.
Fair value information on financial assets and financial
liabilities not measured at fair value is not presented in
the table, if the carrying amount is a reasonable
estimate of the fair value.
FINANCIAL STATEMENTS 2024
179
EURm
31 December 2024
Carrying
amount
Level 1
Level 2
Level 3
Total
Financial assets at fair value
Derivative financial instruments
Interest rate swaps
2
—
2
—
2
Foreign exchange derivatives
11
—
11
—
11
Inflation cover derivatives
13
—
13
—
13
Total
26
—
26
—
26
Financial assets at fair value
through profit or loss
Debt securities
13,325
8,469
4,839
17
13,325
Equity securities
1,288
837
19
432
1,288
Funds
823
491
176
157
823
Total
15,436
9,796
5,033
606
15,436
Total financial assets measured
at fair value
15,462
9,796
5,059
606
15,462
Financial assets measured at
amortised cost
Loans
272
—
101
171
272
Loans and advances to
customers
356
—
—
356
356
Other
1
—
—
1
1
Total
629
—
101
528
629
Total financial assets
16,090
9,796
5,160
1,134
16,090
EURm
31 December 2024
Carrying
amount
Level 1
Level 2
Level 3
Total
Financial liabilities at fair value
Derivative financial instruments
Interest derivatives
50
—
50
—
50
Foreign exchange derivatives
20
—
20
—
20
Inflation cover derivatives
18
—
18
—
18
Total financial liabilities at fair
value
88
—
88
—
88
Financial liabilities measured at
amortised cost
Subordinated debt securities
Subordinated loans
1,642
1,535
20
—
1,555
Debt securities in issue
Bonds
954
847
80
—
927
Amounts owed to credit
institutions
353
—
—
353
353
Financial liabilities measured at
amortised cost total
2,948
2,382
100
353
2,835
Group financial liabilities, total
3,036
2,382
188
353
2,923
FINANCIAL STATEMENTS 2024
180
EURm
31 December 2023
Carrying
amount
Level 1
Level 2
Level 3
Total
Financial assets at fair value
Derivative financial instruments
Interest rate swaps
3
—
3
—
3
Foreign exchange derivatives
20
—
20
—
20
Inflation cover derivatives
16
—
16
—
16
Total
38
—
38
—
38
Financial assets at fair value
through profit or loss
Debt securities
12,925
8,476
4,430
19
12,925
Equity securities
1,640
886
24
730
1,640
Funds
662
480
31
151
662
Deposits and other
40
—
40
—
40
Total
15,267
9,842
4,525
900
15,267
Total financial assets measured
at fair value
15,305
9,842
4,563
900
15,305
Financial assets measured at
amortised cost
Loans
276
—
97
179
276
Loans and advances to
customers
175
—
—
175
175
Other
1
—
—
1
1
Total
452
—
97
354
452
Total financial assets
15,757
9,842
4,660
1,254
15,756
EURm
31 December 2023
Carrying
amount
Level 1
Level 2
Level 3
Total
Financial liabilities at fair value
Derivative financial instruments
Interest derivatives
46
2
44
—
46
Foreign exchange derivatives
58
—
58
—
58
Inflation cover derivatives
12
—
12
—
12
Total financial liabilities at fair
value
116
2
114
—
116
Financial liabilities measured at
amortised cost
Subordinated debt securities
Subordinated loans
1,645
1,448
148
—
1,596
Debt securities in issue
Bonds
959
936
—
—
936
Amounts owed to credit
institutions
194
—
9
184
194
Financial liabilities measured at
amortised cost total
2,798
2,385
157
184
2,726
Group financial liabilities, total
2,914
2,387
271
184
2,842
FINANCIAL STATEMENTS 2024
181
Transfers between levels 1 and 2
EURm
1-12/2024
1-12/2023
Transfers between levels 1 and 2
Transfers
from level 2
to level 1
Transfers
from level 1
to level 2
Transfers
from level
2
to level 1
Transfers
from level 1
to level 2
Financial assets at fair value
through profit or loss
Debt securities
192
181
378
334
Total
192
181
378
334
Transfers are based mainly on the changes of trading volume information provided by
an external service provider.
Sensitivity analysis of fair values
The sensitivity of financial assets and liabilities to changes in exchange rates is
assessed on business area level due to different base currencies.
12/2024
12/2023
EURm
Recognised
in profit or
loss
Recognised
in profit or
loss
If
10 percentage point depreciation of all other currencies against
SEK
17
4
Topdanmark
10 percentage point depreciation of all other currencies against
DKK
-1
-1
Hastings
10 percentage point depreciation of all other currencies against
GBP
8
—
Holding
10 percentage point depreciation of all other currencies against
EUR
-68
-73
The sensitivity analysis of the Group’s fair values of financial assets and liabilities in
different market risk scenarios is presented in the following table. The effects represent
the instantaneous effects of a one-off change in the underlying market variable on the
fair values on 31 December 2024. The sensitivity analysis includes the effects of
derivative positions. All sensitivities are calculated before taxes.
Interest
rate
Interest
rate
Equity
Other
financial
assets
EURm
1% parallel
shift down
1% parallel
shift up
20% fall in
prices
20% fall in
prices
Effect in profit/loss
354
-332
-270
-141
Total effect
354
-332
-270
-141
FINANCIAL STATEMENTS 2024
182
14 Movements in level 3 financial instruments measured at fair value
EURm
Financial assets
At 1 Jan
Total gains/ losses
in income
statement
Purchases and re-
classifi-cations
Sales
Settle-
ments
At 31 Dec 2024
Financial assets at fair value through profit or loss
Debt securities
19
0
—
—
-2
17
Equity securities
730
-1
5
-302
—
432
Funds
151
6
—
—
—
157
Total
900
6
5
-302
-2
606
On 13 May 2024, Sampo completed the sale of its 19.8 per cent stake in Saxo Bank to Mandatum, as agreed in connection with the partial demerger completed in 2023. The
transaction price was EUR 302 million, representing the price agreed in the demerger adjusted for dividends received.
EURm
Financial assets
At 1 Jan
Total gains/ losses in
income statement
Purchases and re-
classifi-cations
Sales
At 31 Dec 2023
Financial assets at fair value through profit or loss
Debt securities
134
1
11
-126
19
Equity securities
763
-14
9
-28
730
Funds
212
-61
—
0
151
Total
1,109
-74
20
-155
900
Mandatum Group’s financial instruments on level 3 are not included in the opening balance 1 January 2023. Additional information on classification of Mandatum Group into
discontinued operations in note 30.
FINANCIAL STATEMENTS 2024
183
Sensitivity analysis of level 3 financial instruments
measured at fair value
12/2024
12/2023
EURm
Carrying
amount
Effect of
reasonably
possible
alternative
assumptions
(+/-)
Carrying
amount
Effect of
reasonably
possible
alternative
assumptions
(+/-)
Financial assets at fair value
through profit or loss
Debt securities
17
-1
19
0
Equity securities
432
-86
730
-146
Funds
157
-31
151
-30
Total
606
-118
900
-176
The value of financial assets regarding the debt security instruments has been tested
by assuming a rise of 1 per cent in interest rate level in all maturities. For other financial
assets, the prices were assumed to go down by 20 per cent.
During the reporting period, on the basis of these alternative assumptions, a possible
change in interest levels would cause a reduction of EUR -1 (-0) million for the debt
instruments, and EUR -118 (-176) million valuation loss for other instruments in the
Group’s statement of profit or loss. The reasonably possible effect, proportionate to
the Group’s equity, would thus be 1.7 (2.4) per cent.
FINANCIAL STATEMENTS 2024
184
15 Deferred tax assets and liabilities
Changes in deferred tax during the financial year 2024
EURm
1 Jan
Business
acquisitions/
disposals
Recognised in
statement of profit
and other
comprehensive
income
Recognised in
equity
Exchange
differences
31 Dec
Deferred tax assets
Tax losses carried forward
1
—
—
—
0
1
Changes in fair values
0
—
—
—
0
0
Other deductible temporary differences
116
—
38
1
0
156
Total
117
—
38
1
0
157
Netting of deferred taxes
-155
Deferred tax assets in the balance sheet, total
117
—
38
1
0
2
Deferred tax liabilities
Depreciation differences and untaxed reserves
224
—
1
—
-5
219
Changes in fair values
194
—
32
—
2
228
Pension assets
7
—
1
0
—
8
Other taxable temporary differences
255
—
-18
0
-3
235
Total
680
—
15
1
-6
690
Netting of deferred taxes
-155
Deferred tax liabilities in the balance sheet, total
680
—
15
1
-6
535
FINANCIAL STATEMENTS 2024
185
Changes in deferred tax during the financial year 2023
EURm
1 Jan
Business
acquisitions/
disposals
Recognised in
statement of profit
and other
comprehensive
income
Recognised in
equity
Exchange
differences
31 Dec
Deferred tax assets
Tax losses carried forward
2
0
-1
—
0
1
Changes in fair values
5
—
-5
—
0
0
Other deductible temporary differences
128
-3
-11
0
2
116
Total
135
-3
-17
0
2
117
Netting of deferred taxes
-114
Deferred tax assets in the balance sheet, total
135
-3
-17
0
2
3
Deferred tax liabilities
Depreciation differences and untaxed reserves
209
-2
21
—
-4
224
Changes in fair values
194
-70
67
0
2
194
Pension assets
7
—
-1
—
—
7
Other taxable temporary differences
379
-93
-32
0
1
255
Total
790
-164
56
0
-1
680
Netting of deferred taxes
-114
Deferred tax liabilities in the balance sheet, total
790
-164
56
0
-1
567
The disposals include the deferred tax assets and liabilities of Mandatum Group, separated from Sampo on 1 October 2023.
FINANCIAL STATEMENTS 2024
186
Pillar II - tax losses
Sampo Group companies have applied a temporary mandatory relief from deferred tax accounting for any impacts of the top-up tax and accounts for it as a current tax should it
occur.
EURm
Tax losses carried forward 2024
Country
Tax losses
carried forward
in local currency
Tax losses
carried forward
Of which no
deferred tax
asset has been
recognised
Of which
deferred tax
asset has been
recognised
Recognised
deferred tax
asset
Applicable tax
rate
Potential
deferred tax
asset not
recognised
Sampo Plc
Finland
EURm 413
413
413
—
—
20,0 %
83
If P&C Insurance Holding Ltd (publ)
Norway
NOKm 83
7
7
—
—
22,0 %
-*
If P&C Insurance Ltd (publ)
Germany
—
—
—
—
—
27,4 %
-*
If P&C Insurance Ltd (publ)
France
EURm 15
15
15
—
—
25,8 %
-*
If P&C Insurance Ltd (publ)
UK
GBPm 9
11
11
—
—
25,0 %
-*
If P&C Insurance AS
Latvia
—
—
—
—
—
20,0 %
—
Insrt AB
Sweden
SEKm 6
1
—
0
0
20,6 %
—
Viking Sverige AB
Sweden
SEKm 61
5
2
4
1
20,6 %
0
Viking Assistance A/S
Denmark
DKKm 27
4
4
0
0
22,0 %
1
Viking Membership AB
Sweden
SEKm 3
0
0
—
—
20,6 %
0
Viking Guard AS
Norway
NOKm 6
1
—
1
0
22,0 %
—
Viking Assistance A/S
Estonia
EURm 0
0
0
—
—
20,0 %
0
Hastings Group Finance plc
UK
GBPm 9
9
9
—
—
25.0%
2
Hastings Holdings Limited
UK
GBPm 0
0
0
—
—
25.0%
0
Hastings (US) Limited
UK
GBPm 0
0
0
—
—
25.0%
0
Total
86
* Loss has occurred in a foreign branch and has been deducted in the head office. Utilisation of the loss locally in the foreign branch would not affect the tax expense for the company as a whole. Therefore,
no deferred tax asset can be recognised relating to the foreign branch.
FINANCIAL STATEMENTS 2024
187
MEUR
Tax losses carried forward 2023
Country
Tax losses
carried forward
in local currency
Tax losses
carried forward
Of which no
deferred tax
asset has been
recognised
Of which
deferred tax
asset has been
recognised
Recognised
deferred tax
asset
Applicable tax
rate
Potential
deferred tax
asset not
recognised
Sampo Plc
Finland
EURm 365
365
365
—
—
20.00%
73
If P&C Insurance Holding Ltd (publ)
Norway
NOKm 83
7
7
—
—
22.00%
-*
If P&C Insurance Ltd (publ)
Germany
EURm 2
2
2
—
—
27.38%
-*
If P&C Insurance Ltd (publ)
France
EURm 16
16
16
—
—
25.83%
-*
If P&C Insurance Ltd (publ)
UK
GBPm 20
23
23
—
—
25.00%
-*
If P&C Insurance AS
Latvia
—
—
—
—
—
20.00%
-
Insrt AB
Sweden
SEKm 6
1
1
—
—
20.60%
—
Viking Sverige AB
Sweden
SEKm 42
4
—
4
1
20.60%
—
Viking Assistance A/S
Denmark
DKKm 33
4
4
—
—
22.00%
1
Viking Nordic Assistance S.L
Spain
—
—
—
—
—
25.00%
—
Hastings Group Finance plc
UK
GBPm 7
8
8
—
—
25.00%
2
Total
1
76
* Loss has occurred in a foreign branch and has been deducted in the head office. Utilisation of the loss locally in the foreign branch would not affect the tax expense for the company as a whole. Therefore,
no deferred tax asset can be recognised relating to the foreign branch.
FINANCIAL STATEMENTS 2024
188
16 Taxes
EURm
2024
2023
Profit before tax
1,559
1,481
Tax calculated at parent company's tax rate
-312
-296
Different tax rates in foreign jurisdictions
-3
-40
Income from associates not subject to tax
2
0
Income not subject to tax
9
46
Non-deductible expenses
-17
-40
Tax losses for which no deferred tax asset has been recognised
-10
-36
Changes in tax rates
0
-8
Tax from previous years
1
2
Total
-330 
-372 
The comparative year taxes include taxes EUR -33 million as part of the result from the
discontinued operations.
Sampo Group has identified that Hastings’ operations in Gibraltar are subject to the
global minimum top-up tax rules under Pillar II regulations. A top-up tax amounting to
EUR -4 million has been recognised during the reporting period.
17 Other assets
EURm
12/2024
12/2023
Receivables arising from direct insurance operations
233
245
Receivables arising from reinsurance operations
174
92
Settlement receivables
8
5
Accrued interest
155
130
Net pension asset
36
32
Other
274
296
Total other asset
880
800
Item Other includes, e.g. assets related to patient insurance pool EUR 56 million (63), 
other receivables, prepaid expenses and damaged goods.
Other assets include non-current assets EUR 53 million (61).
FINANCIAL STATEMENTS 2024
189
18 Insurance contract liabilities
Insurance liabilities reflect the liability the Group has for its insurance undertakings,
meaning the insurance contracts underwritten. The liability consists of two parts, the
liability for remaining coverage and acquisition cash flow assets, as well as the liability
for incurred claims.
The liability for remaining coverage relates to the obligation to investigate and pay
valid claims that have not yet occurred. The liability consists of the premium payments
received for insurance services to be provided after the closing date, i.e. relating to the
unexpired portion of the insurance coverage, and adjusted for acquisition cash flows.
The liability for incurred claims relates to the obligation to investigate and pay valid
claims that have occurred. The liability is designed to cover anticipated future
payments for all claims incurred, including claims not yet reported.
For further information on accounting principles related to insurance contract
liabilities, please see the section Accounting principles.
EURm
12/2024
12/2023
Insurance contract liability - contracts measured under PAA
Liability for remaining coverage
1,877
1,709
Liability for incurred claims
10,409
10,007
Total insurance contract liabilities
12,286 
11,716 
Reinsurance contract assets
Assets for remaining coverage
276
258
Assets for incurred claims
2,342
2,024
Reinsurance contract assets, total
2,618 
2,282 
Total insurance contracts, net of reinsurance
9,668 
9,434 
The table below presents the yield curves by currency as a percentage that have been
used to discount the cash flows of the insurance contract liabilities.
2024
2023
Currency
, %
1 year
5
years
10
years
20
years
30
years
1 year
5
years
10
years
20
years
30
years
DKK
2.23
2.13
2.26
2.25
2.38
3.35
2.31
2.38
2.40
2.53
EUR
2.44
2.34
2.47
2.46
2.55
3.61
2.57
2.64
2.66
2.74
GBP
4.70
4.58
4.92
5.41
5.69
4.83
3.83
4.02
4.51
4.58
NOK
4.82
4.52
4.45
4.23
4.01
4.56
3.87
3.78
3.75
3.70
SEK
2.91
3.07
3.29
3.35
3.33
3.71
2.94
2.93
3.16
3.26
FINANCIAL STATEMENTS 2024
190
19 Reconciliation of
insurance contract liabilities
Insurance contracts
The first table presents the reconciliation of the carrying
amounts of the liability for remaining coverage, and the
liability for incurred claims for issued insurance
contracts during the reporting period, as a result of
amounts recognized in the statement of total
comprehensive income and cash flows.
Reinsurance contracts
The following table presents the reconciliation of the
carrying amounts of the asset for remaining coverage,
and the asset for incurred claims for reinsurance
contracts during the reporting period, as a result of
amounts recognized in the statement of profit and
other comprehensive income and cash flows.
The information is presented on the Sampo Group level
and on the reporting segment level. Information
regarding insurance contract liability is presented on
contracts measured under PAA model.
If and Hastings entered into an internal reinsurance
arrangement at the beginning of 2024. Reconciliation
calculations of the insurance contract liabilities for the
reported segments are presented, including the internal
amounts. On the Sampo Group level these amounts
have been eliminated.
Mandatum Group’s figures are not included in the
reconciliation tables for the comparative year 2023, as
Mandatum is reported as a disposal group held for
distribution to owners. 
FINANCIAL STATEMENTS 2024
191
Sampo Group - Insurance contract liabilities, gross at 31 December 2024 and 31 December 2023
2024
2023
Liabilities for remaining
coverage
Liabilities for incurred
claims
Liabilities for remaining
coverage
Liabilities for incurred
claims
EURm
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Opening balance
1,701
27
9,547
459
11,734
1,499
14
8,931
444
10,889
Acquisition cash flow asset
-18
—
11,716
10,889
Changes in the statement of comprehensive income
Insurance revenue
-9,450
—
—
—
-9,450
-8,417
—
—
—
-8,417
Insurance service expenses
Incurred claims and other insurance service expenses
—
—
6,847
186
7,032
—
—
6,503
154
6,657
Amortisation of insurance acquisition cash flows
262
—
—
—
262
223
—
—
—
223
Changes that relate to past service (LIC)
—
—
-174
-100
-274
—
—
-395
-145
-540
Changes that relate to future service (LRC)
—
-21
—
—
-21
—
12
—
—
12
Total insurance service expenses
262
-21
6,673
85
7,000
223
12
6,108
9
6,351
Insurance service result
-9,188
-21
6,673
85
-2,450
-8,195
12
6,108
9
-2,066
Insurance finance income or expense
—
—
307
—
307
—
—
529
—
529
Other items (including FX effects)
-62
0
24
11
-27
-185
0
91
4
-89
Total changes in the statement of comprehensive
income
-9,250
-21
7,004
97
-2,170
-8,379
12
6,728
13
-1,626
Cash flows during the period
Premiums received 
9,718
—
—
—
9,718
8,785
—
—
—
8,785
Claims and other insurance service expenses paid
—
—
-6,703
—
-6,703
—
—
-6,111
—
-6,111
Insurance acquisition cash flows paid
-283
—
—
—
-283
-221
—
—
—
-221
Total cash flows during the period
9,435
—
-6,703
—
2,732
8,564
—
-6,111
—
2,453
Transfer to other items in the balance sheet
—
—
—
—
—
17
—
—
1
18
Other
5
—
4
0
9
—
—
—
—
—
Closing balance - liabilities relating to insurance
contracts
1,891
6
9,853
557
12,305
1,701
27
9,547
459
11,734
Acquisition cash flow asset
-20
-18
Closing balance
12,286
11,716
FINANCIAL STATEMENTS 2024
192
Sampo Group - Reinsurance contracts at 31 December 2024 and 31 December 2023
2024
2023
Assets for
remaining
coverage
Assets for incurred claims
Assets for
remaining
coverage
Assets for incurred claims
EURm
Estimates of
present value
of future cash
flows
Risk
adjustment
for non-
financial risk
Total
Estimates of
present value
of future cash
flows
Risk
adjustment
for non-
financial risk
Total
Opening assets
258
1,803
220
2,282
221
1,384
215
1,820
Changes in the statement of comprehensive income
Allocation of reinsurance premiums paid
-909
—
—
-909
-1,005
—
—
-1,005
Amounts recoverable from reinsurers
Recoveries of incurred claims and other insurance service expenses
—
521
79
600
—
935
72
1,007
Adjustments to assets for incurred claims
0
21
-52
-31
0
-80
-70
-150
Effect of changes in non-performance risk of reinsurers
—
0
—
0
—
0
—
0
Net expenses from reinsurance contracts
-909
542
28
-340
-1,005
855
2
-148
Insurance finance income or expenses from reinsurance contracts
—
57
—
57
—
83
—
83
Effect of movements in exchange rates
-33
29
4
-1
-8
31
4
26
Reinsurance investment component
—
—
—
—
Total changes in the statement of comprehensive income
-943
628
31
-284
-1,014
969
6
-39
Investment component excluded from the net expenses from
reinsurance contracts
-216
216
—
—
Cash flows
Premiums paid
1,176
—
—
1,176
1,051
—
—
1,051
Amounts received
—
-556
—
-556
—
-550
—
-550
Total cash flows
1,176
-556
—
620
1,051
-550
—
501
Closing assets
276
2,090
252
2,618
258
1,803
220
2,282
FINANCIAL STATEMENTS 2024
193
If  - Insurance contract liabilities, gross at 31 December 2024 and 31 December 2023
2024
2023
Liabilities for remaining
coverage
Liabilities for incurred
claims
Liabilities for remaining
coverage
Liabilities for incurred
claims
EURm
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Opening balance - liabilities relating to insurance contracts
911
17
6,038
175
7,141
868
7
5,655
162
6,693
Acquisition cash flow asset
-7
—
7,134
6,693
Changes in the statement of comprehensive income
Insurance revenue
-5,680
—
—
—
-5,680
-5,330
—
—
—
-5,330
Insurance service expenses
Incurred claims and other insurance service expenses
—
—
4,060
65
4,125
—
—
3,924
58
3,981
Amortisation of insurance acquisition cash flows
107
—
—
—
107
100
—
—
—
100
Changes that relate to past service (LIC)
—
—
-191
-50
-241
—
—
-184
-43
-228
Changes that relate to future service (LRC)
—
-11
—
—
-11
—
10
—
—
10
Total insurance service expenses
107
-11
3,869
15
3,980
100
10
3,739
14
3,863
Insurance service result
-5,573
-11
3,869
15
-1,700
-5,230
10
3,739
14
-1,467
Insurance finance income or expense
—
—
208
—
208
—
—
340
—
340
Other items (including FX effects)
-5
-1
-104
-3
-112
-191
0
57
-2
-135
Total changes in the statement of comprehensive income
-5,579
-11
3,973
12
-1,605
-5,420
10
4,136
13
-1,261
Cash flows during the period
Premiums received 
5,694
—
—
—
5,694
5,572
—
—
—
5,572
Claims and other insurance service expenses paid
—
—
-4,052
—
-4,052
—
—
-3,754
—
-3,754
Insurance acquisition cash flows paid
-125
—
—
—
-125
-108
—
—
—
-108
Total cash flows during the period
5,569
—
-4,052
—
1,517
5,463
—
-3,754
—
1,710
Transfer to other items in the balance sheet
—
—
—
—
—
—
—
—
—
—
Other
5
—
4
—
9
—
—
—
—
—
Closing balance - liabilities relating to insurance contracts
906
6
5,962
188
7,062
911
17
6,038
175
7,141
Acquisition cash flow asset
-14
-7
Closing balance -
Insurance contract liabilities
7,049
7,134
As a consequence of Sampo plc’s partial demerger of Mandatum Holding Ltd in 2023, If Livförsäkring AB concluded an agreement on the transfer of parts of Mandatum’s life portfolio to If Livförsäkring AB.
The transfer was completed on 1 October 2024.
FINANCIAL STATEMENTS 2024
194
If  - Reinsurance contracts at 31 December 2024 and 31 December 2023
2024
2023
Assets for
remaining
coverage
Assets for incurred claims
Assets for
remaining
coverage
Assets for incurred claims
EURm
Estimates of
present value
of future cash
flows
Risk
adjustment
for non-
financial risk
Total
Estimates of
present value
of future cash
flows
Risk
adjustment
for non-
financial risk
Total
Opening assets
36
510
17
563
28
226
10
264
Changes in the statement of comprehensive income
Allocation of reinsurance premiums paid
-423
—
—
-423
-334
—
—
-334
Amounts recoverable from reinsurers
Recoveries of incurred claims and other insurance service
expenses
—
282
11
293
—
339
10
348
Adjustments to assets for incurred claims
—
30
-4
26
—
41
-3
38
Effect of changes in non-performance risk of reinsurers
—
0
—
0
—
0
—
0
Net expenses from reinsurance contracts
-423
312
6
-104
-334
380
7
52
Insurance finance income or expenses from reinsurance contracts
—
20
—
20
—
8
—
8
Effect of movements in exchange rates
1
-7
—
-6
-12
8
0
-4
Reinsurance investment component
—
—
—
—
Total changes in the statement of comprehensive income
-421
325
6
-90
-346
396
7
57
Investment component excluded from the net expenses from
reinsurance contracts
-25
25
—
—
Cash flows
Premiums paid
429
—
—
429
354
—
—
354
Amounts received
—
-223
—
-223
—
-112
—
-112
Total cash flows
429
-223
—
206
354
-112
—
242
Closing assets
20
636
23
679
36
510
17
563
FINANCIAL STATEMENTS 2024
195
Topdanmark - Insurance contract liabilities, gross at 31 December 2024 and 31 December 2023
2024
2023
Liabilities for remaining
coverage
Liabilities for incurred
claims
Liabilities for remaining
coverage
Liabilities for incurred
claims
EURm
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Opening balance - liabilities relating to insurance contracts
282
2
1,546
37
1,867
285
2
1,441
35
1,763
Acquisition cash flow asset
-12
—
1,855
1,763
Changes in the statement of comprehensive income
Insurance revenue
-1,560
—
—
—
-1,560
-1,369
—
—
—
-1,369
Insurance service expenses
Incurred claims and other insurance service expenses
—
—
1,287
39
1,326
—
—
1,093
15
1,108
Amortisation of insurance acquisition cash flows
29
—
—
—
29
31
—
—
—
31
Changes that relate to past service (LIC)
—
—
-31
-16
-47
—
—
-27
-16
-43
Changes that relate to future service (LRC)
—
-2
—
—
-2
—
1
—
—
1
Total insurance service expenses
29
-2
1,256
23
1,306
31
1
1,066
-1
1,097
Insurance service result
-1,530
-2
1,256
23
-253
-1,337
1
1,066
-1
-272
Insurance finance income or expense
—
—
32
—
32
—
—
81
—
81
Other items (including FX effects)
1
0
-1
1
1
0
0
-5
1
-4
Total changes in the statement of comprehensive income
-1,530
-2
1,287
25
-220
-1,337
1
1,142
0
-194
Cash flows during the period
Premiums received 
1,561
—
—
—
1,561
1,336
—
—
—
1,336
Claims and other insurance service expenses paid
—
—
-1,298
—
-1,298
—
—
-1,038
—
-1,038
Insurance acquisition cash flows paid
-29
—
—
—
-29
-18
—
—
—
-18
Total cash flows during the period
1,531
—
-1,298
—
234
1,318
—
-1,038
—
280
Transfer to other items in the balance sheet
—
—
—
—
—
17
—
—
1
18
Other
—
—
—
—
—
—
—
—
—
—
Closing balance - liabilities relating to insurance
contracts
284
0
1,535
61
1,881
282
2
1,546
37
1,867
Acquisition cash flow asset
-6
-12
Closing balance -
liabilities relating to insurance contracts
1,875
1,855
FINANCIAL STATEMENTS 2024
196
Topdanmark  - Reinsurance contracts at 31 December 2024 and 31 December 2023
2024
2023
Assets for
remaining
coverage
Assets for incurred claims
Assets for
remaining
coverage
Assets for incurred claims
EURm
Estimates of
present value
of future
cash flows
Risk
adjustment
for non-
financial risk
Total
Estimates of
present value
of future
cash flows
Risk
adjustment
for non-
financial risk
Total
Opening assets
-1
78
1
79
-2
80
1
79
Changes in the statement of comprehensive income
Allocation of reinsurance premiums paid
-90
—
—
-90
-80
—
—
-80
Amounts recoverable from reinsurers
Recoveries of incurred claims and other insurance service
expenses
—
44
2
46
—
49
—
49
Adjustments to assets for incurred claims
—
2
-1
1
—
1
0
1
Effect of changes in non-performance risk of reinsurers
—
—
—
—
—
—
—
—
Net expenses from reinsurance contracts
-90
46
1
-43
-80
49
0
-31
Insurance finance income or expenses from reinsurance contracts
—
1
—
1
—
2
—
2
Effect of movements in exchange rates
—
—
—
0
0
0
0
0
Reinsurance investment component
—
—
—
—
Total changes in the statement of comprehensive income
-90
47
1
-42
-80
51
0
-29
Investment component excluded from the net expenses from
reinsurance contracts
—
—
—
—
Cash flows
Premiums paid
90
—
—
90
82
—
—
82
Amounts received
—
-54
—
-54
—
-54
—
-54
Total cash flows
90
-54
—
36
82
-54
—
28
Closing assets
-1
72
2
73
-1
78
1
79
FINANCIAL STATEMENTS 2024
197
Hastings - Insurance contract liabilities, gross at 31 December 2024 and 31 December 2023
2024
2023
Liabilities for remaining
coverage
Liabilities for incurred
claims
Liabilities for remaining
coverage
Liabilities for incurred
claims
EURm
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Excluding
loss
component
Loss
component
Estimates
of present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
Opening balance - liabilities relating to insurance contracts
508
7
1,964
247
2,726
347
5
1,835
247
2,434
Acquisition cash flow asset
—
—
2,726
2,434
Changes in the statement of profit or loss
Insurance revenue
-2,234
—
—
—
-2,234
-1,719
—
—
—
-1,719
Insurance service expenses
Incurred claims and other insurance service expenses
—
—
1,517
84
1,601
—
—
1,486
81
1,568
Amortisation of insurance acquisition cash flows
125
—
—
—
125
92
—
—
—
92
Changes that relate to past service (LIC)
—
—
48
-34
14
—
—
-184
-86
-269
Changes that relate to future service (LRC)
—
-8
—
—
-8
—
2
—
—
2
Total insurance service expenses
125
-8
1,566
50
1,733
92
2
1,303
-4
1,391
Insurance service result
-2,109
-8
1,566
50
-501
-1,628
2
1,303
-4
-328
Insurance finance income or expense
—
—
67
—
67
—
—
108
—
108
Other items (including FX effects)
-20
0
129
13
122
6
0
39
5
50
Total changes in the statement of profit or loss
-2,129
-7
1,762
63
-312
-1,622
2
1,449
1
-170
Cash flows during the period
Premiums received 
2,463
—
—
—
2,463
1,877
—
—
—
1,877
Claims and other insurance service expenses paid
—
—
-1,353
—
-1,353
—
—
-1,320
—
-1,320
Insurance acquisition cash flows paid
-129
—
—
—
-129
-95
—
—
—
-95
Total cash flows during the period
2,334
—
-1,353
—
981
1,782
—
-1,320
—
462
Transfer to other items in the balance sheet
—
—
—
—
—
—
—
—
—
—
Other
—
—
—
—
—
—
—
—
—
—
Closing balance - liabilities relating to insurance contracts
713
0
2,373
310
3,396
508
7
1,964
247
2,726
Closing balance -
liabilities relating to insurance contracts
3,396
2,726
FINANCIAL STATEMENTS 2024
198
Hastings - Reinsurance contracts at 31 December 2024 and 31 December 2023
2024
2023
Assets for
remaining
coverage
Assets for incurred claims
Assets for
remaining
coverage
Assets for incurred claims
EURm
Estimates of
present value
of future cash
flows
Risk
adjustment
for non-
financial risk
Total
Estimates of
present value
of future cash
flows
Risk
adjustment
for non-
financial risk
Total
Opening assets
223
1,215
202
1,640
195
1,078
203
1,477
Changes in the statement of comprehensive income
Allocation of reinsurance premiums paid
-420
—
—
-420
-591
—
—
-591
Amounts recoverable from reinsurers
Recoveries of incurred claims and other insurance service
expenses
—
181
63
245
—
548
62
610
Adjustments to assets for incurred claims
0
-11
-46
-57
0
-121
-67
-188
Effect of changes in non-performance risk of reinsurers
—
—
—
—
—
—
—
—
Net expenses from reinsurance contracts
-420
170
17
-232
-591
426
-5
-170
Insurance finance income or expenses from reinsurance
contracts
—
36
—
36
—
73
—
73
Effect of movements in exchange rates
2
63
10
75
4
22
4
30
Total changes in the statement of comprehensive income
-418
269
27
-122
-588
521
-1
-68
Investment component excluded from the net expenses from
reinsurance contracts
-191
191
—
—
Cash flows
Premiums paid
657
—
—
657
615
—
—
615
Amounts received
—
-279
—
-279
—
-384
—
-384
Total cash flows
657
-279
—
378
615
-384
—
231
Closing assets
270
1,396
229
1,896
223
1,215
202
1,640
FINANCIAL STATEMENTS 2024
199
20 Assets for insurance acquisition
cash flows
The table presents the reconciliation from opening to closing balances of the carrying
amount of the acquisition cash flow asset during the reporting periods. 
EURm
2024
2023
Reconciliation of acquisition cash flow asset
At 1 January
18
10
Cash flows recognised as an asset
32
36
Amounts transferred to liability for remaining coverage
-30
-28
At 31 December
20
18
The following table presents the expected timing of when the acquisition cash flow
asset will be derecognised and instead be included in the liability for remaining
coverage of the group of insurance contracts to which they are allocated.
Time bands: Assets for insurance acquisition cash flows
2024
Expected timing of derecognition
EURm
2025
2026-2027
2028-2029
2030-
Total
Acquisition cash flow
asset
7
6
1
5
20
2023
Expected timing of derecognition
EURm
2024
2025-2026
2027-2028
Total
Acquisition cash flow asset
12
4
2
18
21 Non-life claims development
Prior-year estimates of the claims expense for individual claims years also represent a
measure of Sampo Group’s and its reporting segment’s ability to foresee final claims
expenses. The following tables present the expense trend for the claims for individual
claims for the past ten years, before and after reinsurance. For earlier years, the
information is aggregated into one row. The information is presented at the Sampo
Group level and at the reporting segment level.
The upper part of the table shows how an estimate of the total claims expense per
accident year evolves annually in relation to the undiscounted fulfilment cash flows (i.e.
consisting of both best estimate and risk adjustment). The lower section shows how
large a share of this is presented in the balance sheet. More information on insurance
liabilities can be found in the risk management note 34.
Since Sampo Group’s group companies have operations in various countries, their
portfolios are exposed to a number of currencies. To adjust for currency effects, the
local reporting currency has been translated to EUR at the closing rate on 31 December
2024. Consequently, the table is not directly comparable with the corresponding tables
reported in previous years, since all accident years include translated information and
amounts are always translated with the closing balance sheet rates of the financial
year. The table is not directly comparable with the income statement either where
average rates throughout the year are applied, and since the effect is partially
presented in claims incurred and partially within insurance finance income or expense
when relating to changes in indexation of annuities.
FINANCIAL STATEMENTS 2024
200
Sampo Group - Claims development before reinsurance
EURm
Claims expense, gross
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
3,917
4,034
4,129
4,344
4,529
4,531
4,760
5,321
6,342
6,491
one year later
3,937
4,049
4,136
4,429
4,591
4,574
4,916
5,427
6,403
two years later
3,914
4,015
4,120
4,495
4,642
4,650
4,986
5,426
three years later
3,896
3,985
4,164
4,556
4,747
4,658
4,975
four years later
3,843
3,924
4,118
4,560
4,710
4,696
five years later
3,832
4,012
4,137
4,530
4,719
six years later
3,812
3,988
4,106
4,543
seven years later
3,835
3,986
4,142
eight years later
3,803
3,943
nine years later
3,744
ten years later
Current estimate of total claims expense
3,777
3,930
4,100
4,486
4,606
4,515
4,844
5,372
6,430
6,491
Total disbursed
2,469
2,308
2,301
2,526
2,581
2,787
2,700
2,672
2,833
1,963
Liability (gross) reported in the balance
sheet
184
252
289
351
417
504
781
1,109
1,933
3,245
9,066
Liability (gross) relating to prior years
2,859
Discounting effect, gross
-2,120
Liability for claims handling expenses and
other items
624
Elimination
-20
Total liability for incurred claims
10,409
FINANCIAL STATEMENTS 2024
201
Sampo Group - Claims development after reinsurance
EURm
Claims expense, net of reinsurance
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
3,779
3,807
3,929
4,191
4,327
4,244
4,374
4,925
5,529
5,868
one year later
3,797
3,822
3,969
4,258
4,362
4,239
4,465
4,982
5,567
two years later
3,766
3,803
3,949
4,302
4,388
4,270
4,456
4,959
three years later
3,748
3,758
3,968
4,341
4,453
4,295
4,472
four years later
3,692
3,713
3,915
4,334
4,435
4,338
five years later
3,672
3,714
3,930
4,302
4,459
six years later
3,655
3,705
3,902
4,308
seven years later
3,667
3,672
3,916
eight years later
3,634
3,658
nine years later
3,608
ten years later
Current estimate of total claims expense
3,644
3,570
3,698
4,009
4,080
4,030
4,135
4,463
4,929
5,193
Total disbursed
2,435
2,250
2,282
2,419
2,497
2,515
2,475
2,494
2,558
1,861
Liability (net) reported in the balance
sheet
170
171
209
302
306
355
515
761
1,202
2,513
6,504
Liability (net) relating to prior years
2,678
Discounting effect, gross
-1,594
Liability for claims handling expenses
482
Risk of non-performance by reinsurer
1
Elimination
-4
Total liability for incurred claims
8,067
FINANCIAL STATEMENTS 2024
202
If - Claims development before reinsurance
EURm
Claims expense, gross
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
2,515
2,474
2,546
2,678
2,797
2,927
2,917
3,157
3,775
3,921
one year later
2,529
2,505
2,582
2,768
2,839
2,962
3,066
3,273
3,870
two years later
2,513
2,499
2,569
2,796
2,851
3,006
3,049
3,223
three years later
2,487
2,456
2,572
2,812
2,896
2,978
2,997
four years later
2,456
2,443
2,543
2,830
2,887
2,938
five years later
2,450
2,452
2,552
2,799
2,846
six years later
2,435
2,457
2,527
2,790
seven years later
2,445
2,427
2,504
eight years later
2,425
2,411
nine years later
2,413
ten years later
Current estimate of total claims expense
2,413
2,411
2,504
2,790
2,846
2,938
2,997
3,223
3,870
3,921
Total disbursed
2,279
2,270
2,361
2,577
2,646
2,694
2,654
2,759
2,943
2,005
Liability (gross) reported in the balance
sheet
134
141
143
212
200
244
343
464
927
1,916
4,725
Liability (gross) relating to prior years
2,332
Discounting effect, gross
-1,374
Liability for claims handling expenses
467
Total liability for incurred claims
6,150
FINANCIAL STATEMENTS 2024
203
If - Claims development after reinsurance
EURm
Claims expense, net of reinsurance
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
2,479
2,423
2,491
2,628
2,739
2,757
2,797
3,074
3,424
3,627
one year later
2,490
2,433
2,532
2,702
2,771
2,774
2,914
3,163
3,486
two years later
2,471
2,426
2,515
2,729
2,780
2,818
2,879
3,116
three years later
2,454
2,390
2,518
2,747
2,826
2,791
2,824
four years later
2,421
2,378
2,490
2,761
2,820
2,750
five years later
2,414
2,382
2,509
2,731
2,777
six years later
2,400
2,388
2,484
2,721
seven years later
2,410
2,358
2,460
eight years later
2,391
2,343
nine years later
2,379
ten years later
Current estimate of total claims expense
2,379
2,343
2,460
2,721
2,777
2,750
2,824
3,116
3,486
3,627
Total disbursed
2,248
2,216
2,323
2,514
2,586
2,514
2,511
2,675
2,786
2,027
Liability (net) reported in the balance
sheet
131
127
138
207
191
236
313
442
700
1,600
4,083
Liability (net) relating to prior years
2,317
Discounting effect, gross
-1,345
Liability for claims handling expenses
434
Risk of non-performance by reinsurer
1
Total liability for incurred claims
5,491
FINANCIAL STATEMENTS 2024
204
Topdanmark - Claims development before reinsurance
EURm
Claims expense, gross
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
826
800
727
786
789
819
842
882
975
1,087
one year later
836
799
743
798
809
801
834
875
968
two years later
821
785
735
806
815
779
843
868
three years later
818
774
743
814
816
793
847
four years later
812
756
737
812
815
791
five years later
793
759
734
816
817
six years later
787
755
741
817
seven years later
795
756
740
eight years later
789
759
nine years later
788
ten years later
Current estimate of total claims expense
788
759
740
817
817
791
847
868
968
1,087
Total disbursed
752
723
695
753
739
705
727
709
722
600
Liability (gross) reported in the balance
sheet
36
36
45
64
78
86
120
159
246
487
1,357
Liability (gross) relating to prior years
352
Discounting effect, gross
-157
Other items
45
Total liability for incurred claims
1,596
FINANCIAL STATEMENTS 2024
205
Topdanmark - Claims development after reinsurance
EURm
Claims expense, net of reinsurance
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
776
742
703
735
756
782
785
837
925
1,042
one year later
783
745
716
746
773
764
777
830
919
two years later
770
731
707
754
780
743
784
823
three years later
767
719
716
761
781
757
787
four years later
756
701
710
759
778
756
five years later
746
700
707
763
779
six years later
742
698
714
763
seven years later
750
700
713
eight years later
744
702
nine years later
741
ten years later
Current estimate of total claims expense
741
702
713
763
779
756
787
823
919
1,042
Total disbursed
707
667
668
701
703
671
671
669
685
581
Liability (net) reported in the balance
sheet
34
35
45
63
76
85
116
154
234
461
1,303
Liability (net) relating to prior years
351
Discounting effect, gross
-155
Liability for claims handling expenses
24
Total liability for incurred claims
1,523
FINANCIAL STATEMENTS 2024
206
Hastings - Claims development before reinsurance
EURm
Claims expense, gross
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
576
760
856
880
943
786
1,000
1,282
1,591
1,483
one year later
573
744
811
863
943
811
1,016
1,279
1,564
two years later
581
730
817
893
976
865
1,094
1,336
three years later
591
755
849
930
1,035
888
1,131
four years later
574
724
838
918
1,008
967
five years later
590
800
851
915
1,056
six years later
590
776
838
936
seven years later
595
802
898
eight years later
589
774
nine years later
543
ten years later
Current estimate of total claims expense
576
760
856
880
943
786
1,000
1,282
1,591
1,483
Total disbursed
-562
-685
-754
-805
-804
-612
-681
-795
-832
-641
Liability (gross) reported in the balance
sheet
14
75
101
75
139
174
318
486
759
842
2,985
Liability (gross) relating to prior years
176
Discounting effect, gross
-589
Liability for claims handling expenses
112
Total liability for incurred claims
2,683
FINANCIAL STATEMENTS 2024
207
Hastings - Claims development after reinsurance
EURm
Claims expense, net of reinsurance
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
Estimated claims expense
at the close of the claims year
524
642
735
828
832
706
792
1,014
1,180
1,199
one year later
523
643
721
810
818
701
774
989
1,162
two years later
525
646
728
819
828
709
792
1,020
three years later
527
648
734
833
846
746
861
four years later
516
634
716
814
837
832
five years later
512
631
714
808
904
six years later
513
620
704
824
seven years later
506
614
742
eight years later
499
613
nine years later
488
ten years later
Current estimate of total claims expense
524
524
524
524
524
524
524
524
524
524
Total disbursed
-520
-633
-709
-796
-792
-671
-706
-849
-912
-747
Liability (net) reported in the balance
sheet
5
9
26
32
40
35
86
165
268
453
1,118
Liability (net) relating to prior years
10
Discounting effect, gross
-93
Liability for claims handling expenses
24
Total liability for incurred claims
1,058
FINANCIAL STATEMENTS 2024
208
22 Financial liabilities
Group
EURm
12/2024
12/2023
Subordinated debt liabilities
Subordinated loans
1,642
1,645
Total subordinated debt liabilities
1,642
1,645
Other financial liabilities
Derivative financial instruments
88
116
Financial liabilities measured at amortised cost
Debt securities in issue
954
959
Amounts owed to credit institutions
353
194
Total financial liabilities measured at amortised cost
1,307
1,153
Total other financial liabilities
1,395
1,269
Total financial liabilities
3,036
2,914
The segment financial liabilities include subordinated debts, derivatives, debt securities
in issue, and other financial liabilities.
If
EURm
12/2024
12/2023
Subordinated debt securities
Subordinated loans
Maturity
Interest
Subordinated loan, 2021
(nominal value SEKm 1,500)
30 years
3 month
Stibor
+ 1.30%
131
135
Total subordinated debt securities
131
135
Other financial liabilities
Derivative financial instruments
19
58
Total financial liabilities
150
193
The loan of 2021 was issued with floating interest rate terms. The loan includes terms
stating the right of redemption after five years, at any date for a three-month period
after the first five years and thereafter at any interest payment date. The loan is listed
on the Luxembourg Stock Exchange (BdL Market).
FINANCIAL STATEMENTS 2024
209
Topdanmark
EURm
12/2024
12/2023
Subordinated debt securities
Subordinated loans
Maturity
Interest
Subordinated loan tier 1, 2022
(nominal value DKKm 400)
perpetual
3 month Cibor
+ 4.75 %
54
54
Subordinated loan, 2021
(nominal value DKKm 700)
12/2031
3 month Cibor
+ 1.25 %
94
94
Total subordinated debt securities
147
148
Other financial liabilities
Derivative financial instruments
43
36
Amounts owed to credit institutions
—
9
Total financial liabilities
191
193
Subordinated loans are wholly included in Topdanmark’s own funds. Approximately
EUR 127 million (127) (DKK 950 million) of the subordinated loans are subscribed by If.
Hastings
EURm
12/2024
12/2023
Other financial liabilities
Derivative financial instruments
1
2
Amounts owed to credit institutions
353
184
Total financial liabilities
353
186
Hastings has a revolving credit facility with a financial institution, totalling EUR 103
million (98), of which EUR 39 million (56) was undrawn at the end of the reporting
period. The revolving credit facility matures on 20 December 2026, after which the
contract has an extension option of two more years.
Related to the RCF above,  the applicable covenants for Hastings are leverage ratio
and interest cover, and the related carrying amount of the liability would be EUR 63
million. There are no facts or circumstances that would indicate that Hastings may
have difficulty with complying with the covenants, or that Hastings would not have
complied with the covenants if they were assessed for compliance based on Hastings
circumstances at 31 December 2024.
Hastings also has a securitisation facility arrangement with a financial institution to
refinance the acquisition of loans totalling EUR 332 million (201), of which EUR 42
million (58) was undrawn at the end of reporting period. The arrangement ends in
November 2027. 
Hastings has an undrawn credit facility also with Sampo plc, totalling EUR 90 million
with a maturity date of 29 October 2026.
FINANCIAL STATEMENTS 2024
210
Holding
EURm
12/2024
12/2023
Subordinated debt securities
Subordinated loans
Maturity
Interest
Subordinated loan, 2020 (nominal
value EURm 1,000)
32 years
2.50 %
994
993
Subordinated loan, 2019 (nominal
value EURm 500)
30 years
3.38 %
497
496
Total subordinated debt securities
1,491
1,490
Other financial liabilities
Derivative financial instruments
25
20
Debt securities in issue
Maturity
Interest
Bond 2017, (nominal value EURm 500)
8 years
1.25 %
162
162
Bond 2018, (nominal value EURm 500)
10 years
1.625 %
312
311
Bond 2018, (nominal value EURm 500)
12 years
2.25 %
395
395
Bond 2018, (nominal value NOKm 1,000)
10 years
3.10 %
85
89
Other
2
Total bonds
954
959
Total financial liabilities
2,470
2,469
The subordinated loan of 2019 has a fixed interest rate for the first ten years, and the
2020 loan for the first 12 years. After that, the loans become subject to a variable
interest rate, but they also include terms stating the right of redemption at this point in
time or at any interest payment date thereafter. The loans are listed on the London
Stock Exchange.
The determination and hierarchy of fair values of financial assets and liabilities
measured at acquisition cost is disclosed in note 13. According to this determination,
the subordinated debt securities and bonds are categorised either on level 1 or 2.
Eliminations between segments
EURm
12/2024
12/2023
Eliminations between segments
-127
-127
Group financial liabilities total
3,036
2,914
Change in liabilities from financing activities
EURm
1
January
2024
Incoming
cash
flows
Outgoing
cash
flows
Exchange
differences
Other
31
December
2024
Subordinated debt
1,645
—
—
-3
—
1,642
Bonds
959
—
-2
-3
—
954
Other loans
194
194
-48
13
—
353
Total
2,798
194
-50
7
—
2,948
EURm
1
January
2023
Incoming
cash
flows
Outgoing
cash
flows
Exchange
differences
Other
31
December
2023
Subordinated debt
1,983
—
-87
-3
-248
1,645
Bonds
1,306
—
-340
-7
—
959
Other loans
96
143
-46
2
—
194
Total
3,384
143
-473
-8
-248
2,798
Item Other for the reporting period 2023 is mainly related to the separation of
Mandatum.
FINANCIAL STATEMENTS 2024
211
23 Other liabilities
EURm
12/2024
12/2023
Liabilities arising out of direct insurance operations
176
227
Liabilities arising out of reinsurance operations
126
69
Settlement liabilities
90
5
Provisions
174
6
Interests
29
29
Tax liabilities
14
2
Lease liabilities
134
160
Employee benefit liability
21
21
Prepayments and accrued income
265
241
Other
535
581
Total other liabilities
1,562
1,342
Item Other includes, e.g. premium taxes of EUR 148 million (164), liabilities related with
patient insurance pool of EUR 54 million (64), and other tax liabilities and employee
withholding taxes.
The non-current share of other liabilities is EUR 96 million (82).
Leases
The total effect of leases on the statement of cash flows was EUR -36 million (-33).
Non-cash flow additions from IFRS 16 leases to the balance sheet items were EUR 12
million (15).
EURm
1-12/2024
1-12/2023
Items recognised in the p/l from lease liabilities
Interest expenses
-2
-2
Expenses from short-term and low-value lease liabilities
-4
-4
Provisions
EURm
2024
At 1 January
6
Reclassification of Topdanmark's provision
27
Provisions utilized during the financial year
-9
Provisions added during the fiscal year
151
Translation difference
-1
At 31 December
174
In connection with the acquisition and the integration of Topdanmark into If Group, a
restructuring reserve amounting to EUR 149 million was recognised. The costs relate
mainly to redundancies, decommissioning, and sunsetting of systems, as well as
rebranding.
Other restructuring provisions consist of funds amounting to EUR 13 million reserved
for future expenses attributable to previously implemented or planned future
organisational changes including expenses related to the separation of Topdanmark
Liv Holding Group (now Nordea Pension Holding Danmark A/S) to Nordea.
In addition, provisions for employer contributions reserved for commitments
attributable to endowment policies and other uncertain liabilities are also included in
the total amount of the provisions.
The non-current share of provisions is EUR 73 million.
FINANCIAL STATEMENTS 2024
212
24 Employee benefits
Employee benefit obligations
Sampo Group’s subsidiary, If, had defined benefit plans in Sweden and Norway during
the financial year 2024.
If applies IAS 19 Employee Benefits and recognizes defined-benefit pension plans in
Sweden and Norway. Other pension plans existing in the Group have either been
classified as defined-contribution plans or have been classified as defined-benefit
plans, but recognized as defined-contribution plans. This occurs because If lacks the
information necessary to recognize them as defined-benefit plans, or they have been
deemed as insignificant.
For the defined-contribution pension plans, If pays fixed contributions and has no
further payment obligations once the contributions have been paid. The pension
expense for the defined-contribution plans is equal to the premiums paid by If for the
financial year.
Employee benefit obligations of If
EURm
2024
2023
Defined benefit pension obligations, including social costs
217
209
Fair value of plan assets
232
220
Net liability (asset) recognised in the balance sheet
-15
-11
of which recognised as Net pension assets in Other assets
36
32
of which recognised as Net pension liabilities in Other liabilities
21
21
The Swedish defined-benefit pension plan, FTP2, is a multiemployer plan and is closed
to new employees born in 1972 or later. In Norway, there are a few smaller pension
plans, mainly unfunded pension plans, for which If is responsible for ongoing payments.
These include a small number of pension obligations on salary above 12G (G= National
Insurance basic amount) or individual pension agreements.
A common feature of the defined-benefit plans is that the employees and survivors
encompassed by the plans are entitled to a guaranteed pension that depends on the
employees’ service period and pensionable salary at the time of retirement. The
dominating benefit is the old-age pension, referring to a life-long pension after the
anticipated retirement age.
The anticipated retirement age for Sweden, in connection with life-long pension, is 65
years. Life-long old-age pension following a complete service period is payable at a
rate of 10% of the pensionable salary between 0 and 7.5 income base amounts, 65% of
salary between 7.5 and 20 income base amounts and 32.5% between 20 and 30
income base amounts. Paid-up policies and pension payments from the Swedish plans
are normally indexed annually, with an amount corresponding to the change in the
consumer price index. However, there is no agreement guaranteeing the value and
future supplements, in addition to the contractual pension benefit, which could either
rise or fall.
The pensions in Sweden are primarily funded through insurance, whereby the insurer
establishes the premiums and disburse the benefits. If’s obligation is primarily fulfilled
through payment of the premiums. Should the assets that are attributable to the
pension benefits not be sufficient to enable the insurer to cover the guaranteed
pension benefits, If could be forced to pay supplementary insurance premiums or
secure the pension obligations in some other way. However, given the insurer’s high
consolidation ratio, the risk that If will be forced to take any such action is low.
To cover the insured pension benefits in Sweden, as well as for a small plan in Norway,
the related capital is managed as part of the insurers’ management portfolios. New and
existing asset categories are evaluated on an ongoing basis in order to diversify the
asset portfolios, with a view to optimize the anticipated risk-adjusted return. Any
surplus that arises from management of the assets normally accrues to If and/or the
insured, and there is no form of transfer of the asset value to other members of the
insurance collective.
The insurers and If are jointly responsible for monitoring the pension plans, including
investment decisions and contributions. The pension plans are essentially exposed to
similar material risks regarding the final amount of the benefits, longevity, the
investment risk associated with the plan assets, and the fact that the choice of the
discount interest rate affects the valuation in the financial statements.
FINANCIAL STATEMENTS 2024
213
When applying IAS 19, the pension obligation and the pension cost attributed to the
fiscal period are calculated annually, using the Projected Unit Credit method. The
calculation of the defined benefit obligation is based on future expected pension
payments and includes yearly updated actuarial assumptions, such as salary growth,
inflation, mortality and employee turnover. The expected pension payments are then
discounted to a present value, using a discount rate set with reference to AAA and AA
corporate bonds issued in local currency, including mortgage-backed bonds, as of
mid- December. The discount rates chosen in Sweden and Norway take into account
the duration of the company’s pension obligations in each respective country. After a
deduction for the plan assets, a net asset or a net liability is recognized in the balance
sheet.
The following tables contain a number of material assumptions, specifications of
pension costs, assets and liabilities, and a sensitivity analysis showing the potential
effect on the obligations of reasonable changes in those assumptions, as of the end of
the fiscal year.
The carrying amounts have been stated, including special payroll tax in Sweden
(24.26%) and a corresponding fee in Norway (14.1%-19.1%).
Specification of employee benefit obligations by country
2024
2023
EURm
Sweden
Norway
Total
Sweden
Norway
Total
Recognised in income statement and other comprehensive income
Current service cost
2
0
3
3
0
3
Total defined benefit pensions costs in insurance service result
2
0
3
3
0
3
Interest expense on net pension liability
-1
1
-1
-1
1
-1
Remeasurement of the net pension liability
-1
1
0
6
0
6
Total net cost (income) in comprehensive income statement
0
2
2
8
1
8
Recognised in balance sheet
Defined benefit pension obligations, including social costs
194
22
217
186
23
209
Fair value of plan assets
230
1
232
218
2
220
Net liability (net assets) recognised in balance sheet
-36
21
-15
-32
21
-11
Distribution by asset class
Bonds
41%
—
42%
—
Equities
22%
—
20%
—
Properties
9%
—
10%
—
Other
28%
—
28%
—
FINANCIAL STATEMENTS 2024
214
The following actuarial assumptions have been used for the calculation of defined benefit pension plans in Norway and Sweden:
Sweden
Sweden
Norway
Norway
31 Dec 2024
31 Dec 2023
31 Dec 2024
31 Dec 2023
Discount rate
3.25%
3.50%
4.00%
3.75%
Future salary increases
3.00%
3.00%
3.25%
3.25%
Price inflation
2.00%
2.00%
2.25%
2.25%
Mortality table
DUS23
DUS23
K2013
K2013
Average duration of pension liabilities
17 years
17 years
11 years
11 years
Expected contributions to the defined benefit plans during 2025 and 2024
5
6
-
-
2024
2023
Sensitivity analysis of effect of reasonably possible changes
Sweden
Norway
Total
Sweden
Norway
Total
Discount rate, +0.50%
-15
-1
-16
-15
-1
-15
Discount rate, -0.50%
17
1
18
16
1
17
Future salary increases, +0.25%
3
0
4
4
0
4
Future salary increases, -0.25%
-3
0
-3
-3
0
-3
Expected longevity, +1 year
7
1
7
6
1
6
2024
2023
EURm
Funded plans
Unfunded plans
Total
Funded plans
Unfunded plans
Total
Distribution of obligations on funded and unfunded plans
Defined benefit pension obligations, including social costs
196
20
217
188
20
209
Fair value of plan assets
232
—
232
220
—
220
Net pension liability (net assets) recognised in the balance sheet
-36
20
-15
-31
20
-11
FINANCIAL STATEMENTS 2024
215
Analysis of the change in net liability recognised in the
balance sheet
EURm
2024
2023
Pension liabilities
At the beginning of the year
202
204
Current cost
2
3
Interest cost
7
7
Actuarial gains (-) / losses (+) on financial assumptions
7
—
Actuarial gains (-) / losses (+), experience adjustments
4
-3
Exchange differences on foreign plans
-7
-1
Benefits paid
-6
-7
Defined benefit pension obligations on Dec 31, excl. social
security costs
210
203
Social security costs
7
6
Defined benefit plans  on Dec 31, incl. social security costs
217
209
Reconciliation of plan assets
At the beginning of the year
220
220
Interest income
7
7
Difference between actual return and calculated interest income
11
-9
Contributions paid
5
5
Exchange differences on foreign plans
-7
0
Benefits paid
-5
-4
Plan assets at 31 December
232
220
Other short-term employee benefits
There are other short-term employee incentive programmes in the Group, the terms of
which vary according to country, business area, or company. Benefits are recognised in
the profit or loss for the year they arise. An estimated amount of these short-term
incentives, social security costs included, for 2024 is EUR 81 million.
FINANCIAL STATEMENTS 2024
216
25 Equity and reserves
Equity (1,000 shares)
12/2024
12/2023
Equity (1,000 shares)
538,248
501,797
The shares are divided into A and B classes, with the number of A shares being
179,000,000 at minimum and 711,200,000 at maximum, and the number of B shares
being 0 at minimum and 4,800,000 at maximum. Each A share entitles its holder to
one vote and each B share entitles its holder to five votes at a General Meeting of
Shareholders. The shares have no nominal value.
At the end of the financial year 2024, the number of A shares amounted to
538,047,772 and B shares to 200,000 shares.
Treasury shares (1,000 shares)
12/2024
12/2023
Own shares held by Sampo plc (1,000 shares)
—
—
Reserves and retained earnings
Legal reserve
The legal reserve comprises the amounts to be transferred from the distributable
equity, according to the Articles of Association or on the basis of the decision of the
AGM.
Reserve for invested unrestricted equity
The reserve includes other investments of equity nature, as well as the issue price of
shares, to the extent it is not recorded in the share capital by an express decision.
During the financial year 2024, the directed share issue of EUR 2,000 million to acquire
the non-controlling interests of Topdanmark was recognised in the reserve.
Other components of equity
Other components of equity include changes in exchange differences, derivatives used
for cash flow hedges, revaluation reserve and hedges of a net investment.
Changes in the reserves and retained earnings are presented in the Group’s statement
of changes in equity.
FINANCIAL STATEMENTS 2024
217
26 Incentive schemes
Sampo’s long-term incentive scheme 2020 I
The Board of Directors of Sampo plc has decided on the long-term incentive schemes
2020:1 for the key employees of Sampo Group. The Board of Directors of Sampo plc
has authorised the Group CEO to decide on the allocation of incentive units that are
used to determine the incentive reward. The Board decides on the number of incentive
units allocated to the Group CEO and the Group Executive Committee members. Some
90 persons in Sampo plc and If were included in the long-term incentive schemes at
the end of 2024.
The amount of the incentive reward is based on the share price development of the
Sampo A share and Sampo Group’s return on capital at risk (RoCaR). In addition, in
accordance with the terms updated in September 2023, the amount of the incentive
paid in 2024 was partly based on the share price development of Mandatum plc. The
value of one calculated incentive unit is the trade-weighted average price of the
Sampo A share (and for rewards paid in 2024, Mandatum share price) at the time
period specified in the terms of the incentive scheme, reduced by the dividend-
adjusted starting price. The starting price of the incentive schemes varies between
EUR 32.94–44.74. The maximum value of one incentive unit varies between EUR
52.64–64.44. The calculation of the incentive reward furthermore takes into account
the RoCaR. If the RoCaR is at least risk-free return + 5 per cent, the reward is paid out
in full. If the RoCaR is at least risk-free return + 3 per cent but less than risk-free return
+ 5 per cent, the payout is 50 per cent. If the RoCaR is below risk-free return + 3 per
cent, no incentive reward will be paid.
Each plan has three performance periods and incentive rewards are paid in cash in
three instalments. Identified staff shall buy Sampo A shares with 50 per cent of the
amount of the instalment after deducting income tax and other comparable charges.
The shares are subject to disposal restrictions for three years from the date when the
instalment was paid. A premature payment of the incentive reward may occur in the
event of changes in the Group structure. The fair value of the incentive schemes is
estimated by using the Black-Scholes pricing model.
2020:I
2020:I/2
2020:I/3
Terms approved*
5 Aug 2020
5 Aug 2020
5 Aug 2020
Granted  (1,000)  31 Dec 2021
3,815
220
—
Granted  (1,000)  31 Dec 2022
3,805
220
208
Granted  (1,000)  31 Dec 2023**
2,124
170
158
Granted  (1,000)  31 Dec 2024**
1,052
119
158
End of performance period I 30%
Q2-2023
Q2-2024
Q2-2025
End of performance period II  35%
Q2-2024
Q2-2025
Q2-2026
End of performance period III 35%
Q2-2025
Q2-2026
Q2-2027
Payment I 30%
09/2023
09/2024
09/2025
Payment II 35%
09/2024
09/2025
09/2026
Payment III 35%
09/2025
09/2026
09/2027
Price of Sampo A at terms approval date
EUR*
30.30
30.30
30.30
Starting price EUR***
32.94
43.49
44.74
Starting price adjusted with dividend and
Mandatum  EUR at 31 December 2024
18.11
30.36
35.71
Sampo A closing price EUR at 31
December 2024
39.38
Total intrinsic value, EURm
19
1
1
Total debt
21
Total cost for the financial period, EURm
(incl. social cost)
14
* Grant dates vary
** Without Mandatum
*** The trade-weighted average price of the Sampo A share during twenty-five trading days
commencing the day after Sampo plc’s publication of its Half-Year Financial Report in 2020.
FINANCIAL STATEMENTS 2024
218
Sampo’s long-term incentive scheme 2024
On 6 March 2024, the Board of Directors of Sampo plc decided to adopt a
performance-based long-term incentive scheme for the Group Executive Committee
(including the Group CEO) and other senior leaders and key employees of Sampo
Group.
The participants in LTI 2024 were granted 355,699 performance incentive units (out of
a maximum of 370,000). The performance incentive units have a three-year
performance period covering financial years 2024-2026, with subsequent deferral
periods according to the rules and regulations applicable to Sampo Group.
The reward is a cash-based compensation. According to the terms and conditions of
the scheme, identified staff must buy Sampo A shares with 50% of the net reward after
taxes and other comparable charges. The shares are subject to a formal disposal
restriction of three years from the date of payment, and the Board of Directors of
Sampo plc will perform a risk and compliance assessment before any shares are
released to participants.
To achieve a maximum reward from the LTI 2024, excellent financial and operational
performance is required. The performance assessment will be based on the following
performance criteria:
Relative total shareholder return: 25% of the reward is subject to the performance of
the Sampo A share’s relative TSR over the performance period against a peer group of
companies.
Adjusted absolute total shareholder return: 25% of the reward is subject to the
performance of the Sampo A share’s growth and combined dividends over the
performance period.
Underwriting profit growth: 40% of the reward is subject to the performance of
Sampo Group’s underwriting profit growth over the performance period.
Sustainability charter: 10% of the reward is subject to the performance of Sampo
Group’s work related to sustainability.
In addition, the performance incentive units are subject to Sampo A share price
movements over the performance period. The share price growth is capped at a
maximum increase to avoid excessive pay-outs and minimize risk.
The fair value of the scheme has been estimated using the Monte Carlo pricing model.
At the end of the period 76 persons were included in the scheme. The total cost for the
financial period and the liability of the scheme amounted to EUR 1 million.
Topdanmark’s incentive schemes
Long-term incentive programme
Topdanmark’s LTI programme for the Executive Board and other grade A and B+
managers is a revolving option- and/or phantom share units based long-term incentive
programme which entail that a fixed proportion, equivalent to 10 per cent of the salary, 
is paid in the form of share options according to a revolving option programme and/or
as phantom share units based on the development in the share price of Sampo plc’s A
shares.
Upon completion of Sampo’s compulsory acquisition of the remaining Topdanmark
shares in October 2024, the outstanding rights to Topdanmark shares under the LTI
programme have been converted. Instead of options with the right to receive
Topdanmark shares upon exercising of options, the LTI participants have received
phantom share units tied to the development in the share price of Sampo’s listed A
share which will be settled in cash when the phantom share units are exercised. When
converting LTI options under the LTI programme to phantom share units, the market
value of the LTI option was determined per the completion in accordance with the
Black-Scholes formula. Based on the calculated market value, the LTI participant has
been granted a number of phantom share units in Sampo per the Compulsory
Acquisition Date. The LTI participants are compensated for any negative tax effect in
consequence of the convertion into phantom share units.
The options and/or phantom share units are issued at the beginning of a financial year
and may not be exercised any earlier than subsequent to the publication of the first
interim results announced by Sampo three years after the options and/or phantom
share units were acquired. For phantom share units resulting from the conversion of
options under the LTI programme, the calculation is made from the original time of
granting of options.
At the end of the financial period, the liability of the scheme amounted to EUR 15
million.
FINANCIAL STATEMENTS 2024
219
Short-term incentive programme
Topdanmark’s STI programme is a cash and share and/or phantom share-based short-
term incentive programme which is tied up to the completion of a number of
predefined targets for each member of the programme. For the financial year 2024,
individual STI participant agreements have been entered with every member of the
Executive Board, other grade A managers as well as a group of other Material Risk
Takers.
STI bonus cannot exceed 40% of the employee’s fixed basic salary including pension.
As per the Compulsory Acquisition Date, the STI participant’s outstanding rights to
Topdanmark shares under the STI programme have been replaced by rights to
phantom shares tied to the development in the share price of Sampo’s listed A share
which will be settled in cash when the deferral and retention period expires.
The market value of the right to Topdanmark shares under the STI programme is
determined in accordance with the exchange ratio in connection with the share
exchange offer, thus the right to receive a Topdanmark share is replaced by the right
to receive 1.25 phantom shares based on the development in share price of Sampo
shares. The STI participants are compensated for any negative tax effect in
consequence of the convertion into phantom shares.
Payment of STI bonus is 50% cash payment at the time of allocation and 50% shares
and/or phantom shares based on the development in share price of Sampo’s A share.
For larger amounts (generally, more than DKK 750,000), 40% is paid as a cash amount
at the time of allocation, and 60% as shares and/or phantom shares. The number of
shares and/or phantom shares is calculated based on the average trade price of
Sampo’s listed A share four banking days after the announcement of Sampo’s annual
results.
Long-term incentive schemes of Hastings
The total charge for the share-based payments recognised in profit or loss during 2024
was EUR 29 million (7) with a share-based payment liability of EUR 36 million (8) held
at 31 December 2024.
Long-term incentive plan
Certain management personnel of Hastings Group participate in the Group’s Long-
Term Incentive Plan (’LTIP’), which is a cash settled scheme. Vesting is subject to a
three-year service period and the achievement of certain performance conditions. The
performance conditions for the LTIP are profit before tax and live customer policies.
Cash awards totalling EUR 15 million (13) were granted in 2024, and EUR 9 million (6)
of cash awards were forfeited. The expected life is the contractual life of the award
adjusted to reflect management’s best estimate of holder behaviour. There were cash
awards with a value of EUR 40 million (32) outstanding on 31 December 2024.
Restricted stock awards
Restricted Stock Awards are whereby certain individuals are granted cash awards
conditional upon their continued employment with the Group. The expected life is the
contractual life of the award adjusted to reflect management’s best estimate of holder
behaviour. During 2024, certain key management personnel were granted cash awards
with a value of EUR 0.6 million (0.7) conditional upon continued employment within
the Group. There were cash awards with a value of EUR 1.0 million (0.9) outstanding at
31 December 2024.
Capital appreciation plan
At the year end, 31 December 2021, certain key management personnel were invited to
participate in the Hastings Group’s Capital Appreciation Plan (’CAP’), under which they
may be awarded up to five free B Ordinary Shares in HGCL, for every B Ordinary Share
they purchase, subject to performance thresholds, based upon total shareholder return
(’TSR’). The total number of B Ordinary Shares purchased and allotted under the
scheme in 2024 was zero (-). Potential matching awards of B Ordinary Shares have the
potential to vest in two tranches, with 50% being conditional upon a TSR measured
over a four-year period, and 50% being conditional upon TSR measured over a five-
year period, with the number of awards dependent upon the level of return between a
minimum and maximum target. At the end of each performance period, one-half of
shares will vest immediately, and one half will be deferred for 12 months before
becoming exercisable. The vesting is dependent on continuing service by the
participant over the period of any deferment, ranging from three to six years.
The TSR measure for these awards is calculated using the Monte Carlo valuation
model. The fair value of the matching shares was EUR 4 million, or approximately EUR
4 per matching share.
FINANCIAL STATEMENTS 2024
220
27 Investments in subsidiaries
Name
Group holding
%
Carrying
amount
If P&C Insurance Holding Ltd
100
4,820 
If P&C Insurance Ltd
100
1,441 
If P&C Insurance AS
100
39 
Vertikal Helseassistanse AS
100
9 
Viking Assistance Group AS
100
80 
Topdanmark A/S
100
39 
Topdanmark Forsikring A/S
100
4,614 
Topdanmark EDB A/S
100
41 
Topdanmark BidCo A/S*
100
261 
Hastings Group (Consolidated) Ltd
100
2,611 
Hastings Group Holdings Limited
100
2,535 
Advantage Global Holdings Limited
100
1,518 
Advantage Insurance Company Limited
100
283 
Hastings Insurance Services Limited
100
537 
* Topdanmark BidCo A/S relates to the acquisition and holding of Oona Health A/S.
The table excludes dormant companies in Great Britain as well as property and housing companies
accounted for in the consolidated accounts, and other companies that are insignificant to the
consolidated financial statements.
Changes in subsidiary shares in 2024
Sampo acquired all the outstanding NCI shares in Topdanmark A/S through a public
exchange offer, followed by a compulsory acquisition during H2 in 2024. The shares
were then sold to If P&C Holding Ltd in November 2024. At the same time, a
shareholders’ contribution of EUR 2,934 million was made to If P&C Insurance Holding
Ltd by Sampo plc.
The carrying amounts of Hastings’ companies have changed mainly due to internal
restructuring in Hastings’ subgroup.
FINANCIAL STATEMENTS 2024
221
28 Acquisition of
Topdanmark’s non-
controlling interest
Background
On 17 June 2024, Sampo announced that Sampo and
Topdanmark had entered into a combination
agreement, based on which Sampo made  a
recommended best and final public exchange offer to
acquire all of the outstanding shares in Topdanmark not
already owned by Sampo. The offer period began on 9
August 2024 and expired on 9 September 2024. The
transaction was completed by the compulsory
acquisition of the remaining Topdanmark minority
shares on 25 October 2024. Topdanmark shares were
removed from trading on Nasdaq Copenhagen on 18
October 2024. For more detailed description of the
acquisition, please see sections Other developments.
Compensation to non-controlling interests
During the tender offer process, Sampo received
acceptances representing approximately 92.6 per cent
of the entire share capital and total number of voting
rights in Topdanmark, excluding Topdanmark’s treasury
shares. The Board resolved to issue 48,198,710 new
Sampo A shares to the Topdanmark non-controlling
shareholders and the subscription price for the new
class A shares was EUR 41.50 per share. The price was
determined based on the closing price of the Sampo
class A shares on Nasdaq Helsinki Ltd at the last full
trading day prior to the Sampo Board resolving upon
the directed issuance of shares. The share issue
amounting to EUR 2,000 million was recognised in the
invested unrestricted equity.
Following the completion of the tender process, Sampo
commenced a compulsory acquisition of the 6,613,865
Topdanmark shares held by the remaining non-
controlling shareholders of Topdanmark. The total
acquisition cost of the remaining minority shares
amounted to EUR 325 million. Compensation was paid
in cash.
Equity transaction
As the transaction with the non-controlling interest is
accounted for as an equity transaction in Sampo Group,
the compensation paid to the NCI for their shares in
Topdanmark A/S was recognised as a decrease in the
retained earnings, amounting to EUR 2,325 million. The
portion of the NCI’s share in equity, amounting to EUR
394 million, was allocated to the owners of the parent
company, and recognised as an increase in retained
earnings. The total decrease of retained earnings
amounted to EUR 1,931 million. As a result of the
acquisition, there were no accumulated balances at the
year end 2024. In the statement of profit or loss, the
NCI’s share of EUR 49 million was calculated as the
weighted average during the financial year.
The acquisition costs related to the equity transaction,
amounting to EUR 31 million, were accounted for as a
deduction from the equity. Therefore, the transaction
decreased Sampo Group’s total equity by EUR 356
million consisting of compensation paid in compulsory
acquisition of EUR 325 million and transaction costs of
EUR 31 million.
Valuation of Topdanmark A/S shares
The measurement of acquired Topdanmark A/S shares
was based on the compensation given as an exchange
of those shares. For Topdanmark’s shares acquired via
tender offer, the value of the acquired shares was
determined based on the value of Sampo’s shares
issued totalling EUR 2,000 million. For shares acquired
via the compulsory acquisition, the value of acquired
shares was determined based on the compensation
paid in cash totalling EUR 325 million. 
Sale of Topdanmark A/S shares to If P&C
Insurance Holding Ltd
On 1 November 2024, Sampo plc sold all the issued
shares in Topdanmark A/S to If P&C Insurance Holding
Ltd. The transaction was completed at arm’s length
basis. The sale price, based on the recent market value
of EUR 4,659 million, equivalent to approximately DKK
34.7 billion, was paid in full by way of a loan agreement
and a shareholder’s contribution between Sampo plc
and If P&C Insurance Holding Ltd. On 1 November, the
loan agreement, amounting to EUR 1,724 million,
consisted of EUR nominated facility of EUR 862 million
and DKK nominated facility of DKK 6,432 million
(approx. EUR 862 million). The remaining part of the
purchase price was paid by setting-off against
shareholder’s contribution amounting to SEK 34 029
million (approx. EUR 2,934 million) granted by Sampo
plc to If Holding. The shareholder’s contribution was
recognised as an increase in the carrying amount of If
Holding’s shares in Sampo plc’s balance sheet.
As the sale transaction of Topdanmark’s shares is an
intra-group transaction, all impacts, including the sales
gain of the shares, are eliminated at the Sampo Group
level. The intra-group sale of shares meets the definition
of a common control transaction as both If P&C
Insurance Holding Ltd and Topdanmark A/S are under
control of Sampo plc before and after the acquisition.
FINANCIAL STATEMENTS 2024
222
29 Related party disclosures
The related parties of Sampo Group include subsidiaries, associates and joint ventures.
In addition, related parties include, as mentioned below, key management personnel
and their related parties. The Group’s subsidiaries are included in note 27 . At the end
of the financial year, there were no significant associates in the Group.
All intra-group transactions and balances are eliminated upon consolidation. The
related party transactions disclosed in the note include transactions with related
parties that are not eliminated in the preparation of consolidated financial statements.
During the financial year, Sampo plc sold Topdanmark A/S shares to If Holding A/B.
Related to the sale, substantial internal transactions and financing arrangements were
formed between group entities. For further information, please see note 28. 
Transactions with related parties are on an arm’s length basis.
Key management personnel and their related parties
The key management personnel in Sampo Group consists of the members of the Board
of Directors of Sampo plc, the Chief Executive Officer (CEO) and Sampo Group’s
Executive Committee. Their related parties include close family members and the
entities over which the members of the key management personnel or their close
family members have control or significant influence.
Key management compensation
EURm
2024
2023
Short-term employee benefits
-8
-8
Post employment benefits
-4 
-3
Other long-term benefits
-8 
-6
Total
-20 
-17
Short-term employee benefits comprise salaries and other short-term benefits,
including profit-sharing bonuses accounted for the year, and social security costs.
Post-employment benefits include pension benefits under the Employees’ Pensions
Act (TyEL) in Finland and voluntary supplementary pension benefits.
Other long-term benefits consist of the benefits under long-term incentive schemes
accounted for the year (see note 26).
Related party transactions of the key management
The key management does not have any loans from the Group companies.
30 Discontinued operations
Mandatum Group’s business
Mandatum was a wholly owned direct subsidiary of Sampo plc until 1 October 2023
when it was separated from the Group in the partial demerger of Sampo plc. In the
comparative year, Mandatum Group was presented as a discontinued operation, in
accordance with IFRS 5 Non-current assets held for sale and discontinued operations,
until the demerger.
Result of discontinued operations
EURm
1-9/2023
Insurance revenue
255
Insurance service expenses
-213
Reinsurance result
-1
Insurance service result
41
Net investment result
658
Net finance income or expense from insurance contracts
-161
Net result from investment contracts
-369
Net financial result
127
Other income
22
Other expenses
-12
Finance expenses
-4
Profit before taxes
173
Income taxes
-33
Discontinued operations, net of tax
140
The profit from the discontinued operations is attributed entirely to the owners of the
parent company. Other comprehensive income did not include any items from the
discontinued operations.
The profit from discontinued operations in the consolidated income statement,
amounting to 251 million, included also the difference of 9 million from the
derecognition of the dividend liability, and 102 million from the recognition of a loan.
FINANCIAL STATEMENTS 2024
223
31 Business combinations
On 1 December 2023, Topdanmark acquired 100% of the shares of Oona Health A/S,
owner of Dansk Sundhedssikring A/S (DSS), PrimaCare A/S and DSS Hälsa AB. DSS is
an insurance company that offers health insurance to companies and private
individuals.
The purchase price included goodwill of EUR 237 million (DKK 1,770 million), related to
the unique business model and operational setup of DSS. Goodwill is not deductible for
income tax purposes. The following table summarises the consideration paid for Oona
Health, and the assets acquired and liabilities assumed at the acquisition date.
EURm
1 Dec 2023
Cash
257
Contingent consideration
12
Total purchase price
269
Acquisition related costs
5
Identified assets acquired and liabilities assumed
Financial assets
39
Cash and cash equivalents
8
Intangible asset
87
Other assets
11
Total assets
146
Insurance contract liabilities
18
Other liabilities
96
Total liabilities
114
Total identifiable net assets
31
Goodwill
237
Purchase price
269
In accordance with the purchase agreement Topdanmark A/S took over 97% of the
shares of Oona Health A/S at closing and will acquire the remaining 3% at a purchase
price which is variable and dependent on profit after tax in 2026.
On 1 November 2024, shares of Topdanmark A/S were sold to If Holding A/B. The
shares of Oona Health A/S were therefore transferred to If Group. For further
information, please see notes 27 and 28.
FINANCIAL STATEMENTS 2024
224
32 Contingent liabilities, commitments and
legal proceedings
EURm
12/2024
12/2023
Off-balance sheet items
Guarantees
9
9
Investment commitments
40
15
IT acquisitions
—
1
Other
2
2
Total
51
27
Assets pledged as collateral for liabilities or contingent liabilities
12/2024
12/2023
EURm
Assets
pledged
Liabilities/
commitments
Assets
pledged
Liabilities/
commitments
Assets pledged as collateral
Investment securities
403
294
408
293
Subsidiary shares
91
25
91
27
Cash and cash equivalents
66
43
63
36
Total
559
362
561
356
Assets pledged as security
for derivative contracts
Investment securities
—
9
Cash and cash equivalents
66
62
Assets pledged as security
for insurance undertakings
Investment securities
403
399
Assets pledged as security
for loans
Shares in subsidiaries
91
91
The pledged assets are included in the balance sheet item Financial assets, Other assets or Cash.
Policyholder's beneficiary rights
EURm
12/2024
12/2023
Assets covered by policyholders' beneficiary rights
9,748
10,034
Technical provisions, net
-6,021
-6,171
Surplus of registered securities
3,727
3,863
The assets are registered as assets covering technical provisions (Solvency II). In the
event of an insolvency situation, policyholders have a beneficiary right to assets
registered for coverage of technical provisions.
Other financial commitments
If
The subsidiary If P&C Insurance Ltd provides insurance with mutual undertakings
within several pools, such as  the Nordic Nuclear Insurance Pool, Norwegian Natural
Perils’ Pool and the Dutch Terror Pool.
In connection with the transfer of property and casualty insurance business from the
Skandia Group to the If Group as of March 1, 1999, If P&C Holding Ltd and If P&C
Insurance Ltd issued a guarantee for the benefit of Försäkringsaktiebolaget Skandia
(publ.), whereby the aforementioned companies in the If Group mutually guarantee
that companies in the Skandia group will be indemnified against any claims or actions
due to guarantees or similar commitments made by companies in the Skandia Group,
within the property and casualty insurance business transferred to the If Group.
If P&C Insurance Holding Ltd and If P&C Insurance Ltd have separately entered into
agreements with Försäkringsaktiebolaget Skandia (publ.) and Tryg-Baltica Forsikrings
AS, whereby Skandia and Tryg-Baltica will be indemnified against any claims
attributable to guarantees issued by Försäkrings-aktiebolaget Skandia (publ.) and
Vesta Forsikring AS, on behalf of Skandia Marine Insurance Company (U.K.) Ltd.
(renamed Marlon Insurance Company Ltd., company dissolved in July 2017) in favour
of the Institute of London Underwriters. Marlon was sold during 2007, and the
purchaser issued a guarantee in favour of the aforementioned companies in the If
Group for the full amount that they may be required to pay under these guarantees.
If P&C Insurance Company Ltd has outstanding commitments to private equity funds
totalling EUR 40 million, which is the maximum amount that the company has
committed to invest in the funds. Capital will be called to these funds over several
years as the funds make investments.
FINANCIAL STATEMENTS 2024
225
With respect to certain IT systems that If and Sampo
use jointly, If P&C Insurance Holding Ltd has undertaken
to indemnify Sampo for any costs caused by If that
Sampo may incur in relation to the owners of the
systems.
Topdanmark
Sampo Group’s Danish companies and Topdanmark
Group’s companies are jointly taxed, with Topdanmark
A/S being the management company. Pursuant to the
specific rules on corporation taxes etc. in the Danish
Companies Act, the companies are liable for the jointly
taxed companies and for any obligations to withhold
tax from interest, royalties and dividend for companies
concerned.
In connection with the implementation of a new
customer and core system, Topdanmark Forsikring A/S
has undertaken to provide support towards specific
suppliers to fulfil Topdanmark EDB IV ApS’ obligations
in accordance with the contracts.
Contingent liability
Hastings
Entities within Hastings Group are subject to review by
tax authorities in the UK and Gibraltar. The Hastings
Group commenced discussion with HMRC in December
2016 regarding aspects of its business model and the
allocation of certain elements of its profit between the
Group’s operating subsidiaries, Hastings Insurance
Services Limited (’HISL’) in the UK and Advantage
Insurance Company Limited (’AICL’) in Gibraltar. During
the year, management has engaged in correspondence
and meetings with HMRC. Management has reviewed
current and previous tax filings and considered the
nature of the ongoing enquiries, and does not consider
it appropriate to provide for any additional tax due.
Hastings Group provides for potential tax liabilities that
may arise on the basis of the amount expected to be
paid to the tax authorities, having taken into
consideration any ongoing enquiries or reviews and
based on guidance from professional firms. The final
amounts paid may differ from the amounts provided
depending on the ultimate resolution of such matters
and any changes to the estimates or amounts payable
in respect of prior periods are reported through
adjustments relating to prior periods. In the event that
the tax authorities do not ultimately accept the filed tax
position, it is possible that the Hastings Group will have
an additional tax liability. However the ongoing nature
of the enquiry means that it is inherently difficult to
predict a range of potential outcomes with certainty.
Based on the information received from HMRC to date,
management does not believe that it is probable that
any additional amounts will ultimately become payable.
Further information in respect of the enquiries has,
therefore, not been provided in accordance with IAS 37,
on the grounds it is not practicable to do so.
Topdanmark
In December 2022, Sampo plc´s subsidiary Topdanmark
Forsikring A/S sold Topdanmark Liv Holding A/S and all
its subsidiaries to Nordea Life Holding AB. On 1 May
2024, Topdanmark announced that Topdanmark
Forsikring A/S had entered into an agreement with
Nordea regarding the process for completion of the IT
separation of Topdanmark Liv Holding A/S (today
Nordea Pension Holding Danmark A/S).
As announced by Topdanmark in the first quarter of
2024, Nordea Group has reserved the right to raise
claims against Topdanmark Forsikring A/S for certain
potential losses. At present, it is not possible for
Topdanmark A/S to determine the size or existence of
the potential losses, and thus it is not possible to assess
whether they would constitute losses for which
Topdanmark Forsikring A/S may be held liable under
the signed Share Purchase Agreement (SPA). Currently,
there is no new information on the potential claims, and
thus the contingent liability remains.
Rental commitments
During the reporting period 2024, Sampo plc signed a
rental agreement on new office premises commencing
in June 2025. 
Legal proceedings
There are a number of legal proceedings against the
Group companies outstanding as of 31 December 2024,
arising in the ordinary course of business. The
companies estimate it unlikely that any significant loss
will arise from these proceedings.
FINANCIAL STATEMENTS 2024
226
33 Subsequent events after
the balance sheet date
Dividend proposal to the AGM
In the meeting on 6 February 2025, the Board of
Directors decided to propose, at the Annual General
Meeting on 23 April 2025, a divided distribution of EUR 
1.70 per share (totalling approx. EUR 915 million based
on the number the number of outstanding shares at the
balance sheet date). The dividends to be paid will be
accounted for in equity in 2025 as a deduction of
retained earnings.
Share split
On 5 February 2025, the Board of Directors of Sampo
plc resolved on a share split by way of a share issue
without consideration in proportion to shares owned by
shareholders. In the share split, Sampo issued four (4)
new A shares for each existing A share and four (4) new
B shares for each existing B share to shareholders in
proportion to their existing holdings on the record day
of the share issuance on 12 February 2025. In total,
2,152,191,088 new Sampo A shares and 800,000 new
Sampo B shares were issued. Following the registration
of the new shares, Sampo’s total share count amounts
to 2,691,238,860 shares.
The resolution was based on the authorisation granted
by Annual General Meeting held on 25 April 2024. The
share split does not require any action from
shareholders nor holders of Swedish depository
receipts. Further information is available at
www.sampo.com/sharesplit.
FINANCIAL STATEMENTS 2024
227
34 Risk Management
disclosure
Sampo Group business and risk
strategy
Sampo’s strategy is to create long-term value from its
non-life insurance operations. The Group’s focus within
non-life insurance is on the private and SME business in
the Nordic countries, and the digital distribution market
in the United Kingdom. Sampo Group is first and
foremost exposed to the general performance of the
Nordic economies. However, the Nordic economies
typically are at different stages of their economic cycles
at any given time, for reasons such as different
economic structures and separate currencies. Also,
geographically the Nordics as a large area is more a
source of underwriting diversification than
concentration. Hence, the Nordic area is inherently a
good basis for a diversified business. Geographic
diversification is also extended outside of the Nordics
into the United Kingdom and to a smaller extent the
Baltics.
To further maintain diversification of businesses, Sampo
Group proactively prevents concentrations, to the
extent possible, by segregating the duties of separate
business areas. Despite proactive strategic decisions on
segregation of duties, concentrations in underwriting
and investments may appear, and hence liabilities and
assets are monitored at the Group level to identify
potential concentrations at a single company or risk
factor level.
Underwriting and market risk concentrations, and their
management are described in the later sections, as well
as the parent company’s role as a risk manager of
group-wide risks and as a source of liquidity.
Sampo's risk management strategy is to:
• Ensure that risks affecting the profit and loss account
and the balance sheet are identified, assessed,
managed, monitored, and reported in all business
activities and at the Group level;
• Ensure cost-efficient customer business that is
soundly priced in terms of risks and adding value to
our clients;
• Ensure the overall efficiency and resilience of
operations;
• Ensure that risk buffers – in the form of capital and
foreseeable profitability – are adequate in relation to
the current risks inherent in business activities and the
existing market environment;
• Limit M&A transactions to bolt-ons in non-life
insurance within current markets;
• Dispose of non-strategic or otherwise unnecessary
balance sheet items and distribute the released
capital and reserves to the parent company as
appropriate; and
• Arrange its activities in ways that safeguard the
Group’s reputation, since in addition to the ability to
provide value-adding services for its clients and
sound capitalisation, the confidence of the clients and
other stakeholders is among the most significant
assets of Sampo Group.
Sampo Group risk management
system
The purpose of risk management is the creation and
protection of value. The risk management system is part
of the larger internal control system, and it integrates
risk management into the governance of the Group and 
its significant activities and functions, including decision
making. The risk management system comprises the
overall organisational structure, documented rules,
processes, and procedures, as well as resources to
identify, measure, or assess, contain, monitor, and
report on risk exposure and overall risk management. It
is supported by Sampo’s corporate governance system
and risk culture. It is built on the risk management
principles and the corresponding policies.
Effective management of risks
Effective risk management is carried out by way of the
risk management process, which involves the
systematic application of policies, procedures and
practices to the identifying, assessing, treating,
monitoring, measuring, and reporting risk:
• Identification of risks: The risks involved in business
operations and business environment, are monitored
continuously together with earnings potential. In
particular, when new services are launched or
business environment is changing, earnings potential
and risks including reputational risks shall be
thoroughly analysed.
• Assessment of capital need: The capital need to cover
measured risks, risk-based capital, is assessed and
analysed regularly by risk types and over risks and
business areas. In addition, management considers
the size of the buffers over risk-based capital to get
actual amount of capital.
• Pricing of risks: Sound pricing of customer
transactions and careful risk/return consideration of
investments is the prerequisite for achieving the
targeted financial performance and profitability over
time. In general, the starting points of insurance policy
pricing and investment decisions are (i) adequate
expected return on allocated capital and (ii) operating
costs.
• Managing risk exposures, capital positions, and
operational processes: The risks of insurance
liabilities, investment portfolios and operative
processes and capital positions are adjusted to
maintain a sound risk-to-return ratio and return on
capital. 
FINANCIAL STATEMENTS 2024
228
• Measuring and reporting of risks: Results, risks,
profitability, and needed capitalisation are measured,
analysed, and reported by Finance and Risk
Management functions, which are independent from
business activities
Classification of risks
Risks in Sampo Group are classified under three broad
categories, namely business risks, reputational risk, and
risks inherent in business operations, as shown in the
picture Classification of risks in Sampo Group.
Classification of risks in Sampo Group
25_3_1_Classification_of_risks_in_Sampo_Group.svg
FINANCIAL STATEMENTS 2024
229
Risks inherent in business
operations
In its underwriting and investment operations, Sampo
Group is consciously taking certain risks to generate
earnings. These earnings risks are carefully selected and
actively managed. Underwriting risks are priced to
reflect their inherent risk levels and the expected return
of investments is compared to the related risks.
Furthermore, earnings related risk exposures are
adjusted continuously and their impact on the capital
need is assessed regularly.
Successful management of underwriting risks and
investment portfolio market risks is the main source of
earnings for Sampo Group. Day-to-day management of
these risks, i.e., maintaining them within given limits and
authorisations is the responsibility of the business areas
and the investment units.
Some risks, such as counterparty default risks and
operational risks presented in the graph Classification of
Risks in Sampo Group are indirect repercussions of
Sampo’s normal business activities. They are one-sided
risks, which in principle have no related earnings
potential. Accordingly, the risk management objective is
to mitigate these risks efficiently rather than actively
manage them. Mitigation of consequential risks is the
responsibility of the business areas and the investment
units. The capital need for these risks is measured by
independent risk management functions. It must be
noted that the categorisation of risks between earnings
and consequential risks varies, depending on the
industry. For Sampo Group’s clients, for instance, the
events that are subject to insurance policies are
consequential risks and for Sampo Group these same
risks are earnings risks.
Some risks such as interest rate, currency, and liquidity
risks are by their nature simultaneously linked to various
activities. To manage these risks efficiently, Sampo
Group must have a detailed understanding of expected
cash flows and their variance within its business
operations. In addition, a thorough understanding of
how the market values of assets and liabilities may
fluctuate at the total balance sheet level under different
scenarios is needed. These balance sheet level risks are
commonly defined as Asset and Liability Management
(“ALM”) risks. In addition to interest rate, currency, and
liquidity risk, inflation risk and risks relating to GDP
growth rates are central ALM risks in Sampo Group. The
ALM risks are one of the focus areas of senior
management because of their relevance to risks and
earnings in the long run.
In general, concentration risk arises when the
company’s risk exposures are not diversified enough.
When this is the case, an extremely unfavourable claim
or financial market event, for instance, could threaten
the solvency of the company.
Concentrations can evolve within separate activities –
such as large single name or industry specific insurance
or investment exposures – or across activities when a
single name or an industry is contributing widely to the
profitability and risks of the company through both
insurance and investment activities.
Concentration risk may also materialise indirectly when
profitability and the capital position react similarly to
general economic developments or to structural
changes in the institutional environment in different
areas of business.
Emerging risks
Emerging risk refers to newly developing or changing
risks that are difficult to quantify and which may have a
major impact on Sampo Group. Being aware of the risk,
gathering information about it, and reviewing
contractual terms in light of development are means of
managing and mitigating the risk.
Sustainability approach
Sampo Group has a sustainability programme, which
drives group level sustainability work. The programme
consists of three strategic sustainability themes:
Business management and practices, People and
communities, and Climate and environment. Under each
theme, the most material sustainability topics have been
identified. They link to Sampo Group’s strategy,
business, and risk management and are seen as
important by the Group’s various stakeholders.
When drafting the programme, views of both internal
and external stakeholders have been considered. This
includes, for example, regulatory requirements
regarding current and future sustainability reporting
(e.g., CSRD, CSDDD), feedback from investors and
employees, industry best practices, relevant reporting
frameworks (e.g., GRI Standards, TCFD), and the views
of various ESG rating agencies.
The business management and practices theme focuses
on topics that are fundamental to Sampo Group‘s
operations. This includes especially good corporate
governance, sustainable insurance operations and
supply chain management, and responsible investment.
Good governance in Sampo Group means effective
policies, management practices, and training that
provide assurance that the Group complies with laws,
regulations, and generally accepted principles, for
example, regarding anti-corruption and bribery and
anti-money laundering, and counter-terrorist financing.
Furthermore, they include comprehensive information
security and cybersecurity governance systems, and
data privacy activities, as well as effective
whistleblowing and grievance procedures.
FINANCIAL STATEMENTS 2024
230
Sustainable insurance operations are important in
meeting the evolving needs of all customers and in
mitigating potential adverse impacts on the Group’s
reputation. Therefore, Sampo Group aims to take ESG
considerations into account in product and service
development, and insurance underwriting. By
integrating ESG considerations into insurance
operations, Sampo Group aims to prevent association
with business activities that do not comply with the
company’s sustainability policies, and offer products
and services aligned with customers’ need and
preferences. This means, for example, that Sampo
Group integrates ESG considerations into insurance
underwriting (e.g. expectations for corporate clients to
respect international norms and standards as defined
by the UN Global Compact, integration of sustainability
considerations into underwriting principles and/or other
relevant policies), provides loss prevention services,
handles claims in a sustainable way, and develops
products and services in accordance with relevant legal
requirements (e.g. the EU Taxonomy).
Sampo Group emphasises sustainability factors when
working with suppliers. Sampo Group is a major
procurer of goods and services, especially in claims
handling, and therefore has an impact on the economy,
the environment, and people. Supply chains are also a
crucial part of the sustainability of Sampo Group’s
products and services. Sustainability issues can carry
significant reputational and operational risks if not
managed correctly. Therefore, Sampo Group takes ESG
considerations into account in supply chain
management, for example, by using supplier codes of
conduct, setting additional contractual requirements for
specific suppliers (e.g. based on ESG risks, sector, size,
geography, business relevance), setting targets related
to supply chain management, and conducting supplier
risk assessments (e.g. audits, questionnaires). Sampo
Group is also committed to encouraging and supporting
the company’s suppliers and partners in their efforts to
use more sustainable methods in their operations.
Responsible investment management and operations
are important in managing investment-related risks, and
in mitigating potential adverse impacts on the Group's
reputation. Therefore, Sampo Group takes ESG
considerations into account when assessing the
security, quality, liquidity, and profitability of
investments. Investment opportunities are carefully
analysed before any investments are made, and ESG
considerations are analysed in parallel with other
factors that might affect the risk-return ratio of
individual investments. Depending on the asset class,
Sampo Group uses different ESG strategies to ensure
the effective consideration and management of
investment risks arising from ESG considerations. The
strategies used include, for example, ESG integration,
sector-based screening, norms-based screening, and
engagement with investee companies.
The people and communities theme includes topics
relating to human rights and labour practices; diversity,
equity, and inclusion; health, safety, and wellbeing;
competence development; customer needs and
preferences; and sustainable sales and marketing
practices.
Sampo Group wants to provide customers with the best
service in all situations. Here, skilled and motivated
employees are an essential success factor. Losing talent
or being perceived as an unattractive employer would
pose large risks for the businesses. Therefore, Sampo
Group strives to ensure a sound work environment, not
only because it is stipulated by law but also because it
lays the foundation for sustainable business
performance. Diversity and inclusion are key focus areas
for Sampo Group, as it is committed to providing a non-
discriminatory, open, and agreeable work environment
where everyone is treated fairly and equally. Risks
related to these themes are managed, for example, by
having strong internal policies and governance
structures, conducting organisational development
programmes, and offering employees training,
interesting career opportunities, and attractive
remuneration packages.
Additionally, a sustainable product and service offering
requires being attentive to the risks relating to
inappropriate customer advice and product sales, errors
in claims handling and complaint processes, and a lack
of clarity on conditions, prices, and fees. The focus in
sales and marketing practices is on meeting the
demands and needs of the customer and providing the
customer with the information necessary for them to
make well-informed decisions on their insurance
coverage. Sampo Group manages risks related to these
themes, for example, by having effective internal
policies and governance structures, and offering
employees training.
The climate and environment theme includes topics,
such as, climate change, resource use and circular
economy as well as biodiversity.
Climate change and environmental issues are factors
that are expected to have a mid- and long-term effect
on Sampo Group’s businesses. Climate-related risks can
be categorised into physical risks and transition risks.
The financial position and results of Sampo Group’s
insurance operations are affected especially by physical
risks. The increasing likelihood of extreme weather
conditions and natural disasters is included in internal
risk models. Climate-related risks are also managed
effectively with reinsurance programmes and price
assessments. Since climate change can increase the
frequency and/or severity of physical risks, Sampo
Group conducts sensitivity analyses using scenarios in
which the severity of natural catastrophes is assumed to
FINANCIAL STATEMENTS 2024
231
increase. Sampo Group also helps its corporate and
private customers to manage climate-related risks.
Extreme weather events can, for example, damage
properties and lead to crop failure and business
interruption. Loss prevention is an essential part of
insurance services, as it helps customers to reduce
economic losses and mitigates the impacts of climate
change.
Sampo Group’s investments can be exposed to both
physical risks and transition risks, depending on the
investment in question. Investments are particularly
exposed to physical risks in the form of losses incurred
from extreme weather events. The transition to a low-
carbon society, with potentially increasing
environmental and climate regulation, more stringent
emission requirements, and changes in market
preferences, could in turn cause transition risks for the
Group’s investments, and a possible revaluation of
assets as operating models in carbon-intense sectors
change. To manage physical risks and transition risks,
investment opportunities are carefully analysed before
any investments are made, and climate-related risks are
considered along with other factors affecting the risk-
return ratio of individual investments. The methods
used by Sampo Group include annual analysis of the
carbon footprint and climate impact of investments,
sector-based screening and ESG integration, monitoring
the geographical distribution of investments, and
engagement with investee companies.
In terms of climate change scenario analysis, Sampo
Group, together with the external vendor ORTEC
Finance, has analysed the Group investment portfolio's
exposure to systemic economic and financial climate
change risks in four different climate scenarios over the
next 40 years. Based on the impact on macroeconomic
variables as well as the potential effect on claims related
to natural catastrophes, including consequences on
pricing of insurance contracts, the impact on the
insurance results has also been analysed.
For more information on the scenario analysis, see the
section Climate change in the Sustainability Statement.
Core risk management activities
To create value for all stakeholders in the long run,
Sampo Group must have the following forms of capital
in place:
• Financial flexibility in the form of adequate capital and
liquidity.
• Good technological infrastructure.
• Intellectual capital in the form of comprehensive
proprietary actuarial data and analytical tools to
convert this data into information.
• Human capital in the form of skilful and motivated
employees.
• Social and relationship capital in the form of good
relationships with society and clients to understand
the changing needs of different stakeholders.
These resources are being continuously developed in
Sampo Group. They are in use when the following core
activities related to risk pricing, risk taking, and active
management of risk portfolios are conducted. 
Appropriate selection and pricing of underwriting risks
• Underwriting risks are carefully selected and are
priced to reflect their inherent risk levels.
• Insurance products are developed proactively to
meet clients’ changing needs and preferences.
Effective management of underwriting exposures
• Diversification is actively sought.
• Reinsurance is used effectively to reduce largest
exposures.
Careful selection and execution of investment
transactions
• Risk return ratios and sustainability issues of separate
investments opportunities are carefully analysed.
• Transactions are executed effectively.
Effective mitigation of consequential risks
• Counterparty default risks are mitigated by carefully
selecting counterparties, applying collateral
agreements, and assuring adequate diversification.
• High quality and cost-efficient business processes are
maintained.
• Continuity and recovery plans are continuously
developed to secure business continuity.
Effective management of investment portfolios and the
balance sheet
• Balance between expected returns and risks in
investment portfolios and the balance sheet is
optimised, considering the features of insurance
liabilities, internally assessed capital needs, regulatory
solvency rules and rating requirements.
• Liquidity risks are managed by having an adequate
portion of investments in liquid instruments. The
portion is mainly dependent on the features of the
liabilities.
At the Group level, the risk management focus is on
capitalisation, leverage, and liquidity. It is also essential
to identify potential risk concentrations, and to have a
thorough understanding of how solvency and reported
profits of Group companies would develop under
different scenarios. These concentrations and
correlations may influence Group level capitalisation,
FINANCIAL STATEMENTS 2024
232
leverage, and liquidity, as well as on Group level
management actions.
When the above-mentioned core activities are
successfully implemented, a balance between profits,
risks and capitalisation can be achieved and shareholder
value can be created.
Underwriting risks at Sampo Group
With respect to the underwriting businesses carried out
in the subsidiary companies, it has been established that
If and Topdanmark operate within the Nordic countries,
but mostly in different geographical areas, and in
different lines of business; hence their underwriting risks
differ by nature. However, there are no material
underwriting risk concentrations in the normal course of
business. Hastings operates solely in the
United Kingdom and hence, its underwriting risks are
geographically distinct from the Nordics. Consequently,
business lines as such are contributing diversification
benefits rather than a concentration of risks. 
Sampo Group’s insurance service result increased in
2024 by 14 per cent to EUR 1,394 million (1,193). The
table Underwriting performance, 31 December 2024
and 31 December 2023 presents the development of
insurance revenue, claims expenses, operating
expenses, and insurance service result for the last two
years.
Underwriting performance
Sampo Group, 31 December 2024 and 31 December 2023
EURm
Insurance revenue
Reinsurance premiums
expenses
Insurance service
expenses, Claims
incurred
Insurance service
expenses, Operating
expenses
Reinsurers' share of
claims incurred
Insurance service result
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Motor
4,520
3,973
-392
-590
-2,989
-2,688
-680
-621
173
424
632
499
Workers'
compensation
314
309
-6
-6
-164
-106
-43
-42
5
1
106
155
Liability
460
446
-71
-68
-213
-222
-68
-65
36
22
143
114
Accident
1,162
910
-8
-6
-746
-542
-180
-148
6
4
234
217
Property
2,796
2,532
-406
-307
-2,054
-2,097
-388
-347
297
393
244
173
Marine, aviation,
transport
136
142
-24
-27
-75
-79
-21
-22
16
13
31
28
Other
62
105
-2
-2
-46
-76
-16
-22
4
1
3
7
Total
9,450
8,418
-909
-1,006
-6,287
-5,810
-1,396
-1,266
537
858
1,394
1,193
FINANCIAL STATEMENTS 2024
233
Key sensitivities
Effects from instant change on profit or loss in year 2024
EURm
Shock
2024
Combined ratio (quarterly effect)
Discount rate  +100 bps
-0.60 %
Combined ratio (quarterly effect)
Discount rate  -100 bps
0.60%
Insurance finance income and expense, net
Discount rate  +100 bps
330
Insurance finance income and expense, net
Discount rate  -100 bps
-380
Net investment income
Interest rates  +100 bps
-320
Net investment income
Interest rates  -100 bps
350
Net investment income
Spreads +100 bps
-330
Net investment income
Equities  -10%
-220
The main non-life underwriting risks that may influence
future claims are the risk of single large claims and the
risk of catastrophe events. However, Sampo Group has
comprehensive reinsurance programmes in place,
contributing to the low level of underwriting risk. The
negative economic impacts of natural catastrophes and
single large claims are also mitigated by the Group’s
well-diversified portfolio. Claims costs may also be
affected by uncertainty in claims outstanding caused by
higher-than-expected claims inflation, lower discount
rates, or an increased retirement age with the
consequence that both annuities and lump sum
payments would increase. However, higher long-term
inflation would be expected to coincide with higher
nominal discount rates, whereby the effects would in
part cancel each other out.
Net liabilities for incurred claims have been presented in
the following table. 
Net liabilities for incurred claims
Sampo Group, 31 December 2024
Sweden
Norway
Finland
Denmark
Baltics
UK
Total
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
Motor other and MTPL
779
8.9
163
1.3
655
11.0
273
2.2
111
4.0
1,030
2.2
3,011
5.9
- whereof MTPL
679
10.2
91
2.0
633
11.4
238
2.3
98
4.5
—
—
1,739
8.8
Workers' compensation
—
—
97
2.8
773
10.3
1,137
7.3
—
—
—
—
2,008
8.3
Liability
229
3.8
100
1.5
113
2.7
193
2.5
23
2.0
—
—
658
2.8
Accident
253
6.0
338
5.9
190
7.1
269
2.3
3
0.3
—
—
1,053
5.2
Property
349
0.9
334
0.9
160
0.8
325
1.1
34
0.4
44
1.0
1,245
0.9
Marine, aviation, transport
17
0.7
18
0.7
9
1.0
13
0.7
2
0.6
—
—
59
0.8
Other
—
—
0
—
—
—
34
1.1
—
0.0
—
—
34
1.1
Total
1,628
6.0
1,050
2.8
1,900
8.9
2,243
4.6
172
3.0
1,074
2.1
8,067
5.3
FINANCIAL STATEMENTS 2024
234
Underwriting risks at If Group
As shown in the graph Breakdown of gross written
premiums by business area, country, and line of
business, If, 31 December 2024, the If insurance portfolio
is well diversified across business areas, countries, and
lines of business. The six lines of business are
segmented in accordance with the insurance class
segmentation used in IFRS.
Breakdown of gross written premiums by business area, country, and line of business
If, 31 December 2024, total EUR 5,860 million (5,468)
25_17_2_Breakdown of gross written premiums If.svg
25_17_2_Breakdown of gross written premiums If 2.svg
25_17_2_Breakdown of gross written premiums If 3.svg
FINANCIAL STATEMENTS 2024
235
There are minor differences between the figures
reported by Sampo Group and If due to different
foreign exchange rates used in the consolidation.
Premium and catastrophe risk and their
management and control
The main factors affecting If’s premium risk are claims
volatility, claims inflation, and pricing methodology.
Given the inherent uncertainty of P&C insurance
operations, there is a risk of losses due to unexpectedly
high claim expenses. Examples of what could lead to
high claim expenses include large fires, natural
catastrophes, or an unforeseen increase in the
frequency or the average size of small and medium-
sized claims. Another example is claims inflation, which
is taken into account in the pricing process and can
affect competitiveness when claim costs increases.
The principal methods for mitigating premium risk are 
reinsurance and risk sharing, portfolio diversification,
prudent underwriting, and detailed and frequent follow-
ups linked to the strategy and financial planning
process.
An analysis of how changes in the combined ratio,
insurance revenue, and claims incurred affect the result
before tax is presented in the table Sensitivity analysis,
premium risk, If, 31 December 2024 and 31 December
2023.
Sensitivity analysis, premium risk
If, 31 December 2024 and 31 December 2023
Level 2024
Change in current
level
Effect on result before tax (Gross)
Effect on result before tax (Net)
Key Figures
(Gross)
(Net)
2024
2023
2024
2023
Combined ratio, business area Private
81.9%
82.2%
+/- 1 percentage point
+/-­ 30.1
+/-­ 28.7
+/-­ 29.7
+/-­ 28.4
Combined ratio, business area Commercial
89.4%
83.6%
+/- 1 percentage point
+/-­ 13.7
+/-­ 13.2
+/-­ 13.6
+/-­ 13.1
Combined ratio, business area Industrial
76.9%
88.7%
+/- 1 percentage point
+/-­ 10.3
+/-­ 9.2
+/-­ 6.6
+/-­ 6.3
Combined ratio, business area Baltics
85.6%
86.0%
+/- 1 percentage point
+/-­ 2.4
+/-­ 2.3
+/-­ 2.4
+/-­ 2.2
Insurance revenue (net of reinsurance premium
expenses EURm)
5,680
5,258
+/- 1 per cent
+/-­ 56.8
+/-­ 53.3
+/-­ 52.6
+/-­ 49.9
Claims incurred (EURm)
3,873
3,554
+/- 1 per cent
+/-­ 38.7
+/-­ 37.6
+/-­ 35.5
+/-­ 33.7
The overall risk appetite and risk tolerance limit for
underwriting risk is set out in the Risk Management
Policy, which is complemented by sub-limits for risks
within the underwriting operations. The Underwriting
Policy sets general principles, restrictions, and
directions for the underwriting activities, and is
supplemented by guidelines outlining in greater detail
how to conduct underwriting within each business area.
The Reinsurance Policy stipulates guidelines for the
purchase of reinsurance. The optimal choice of
reinsurance program is evaluated by comparing the
expected cost with the benefit of the reinsurance, as
well as the impact on result volatility and capital
requirements. The main tool for this evaluation is the
Sampo Group internal model in which small claims,
large claims, and natural catastrophes are modelled.
The Reinsurance Policy includes limitations on
permitted reinsurers as well as limits relating to
concentration risk and reinsurance risk.
In 2024, retention levels were between SEK 100 million
(approximately EUR 11.0 million) and SEK 300 million
(approximately EUR 34.0 million) per risk and SEK 300
million (approximately EUR 34.0 million) per event.
FINANCIAL STATEMENTS 2024
236
Reserve risk and its management and control
If's main reserve risks are claims inflation and increased
retirement age.
Reserves, especially in long tailed business, are sensitive
to assumptions of future claims inflation, as they affect
the future claim amount. An increased retirement age,
through for instance a political decision, will increase
the duration and present value of annuities as they
decrease, or expire, at retirement. An increase in life
expectancy will likewise increase the duration and
present value of annuities.
The valuation of the liability for incurred claims always
includes a degree of uncertainty, since it is based on
estimates of the size and the frequency of future claim
payments. The uncertainty in the valuation is normally
greater for new portfolios for which complete run-off
statistics are not yet available, and for portfolios
including claims that take a long time to settle. Workers’
compensation, motor third party liability (MTPL),
personal accident, and liability insurance are products
with the latter characteristics.
The value of the net liability for incurred claims is, in
addition to risk factors relating to reserve risk, also
impacted by changes in discount rates and exchange
rates. These market risks are described in sections for
interest rate risk and currency risk. Reserve risk differs
from interest rate risk since it relates to the size of
future cash flows, while the interest rate risk only
impacts the present value of future cash flows.
The duration of the provisions, and thus the sensitivity
to changes in discount rates, varies with each product
portfolio. The weighted average duration for 2024
across the product portfolios was 6.1 years (6.2).
A large part of the exposure relates to lines of business
MTPL and workers’ compensation, where a part of the
liability for these lines includes annuities. In 2024 the
proportion of liability for incurred claims related to
MTPL and workers’ compensation was 51 per cent (52).
In the table Net liability for incurred claims by line of
business and major geographical area, If, 31 December
2024 and 31 December 2023, the size and duration of
If’s IFRS net liability for incurred claims are presented
by line of business and major geographical area.
Net liabilities for incurred claims by line of business and major geographical area
If, 31 December 2024
Sweden
Norway
Finland
Denmark
Baltics
Total
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
Motor other and MTPL
800
8.8
163
1.3
655
11.0
102
2.3
111
4.0
1,831
8.3
- whereof MTPL
699
10.0
91
2.0
633
11.4
97
2.4
98
4.5
1,618
9.3
Workers' compensation
—
—
97
2.8
773
10.3
319
8.1
—
—
1,190
9.1
Liability
229
3.8
100
1.5
113
2.7
84
2.8
23
2.0
548
2.9
Accident
253
6.0
338
5.9
190
7.1
79
1.9
3
0.3
863
5.8
Property
349
0.9
334
0.9
160
0.8
125
0.3
34
0.4
1,001
0.8
Marine, aviation, transport
17
0.7
18
0.7
9
1.0
12
0.7
2
0.6
58
0.7
Total
1,648
5.9
1,050
2.8
1,900
8.9
721
4.5
172
3.0
5,491
6.1
Includes internal items with Hastings.
FINANCIAL STATEMENTS 2024
237
Net liabilities for incurred claims by line of business and major geographical area
If, 31 December 2023
Sweden
Norway
Finland
Denmark
Baltics
Total
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
EURm
Duration
Motor other and MTPL
868
9.2
226
1.7
669
10.8
103
3.0
107
4.0
1,972
8.2
- whereof MTPL
774
10.2
159
2.3
647
11.1
89
3.1
93
4.5
1,762
9.2
Workers' compensation
—
—
116
2.9
805
10.4
300
8.2
—
—
1,220
9.1
Liability
249
4.0
120
1.5
117
3.3
74
2.9
20
2.0
580
3.1
Accident
283
6.4
319
6.1
163
7.0
80
1.7
3
0.3
847
5.9
Property
330
1.0
364
0.8
175
0.7
101
0.4
26
0.6
996
0.8
Marine, aviation, transport
17
0.7
16
0.7
9
1.1
26
0.6
3
0.7
70
0.7
Total
1,747
6.3
1,162
2.7
1,938
8.9
681
4.7
158
3.1
5,686
6.2
A sensitivity analysis of the reserve risk is presented in
the table below, as well as the interest rate risk relating
to insurance contracts. The effects represent the
immediate impact on the liability values as a result of
changes in the different risk factors as per December 31
each year. The sensitivity analysis is calculated before
tax. Changes in the liability for incurred claims, net will
result in a corresponding change in result before
income taxes. The effect in the income statement is
presented in either the insurance service result or the
net financial result.
Sensitivity analysis, reserve risk
If, 31 December 2024 and 31 December 2023
Insurance liabilities item
Risk factor
Change in risk parameter
Country
Effect EURm
2024 Gross
Effect EURm
2024 Net
Effect EURm
2023 Gross
Effect EURm
2023 Net
Discounted estimated future cash
flows
Inflation increase
Increase by 1 percentage point
Sweden
110.4
106.5
124.5
120.1
Denmark
35.7
33.8
33.6
33.0
Finland
29.0
27.9
25.5
25.2
Norway
17.3
16.2
21.5
20.2
Annuities and reated INBR
Decrease in mortality
Life expectancy increase
by 1 year
Sweden
14.7
14.7
15.1
15.1
Denmark
1.1
1.1
1.0
1.0
Finland
49.1
49.1
49.2
49.2
Norway
0.2
0.2
0.2
0.2
Discounted liability for incurred
claims
Decrease in discount rate
Decrease by 1 percentage point to
liquid part of yield curve
Sweden
79.0
75.2
87.0
82.6
Denmark
35.3
33.4
33.5
32.9
Finland
169.5
168.4
171.6
171.3
Norway
28.6
27.5
31.4
30.1
FINANCIAL STATEMENTS 2024
238
The output from the sensitivity analysis is illustrated
both before and after reinsurance in the claims cost
trend tables. These are disclosed in note 21.
The Boards of Directors decide on the guidelines
governing the calculation of insurance liabilities. The
Chief Actuary is responsible for developing and
presenting guidelines on how the insurance liabilities
are to be calculated, and for assessing whether the level
of total liability is sufficient.
The actuarial estimates are based on historical claims
data and exposures that are available at the closing
date. Considered factors include loss development
trends, level of unpaid claims, changes in legislation,
case law and economic conditions. When estimating the
liability, established actuarial methods are generally
used, combined with projections of the number of
claims and average claim costs.
Underwriting risks in Topdanmark
As shown in the graph Breakdown of gross written
premiums by business area, country and line of
business, Topdanmark, 31 December 2024,
Topdanmark’s insurance portfolio is well diversified
across Business areas and lines of business.
Breakdown of gross written premiums by business area, country and line of business
Topdanmark, 31 December 2024, Total EUR 1,553 million (1,339)
25_17_2_Breakdown of gross written premiums Topdanmark.svg
25_17_2_Breakdown of gross written premiums Topdanmark 2.svg
25_17_2_Breakdown of gross written premiums Topdanmark 3.svg
FINANCIAL STATEMENTS 2024
239
Premium and catastrophe risk and their
management and control
The main underwriting risk that influences the
performance is the risk of catastrophe events. However,
the insurance risk of Topdanmark Forsikring is
mitigated by a comprehensive reinsurance program.
The reinsurance program focuses on catastrophe risks
such as storm, cloudburst, fire, and other cumulative
risks, where several policyholders are affected by the
same event. The biggest retentions are on storm with
DKK 150 million plus reinstatement for each event, while
the biggest retention on fire is DKK 30 million with a
maximum capacity of DKK 1,245 billion. In workers'
compensation risks are covered up to DKK 1 billion with
a retention of DKK 50 million.
Nearly all insurance risks in Topdanmark Forsikring are
measured by a partial internal model instead of the
Solvency ll standard model. The partial internal model
has been approved by the Danish Supervisory
Authorities for solvency calculations. The efficiency of
the reinsurance programme is assessed by the partial
internal model.
With certain restrictions, acts of terrorism are covered
by the reinsurance contracts. The NBCR (nuclear,
biological, chemical, radiological) acts of terrorism are
covered by a public organisation. This is based on an
Act on NBCR acts of terrorism. Under this scheme the
costs from a NBCR attack in Denmark will initially be
borne by the State, but those costs will subsequently be
recovered from policyholders.
Premium risk reduction measures taken at different
levels of operations are as follows:
• Collection of data on risk and claims history
• Use of collected and processed data in profitability
reporting, risk analyses, and in the internal model
• Ongoing follow-up on risk developments, as well as
quarterly forecasts for future risk development
• Correct pricing using a statistical model tool,
including customer scoring tools
• Reinsurance cover that reduces the risk, especially for
catastrophe events
• Ongoing follow-up on the risk overview and
reinsurance coverage in Topdanmark's Risk
Committee.
To maintain product and customer profitability,
Topdanmark monitors changes in its customer
portfolios. Provisions are recalculated, and the
profitability reports are updated in the same context on
a monthly basis. Based on this reporting, trends in claim
levels are carefully assessed, and price levels may be
adjusted if considered necessary.
In the private market segment, customer scoring is
used, and customers are divided into groups, according
to their expected profitability levels. The customer
scoring has two roles. First, it helps to maintain the
balance between the individual customer's price and
risk. Secondly, it facilitates the fairness between
individual customers by ensuring that no customers are
paying too large premiums to cover losses from
customers who pay too small premiums.
The historical profitability of major SME customers with
individual insurance schemes is monitored using
customer assessment systems. These assessment
systems enable Topdanmark to achieve accurate
information about income, claims expenses, combined
ratio etc., for each customer.
In addition to the analysis described above,
Topdanmark continuously improves its administration
systems to achieve more detailed data, which, in turn
enables the company to continuously improve pricing
and gain even better insight into how the different
types of claims are composed.
The insurance risk scenarios are presented in the table
Sensitivity analysis, premium risk, Topdanmark, 31
December 2024 and 31 December 2023.
FINANCIAL STATEMENTS 2024
240
Sensitivity analysis, premium risk
Topdanmark, 31 December 2024 and 31 December 2023
Key figures
Current level 2024
(Gross)
Current level 2024
(Net)
Change in current
level
Effect on result before tax (Gross)
Effect on result before tax (Net)
2024
2023
2024
2023
Combined ratio, business area
Private
85.6%
85.4%
+/- 1 percentage
point
+/- 8.2
+/- 7.6
+/- 8.1
+/- 7.5
Combined ratio, business area
Commercial
85.0%
83.2%
+/- 1 percentage
point
+/- 7.4
+/- 7.0
+/- 6.6
+/- 6.4
Insurance revenue (net of
insurance premium expense,
EURm)
—
1,468
+/- 1 per cent
—
—
+/- 14.7
+/- 13.8
Claims incurred (EURm)
1,017
971
+/- 1 per cent
+/- 10.2
+/- 9.5
+/- 9.7
+/- 9.1
Reserve risk and its management and control
The insurance lines of business are divided into short-
tail i.e., those lines where the period from notification
until settlement is short, and long-tail i.e., those lines
where the period from notification until settlement is
long. The main short-tail lines in Topdanmark Forsikring
are buildings, other property, and motor. Other short
tail lines are health products registered via Oona A/S.
For the short-tail lines, the claims are mainly settled
within the first year. Long-tail lines relate to personal
injury and liability, and consist of the lines Workers'
compensation, Accident, Motor third party insurance,
and Commercial liability. Composition of non-life
provisions for outstanding claims is presented in the
following table.
Net liability for incurred claims by line of business
Topdanmark, 31 December 2024 and 31 December 2023
2024
2023
EURm
Duration
EURm
Duration
Motor other and MTPL
170
2.1
159
2.1
- whereof MTPL
141
2.3
133
2.3
Workers' compensation
818
7.1
813
7.2
Liability
110
2.3
105
2.3
Accident
190
2.5
179
2.5
Property
199
1.5
209
1.4
Marine, aviation, transport
1
1.2
1
1.0
Other
35
1.1
37
1.0
Total
1,523
4.7
1,503
4.8
FINANCIAL STATEMENTS 2024
241
Due to the longer period of claims settlement, the risk
profile of the long-tail lines of business are generally
more uncertain than that of the short-tail lines. It is not
unusual that claims in long-tail lines are settled three to
five years after notification and in rare cases up to ten
to fifteen years.
The reserve risk is calculated using Topdanmark’s
partial internal model for insurance risk. Workers’
compensation claims provision has by far the biggest
risk, followed by the other long-tail lines’ claims
provisions.
During such a long period of settlement, the levels of
compensation could be significantly affected by
changes in legislation, case-law or practice in the
compensation of claim incidents adopted by the Danish
Labour Market Insurance, which decides on
compensation for injury and loss of earnings potential in
all cases of serious industrial injuries. The practice
adopted by the Danish Labour Market Insurance also
has some impact on the levels of compensation for
accident and personal injury within motor liability and
commercial liability insurance. Supreme court decisions
can also influence the provisions for former years,
especially for Workers’ compensation.
The reserve risk represents mostly the ordinary
uncertainty of calculation and claims inflation, i.e., an
increase in the level of compensation due to the annual
increase in compensation per policy being higher than
the general development in prices, or due to a change
in judicial practice or legislation. The sufficiency of the
provisions is tested in key lines by calculating the
provisions using alternative models as well, and then
comparing the compensation with information from
external sources, primarily statistical material from the
Danish Labour Market Insurance and the Danish Road
Sector/Road Directorate.
The sensitivity analysis of the reserve risk is presented
in the following table.
Sensitivity analysis, reserve risk
Topdanmark, 31 December 2024 and 31 December 2023
Insurance liabilities item
Risk factor
Change in risk parameter
Country
Effect
EURm
2024
Effect
EURm
2024 Net
Effect
EURm
2023
Effect
EURm
2023 Net
Discounted estimated future cash flows
Inflation increase
Increase by 1 percentage point
Denmark
49.9
49.9
50.7
50.7
Annuities and reated INBR
Decrease in mortality
Life expectancy increase by 1 year
Denmark
0.9
0.9
0.9
0.9
Discounted insurance liabilities, net
Decrease in discount rate
Decrease by 1 percentage point
Denmark
59.1
58.7
62.4
61.7
Underwriting risks in Hastings Group
Hastings provides motor, home insurance products, and
is a provider of regulated consumer credit in the current
form of personal loans. In the United Kingdom (UK)
market, the motor and home insurance products are
provided through its Gibraltar-based general insurance
underwriting company Advantage.
For Solvency II reporting purposes the lines of business
are:
• Motor vehicle liability insurance (Motor liability)
• Other motor insurance (Motor other)
• Fire and other damage to property insurance
FINANCIAL STATEMENTS 2024
242
Net liability for incurred claims by line of business
Hastings, 31 December 2024 and 31 December 2023
31 Dec 2024
31 Dec 2023
EURm
Duration
EURm
Duration
Motor
1,014
2.2
755
2.2
Property
44
1.0
40
1.8
Total
1,058
2.1
794
2.2
Sensitivity analysis, premium risk
Hastings, 31 December 2024 and 31 December 2023
Key figure
Level, 2024
(Gross)
Level, 2024
(Net)
Change
Effect on pre-tax profit (Gross), EURm
Effect on pre-tax profit (Net), EURm
2024
2023
2024
2023
Operating ratio
—%
89%
+/- 1 percentage point
—
—
+/- 16.7
+/- 12.5
Insurance revenue (net of reinsurance
premium expense)
2234
1814
+/- 1 per cent
+/- 22.3
+/- 17.2
+/- 18.2
+/- 11.3
Claims incurred
1417
1230
+/- 1 per cent
+/- 14.2
+/- 11.4
+/- 12.3
+/- 7.1
Pricing risk
Advantage's risk appetite requires management to
maintain rates that are projected to achieve loss ratios
within the target loss ratio range. As a response to
market conditions, rates were regularly adjusted, after
review by management, to remain competitive and
provide customer-focused benefits to policyholders.
The rate changes were regularly reviewed and
amended, in keeping with an agile approach to pricing
and appropriately factoring in ongoing claims cost
inflation risk. Robust technical product pricing with
strong governance controls for both Motor and
Household products is the principal way Advantage
manages insurance risk exposures, in order to mitigate
the risk of pricing ineffectively. 
Changes to technical rates are constructed based upon
the analysis of current and future predicted frequency
and severity patterns, new business acquisition, and
existing case models to ensure an appropriate risk
spread and balance. Competitor monitoring also feeds
into the development of pricing and product
segmentation.
Weekly governance arrangements approve changes to
rate plan and review account performance. The Rating
Analysis Committee approves decisions for segment
level rate changes and book level rate changes. The
goal is to ensure that the business being written will be
profitable.
Audits are conducted on a regular basis to ensure that
all underwriting and rating rules are being applied
correctly.
FINANCIAL STATEMENTS 2024
243
Reserve risk
Advantage does not take significant reserve risk and
holds an internal risk margin at a 75 per cent confidence
level versus the internal best estimate. Since reserving is
subject to expert judgment, the Group Chief Actuary
calculates the best estimate, the Hastings Group Senior
Actuary verifies the data, appropriateness of techniques
utilised, and assumptions used to create the best
estimate, and an additional best estimate is created by
a fully independent third party. Advantage has a series
of monthly, quarterly, and semi-annual controls to
ensure reserve adequacy.
Hastings’ Gross Written Premiums (GWP) for 2024
amounted to EUR 2,161 million.
Breakdown of gross written premiums by business area, country and line of business
Hastings, 31 December 2024, Total EUR 2,161 million (1,706)
25_17_2_Breakdown of gross written premiums Hastings.svg
25_17_2_Breakdown of gross written premiums Hastings 2.svg
25_17_2_Breakdown of gross written premiums Hastings 3.svg
Advantage maintained a disciplined approach to pricing
despite continued market competition. Live customer
policies grew year-on-year in 2024. This disciplined but
agile underwriting and pricing approach led to many
selective rate adjustments during 2024.
Claims cost inflation remained a large influence on the
risk profile for 2024. Effective pricing, claims
management, and frequency experience has resulted in
profits and capital with the solvency ratio within or
above of Advantage’s target range during the year.
FINANCIAL STATEMENTS 2024
244
Sensitivity analysis, reserve risk
Hastings, 31 December 2024 and 31 December 2023
Insurance liabilities item
Risk factor
Change in risk parameter
Effect Gross
EURm
2024
Effect Net
EURm
2024
Effect Gross
EURm
2023
Effect Net
EURm
2023
Discounted estimated future cash
flows
Inflation increase
Increase by 1 percentage point
66.1
12.6
63.0
10.1
Periodic Payment Orders (PPOs)
Decrease in mortality
Life expectancy increase by 1 year
3.4
0.1
3.1
0.1
Discounted insurance liabilities, net
Decrease in discount rate
Decrease by 1 percentage point
58.8
17.3
37.4
10.2
Market risks at Sampo Group
For all insurance entities, their insurance liabilities and
the company specific risk appetite are the starting
points for their investment activities. The insurance
liabilities, including loss-absorbing buffers, as well as the
risk appetite of the insurance entities in If, Topdanmark,
and Hastings differ, and as a result, the structures and
risks of the investment portfolios and the balance
sheets of the companies differ respectively. Sampo
Group’s investment assets presented in the tables and
graphs in this section do not include investments in the
shares of subsidiaries.
The total amount of Sampo Group’s investment assets
as at 31 December 2024 was EUR 16,727 million (17,160)
as presented in the following table, Investment
Allocation, Sampo Group, 31 December 2024 and 31
December 2023.
FINANCIAL STATEMENTS 2024
245
Investment allocation
Sampo Group, 31 December 2024 and 31 December 2023
2024
2023
Asset class
Market value,
EURm
Weight, %
Average maturity,
years
Market value,
EURm
Weight, %
Average maturity,
years
Fixed income total
14,780
88%
3.7
14,903
87%
3.4
Money market securities and cash
1,262
8%
0.1
2,026
12%
0.1
Government bonds
1,597
10%
4.1
1,299
8%
3.4
Credit bonds, funds and loans
11,922
71%
3.9
11,579
67%
3.9
Covered bonds
4,175
25%
4.9
4,022
23%
4.8
Investment grade bonds and loans
6,518
39%
3.4
6,013
35%
3.6
High-yield bonds and loans
1,228
7%
3.3
1,544
9%
3.1
Listed equity total
1,520
9%
-
1,474
9%
-
Nordic Countries
693
4%
-
735
4%
-
Western Europe
447
3%
-
416
2%
-
North America
204
1%
-
155
1%
-
Asia
176
1%
-
147
1%
-
Others
0
0%
-
20
–%
-
Alternative investments total
465
3%
-
800
5%
-
Real estate
0
0%
-
1
0%
-
Private equity
464
3%
-
765
4%
-
Other alternative
0
0%
-
34
0%
-
Derivatives
-38
0%
-
-17
0%
-
Asset classes total
16,727
100 %
-
17,160
100%
-
The financial assets, as presented in the note 12, differ from the investment allocation because the latter does not include the Hastings lending business and the associated expected credit loss (ECL)
provision. Additionally, investment allocation includes cash and cash equivalents, accrued interest and derivatives with negative market value. It also includes settlement receivables and liabilities.
FINANCIAL STATEMENTS 2024
246
Investment activities and market risk taking are
arranged pro-actively in order to diversify single name
risks, except with regards to Nordic banks, where most
Sampo Group companies have placed their extra funds
in short-term money market assets and cash. From the
diversification of the assets on the balance sheet
perspective, Topdanmark is a positive factor because
the role of Danish assets is dominant in its portfolios,
and especially the role of Danish covered bonds is
central. In Sampo Group’s other insurance companies’
portfolios, the weight of Danish investments has been
immaterial. Also Hastings’ investment
portfolio has a positive impact on the diversification of
Sampo Group’s investments. Most Hastings’ assets are
British investments, denominated in pound sterling,
which is a market that Sampo Group otherwise has very
limited exposure to. Moreover, Hastings’ investment
portfolio consists mainly of investment grade fixed
income investments.
In the next paragraphs concentrations by homogenous
risk groups and by single names are presented first, and
after that balance sheet level risks are discussed.
Holdings by sector, geographical area and
asset class
Regarding fixed income and equity exposures, financial
institutions and covered bonds have a material weight
in the group-wide portfolios, whereas the role of public
sector investments is quite limited. Most of these assets
are issued by Nordic corporates and institutions,
although Hastings brings some diversification in this
respect. Most corporate issuers, although being based
in the Nordic countries, are operating at global markets
and hence their performance is not as dependent on the
Nordic markets. Exposures by sector, asset class, and
rating are presented in the following table. Sampo
considers that the balance sheet values to be
descriptive of the maximum exposure amount exposed
to credit risk.
FINANCIAL STATEMENTS 2024
247
Exposures by sector, asset class and rating
Sampo Group, 31 December 2024
EURm
AAA
AA+
-
AA-
A+
-
A-
BBB+
-
BBB-
BB+
-
C
D
Non-
rated
Fixed
income
total
Listed
equities
Other
Counter-
party risk
Total
Change
from 31
Dec 2023
Basic industry
–
–
36
171
28
–
31
266
32
–
–
297
-49
Capital goods
–
15
100
228
26
–
31
399
518
–
–
917
-84
Consumer products
–
57
272
323
22
–
122
796
173
1
–
969
-12
Energy
–
21
44
–
–
–
44
108
13
–
–
122
2
Financial institutions
34
962
2,122
800
27
–
81
4,026
–
404
3
4,432
-1,049
Governments
487
209
–
–
–
–
15
711
–
–
–
711
240
Government guaranteed
55
25
–
–
–
–
–
80
–
–
–
80
6
Health care
–
–
17
141
23
–
47
228
2
–
–
230
32
Insurance
17
20
44
230
8
–
4
324
–
–
–
324
-210
Media
–
–
–
5
5
–
47
57
–
–
–
57
42
Packaging
–
–
–
6
12
–
9
27
–
–
–
27
2
Public sector, other
478
18
–
–
–
–
–
496
–
–
–
496
-27
Real estate
–
35
149
137
27
3
154
506
–
–
–
507
-133
Services
–
–
42
193
135
–
59
428
–
–
–
428
68
Supranationals
310
–
–
–
–
–
–
310
–
–
–
310
107
Technology and electronics
–
12
28
68
–
–
86
193
–
1
–
194
38
Telecommunications
–
–
35
263
–
–
–
298
43
–
–
341
51
Transportation
–
49
85
48
5
–
62
249
–
–
–
249
29
Utilities
–
–
130
238
60
–
94
522
–
–
–
522
114
Others
–
–
31
20
–
–
42
93
4
25
–
122
32
Covered bonds
3,764
–
109
–
–
–
302
4,175
–
–
–
4,175
137
Funds
157
79
120
18
24
–
81
480
735
13
–
1,228
-22
Clearing house
–
–
–
–
–
–
–
–
–
–
9
9
7
Total
5,302
1,502
3,363
2,887
402
3
1,311
14,771
1,520
445
12
16,748
-677
Change from 31 Dec 2023
-111
-235
-118
206
10
3
18
-228
43
-436
-57
-677
Total assets differ from the table Investment allocation due to derivatives.
FINANCIAL STATEMENTS 2024
248
Most of the financial institutions and covered bonds are
in the Nordic countries, which can be seen in the table
Fixed income investments in the financial sector, Sampo
Group, 31 December 2024 and 31 December 2023.
Fixed income investments in the financial sector
Sampo Group, 31 December 2024
EURm
Covered bonds
Cash and money
market securities
Long-term senior debt
Long-term
subordinated debt
Total
%
Denmark
2,214
7
332
168
2,721
32,3 %
Sweden
1,506
40
474
175
2,195
26,0 %
Norway
303
–
361
311
974
11,6 %
Finland
39
310
269
161
778
9,2 %
France
–
153
233
15
401
4,8 %
United States
–
–
331
–
331
3,9 %
United Kingdom
–
134
144
–
278
3,3 %
Canada
64
–
131
–
195
2,3 %
Netherlands
–
–
159
32
192
2,3 %
Australia
45
–
37
–
82
1,0 %
Switzerland
5
–
70
–
75
0,9 %
Iceland
–
–
61
–
61
0,7 %
Germany
–
–
50
–
50
0,6 %
Spain
–
–
37
–
37
0,4 %
Belgium
–
–
33
–
33
0,4 %
Austria
–
–
21
–
21
0,2 %
Bermuda
–
–
3
8
11
0,1 %
Total
4,175
644
2,745
871
8,435
100,0 %
FINANCIAL STATEMENTS 2024
249
Fixed income investments in the financial sector
Sampo Group, 31 December 2023
EURm
Covered bonds
Cash and money
market securities
Long-term senior debt
Long-term
subordinated debt
Total
%
Sweden
1,776
191
566
169
2,702
32,1 %
Denmark
1,863
79
315
162
2,419
28,7 %
Finland
52
750
275
125
1,202
14,3 %
Norway
338
–
384
319
1,041
12,4 %
France
–
249
133
5
388
4,6 %
United States
–
2
179
–
181
2,2 %
Netherlands
–
–
92
21
113
1,3 %
Iceland
–
–
60
2
62
0,7 %
Switzerland
–
–
52
–
52
0,6 %
Canada
–
–
51
–
51
0,6 %
Ireland
–
–
47
–
47
0,6 %
United Kingdom
–
–
41
–
41
0,5 %
Australia
–
–
36
–
36
0,4 %
Austria
–
–
20
–
20
0,2 %
Germany
–
–
18
–
18
0,2 %
Spain
–
–
15
–
15
0,2 %
Belgium
–
–
15
–
15
0,2 %
New Zealand
–
–
11
–
11
0,1 %
Bermuda
–
–
–
7
7
0,1 %
Total
4,028
1,271
2,310
811
8,420
100,0 %
The public-sector exposure includes government bonds,
government guaranteed bonds, and other public-sector
investments including supranationals, as shown in the
tables Fixed income investments in the public sector,
Sampo Group 31 December 2024 and 31 December
2023. The public sector has had a relatively minor role
in Sampo Group’s portfolios and these exposures have
been mainly in the Nordic countries.
FINANCIAL STATEMENTS 2024
250
Fixed income investments in the public sector
Sampo Group, 31 December 2024
EURm
Governments
Government
guaranteed
Public sector,
other
Total
Sweden
415
–
96
511
Norway
72
–
397
470
Supranationals
–
–
313
313
United States
122
–
–
122
United Kingdom
87
–
–
87
Germany
–
56
–
56
Finland
14
25
–
39
Total
711
80
806
1,597
Sampo Group, 31 December 2023
EURm
Governments
Governments
guaranteed
Public sector,
other
Total
Sweden
421
–
131
552
Norway
–
–
391
391
Supranationals
–
6
191
197
United States
46
–
–
46
Germany
–
46
–
46
Finland
–
25
–
25
Denmark
7
–
–
7
Total
473
77
713
1,264
The listed equity investments of Sampo Group totalled
EUR 1,520 million at the end of year 2024 (1,474).
The geographical core of Sampo Group’s equity
investments is in Nordic companies. The proportion of
Nordic equities corresponds to 46 per cent of the total
equity portfolio. A breakdown of the listed equity
exposures of Sampo Group is shown in the graph
Breakdown of listed equity investments by
geographical regions, Sampo Group, 31 December 2024
and 31 December 2023.
Breakdown of listed equity investments by geographical regions
Sampo Group, 31 December 2024 and 31 December 2023
25_17_2_Breakdown of listed equity investments by geographical regions 2024.svg
Equity funds and ETFs are reported using a fund look-through approach for both the 2024 and 2023 reporting periods.
25_17_2_Breakdown of listed equity investments by geographical regions 2023.svg
FINANCIAL STATEMENTS 2024
251
Largest holdings by single name
The largest exposures by individual issuers and
counterparties are presented in the tables Largest
exposures by issuer and asset class, Sampo Group
31 December 2024 and 31 December 2023.
Largest exposures by issuer and asset class
Sampo Group, 31 December 2024
Issuer
Total, EURm
% of total
investment
assets
Cash &
short-term
fixed income
Long-term
fixed income:
Covered
bonds
Long-term
fixed income:
Other bonds
Equities
Uncolla-
teralised part
of derivatives
Nordea Bank
1,174
7%
204
788
181
—
1
Nykredit Association
897
5%
—
815
82
—
—
Swedbank
658
4%
—
546
112
—
—
Svenska Handelsbanken
582
3%
40
451
91
—
—
Realkredit Danmark
558
3%
—
558
—
—
—
Sweden
511
3%
—
—
511
—
—
Norway
472
3%
—
—
472
—
—
NOBA
433
3%
—
—
9
424
—
Jyske Bank
299
2%
—
226
73
—
—
Danske Bank
223
1%
34
15
174
—
1
Total top 10 exposures
5,808
35%
278
3,399
1,704
424
2
Other
10,919
65%
Total investment assets
16,727
100%
FINANCIAL STATEMENTS 2024
252
Largest exposures by issuer and asset class
Sampo Group, 31 December 2023
Issuer
Total, EURm
% of total
investment
assets
Cash &
short-term
fixed income
Long-term
fixed income:
Covered
bonds
Long-term
fixed income:
Other bonds
Equities
Uncolla-
teralised part
of derivatives
Nordea Bank
959
6%
284
489
183
—
2
Svenska Handelsbanken
814
5%
108
622
83
—
—
Swedbank
713
4%
—
589
124
—
—
Nykredit Realkredit A/S
598
3%
—
598
—
—
—
Realcredit Danmark
592
3%
—
592
—
—
—
Sweden
552
3%
—
—
552
—
—
NOBA
471
3%
—
—
46
425
—
Skandinaviska Enskilda Banken
439
3%
252
22
164
—
2
Danske Bank
429
2%
251
24
152
—
1
Norway
391
2%
—
—
391
—
—
Total top 10 exposures
5,958
35%
896
2,936
1,696
425
5
Other
11,202
65%
Total investment assets
17,160
100%
The largest high-yield and non-rated fixed income
investment single-name exposures are presented in the
tables Ten largest direct high yield and non-rated fixed
income investments, Sampo Group, 31 December 2024
and 31 December 2023. Furthermore, the largest direct
listed equity exposures are presented in the tables Ten
largest direct listed equity investments, Sampo Group,
31 December 2024 and 31 December 2023.
FINANCIAL STATEMENTS 2024
253
Ten largest high yield and non-rated fixed income investments and listed equity investments
Sampo Group, 31 December 2024
Ten largest high yield and non-rated
fixed income investments
Rating
Total, EURm
% of total fixed
income investments
Ten largest listed equity investments
Total, EURm
% of total equity
investments
Vattenfall AB
BB+
60
0.4%
NOBA *
424
21,8 %
Pohjolan Voima Oy
NR
32
0.2%
Nexi S.p.A. **
156
8,0 %
Campus Byen A/S
NR
29
0.2%
Volvo
148
7,6 %
Swedavia AB
NR
29
0.2%
ABB
88
4,5 %
Visma AS
NR
28
0.2%
Nederman Holding
66
3,4 %
Hexagon AB
NR
24
0.2%
Veidekke
61
3,1 %
Sanoma Oyj
NR
22
0.2%
Autoliv Inc
57
2,9 %
Altera Shuttle
NR
21
0.1%
Telia Company
43
2,2 %
Granite Debtco 9 Ltd
NR
20
0.1%
Husqvarna
40
2,1 %
Ica Gruppen AB
NR
20
0.1%
Beijer AB
32
1,7 %
Total top 10 exposures
286
1.9%
Total top 10 exposures
1,116
57,4 %
Other fixed income investments
14,494
98.1%
Other equity investments
828
42,6 %
Total fixed income investments
14,780
100.0%
Total equity investments
1,944
100,0 %
* Although NOBA is not listed company, it is major equity investment in Sampo plc's portfolio and therefore included in the table.
** Investment in Nexi S.p.A is managed by HF Evergood partners.
Ten largest high yield and non-rated fixed income investments and listed equity investments
Sampo Group, 31 December 2023
Ten largest high yield and non-rated
fixed income investments
Rating
Total, EURm
% of total fixed
income investments
Ten largest direct listed equity investments
Total, EURm
% of total direct
equity investments
Saab
NR
56
0.4%
NOBA*
425
19.3%
NOBA
NR
46
0.3%
Saxo Bank*
302
13.7%
ALM Equity
NR
38
0.3%
Volvo
180
8.2%
Ellevio Holding 1 AB
NR
35
0.2%
Nexi S.p.A.**
149
6.8%
Visma Group Holding
NR
35
0.2%
ABB
86
3.9%
Altera Infrastructure Holdings LLC
NR
30
0.2%
Autoliv Inc
64
2.9%
Swedavia
NR
30
0.2%
Husqvarna
59
2.7%
Campus Byen A/S
NR
29
0.2%
Nederman Holding
56
2.6%
Resource Group TRG
NR
27
0.2%
Veidekke
46
2.1%
Huhtamaki
BB+
25
0.2%
Volvo Cars
38
1.7%
Total top 10 exposures
351
2.4%
Total top 10 exposures
1,405
63.8%
Other fixed income investments
14,031
97.6%
Other equity investments
797
36.2%
Total fixed income investments
14,382
100.0%
Total equity investments
2,202
100.0%
* Although NOBA and Saxo Bank are not listed companies, they are major equity investments in Sampo plc's portfolio and are therefore included in the table.
** Investment in Nexi S.p.A is managed by HF Evergood partners.
FINANCIAL STATEMENTS 2024
254
The exposures in fixed income instruments issued by
non-investment grade issuers are significant, because a
relatively small number of Nordic companies are rated.
Furthermore, many of the Nordic rated companies have
a high yield rating.
Balance sheet concentrations
In general, Sampo Group is structurally dependent on
the performance of the Nordic economies, as described
earlier. Sampo Group is also economically exposed to a
fall in interest rates. This follows from the duration of
insurance liabilities being longer than the fixed income
asset duration in If. In Topdanmark and Hastings,
interest rate risk of the balance sheet is limited, and
hence, Topdanmark or Hastings are not increasing
interest rate risk materially at the Group level.
Sampo Group benefits when interest rates rise, as the
economic value of insurance liabilities decreases more
than the value of assets backing them.
Market risks at If Group
The total market value of If’s investment portfolio at 31
December 2024 was EUR 10,704 million (11,156). A large
part of the fixed income portfolio was concentrated to
corporate bonds issued by financial institutions, and
bank account balances amounted to 29.6 per cent of
the fixed income portfolio. When including covered
bonds, the concentration to financial institutions was
49.4 per cent. Consumer products represent the second
largest concentration of 4.7 per cent.
The overall risk appetite and risk tolerance limit for
market risk is set out in the Risk Management Policy,
which is complemented by sub-limits for risks within 
investment operations in the Investment Policy and
Currency Risk Policy. The Investment Policy is the
principal document for managing market risk. It sets the
guiding principles, for instance, the prudent person
principle, specific risk restrictions, and decision-making
structure for asset management. If also has a 
Responsible Investment Policy, expanding the scope of
the responsible investment processes and increasing
alignment across the Sampo Group. Investment
performance and market risk are actively monitored
and controlled by the Investment Control Committee.
If’s investment management strategy is conservative,
with a low equity share and low fixed-income duration.
Market risks of balance sheet
Asset and liability management risk
If’s exposure to ALM risk arises mainly from interest rate
risk, inflation risk, and currency risk. ALM risk is
considered through the risk appetite framework and is
governed by the Investment Policy. To maintain the
ALM risk within the overall risk appetite, the insurance
liabilities may be matched by investing in appropriate
fixed income instruments, and by using currency and
interest rate derivatives.
Interest rate risk
The exposure to interest rate risk from issued insurance
contracts and held reinsurance contracts arises from
the net liability for incurred claims, where future claim
payments are discounted to present value and,
therefore, impacted by changes in discount rates.
The duration sensitivity to changes in interest rates in
the net liability for incurred claims is analysed in the
Reserve risk section. For more information see the
tables Sensitivity analysis, reserve risk, If, 2024 and
2023 in the section Underwriting risks.
If’s exposure to interest rate risk from financial
instruments arises primarily from fixed income
investments.
On a net basis, If is negatively affected when interest
rates are decreasing, as the duration of insurance
liabilities is longer than the duration of investment
assets. The duration of fixed income investments at
year-end 2024 was 2.5 years (2.4). The respective
duration of insurance liabilities was 6.1 years (6.2).
Interest rate risk relating to insurance liabilities is, in
accordance with the Investment Policy, considered in
the composition of investment assets. The interest rate
risk is managed by sensitivity limits for instruments
sensitive to interest rate changes.
Currency risk
If writes insurance policies that are mostly denominated
in the Scandinavian currencies and in euro. If is mainly
exposed to transaction currency risk due to its
insurance operations in foreign currencies. In addition,
If’s investment decisions create currency exposure. The
currency risk has decreased compared to 31 December
2023.
Transaction currency risk is reduced by matching
insurance liabilities with investment assets in
corresponding currencies or by using currency
derivatives. The currency exposure in insurance
operations is hedged to the functional currency at
branch level on a regular basis. The currency exposure
in investment assets is monitored weekly and is hedged
when the exposure reaches a specified level, which is
set with respect to cost efficiency and minimum
transaction size. The transaction risk positions to the
Swedish krona are shown in the tables Transaction risk
position, If, 31 December 2024 and 31 December 2023.
The tables show the net transaction risk exposures and
the changes in the value of positions, given a 10 per
cent decrease in the value of the functional currency.
FINANCIAL STATEMENTS 2024
255
Transaction risk position
If, 31 December 2024
Base currency SEK (in EURm)
EUR
USD
JPY
GBP
SEK
NOK
DKK
Other
Total, net
Insurance operations
-3,225
-156
0
-93
13
-2,332
-1,163
-32
-6,989
Investments
3,261
480
0
68
97
1,930
53
1
5,889
Derivatives
-117
-323
12
20
-109
354
976
7
820
Transaction risk, net position
-82
1
12
-5
1
-49
-134
-25
-280
Sensitivity: SEK -10%
-8
0
1
0
0
-5
-13
-2
-28
Transaction risk position
If, 31 December 2023
Base currency SEK (in EURm)
EUR
USD
JPY
GBP
SEK
NOK
DKK
Other
Total, net
Insurance operations
-3,255
-180
0
-49
37
-2,233
-1,114
-29
-6,823
Investments
3,091
319
0
24
113
1,869
187
0
5,604
Derivatives
117
-123
5
22
-168
350
916
22
1,141
Transaction risk, net position
-47
15
5
-4
-18
-13
-11
-7
-79
Sensitivity: SEK -10%
-5
2
0
0
-2
-1
-1
-1
-8
The transaction risk position in SEK represents exposure in foreign subsidiaries/branches within If with a functional currency other than SEK.
In addition to transaction risk, If is also exposed to
translation risk at Group level, stemming from foreign
operations, predominantly through If P&C insurance Ltd
branches, with other functional currencies than SEK.
Liquidity risk
Liquidity risk is not deemed material since premiums are
collected in advance, and large claim payments are
usually known well in advance. The risk is managed in
accordance with the principles set out in the Investment
Policy. In general, the liquidity position for If is strong,
from both availability and maturity point of view.
Liquidity risk is reduced by investing in assets that are
readily marketable in liquid markets. The available
liquidity of financial assets, meaning the part of the
assets that can be converted into cash at a specific
point in time, is continuously analysed and reported to
the Risk Committee.
The maturities of cash flows from financial instruments,
insurance liabilities, and reinsurance contracts are
presented in the tables Cash flows, according to
contractual maturity, If, 31 December 2024 and 31
December 2023, where financial assets and liabilities are
divided into contracts with a contractual maturity
profile, and other contracts. The tables also show
expected future cash flows for insurance liabilities and
reinsurance assets, which by nature are inherently
associated with a degree of uncertainty. The average
maturity of fixed income investments was 3.4 years
(3.2).
FINANCIAL STATEMENTS 2024
256
Cash flows according to contractual maturity
If, 31 December 2024
EURm
Carrying amount
total
Carrying amount
without contractual
maturity
Carrying amount with
contractual maturity
Cash flows
2025
2026
2027
2028
2029
2030-
2039
2040-
Financial assets
10,848
1,353
9,495
1,434
1,850
2,524
1,577
1,129
1,945
3
Financial assets (non-derivatives)
10,838
1,353
9,484
1,423
1,850
2,524
1,577
1,129
1,945
3
FX derivatives
11
—
11
11
—
—
—
—
—
—
Asset for incurred claims
659
—
659
424
131
52
23
11
18
1
Financial liabilities
-482
-1
-481
-323
-134
-27
—
—
—
—
Financial liabilities (non-derivatives)
-462
-1
-461
-305
-134
-27
—
—
—
—
FX derivatives
-19
—
-19
-18
—
—
—
—
—
—
Lease liabilities
-125
—
-125
-27
-24
-20
-17
-16
-44
—
Liability for incurred claims and
other insurance related payables
-6,445
—
-6,445
-2,606
-789
-475
-339
-265
-1,209
-762
All intra-group cashflows are eliminated.
Cash flows according to contractual maturity
If, 31 December 2023
EURm
Carrying amount
total
Carrying amount
without contractual
maturity
Carrying amount with
contractual maturity
Cash flows
2024
2025
2026
2027
2028
2029-
2038
2039-
Financial assets
11,296
1,485
9,812
1,605
1,835
2,142
2,561
1,400
1,487
—
Financial assets
(non-derivatives)
11,275
1,485
9,791
1,585
1,835
2,142
2,561
1,400
1,487
—
Interest rate swaps
2
—
2
2
—
—
—
—
—
—
FX derivatives
19
—
19
19
—
—
—
—
—
—
Asset for incurred claims
527
—
527
328
108
44
19
11
18
1
Financial liabilities
-550
—
-550
-402
-31
-137
—
—
—
—
Financial liabilities (non-derivatives)
-492
—
-492
-344
-31
-137
—
—
—
—
FX derivatives
-58
—
-58
-58
—
—
—
—
—
—
Lease liabilities
-148
—
-148
-27
-26
-23
-20
-14
-47
—
Liability for incurred claims and
other insurance related payables
-6,443
—
-6,443
-2,483
-794
-471
-339
-262
-1,301
-795
FINANCIAL STATEMENTS 2024
257
Market risks at Topdanmark
In general, long-term value creation shall be based
mainly on the acceptance of insurance risks. To
supplement the profit from insurance activities, 
Topdanmark accepts a certain level of market risks,
given its strong liquidity position and stable, high
earnings from insurance operations. Hence, in addition
to fixed income instruments, Topdanmark has invested,
among other things, in equities and fixed income assets
to improve the average investment return.
Market risks are kept on an appropriate level in order to
limit negative profit and loss effects to very
unfavourable financial market scenarios. The investment
portfolio shall be managed to ensure that market risks
will not endanger the insurance operations, even in
unfavourable market conditions. 
To achieve company level targets, the investment policy
sets the company's objectives, strategies, organisation,
and reporting practices on investments. The investment
strategy is more precisely determined in terms of
market risk limits, and specific requirements for certain
investments and sub-portfolios (risk appetite). The
investment strategy is determined by the Board and
revised at least once a year. Appropriate financial risk
mitigation techniques are used.
When selecting the investment assets, a portfolio
composition that matches the risk features of the
corresponding liabilities is sought. The purpose of the
investment policy is also to ensure that the company
has effectively implemented the organisation, systems,
and processes necessary to identify, measure, monitor,
manage, and report on investment risks to which it is
exposed.
When market risks are measured and managed, all
exposures are included, regardless of whether they
arise from active portfolio management of investments
or from annuities, which are considered market risk.
Investment allocation
The equity portfolios, excluding associated companies,
are well-diversified and without large concentrations.
Investment assets are mostly comprised of government
and Danish mortgage bonds. These assets are interest
rate sensitive and to a significant extent equivalent to
the total interest rate sensitivity of the non-life
insurance liabilities. Consequently, the return on
government and mortgage bonds should be assessed in
connection with return and revaluation of non-life
insurance liabilities.
The small allocation to credit bonds is through an ETF,
and is primarily exposed to European issuers.
Index-linked bonds comprise primarily, Danish
mortgage bonds, for which the coupon and principal
are index-linked.
Market risks of balance sheet
Interest rate risk
Interest rate risk is calculated for assets, liabilities, and
derivative instruments, for which the carrying amount is
dependent on the interest rate level. Regarding
insurance liabilities, Topdanmark is exposed to interest
rate risk due to provisions for outstanding claims.
Shifting the market yield curve upwards and
downwards or changing its shape leads to changed
market values of assets and derivatives, and thus to
unrealised gains or losses.
When assessing the value and sensitivity of insurance
provisions, Topdanmark has used the Solvency II
discount curve that is based on the market yield curve.
Generally, the interest rate risk is limited and controlled
by investing in interest-bearing assets in order to
reduce the overall interest rate exposure of the assets
and liabilities to the desired level. Therefore, the Danish
mortgage bonds and government bonds have a central
role in the asset portfolios. To further reduce the
interest rate sensitivity of the balance sheet, interest
rate swaps have been used for hedging purposes -
especially in the long end as the Danish fixed income
market presents few alternative assets.
Equity risk
The Danish part of the equity portfolio is based on the
OMXCCAP index and is approximated by the ETF Xact
OMXC25. The rest of the equity holdings are in the
foreign equity portfolio that seeks to track the MSCI
World DC index by the relevant geographical ETF in
USA, Europe, and Japan. As a result, Topdanmark’s
equity holdings are well-diversified, both in terms of
geographical and company-specific risks.
Real estate risk
Real estate risk is limited to one property in own use
and is located in Ballerup. The property is valued in
accordance with Danish accounting rules.
Spread risk
Most of Topdanmark's interest-bearing assets comprise
of AAA rated Danish mortgage bonds. The risk of credit
losses is minor due to the high credit quality of the
issuers and because investments have been made at
spreads that are in balance with Topdanmark’s desired
risk ratio levels. The portfolio is well-diversified by
issuer, issuer type, and capital centres, and therefore,
the exposure to concentration risk is insignificant.
The investment policy stipulates that the portfolio must
be well-diversified by the number of counterparties and
by the amount of exposure to individual counterparties.
The main source of spread risk is the mortgage bonds.
FINANCIAL STATEMENTS 2024
258
Due to high allocation of these investments in the
portfolios, spread risk is the most material source of
market risk SCR.
Currency risk
In practice, the investment assets are the only source of
currency risk, while the insurance liabilities are in Danish
krones. The currency risk is mitigated by derivatives,
and net exposures in different currencies are minor
except in the euro.
The currency risk is assessed based on the SCR. The
value of the base currency is shocked by 25 per cent
against most currencies, except against the euro, where
the largest exposure exists, and the shock is 0.39 per
cent because the Danish krone is pegged to the euro.
Inflation risk
Future inflation is implicitly included in the models
Topdanmark uses to calculate its insurance liabilities.
The insurance liabilities are calculated based on the
expected future indexation of wages and salaries.
An expected higher future inflation rate would generally
be included in the insurance liabilities with a certain
time delay, while, at the same time, the result would be
impacted by higher future indexation of premiums. To
reduce the risk of inflation within Workers'
compensation, Topdanmark uses index-linked bonds
and inflation derivatives to hedge a proportion of the
expected cash flows sensitive to future inflation. The
inflation sensitivity of capitalisation factors is not
hedged.
Liquidity risk
Topdanmark has a strong liquidity position. Firstly, as
premiums are paid in the beginning of the coverage
period, liquidity risk related to customers’ payments is
very limited. Secondly, the nature of a diversified
insurance business means that it is highly unlikely that a
liquidity shock could occur. Insurance liabilities are quite
stable and on the investment side, money market
investments are complemented by a large portfolio of
liquid listed Danish government and mortgage bonds.
The maturities of cash flows from financial instruments,
insurance liabilities and reinsurance contracts are
presented in the tables Cash flows according to
contractual maturity, Topdanmark, 31 December 2024
and 31 December 2023.
FINANCIAL STATEMENTS 2024
259
Cash flows according to contractual maturity
Topdanmark, 31 December 2024
EURm
Carrying
amount total
Carrying
amount
without
contractual
maturity
Carrying
amount with
contractual
maturity
Cash flows
2025
2026
2027
2028
2029
2030-
2039
2040-
Financial assets
2,278
—
2,278
668
485
347
314
211
374
142
Financial assets (non-derivatives)
2,276
—
2,276
668
485
347
314
211
373
142
Interest rate swaps
2
—
2
0
0
0
0
0
1
0
FX forwards
0
—
0
0
—
—
—
—
—
—
Asset for incurred claims
73
—
73
52
9
5
3
2
4
—
Financial liabilities
-348
-175
-172
-9
-103
-60
-2
-2
-18
-2
Financial liabilities (non-derivatives)
-323
-175
-148
-7
-101
-57
—
—
—
—
Interest rate swaps
-25
—
-25
-2
-2
-2
-2
-2
-18
-2
FX derivatives
0
—
0
0
—
—
—
—
—
—
Lease liabilities
—
—
—
—
—
—
—
—
—
—
Liability for incurred claims and other
insurance related payables
-1,596
—
-1,596
-606
-261
-175
-124
-90
-306
-169
All intra-group cashflows are eliminated.
Cash flows according to contractual maturity
Topdanmark, 31 December 2023
EURm
Carrying
amount total
Carrying
amount
without
contractual
maturity
Carrying
amount with
contractual
maturity
Cash flows
2024
2025
2026
2027
2028
2029-
2038
2039-
Financial assets
1,861
—
1,861
420
424
321
170
166
505
113
Financial assets (non-derivatives)
1,859
—
1,859
420
424
321
170
166
504
113
Interest rate swaps
1
—
1
0
0
0
0
0
1
0
FX forwards
0
—
0
0
—
—
—
—
—
—
Asset for incurred claims
79
—
79
58
9
4
3
2
4
0
Financial liabilities
-299
-128
-172
-10
-9
-102
-59
-1
-21
-1
Financial liabilities (non-derivatives)
-275
-128
-148
-9
-7
-101
-57
—
—
—
Interest rate swaps
-24
—
-24
-1
-2
-1
-1
-1
-21
-1
FX derivatives
0
—
0
0
—
—
—
—
—
—
Lease liabilities
—
—
—
—
—
—
—
—
—
—
Liability for incurred claims and other
insurance related payables
-1,582
—
-1,582
-603
-249
-183
-118
-87
-303
-184
FINANCIAL STATEMENTS 2024
260
Market risks at Hastings Group
Hastings’ investment portfolio has been designed to
generate a targeted return whilst operating within the
conservative risk appetite parameters set by the Board.
Management aims to prudently operate within its risk
appetite. The risk appetite includes a low appetite for
losses arising from volatility of market prices affecting
values of assets and liabilities, and for assets not
matching the profile of liabilities. As a result,
the investment strategy includes only a very limited
amount of equity exposure.
The total market value of Hastings' investment portfolio
at 31 December 2024 was EUR 2,263 million (1,680). The
investment portfolio was dominated by investment
grade fixed income investments, which comprised 60
per cent of total investment assets. The rest was
invested in money market securities and cash
amounting to 15 per cent, government bonds
amounting to 18 per cent, and high yield and alternative
investments with a combined allocation of 6 per cent.
Investment allocation
The core investment portfolio of debt securities,
supplemented by a diversified portfolio of holdings in
collective investment schemes, is held by Advantage.
The Advantage Board works with the investment
managers and investment consultants to maximise
return, whilst minimising risk and preserving capital. The
criteria for the portfolio structure, classes of holdings,
and individual limits are consistent with a very low risk
appetite. These investment rules are monitored on a
quarterly basis internally and using an external
consultancy. The monitoring outputs are provided to
the Investment Committee and Risk & Compliance
Committee quarterly.
Advantage made no direct use of derivatives during the
period. Derivatives are, however, utilised within
Investment Funds, in which Advantage has a share,
both for hedging purposes and to generate additional
return.
Interest rate risk
Hastings manages balance sheet interest rate risk
principally through matched duration of assets and
liabilities, meaning that interest rates are aligned as far
as possible, and interest rate risk is reduced. This is
monitored in the quarterly Investment Committee
meetings and includes adherence to tight duration
mismatch tolerances which form part of the relevant
risk appetite statement.
Liquidity risks
Hastings maintains a short duration and highly liquid
portfolio, in line with its low risk appetite. Liquidity Risk
is largely managed at Advantage. Cash and cash
equivalent balances are held in current accounts or
short-term money market instruments. These are
generally less than 60 days in duration, with low
sensitivity to movements in interest rates compared to
longer duration assets.
The liquidity profile and cashflow of investments is
monitored at the quarterly Investment Committee to
ensure Advantage can meet its liabilities into the future.
Advantage’s investment managers actively manage
liquidity risk in the portfolio to ensure that bonds can be
sold efficiently to meet cash needs. Informed by market
data, they look to purchase bonds with less than 5 years
since issue date, larger issue sizes, and which trade
regularly. Liquidity scoring is conducted by Advantage’s
investment managers, based on time since issue, issue
size, traded volumes, and observed bid-ask spreads. 
FINANCIAL STATEMENTS 2024
261
Cash flows according to contractual maturity
Hastings, 31 December 2024
EURm
Carrying
amount total
Carrying
amount
without
contractual
maturity
Carrying
amount with
contractual
maturity
Cash flows
2025
2026
2027
2028
2029
2030-
2039
2040-
Financial assets
2,263
438
1,825
438
497
373
391
103
13
11
Financial assets
(non-derivatives)
2,263
438
1,825
437
497
373
391
103
13
11
FX forwards
0
—
0
0
—
—
—
—
—
—
Asset for incurred claims
1,537
1,537
—
409
264
225
64
99
169
307
Financial liabilities
-355
—
-355
-22
-85
-305
—
—
—
—
Financial liabilities
(non-derivatives)
-354
—
-354
-21
-85
-305
—
—
—
—
Interest rate swaps
-1
—
-1
-1
—
—
—
—
—
—
FX derivatives
-0
—
-0
-0
—
—
—
—
—
—
Lease liabilities
-5
—
-5
-3
-1
-0
-0
-0
—
—
Liability for incurred claims and
other insurance related payables
-2,683
-2,683
—
-908
-493
-390
-154
-151
-227
-358
Cash flows according to contractual maturity
Hastings, 31 December 2023
EURm
Carrying
amount total
Carrying
amount
without
contractual
maturity
Carrying
amount with
contractual
maturity
Cash flows
2024
2025
2026
2027
2028
2029-
2038
2039-
Financial assets
1,869
704
1,165
143
341
349
179
154
—
—
Financial assets
(non-derivatives)
1,869
704
1,165
143
341
349
179
154
—
—
Asset for incurred claims
1,333
1,333
—
349
236
183
61
96
169
240
Financial liabilities
-187
—
-187
-73
-71
-43
—
—
—
—
Financial liabilities
(non-derivatives)
-185
—
-185
-71
-71
-43
—
—
—
—
Interest rate swaps
-2
—
-2
-2
—
—
—
—
—
—
Lease liabilities
-10
—
-10
-6
-3
-1
-0
-0
-0
—
Liability for incurred claims and
other insurance related payables
-2,125
-2,125
—
-670
-404
-302
-127
-137
-211
-275
FINANCIAL STATEMENTS 2024
262
Counterparty risks at If Group
In If, the major sources of counterparty risk stem from
reinsurance recoverables and investments.
Counterparty default risk arising from receivables from
policyholders and other receivables related to
commercial transactions is limited, as non-payment of
premiums generally results in cancellation of insurance
policies.
Reinsurance counterparty risk
The distribution of reinsurance recoverables and pooled
solutions is presented in the table below. In the table,
EUR 220 million (206) is excluded, which mainly relates
to captives and statutory pool solutions.
Reinsurance recoverables and pooled solutions
If, 31 December 2024 and 31 December 2023
31 Dec 2024
31 Dec 2023
Rating
Total EURm
% of total
Total EURm
% of total
AAA
—
—%
—
—%
AA+ - A-
633
100%
450
100%
BBB+ - BBB-
—
—
—
—%
BB+ - C
—
—%
—
—%
D
—
—%
—
—%
Non-rated
—
—%
—
—%
Total
633
100%
450
100%
The amount of the recoverables reported above is
exposed to counterparty default risk, as recoverables
are typically not covered by collaterals.
To limit and control credit risk associated with ceded
reinsurance, the Reinsurance Policy sets requirements
for the reinsurers’ minimum financial strength ratings
and the maximum exposure limits to individual
reinsurers. Credit ratings from rating agencies are used
to determine the creditworthiness of reinsurance
companies.
Counterparty risk related to investments
Before investing, potential investments are analysed
thoroughly. The creditworthiness and outlook of the
issuer are assessed together with any collateral and
structural details of the potential investment. Internal
risk indicators are important factors in the assessment,
although the macroeconomic environment, market
trends, and external opinions of analysts and credit
ratings by rating agencies are also taken into account.
In addition, the portfolio performance and the
counterparties’ credit standings are monitored
continuously.
FINANCIAL STATEMENTS 2024
263
Counterparty risks at Topdanmark
Topdanmark is exposed to counterparty risk in both its
insurance and investment activities. The default risk
related to fixed income and equity investments is
covered by spread-risk and equity-risk models in SCR
calculations, and hence are not discussed in this
context.
The main sources of counterparty risk are deposits
made to individual banks, derivative contracts with
banks, and current receivables from reinsurance
companies, with the addition of potential receivables
that will arise in case of a 1-in-200-year catastrophe
event. Topdanmark's counterparty risk is assessed by
the SCR standard formula
Reinsurance
Within insurance activities the reinsurance companies'
ability to pay is the most important counterparty risk
factor. Topdanmark minimises this risk by primarily
buying reinsurance cover from reinsurance companies
with a minimum rating of A-, and by spreading
reinsurance cover over many reinsurers.
For reinsurance counterparties, the Board approves
security guidelines which determine the maximum size
of reinsurance contract cover per a separate reinsurer.
This portion is dependent on the reinsurer's rating as
well as on Topdanmark’s own assessment of the
reinsurer. The largest risk concentrations may occur in
case of major catastrophe events, including storms and
cloudbursts.
Investments
Topdanmark may suffer losses due to their
counterparties’ inability to meet their obligations on
bonds, loans, and other contracts including derivatives.
The majority of Topdanmark’s interest bearing assets
comprise of Danish mortgage bonds.
To limit the counterparty risk of financial contracts,
including derivative contracts, the choice of
counterparties is restrictive, and collateral is required
when the value of the financial contracts exceeds the
predetermined limits. The size of the limits depends on
the counterparty's credit rating and the terms of the
contract.
FINANCIAL STATEMENTS 2024
264
Counterparty risks at Hastings Group
Hastings is exposed to counterparty risk through
reinsurance assets, financial assets and cash, and cash
equivalents. A number of controls exist within the
Hastings Group to mitigate against counterparty
default, such as annual reviews of reinsurance panels,
credit rating tolerances in line with a low-risk appetite,
and a low-risk, diversified investment portfolio.
Reinsurance counterparty risk
A key component of risk mitigation is reinsurance.
Advantage manages the tender of the reinsurance
programme, which consists of both non-capitalised
Excess of Loss (“XoL”) and Quota Share (“QS”)
protection. Under the 2024 arrangements, the Motor
exposure risk to Advantage is capped at GBP 2 million
per loss, net of XoL reinsurance, and Household
exposure is capped at GBP 17.5 million (approximately
EUR 21.1 million)  per event loss. In 2024, the Advantage
Board maintained the motor QS participation at 30 per
cent. Advantage’s reinsurance strategy will continue to
be reviewed in line with risk appetite. 
Reinsurance recoverables
Hastings, 31 December 2024 and 31 December 2023
2024
2023
Rating
Total, EURm
% of total
Total, EURm
% of total
AAA
—
—%
—
—%
AA
1,232
65%
1,031
63%
A
664
35%
608
37%
BBB
—
—%
2
0%
Less than BBB
—
—%
—
—%
Unrated
—
—%
—
—%
Total
1,896
100%
1,640
100%
To mitigate the inherent counterparty and credit risk
posed by the reinsurance programme to Advantage’s
balance sheet, Advantage has set criteria for the
minimum credit quality of the reinsurance
counterparties and for concentration limits. These
tolerances are monitored and mitigated on a continual
basis, with line of sight to the Board quarterly, or ad-hoc
as needed.
To better protect itself where possible, Advantage aims
to:
• Place with parent entities within reinsurance groups
to mitigate counterparty risk in accepting reinsurance
from small regional branches
• Where exposure to non-parent reinsurers is
unavoidable, seek to put in place collateralisation of
cut-through terms and/or parental guarantees to
mitigate counterparty risk
• Ensure special termination clauses are in place in the
event of rating downgrade or reorganisation of
reinsurance groups to which Advantage is exposed
• Historically, Advantage has sought to increase the
number of reinsurance partners on its panels to
facilitate the growth of the product exposure and
reinsurance capacity from the market.
FINANCIAL STATEMENTS 2024
265
Capitalisation
Sampo’s core business competences are skilful pricing
of risks inherent in business operations and high-quality
management of arising risk-exposures, and capital
needed to cover these risks. A balance between
earnings, risks, and capital contributes positively to
return on equity and to stakeholder confidence,
facilitating the creation of shareholder value.
Sampo plc is responsible for the group’s capital
management activities. These actions are guided by
targets set for group-level solvency and financial
leverage, and they include decisions on group-level
investment exposures, business growth and
performance targets, reinsurance strategies, capital
distributions, and capital instrument issuances.
Group level capitalisation is managed within Sampo’s
capital management framework, which sets targets for
solvency and informs potential risk management
actions.
Group-level capitalisation and the factors affecting it
are illustrated in the graph Sampo Group’s capitalisation
framework.
Sampo Group’s capitalisation framework
25_3_1_Sampo_Groups_capitalisation_framework.svg
FINANCIAL STATEMENTS 2024
266
The Group’s capital requirement is dependent mainly on
the capital requirements of the insurance entities. The
parent company’s contribution to the Group capital
need is relatively small, because Sampo plc does not
have any business activities of its own, other than the
management of its capital structure and liquidity
portfolio. Sampo still holds two private equity
investments on the parent company’s balance sheet,
also contributing to the Group’s capital requirement.
Diversification benefit exists at two levels, within the
companies and between the companies. The former is
included in the companies’ solvency capital requirement
(SCR).
Conceptually, the Group’s own funds equals the
difference between the market value of assets and
liabilities plus the subordinated liabilities. This difference
has accrued during the lifetime of the Group and it
includes the following main components:
• accrued profits that have not been paid as dividends
over the years
• valuation differences between IFRS and Solvency II
• issued capital and subordinated liabilities meeting
Solvency II requirements.
At the Group level, the capital requirement and own
funds are both exposed to foreign currency translation
risk. The actual capital and the capital needs of If,
Topdanmark, and Hastings are converted from their
reporting currencies to the euro. When the reporting
currencies of the subsidiary companies depreciate, the
actual amount of the Group’s capital in euros decreases,
and the capital requirements of the subsidiary
companies will be lower in euro terms. Translation
currency risk is monitored internally, and its effect on
Sampo Group’s solvency on a going concern basis is
analysed regularly. However, internally, no capital need
is set for translation risk, because it is realised only
when a subsidiary company is divested.
The Group-level buffers equal, in total, to the difference
between the amount of the Group’s own funds and the
Group capital requirement. In addition to insurance
entity level factors – expected profits and their volatility,
business growth prospects, volatility of the balance
sheet due to fluctuations in the market value of
investments and insurance liabilities, and the ability to
issue Solvency II compliant capital instruments – there
are factors that are additionally relevant when
considering the size of the Group-level buffers. The
most material of them are correlation of Group
companies’ profits, parent company’s capacity to
generate liquidity, probability of business arrangements,
and shareholders’ dividend expectations.
The role of Sampo plc
As the Group’s parent company, Sampo plc is
responsible for the Group’s capital management
activities. These actions are guided by targets set for
group-level solvency and financial leverage, and they
include decisions on group-level investment exposures,
business growth and performance targets, reinsurance
strategies, capital distributions, and capital instrument
issuances. In addition, group-level risk accumulations
and concentrations are monitored regularly, and
managed by adjusting aggregated risks, where
necessary.
The parent company Sampo plc is also a source of
liquidity within the Group. Hence, the healthy funding
structure and the capacity to generate funds, if needed,
are a continuous focus. Sampo plc needs liquidity to
manage the group’s financing needs, enable dividend
security, and to finance potential transactions. Sampo
plc funding is mainly limited to internal dividends and
investment returns but can be periodically
complemented with new debt, and capital or asset
sales. Hence, the parent company liquidity needs to be
managed holistically, together with the dividend policy,
strategic ambitions, and balance sheet targets.
As at 31 December 2024, Sampo plc had long-term
strategic holdings of EUR 7,431 million in the subsidiary
companies, and they were funded mainly by capital of
EUR 7,989 million. Sampo plc had outstanding senior
debt of EUR 954 million and subordinated debt of EUR
1,491 million. Average remaining maturity of senior debt
was 3.8 years and EUR 395 million of it had a maturity
longer than five years. Funding structure of strategic
holdings and other holdings can be considered strong.
The capacity to generate funds is dependent on
leverage and liquidity buffers, which can be inferred
from the table Balance sheet structure, Sampo plc, 31
December 2024 and 31 December 2023.
FINANCIAL STATEMENTS 2024
267
Balance sheet structure
Sampo plc, 31 December 2024 and 31 December
2023
EURm
31 Dec 2024
31 Dec 2023
Assets total
10,508
7,970
Liquidity
626
1,352
Investment assets
2,408
980
Other investments
3
3
Fixed income
1,826
101
Equity & private equity
580
876
Equity holdings
7,431
5,618
Subsidiaries
7,431
5,618
Other assets
44
20
EURm
31 Dec 2024
31 Dec 2023
Liabilities total
10,508
7,970
Long-term senior debt
954
959
Bonds issued
954
959
Subordinated debt
1,491
1,490
Capital
7,989
5,445
Undistributable capital
98
98
Distributable capital
7,891
5,347
Other liabilities
75
76
The amounts in the table are IFRS numbers, including the
internal loan with If.
Regarding liquidity, Sampo plc held EUR 626 million
(1,352) in bank account balances and short-term money
market investments. Liquidity is mainly affected by
received and paid dividends, as well as changes in
issued debt instruments and changes in investments.
Sampo’s dividend payment takes place in May and it will
significantly lower the liquidity position of the holding
company. A part of the investment assets can be sold in
case liquidity is needed. Short-term liquidity can be
considered adequate.
All in all, Sampo plc is in a good position to refinance its
current debt and even issue more debt. This capacity,
together with the tradable financial assets, means that
Sampo plc can generate liquid funds.
Sampo plc is able to balance risks within Sampo Group.
When Sampo plc is managing its funding, capital
structure, and liquidity, it takes into account that most
insurance entities in the Group have other base
currencies than the euro (the Swedish krona, the Danish
krone, pound sterling), and the Group is exposed to
lower interest rates. These risks may affect Sampo’s
decisions on the issuance of debt instruments and the
composition of the liquidity portfolio.
FINANCIAL STATEMENTS 2024
268
The maturities of financial assets and liabilities, and
lease liabilities are presented in the table Cash flows,
according to contractual maturity, Sampo plc, 31
December 2024 and 31 December 2023.
Cash flows according to contractual maturity
Sampo plc, 31 December 2024 and 31 December 2023
31 Dec 2024
Carrying amount total
Cash flows
EURm
Carrying amount
total
Carrying amount
without contractual
maturity
Carrying amount
with contractual
maturity
2025
2026
2027
2028
2029
2030-
2039
2040-
Financial assets
1,307
828
479
395
2
2
30
36
29
—
Financial assets (non-derivatives)
1,307
828
479
395
2
2
30
36
29
—
Financial liabilities
-2,520
—
-2,520
-232
-58
-59
-475
-551
-1,481
—
Financial liabilities (non-derivatives)
-2,495
—
-2,495
-229
-59
-59
-456
-551
-1,481
—
Interest rate swaps
-25
—
-25
-2
1
—
-19
—
—
—
Lease liabilities
-1
—
-1
-1
—
—
—
—
—
—
Intra-group cashflows are eliminated.
31 Dec 2023
Carrying amount total
Cash flows
EURm
Carrying amount
total
Carrying amount
without contractual
maturity
Carrying amount
with contractual
maturity
2024
2025
2026
2027
2028
2029-
2038
2039-
Financial assets
2,325
1,623
702
617
14
2
2
30
65
0
Financial assets (non-derivatives) 
2,325
1,623
702
617
14
2
2
30
65
0
Financial liabilities
-2,527
—
-2,527
-72
-223
-59
-59
-475
-2,032
—
Financial liabilities (non-derivatives)
-2,507
—
-2,507
-70
-223
-59
-59
-461
-2,032
—
Interest rate swaps
-20
—
-20
-2
0
0
0
-14
0
—
Lease liabilities
-2
—
-2
-1
1
—
—
—
—
—
FINANCIAL STATEMENTS 2023
269
Sampo plc’s Financial Statements
Sampo plc’s income statement ...........................
Sampo plc’s balance sheet ...................................
FINANCIAL STATEMENTS 2023
270
Sampo plc’s income statement
EURm
Note
1–12/2024
1–12/2023
Sales
2
1
Staff expenses
Salaries and remunerations
-17
-14
Social security costs
Pension costs
-2
-2
Other
-3
-3
Other operating expenses
1
-21
-39
Operating profit
-42
-57
Financial income and expense
3
Income from shares in Group companies
768
1,039
Income from other shares
—
23
Other interest and financial income
Group companies
12
—
Other
26
23
Other investment income and expense
1,130
-9
Other interest income
30
37
Interest and other financial expense
-74
-95
Exchange result
14
3
Profit before appropriations and taxes
1,863
963
Income taxes
0
0
Profit for the financial year
1,862
963
FINANCIAL STATEMENTS 2023
271
Sampo plc’s balance sheet
EURm
Note
2024
2023
Assets
Intangible assets
1
1
Tangible assets
3
3
Investments
Shares in Group company
20
7,448
5,635
Receivables from Group companies
4
1,725
—
Other shares and participations
5
524
876
Other investments
6
479
706
Short-term receivables
Other receivables
7
25
20
Prepayments and accrued income
8
18
2
Cash and cash equivalents
248
747
Total assets
10,469
7,990
EURm
Note
2024
2023
Liabilities
Equity
9,10
Share capital
98
98
Invested unrestricted equity
3,527
1,527
Other reserves
273
273
Retained earnings
2,189
2,604
Profit for the financial year
1,862
963
Liabilities
Long-term liabilities
12
Bonds
792
959
Subordinated debt securities
1,491
1,490
Short-term liabilities
Bonds
162
—
Other liabilities
2
5
Accruals and deferred income
11
72
71
Total liabilities
10,469
7,990
FINANCIAL STATEMENTS 2023
272
Sampo plc’s statement of cash flows
EURm
1–12/2024
1–12/2023
Operating activities
Profit before tax
1,863
963
Adjustments
Realised gains and losses on investments
-18
9
Other adjustments1
-1,118
-14
Adjustments total
-1,136
-5
Change (+/-) in assets of operating activities
Investments
529
341
Other assets
47
11
Total
576
351
Change (+/-) in liabilities of operating activities
Financial liabilities
-2
-2
Other liabilities
4
1
Paid interests
-66
-72
Paid taxes
0
0
Total
-65
-73
Net cash from operating activities
1,238
1,237
Investing activities
Investments in subsidiaries
-356
-108
Net cash used in investing activities
-356
-108
EURm
1–12/2024
1–12/2023
Financing activities
Dividends paid
-903
-1,321
Purchase of own shares
-475
-555
Repayments of debt securities in issue
-2
-334
Received group contribution
—
29
Net cash used in financing activities
-1,380
-2,180
Total cash flows
-499
-1,051
Cash and cash equivalents at 1 January
747
1,798
Cash and cash equivalents at 31 December
248
747
Net change in cash and cash equivalents
-499
-1,051
Additional information to the statement of cash flows
EURm
1–12/2024
1–12/2023
Interest income received
54
63
Interest expense paid
-66
-72
Dividend income received
768
1,062
1Other adjustments include items related to the acquisition of Topdanmark A/S minority shares and
the sale of the Topdanmark A/S shares to If P&C Insurance Holding Ltd.
FINANCIAL STATEMENTS 2023
273
Sampo plc’s notes to the financial statements
Notes .............................................................................
1 Other operating expenses ...................................
2 Auditors' fees ..........................................................
3 Financial income and expense ..........................
5 Other shares and participations .......................
6 Other investments .................................................
7 Other receivables ...................................................
9 Movements in the parent
company's equity ......................................................
10 Share capital ..........................................................
11 Accruals and deferred income .........................
12 Long-term liabilities .............................................
14 Pension liabilities ..................................................
15 Rental commitments ...........................................
17 Number of personnel ..........................................
18 Salaries and remuneration of the Board
and the Group CEO ..................................................
20 Shares held ...........................................................
FINANCIAL STATEMENTS 2024
274
Sampo plc’s notes to the financial statement
Summary of significant
accounting policies
Sampo plc (business ID 0142213-3) is Sampo Group’s
parent company and a Finnish public company listed in
Helsinki Nasdaq. Sampo has a dual listing in Nasdaq
Stockholm and in Nasdaq Copenhagen. It is domiciled in
Helsinki, and the headquarters are at Fabianinkatu 27,
00100 Helsinki, Finland.
The presentation of Sampo plc’s financial statements
have been prepared in accordance with the Finnish
Accounting Act and Ordinance, and in compliance with 
other regulations on the preparation of financial
statements.
The acquisition of Topdanmark A/S minority
shares and related sale of shares to If P&C
Insurance Holding
On 17 June 2024, Sampo announced that Sampo and
Topdanmark had entered into a combination
agreement, based on which Sampo made a public
exchange offer to acquire all of the outstanding shares
in Topdanmark not already owned by Sampo. The
transaction was completed by the compulsory
acquisition of the remaining Topdanmark minority
shares on 25 October 2024. For more detailed
description of the acquisition, please see Sampo Group
financial statements’ note 28.
In the public offer, minority shareholders were issued, as
a compensation, new Sampo A shares. The share issue
amounting to EUR 2,000 million was recognised in the
invested unrestricted equity. 
In the compulsory acquisition, the total acquisition cost
of the remaining minority shares amounted to EUR 325
million. Compensation was paid in cash.
The measurement of the acquired Topdanmark A/S
shares was based on the compensation given as an
exchange of those shares. The acquisition costs directly
related  to the acquisition were activated to the balance
sheet value of the acquired shares.
After the completion of the acquisition of minority
shares, Sampo plc sold all the issued shares in
Topdanmark A/S to If P&C Insurance Holding Ltd. The
transaction was completed at an arm’s length basis.
The sale price was based on the recent market value
and amounted to EUR 4,659 million. The sale price was
paid in full by way of a loan agreement and a
shareholder’s contribution between Sampo plc and If
P&C Insurance Holding Ltd. The shareholder’s
contribution was recognised as an increase in the
carrying amount of If Holding’s shares in Sampo plc’s
balance sheet.
Partial demerger 2023
The Annual General Meeting of Sampo Group approved
the partial demerger on 17 May 2023.  The partial
demerger was completed as planned on 1 October
2023. In the demerger, all shares in Mandatum Holding
Ltd, amounting to EUR 538 million, were transferred
without a liquidation procedure to Mandatum plc, a
company incorporated in the demerger on the effective
date.
In addition, a part of Sampo's general liabilities, not
allocated to any specific business operations, were
allocated to Mandatum plc. The recognition of a loan
receivable had an impact on the parent company’s
equity amounting to EUR 102 million during the
comparative period.
Foreign currency translation
Foreign currency transactions are translated using the
prevailing exchange rate at the date of transactions or
the average rate for the month. The Balance sheet items
denominated in foreign currencies are translated at the
prevailing rate at the balance sheet date. The exchange
differences are recognised in the income statement.
Non-current assets
Intangible and tangible assets
Intangible and tangible assets are stated at acquisition
cost less depreciation or amortisation.
Investments
In Sampo plc financial instruments are measured in
accordance with Chapter 5 section 2 § of the Finnish
Accounting Act and are part of non-current assets.
Investments are measured at acquisition cost and, in
case there is objective evidence of an impairment, and
the fair value is expected to be permanently lower than
the book value, the impairment is recognised through
profit or loss. Impairment recognition cannot be not
reversed.
FINANCIAL STATEMENTS 2024
275
Derivatives
Financial derivatives held for trading are initially
recognised at fair value. If the difference between the
acquisition value and the fair value at reporting date is
negative, the difference is recognized as a loss for the
period in the income statement and as a liability in the
balance sheet. Positive difference is not recognized.
In addition, interest income and expense as well as
income and expense related to the closing or expiry of a
contract is recognised in the financial income and
expense.
If an interest rate swap or a cross currency interest rate
swap is used to hedge a separate loan or a similar
balance sheet item, and the floating rate cash flows net
each other, the net interest expense of the transaction is
recognised in the income statement, amounting to the
fixed interest rate amount. Also, any potential exchange
rate differences are netted. Financial derivatives are
used only for operational hedging, hedge accounting is
not applied.
Revenue recognition
Revenue is recognised when it occurs.
Financial income and expense
Financial income and expense includes income from
shares in the Group companies, interest income and
expense on investments, and financial derivatives
allocated for the reporting period, sale profits and
losses on investments, income and expense related to
the closing or expiry of derivative contracts, as well as
impairment losses recognized on investments.
Leases
Lease payments are treated as rentals.
Income taxes
The income statement includes the company's income
taxes based on taxable profit for the period. Income tax
includes tax expense based on taxable profit for the
period as well as deferred tax. Tax expense is
recognised in profit or loss except for the items
recognised directly in equity, in which case tax is
recognised accordingly. Tax is adjusted for possible
items related to previous reporting periods.
Risk management
The risk management note 34 includes detailed
information on the risk management.
FINANCIAL STATEMENTS 2024
276
1 Other operating expenses
EURm
1–12/2024
1–12/2023
Rental expenses
-1
-1
IT expenses
-3
-1
External services
-10
-28
Other staff costs
-1
-1
Other
-5
-7
Total
-21
-39
Item Other includes e.g. administration fees.
2 Auditors' fees
EUR thousand
1–12/2024
1–12/2023
Auditing fees
-450
-1,166
CSRD assurance
-137
—
Other fees
-204
-53
Total
-791
-1,219
Auditing fees in 2023 include also fees related to IFRS 17 transition.
3 Financial income and expense
EURm
1–12/2024
1–12/2023
Dividend income
768
1,062
Interest income
67
60
Interest expense
-68
-72
Gains on disposal
1,199
—
Exchange result
14
3
Other
-74
-32
Total
1,905
1,020
The gains on disposal consist of the sale gain of the Topdanmark A/S shares to If P&C
Insurance Holding Ltd, amounting to EUR 1 180 million, and the sale gain from the
shares of Saxo Bank AS, amounting to EUR 18 million.
4 Receivables from Group companies
EURm
2024
2023
Carrying amount at the beginning of the year
—
100
Additions
1,725
—
Disposals
—
-100
Carrying amount at the end of the year
1,725
—
As part of the sale of shares in Topdanmark A/S, Sampo granted a loan of EUR 1,724
million to If Holding, which consisted of EUR nominated facility of EUR 862 million and
DKK nominated facility of DKK 6,432 million (approx. EUR 862 million)
During the comparative period 2023, in connection with the partial demerger,
Mandatum redeemed issued Capital Notes with the nominal value of EUR 100 million.   
5 Other shares and participations
EURm
2024
2023
Acquisition cost 1 January
876
961
Increase
—
7
Decrease
-352
-92
Acquisition cost 31 December
524
876
Decrease in Other shares include the sale of Saxo Bank AS shares of EUR 284 million.
In addition, a permanent impairment of EUR 68 million was recorded into H&F
Evergood partners SA private equity fund.
During the comparative period 2023, in connection with the demerger, Sampo sold
certain financial assets to Mandatum. These assets included holdings in Enento Group,
guarantee shares of Kaleva Mutual Insurance Company and other smaller equity, debt,
and alternative investments.
FINANCIAL STATEMENTS 2024
277
6 Other investments
EURm
2024
2023
Acquisition cost 1 January
706
696
Increase
1,659
2,325
Decrease
-1,886
-2,315
Acquisition cost 31 December
479
706
EURm
2024
2023
Bonds
75 
15 
Money market
303 
590 
Loan receivable
101 
101 
Total
479 
706 
Loan receivable consists of a loan from Mandatum plc in order to allocate general
liabilities due to the demerger in 2023.
7 Other receivables
EURm
2024
2023
Other
25 
20 
Total
25 
20 
Item Other includes derivative guarantees EUR 25 (20) million.
8 Prepayments and accrued income
EURm
2024
2023
Accrued interest
15
2
Other
3
0
Total
18
2
EURm
2024
Fair value
2023
Fair value
Derivatives
Contract
/notional
value
Assets
Liabilities
Contract
/notional
value
Assets
Liabilities
Derivatives held for
trading
Interest rate
derivatives
85
—
25
89
—
20
Total
85
—
25
89
—
20
FINANCIAL STATEMENTS 2024
278
9 Movements in the parent company's equity
Restricted equity
Unrestricted equity
EURm
Share capital
Invested
unrestricted capital
Other reserves
Retained earnings
Total
Carrying amount at 1 January 2023
98
1,527
273
4,916
6,814
Dividends
—
—
—
-1,321
-1,321
Acquisition of own shares
—
—
—
-555
-555
Partial demerger
—
—
—
-539
-539
Loan receivable due to partial demerger
—
—
—
102
102
Profit for the year
—
—
—
963
963
Carrying amount at 31 December 2023
98
1,527
273
3,567
5,465
Restricted equity
Unrestricted equity
EURm
Share capital
Invested
unrestricted capital
Other reserves
Retained earnings
Total
Carrying amount at 1 January 2024
98
1,527
273
3,567
5,465
Dividends
—
—
—
-903
-903
Acquisition of own shares
—
—
—
-475
-475
Directed share issue
—
2,000
—
—
2,000
Profit for the year
—
—
—
1,862
1,862
Carrying amount at 31 December 2024
98
3,527
273
4,051
7,949
As part of the public exchange offer, the owners of Topdanmark’s minority shares were given Sampo A shares in return. The share issue of EUR 2,000 million was recognised in the
invested unrestricted equity fund.
Distributable funds
EURm
2024
2023
Parent company
Profit for the year
1,862
963
Retained earnings
2,189
2,604
Invested unrestricted capital
3,527
1,527
Other reserves
273
273
Total
7,851
5,367
FINANCIAL STATEMENTS 2024
279
10 Share capital
Information on share capital is disclosed in Sampo Group’s note 25 in the consolidated
financial statements.
11 Accruals and deferred income
EURm
2024
2023
Deferred interest
28
29
Derivatives
25
20
Other
19
23
Total
72
71
Additional information on derivatives is included in the note 8.
12 Long-term liabilities
EURm
2024
2023
Bonds
792
959
Subordinated debt securities
1,491
1,490
Total
2,283
2,449
More information can be found in Sampo Group’s consolidated note 22 Financial
liabilities .
13 Deferred tax assets and liabilities
The parent company did not have any deferred tax liability or asset in the balance
sheet at the end of 2024 or 2023.
14 Pension liabilities
The basic and supplementary pension insurance of Sampo plc’s staff is handled
through insurance policies in pension insurance companies in Finland and Sweden.
15 Rental commitments
EURm
2024
2023
Not more than one year
1
1
Over one year but not more than ten years
15
1
Total
16
2
During the reporting period 2024, Sampo plc has signed a ten-year rental agreement
for new office premises commencing in June 2025. 
16 Other liabilities and commitments
Sampo plc has granted a credit facility to Hastings Group Holdings Ltd of GBP 75
million, which will terminate in October 2026. The credit facility was undrawn at the
end of the reporting period. More information is in Sampo Group’s note 22 Financial
liabilities. 
The fund commitments given amounted to EUR 7 (7) million.
17 Number of personnel
2024
Average during
the year
2023
Average during
the year
Full-time personnel
61
54
Part-time personnel
—
1
Temporary personnel
4
—
Total
65
55
FINANCIAL STATEMENTS 2024
280
18 Salaries and remuneration of the Board
and the Group CEO
EUR thousand
2024
2023
Group CEO
Torbjörn Magnusson
4,257
3,139
Members of the Board of Directors
Antti Mäkinen
235
228
Christian Clausen
104
101
Fiona Clutterbuck
—
107
Georg Ehrnrooth
104
107
Jannica Fagerholm
164
159
Johanna Lamminen
—
45
Steve Langan
111
107
Risto Murto
104
101
Markus Rauramo
111
101
Annica Withchard
111
107
Astrid Stange
111
—
In accordance with the decision of the Annual General Meeting in 2024, the company
has compensated the transfer tax related to the acquisition of the company shares, in
total EUR 6,482.75 (EUR 1.758,66 pertaining to the Chairman and EUR 4.724,09 to the
other members of the Board).
19 Pension contributions to the CEO, deputy
CEO and the members of the Board
EUR thousand
Supplementary
pension costs
Statutory
pension costs
Total
Pension contributions paid during the
year
President/CEO1
905
615
1,520
Former Chairmen of the Board
Kalevi Keinänen2
74
—
74
Former Presidents/CEO:s
Harri Hollmen3
186
—
186
Total
1,165
615
1,780
1 The Group CEO is entitled to a supplementary defined contribution pension in accordance with
the present pension contract.
2 Group pension agreement with a retirement age of 60 years and pension benefit of 66 per cent of
the pensionable TyEL-salary (TyEL: Employees’s Pension Act). The payment for 2024 is based on a
TyEL index adjustment.
3 Group pension agreement with a retirement age of 60 years and a pension benefit of 60 per cent
of the pensionable TyEL-salary. The payment for 2024 is based on a TyEL index adjustment.
FINANCIAL STATEMENTS 2024
281
20 Shares held
2024
2023
Company name
Percentage
of share
capital held
Carrying
amount
EURm
Percentage
of share
capital held
Carrying
amount
EURm
Group undertakings
P&C insurance
If P&C Insurance Holding Ltd,
Stockholm, Sweden
100.00
4,820
100.00
1,886
P&C insurance
Topdanmark A/S, Copenhagen,
Denmark
—
—
48.92
1,122
P&C insurance
Hastings Group (Consolidated) Plc,
London, United Kingdom
100.00
2,627
100.00
2,627
Sampo Plc has a branch located in Sweden.
During the financial year, Sampo plc sold the shares of Topdanmark A/S to If P&C
Insurance Holding Ltd. For a more detailed description of the acquisition, please see
Sampo Group financial statements’ note 28.
As part of the sale of Topdanmark A/S shares, Sampo plc granted If P&C Insurance
Holding Ltd a shareholder’s contribution amounting to EUR 2 934 million. If Holding
used the shareholder’s contribution to set off a part of the sale price of the
Topdanmark shares. The shareholder’s contribution was recognised as an increase in
the carrying amount of If Holding’s shares in Sampo plc’s balance sheet.
FINANCIAL STATEMENTS 2024
282
Approval of the Board of Directors’ Report, the Sustainability
Statement and the Financial Statements
The Financial Statements prepared in accordance with the applicable accounting regulations provide a true and fair view of the assets, liabilities, financial position, and profit or loss
of both the company and the entities included in its consolidated financial statements.
The Board of Directors’ Report includes a description of a true and fair view of the development and results of the business activities of both the company and the entities included
in its consolidated financial statements, as well as a description of the most significant risks and uncertainties and other aspects concerning the company.
The Sustainability Statement included in the Board of Directors’ Report has been prepared in accordance with the sustainability reporting standards referred to in Chapter 7 of the
Accounting Act and Article 8 of the Taxonomy Regulation.
                                                                                                                                    Helsinki, 12 March 2025
                                                                Sampo plc
                                                                Board of Directors
Christian Clausen
Georg Ehrnrooth
Jannica Fagerholm
Steve Langan
Risto Murto
Markus Rauramo
Astrid Stange
Annica Witschard
Antti Mäkinen
Chairman
Torbjörn Magnusson
Group CEO
FINANCIAL STATEMENTS 2024
283
Auditor’s note
An auditor's report on the audit performed has been issued today.
Helsinki, 13 March 2025
Deloitte Oy
Audit firm
Jukka Vattulainen
APA
FINANCIAL STATEMENTS 2024
284
Auditor’s Report (Translation of the Finnish Original)
To the Annual General Meeting of Sampo plc
Report on the Audit of
the Financial Statements
Opinion
We have audited the financial statements of Sampo plc
(business identity code 0142213-3) for the year ended
31 December, 2024. The financial statements comprise
the consolidated balance sheet, income statement,
statement of comprehensive income, statement of
changes in equity, statement of cash flows and notes,
including material accounting policy information, as well
as the parent company’s balance sheet, income
statement, statement of cash flows and notes.
In our opinion
• the consolidated financial statements give a true and
fair view of the group’s financial position, financial
performance and cash flows in accordance with IFRS
Accounting Standards as adopted by the EU
• the financial statements give a true and fair view of
the parent company’s financial performance and
financial position in accordance with the laws and
regulations governing the preparation of financial
statements in Finland and comply with statutory
requirements.
Our opinion is consistent with the additional report
submitted to the Audit Committee.
Basis for Opinion
We conducted our audit in accordance with good
auditing practice in Finland. Our responsibilities under
good auditing practice are further described in the
Auditor’s Responsibilities for the Audit of the Financial
Statements section of our report.
We are independent of the parent company and of the
group companies in accordance with the ethical
requirements that are applicable in Finland and are
relevant to our audit, and we have fulfilled our other
ethical responsibilities in accordance with these
requirements.
In our best knowledge and understanding, the non-
audit services that we have provided to the parent
company and group companies are in compliance with
laws and regulations applicable in Finland regarding
these services, and we have not provided any
prohibited non-audit services referred to in Article 5(1)
of regulation (EU) 537/2014. The non-audit services that
we have provided have been disclosed in note 6 to the
consolidated financial statements and in note 2 to the
parent company notes.
We believe that the audit evidence we have obtained is
sufficient and appropriate to provide a basis for our
opinion.
Key Audit Matters
Key audit matters are those matters that, in our
professional judgment, were of most significance in our
audit of the financial statements of the current period.
These matters were addressed in the context of our
audit of the financial statements as a whole, and in
forming our opinion thereon, and we do not provide a
separate opinion on these matters.
We have also addressed the risk of management
override of internal controls. This includes consideration
of whether there was evidence of management bias
that represented a risk of material misstatement due to
fraud.
FINANCIAL STATEMENTS 2024
285
Key Audit Matter
How our audit addressed the Key Audit Matter
Valuation of insurance contract liabilities
We refer to Summary of Material Accounting policies in the financial statements as well
as notes 18 and 19.
As at 31.12.2024 Sampo Group has insurance contract liabilities totalling EUR 12,286
million (2023: EUR 11,716 million), consisting primarily of property and casualty (P&C)
insurance contract liabilities. The measurement of insurance liabilities consists of the
liability for remaining coverage (LRC) and the liability for incurred claims (LIC) including
both reported but not settled claims as well as incurred but not reported claims (IBNR).
The result of management's assessments regarding the calculation of the liability for
incurred claims depends on inputs, the choice of actuarial methods and the precision of
management judgment in determining actuarial assumptions. Key assumptions with the
greatest impact on the carrying amount include inflation, discount rates as well as
estimated future payments for claims.
Valuation of insurance contract liabilities requires significant management judgment and
accounting assumptions about uncertain future events, which may materially affect the
carrying amount, and thus this is a key audit matter.
We have assessed the measurement of the provisions for insurance contracts as
calculated by Management. Our audit procedures included testing of the key controls
relating to valuation of insurance liabilities and key assumptions.
We have involved Deloitte´s actuarial experts together with IFRS 17 subject matter
experts in our audit procedures and evaluated methods and models used by the
management. We have compared the information used in the calculations with the
historical data and we have analysed the developments in risk, interest and cost trends.
We have evaluated management’s significant estimations and judgments and performed
independent calculations based on actuarial methods for a substantial part of the
insurance contract liabilities.
We have evaluated and examined a selection of general IT controls linked to relevant
systems and applications assessed as critical to the data that forms the basis for the
calculation of the liability for incurred claims. On a sample basis we have examined input
data used in the calculations of the liability for incurred claims.
We have assessed the disclosures of the insurance contract liabilities in the financial
statements.
FINANCIAL STATEMENTS 2024
286
Key Audit Matter
How our audit addressed the Key Audit Matter
Valuation of financial assets
We refer to Summary of Material Accounting policies in the financial statements as well
as notes 12-14.
The Group's investments amount to EUR 16,090 million (2023: EUR 15,757 million).
Financial assets represent a significant part of the group's balance sheet.
Major part of the Group's financial assets are measured at fair value. At level 1, the
valuation of the financial asset is based on the quoted price in an active market. Level 2
valuation also uses other verifiable prices as inputs, either directly or derived from them,
using valuation techniques. At level 3, valuation is based on non-observable market data.
Audit focus areas relate to valuations on level 2 and 3 in line with IFRS in which the
valuation techniques include inputs which are not directly observable from the markets.
The use of different valuation techniques and assumptions may result in different
estimates of fair value and hence this is a key audit matter.
Our audit procedures have included the evaluation of the internal controls,
appropriateness of accounting policies used and the reasonableness of accounting
estimates made by management.
We have evaluated the appropriateness of the valuation models and accounting policies
used by the company to assess whether the fair value measurement is in accordance
with generally accepted standards and industry practices. We have requested external
confirmations to verify the existence of the investment.
Together with our valuation specialists, we have assessed the assumptions used by
management in the valuation calculation. We have utilized Deloitte´s valuation analytics
and performed the recalculation of fair values based on the information available on the
market.
For financial assets that are valued on the basis of non-market information, we have also
evaluated the practices and assumptions used by management in determining fair
values.
We have assessed the disclosures of the investments in the financial statements.
There are no significant risks of material misstatement referred to in EU regulation No 537/2014, point (c) of Article 10(2) relating to the parent company’s financial statements.
FINANCIAL STATEMENTS 2024
287
Responsibilities of the Board of
Directors and the Group CEO for
the Financial Statements
The Board of Directors and the Group CEO are
responsible for the preparation of consolidated financial
statements that give a true and fair view in accordance
with IFRS Accounting Standards as adopted by the EU,
and of financial statements that give a true and fair view
in accordance with the laws and regulations governing
the preparation of financial statements in Finland and
comply with statutory requirements. The Board of
Directors and the Group CEO are also responsible for
such internal control as they determine is necessary to
enable the preparation of financial statements that are
free from material misstatement, whether due to fraud
or error.
In preparing the financial statements, the Board of
Directors and the Group CEO are responsible for
assessing the parent company’s and the group’s ability
to continue as a going concern, disclosing, as
applicable, matters relating to going concern and using
the going concern basis of accounting. The financial
statements are prepared using the going concern basis
of accounting unless there is an intention to liquidate
the parent company or the group or cease operations,
or there is no realistic alternative but to do so.
Auditor’s Responsibilities for the
Audit of Financial Statements
Our objectives are to obtain reasonable assurance
about whether the financial statements as a whole are
free from material misstatement, whether due to fraud
or error, and to issue an auditor’s report that includes
our opinion. Reasonable assurance is a high level of
assurance, but is not a guarantee that an audit
conducted in accordance with good auditing practice
will always detect a material misstatement when it
exists. Misstatements can arise from fraud or error and
are considered material if, individually or in the
aggregate, they could reasonably be expected to
influence the economic decisions of users taken on the
basis of the financial statements.
As part of an audit in accordance with good auditing
practice, we exercise professional judgment and
maintain professional skepticism throughout the audit.
We also:
• Identify and assess the risks of material misstatement
of the financial statements, whether due to fraud or
error, design and perform audit procedures
responsive to those risks, and obtain audit evidence
that is sufficient and appropriate to provide a basis
for our opinion. The risk of not detecting a material
misstatement resulting from fraud is higher than for
one resulting from error, as fraud may involve
collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
• Obtain an understanding of internal control relevant
to the audit in order to design audit procedures that
are appropriate in the circumstances, but not for the
purpose of expressing an opinion on the effectiveness
of the parent company’s or the group’s internal
control.
• Evaluate the appropriateness of accounting policies
used and the reasonableness of accounting estimates
and related disclosures made by management.
• Conclude on the appropriateness of the Board of
Directors’ and the Group CEO’s use of the going
concern basis of accounting and based on the audit
evidence obtained, whether a material uncertainty
exists related to events or conditions that may cast
significant doubt on the parent company’s or the
group’s ability to continue as a going concern. If we
conclude that a material uncertainty exists, we are
required to draw attention in our auditor’s report to
the related disclosures in the financial statements or,
if such disclosures are inadequate, to modify our
opinion. Our conclusions are based on the audit
evidence obtained up to the date of our auditor’s
report. However, future events or conditions may
cause the parent company or the group to cease to
continue as a going concern.
• Evaluate the overall presentation, structure and
content of the financial statements, including the
disclosures, and whether the financial statements
represent the underlying transactions and events so
that the financial statements give a true and fair view.
• Plan and perform the group audit to obtain sufficient
appropriate audit evidence regarding the financial
information of the entities or business units within the
group as a basis for forming an opinion on the group
financial statements. We are responsible for the
direction, supervision and review of the audit work
performed for purposes of the group audit. We
remain solely responsible for our audit opinion.
FINANCIAL STATEMENTS 2024
288
We communicate with those charged with governance
regarding, among other matters, the planned scope and
timing of the audit and significant audit findings,
including any significant deficiencies in internal control
that we identify during our audit.
We also provide those charged with governance with a
statement that we have complied with relevant ethical
requirements regarding independence, and
communicate with them all relationships and other
matters that may reasonably be thought to bear on our
independence, and where applicable, related
safeguards.
From the matters communicated with those charged
with governance, we determine those matters that were
of most significance in the audit of the financial
statements of the current period and are therefore the
key audit matters. We describe these matters in our
auditor’s report unless law or regulation precludes
public disclosure about the matter or when, in
extremely rare circumstances, we determine that a
matter should not be communicated in our report
because the adverse consequences of doing so would
reasonably be expected to outweigh the public interest
benefits of such communication.
Other Reporting
Requirements
Information on our audit
engagement
We were first appointed as auditors by the Annual
General Meeting on 19 May, 2021, and our appointment
represents a total period of uninterrupted engagement
of 4 years.
Other information
The Board of Directors and the Group CEO are
responsible for the other information. The other
information comprises the report of the Board of
Directors.
Our opinion on the financial statements does not cover
the other information.
In connection with our audit of the financial statements,
our responsibility is to read the other information and, in
doing so, consider whether the other information is
materially inconsistent with the financial statements or
our knowledge obtained in the audit, or otherwise
appears to be materially misstated. Our responsibility
also includes considering whether the report of the
Board of Directors has been prepared in compliance
with the applicable provisions, excluding the
sustainability report information on which there are
provisions in Chapter 7 of the Accounting Act and in
the sustainability reporting standards.
In our opinion, the information in the report of the
Board of Directors is consistent with the information in
the financial statements and the report of the Board of
Directors has been prepared in compliance with the
applicable provisions. Our opinion does not cover the
sustainability report information on which there are
provisions in Chapter 7 of the Accounting Act and in
the sustainability reporting standards.
If, based on the work we have performed, we conclude
that there is a material misstatement of the report of
the Board of Directors, we are required to report that
fact. We have nothing to report in this regard.
Other opinions
We support that the financial statements should be
adopted. The proposal by the Board of Directors
regarding the use of the profit shown in the balance
sheet is in compliance with the Limited Liability
Companies Act. We support that the Members of the
Board of Directors of the parent company and the
Group CEO should be discharged from liability for the
financial period audited by us.
Helsinki, 13 March 2025
Deloitte Oy
Audit Firm
Jukka Vattulainen
Authorised Public Accountant (KHT)
FINANCIAL STATEMENTS 2024
289
Assurance report on the Sustainability Statement
(Translation of the Finnish Original)
To the Annual General Meeting of Sampo plc
We have performed a limited assurance engagement on
the group sustainability report (“Sustainability
Statement”) of Sampo plc (0142213-3) that is referred
to in Chapter 7 of the Accounting Act and that is
included in the report of the Board of Directors for the
financial year 1.1.–31.12.2024.
Opinion
Based on the procedures we have performed and the
evidence we have obtained, nothing has come to our
attention that causes us to believe that the
Sustainability Statement does not comply, in all material
respects, with
• the requirements laid down in Chapter 7 of the
Accounting Act and the sustainability reporting
standards (ESRS);
• the requirements laid down in Article 8 of the
Regulation (EU) 2020/852 of the European
Parliament and of the Council on the establishment of
a framework to facilitate sustainable investment, and
amending Regulation (EU) 2019/2088 (EU
Taxonomy).
Point 1 above also contains the process in which Sampo
plc has identified the information for reporting in
accordance with the sustainability reporting standards
(double materiality assessment) and the tagging of
information as referred to in Chapter 7, Section 22 of
the Accounting Act.
Our opinion does not cover the tagging of the
Sustainability Statement with digital XBRL sustainability
tags in accordance with Chapter 7, Section 22,
Subsection 1(2), of the Accounting Act, because
sustainability reporting companies have not had the
possibility to comply with that provision in the absence
of the ESEF regulation or other European Union
legislation.
Basis for Opinion
We performed the assurance of the Sustainability
Statement as a limited assurance engagement in
compliance with good assurance practice in Finland and
with the International Standard on Assurance
Engagements (ISAE) 3000 (Revised) Assurance
Engagements Other than Audits or Reviews of
Historical Financial Information.
Our responsibilities under this standard are further
described in the Responsibilities of the Authorised
Group Sustainability Auditor section of our report.
We believe that the evidence we have obtained is
sufficient and appropriate to provide a basis for our
opinion.
Other Matter
We draw attention to the fact that the group
sustainability report (“Sustainability Statement”) of
Sampo plc that is referred to in Chapter 7 of the
Accounting Act has been prepared and assurance has
been provided for it for the first time for the financial
year 1.1.–31.12.2024.
Our opinion does not cover the comparative
information that has been presented in the
Sustainability Statement. Our opinion is not modified in
respect of this matter.
Authorised group sustainability
auditor's Independence and
Quality Management
We are independent of the parent company and of the
Group companies in accordance with the ethical
requirements that are applicable in Finland and are
relevant to our engagement, and we have fulfilled our
other ethical responsibilities in accordance with these
requirements.
The authorised group sustainability auditor applies
International Standard on Quality Management ISQM 1,
which requires the authorised sustainability audit firm to
design, implement and operate a system of quality
management including policies or procedures regarding
compliance with ethical requirements, professional
standards and applicable legal and regulatory
requirements.
FINANCIAL STATEMENTS 2024
290
Responsibilities of the Board of
Directors and the Managing
Director
The Board of Directors and the Managing Director of
Sampo plc are responsible for:
• the Sustainability Statement and for its preparation
and presentation in accordance with the provisions of
Chapter 7 of the Accounting Act, including the
process that has been defined in the sustainability
reporting standards and in which the information for
reporting in accordance with the sustainability
reporting standards has been identified as well as the
tagging of information as referred to in Chapter 7,
Section 22 of the Accounting Act and
• the compliance of the Sustainability Statement with
the requirements laid down in Article 8 of the
Regulation (EU) 2020/852 of the European
Parliament and of the Council on the establishment of
a framework to facilitate sustainable investment, and
amending Regulation (EU) 2019/2088;
• such internal control as the Board of Directors and
the Managing Director determine is necessary to
enable the preparation of a Sustainability Statement
that is free from material misstatement, whether due
to fraud or error.
Inherent Limitations in the
Preparation of a Sustainability
Statement
In preparing the sustainability report, the company is
required to conduct a materiality assessment to identify
relevant matters to be reported. This process involves
significant management judgement and choices. Due to
the nature and characteristics of sustainability
reporting, this type of information involves estimates
and assumptions, as well as measurement and
evaluation uncertainties.
In reporting forward-looking information, management
is required to prepare the forward-looking information
on the basis of disclosed assumptions about events that
may occur in the future and possible future actions by
the Group. The actual outcome is likely to be different
since anticipated events frequently do not occur as
expected.
Responsibilities of the Authorised
Group Sustainability Auditor
Our responsibility is to perform an assurance
engagement to obtain limited assurance about whether
the Sustainability Statement is free from material
misstatement, whether due to fraud or error, and to
issue a limited assurance report that includes our
opinion. Misstatements can arise from fraud or error and
are considered material if, individually or in the
aggregate, they could reasonably be expected to
influence the decisions of users taken on the basis of
the Sustainability Statement.
Compliance with the International Standard on
Assurance Engagements (ISAE) 3000 (Revised)
requires that we exercise professional judgment and
maintain professional scepticism throughout the
engagement. We also:
• Identify and assess the risks of material misstatement
of the Sustainability Statement, whether due to fraud
or error, and obtain an understanding of internal
control relevant to the engagement in order to design
assurance procedures that are appropriate in the
circumstances, but not for the purpose of expressing
an opinion on the effectiveness of the parent
company’s or the Group’s internal control.
• Design and perform assurance procedures responsive
to those risks to obtain evidence that is sufficient and
appropriate to provide a basis for our opinion. The
risk of not detecting a material misstatement resulting
from fraud is higher than for one resulting from error,
as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of
internal control.
Description of the Procedures That
Have Been Performed
The procedures performed in a limited assurance
engagement vary in nature and timing from, and are
less in extent than for, a reasonable assurance
engagement. The nature, timing and extent of
assurance procedures selected depend on professional
judgment, including the assessment of risks of material
misstatement, whether due to fraud or error.
Consequently, the level of assurance obtained in a
limited assurance engagement is substantially lower
than the assurance that would have been obtained had
a reasonable assurance engagement been performed.
FINANCIAL STATEMENTS 2024
291
Our procedures included for example the following:
• Performed inquiries of the company’s management and personnel responsible for
collecting and reporting the information contained in the Sustainability Statement at
the group level and for subsidiaries, as well as at the different levels and business
areas of the organization.
• Obtained an understanding of the company’s sustainability reporting process, internal
controls, and information systems related to the sustainability reporting process
through inquiries.
• Reviewed the supporting documentation and records prepared by the company,
where applicable, and assessed whether they support the information included in the
Sustainability Statement.
• With respect to the double materiality assessment process, we evaluated the
implementation of the process conducted by the company in relation to the
requirements of the ESRS standards and assessed whether the disclosed information
on the double materiality assessment is in accordance with the ESRS standards.
• Evaluated whether the Sustainability Statement  meets the requirements of the ESRS
standards, in all material aspects, regarding material sustainability matters to a
significant extent.
• With respect to the EU taxonomy information, we obtained an understanding of the
process by which the company has identified taxonomy-eligible and taxonomy-
aligned economic activities and assessed the compliance of the related disclosed
information with the regulations.
Helsinki, 13 March 2025
Deloitte Oy
Authorised Sustainability Audit Firm
Jukka Vattulainen
Authorised Sustainability Auditor
FINANCIAL STATEMENTS 2024
292
Independent auditor’s report on the ESEF financial statements
of Sampo plc (Translation of the Finnish Original)
To the Board of Directors of Sampo plc
We have performed a reasonable assurance
engagement on the consolidated financial statement
(743700UF3RL386WIDA22-2024-12-31-fi.zip) of Sampo
plc (0142213-3) that have been prepared in accordance
with the Commission's regulatory technical standard for
the financial year ended 31.12.2024.
Responsibilities of
the board of directors
and the Group CEO
The Board of Directors and the Group CEO are
responsible for the preparation of the company’s report
of the Board of Directors and financial statements (the
ESEF financial statements) in such a way that they
comply with the requirements of the Commission's
regulatory technical standard. This responsibility
includes:
• preparing the ESEF financial statements in XHTML
format in accordance with Article 3 of the
Commission's regulatory technical standard
• tagging the primary financial statements, notes and
company's identification data in the consolidated
financial statements that are included in the ESEF
financial statements with iXBRL tags in accordance
with Article 4 of the Commission's regulatory
technical standard and
• ensuring the consistency between ESEF financial
statements and the audited financial statements.
The Board of Directors and the Group CEO are also
responsible for such internal control as they determine
is necessary to enable the preparation of ESEF financial
statements in accordance with the requirements of the
Commission's regulatory technical standard.
Auditor’s independence and
quality management
We are independent of the company in accordance
with the ethical requirements that are applicable in
Finland and are relevant to the engagement we have
performed, and we have fulfilled our other ethical
responsibilities in accordance with these requirements.
The auditor applies International Standard on Quality
Management (ISQM) 1, which requires the firm to
design, implement, and operate a system of quality
management including policies or procedures regarding
compliance with ethical requirements, professional
standards, and applicable legal and regulatory
requirements.
FINANCIAL STATEMENTS 2024
293
Auditor’s responsibilities
Our responsibility is to, in accordance with Chapter 7,
Section 8 of the Securities Markets Act, provide
assurance on the financial statements that have been
prepared in accordance with the Commission's
regulatory technical standard. We express an opinion
on whether the consolidated financial statements that
are included in the ESEF financial statements have been
tagged, in all material respects, in accordance with the
requirements of Article 4 of the Commission's
regulatory technical standard.
Our responsibility is to indicate in our opinion to what
extent the assurance has been provided. We conducted
a reasonable assurance engagement in accordance with
International Standard on Assurance Engagements
(ISAE) 3000.
The engagement includes procedures to obtain
evidence on:
• whether the primary financial statements in the
consolidated financial statements that are included in
the ESEF financial statements have been tagged, in all
material respects, with iXBRL tags in accordance with
the requirements of Article 4 of the Commission's
regulatory technical standard and
• whether the notes and company's identification data
in the consolidated financial statements that are
included in the ESEF financial statements have been
tagged, in all material respects, with iXBRL tags in
accordance with the requirements of Article 4 of the
Commission's regulatory technical standard and
• whether there is consistency between the ESEF
financial statements and the audited financial
statements.
The nature timing and extent of the selected
procedures depend on the auditor’s judgment. This
includes an assessment of the risk of a material
deviation due to fraud or error from the requirements of
the Commission's regulatory technical standard.
We believe that the evidence we have obtained is
sufficient and appropriate to provide a basis for our
opinion.
Opinion
Our opinion pursuant to Chapter 7, Section 8 of the
Securities Markets Act is that the primary financial
statements, notes and company's identification data in
the consolidated financial statements that are included
in the ESEF financial statements of Sampo plc
(743700UF3RL386WIDA22-2024-12-31-fi.zip) for the
financial year ended 31.12.2024 have been tagged, in all
material respects, in accordance with the requirements
of the Commission's regulatory technical standard.
Our audit opinion on the audit of the consolidated
financial statements of Sampo plc for the financial year
ended 31.12.2024 has been expressed in our auditor’s
report dated 13 March 2025. With this report we do not
express an opinion on the audit of the consolidated
financial statements nor express another assurance
conclusion. 
Helsinki 13 March 2025
Deloitte Oy
Audit Firm
Jukka Vattulainen
APA
Sampo plc (business id 0142213-3) is a Finnish public company listed in Helsinki Nasdaq. It is domiciled in Helsinki and the headquarters are at Fabianinkatu 27, 00100 Helsinki, Finland. The consolidated
financial statements of Sampo Group include Sampo plc together with its subsidiaries and associates as of 31 December 2022. The group subsidiaries have insurance and financing activities in Finland,
Sweden, Norway, Denmark, the Baltic countries, and the United Kingdom. A copy of Group’s financial statements is available at internet address www.sampo.com. Copyright Sampo plc, Finland.