743700UF3RL386WIDA22-2025-12-31-1-en

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
• the 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 effectiveness and efficiency of Sampo
Group’s internal audit function and reporting

• the Sampo Group Internal Audit plan, and the
Internal Audit policy
• 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 and the sustainability reporting assurance
provider’s election and their fees.

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

Auditor’s Report

≡

the financial statements

Sampo plc’s notes to

the financial statements

Contents


Board of Directors’ Report 2025 ...........................	3
Review of the 2025 financial year .........................	4
Financial overview .......................................................	6
Outlook ............................................................................	7
Operating environment and assumptions ......	7
Outlook for 2026 .....................................................	7
The major risks and uncertainties for the Group in the near-term .........................................	8
Dividend proposal ........................................................	9
Operating environment ..............................................	10
Segments .........................................................................	12
Private Nordic ..........................................................	12
Private UK ..................................................................	13
Nordic Commercial .................................................	14
Nordic Industrial ......................................................	15
Net financial result and other items .......................	16
Financial position ..........................................................	17
Group solvency ........................................................	17
Financial leverage position ..................................	17
Ratings ........................................................................	18
Other developments ...................................................	19
Changes to the Group Executive Committee .................................................................	19
Group Partial Internal Model ...............................	19
Sale of shares in NOBA Group ...........................	19
Changes in the Group’s financial debt .............	19
Conversion of Sampo’s Swedish Depositary Receipts ......................................................................	20
Proposals to the AGM of 2026 ...........................	20


Shares, share capital and shareholders ................	21
Shares and share capital .......................................	21
Shareholders .............................................................	23
Holdings of the Board and Executive Management .............................................................	24
Share buyback programmes ...............................	24
Events after the end of the reporting period .....	25
Update to Sampo’s distribution policy ............	25
Share buyback programme .................................	25
Issuance of new Restricted Tier 1 notes ..........	25
Reduction of ownership in NOBA Group .......	25
Corporate Governance Statement ...................	26
Governance in Sampo plc ....................................	27
Changes in Group structure ................................	28
General meeting ......................................................	30
Board of Directors ..................................................	32
Board-appointed committees ............................	38
Sampo Group CEO .................................................	41
Sampo Group Executive Committee ...............	42
Remuneration ...........................................................	47
Personnel ...................................................................	48
Internal control in Sampo Group .......................	49
Sustainability Statement .....................................	56
General information ...............................................	57
Environmental information ..................................	72
Social information ...................................................	94
Governance information .......................................	121
Annexes ......................................................................	125


Key figures .....................................................................	132
Calculation of key figures ..........................................	135
Group’s IFRS Financial Statements ......................	138
Statement of profit and other comprehensive income .........................................	139
Consolidated balance sheet ................................	140
Statement of changes in equity .........................	141
Statement of cash flows .......................................	142
Group’s notes to the financial statements ...	143
Summary of material accounting principles ..	144
Segment information .............................................	159
Geographical information ....................................	164
Other notes ...............................................................	165
Sampo plc’s Financial Statements ........................	240
Sampo plc’s income statement ..........................	241
Sampo plc’s balance sheet ..................................	242
Sampo plc’s statement of cash flows ..............	243
Sampo plc’s notes to the financial statements .................................................................	244
Approval of the Board of Directors’ Report, the Sustainability Statement and the Financial Statements ..................................................	253
Auditor’s note ................................................................	254
Auditor’s Report ..........................................................	255
Assurance report on the Sustainability Statement ........................................................................	260
Independent auditor’s report on the ESEF financial statements of Sampo plc ......	263

REPORTS FOR THE YEAR 2025

WWW.SAMPO.COM/YEAR2025


	BOARD OF DIRECTORS’ REPORT 2025	3

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Board of Directors’ Report 2025


Review of the 2025 financial year ..........................................................................	4
Financial overview .........................................................................................................	6
Outlook ...............................................................................................................................	7
Operating environment and assumptions .................................................................	7
Outlook for 2026 ................................................................................................................	7
The major risks and uncertainties for the Group in the near-term ...................	8
Dividend proposal ..........................................................................................................	9
Operating environment ...............................................................................................	10
Segments ...........................................................................................................................	12
Private Nordic ......................................................................................................................	12
Private UK .............................................................................................................................	13
Nordic Commercial ............................................................................................................	14
Nordic Industrial .................................................................................................................	15
Net financial result and other items .......................................................................	16
Financial position ...........................................................................................................	17
Group solvency ...................................................................................................................	17
Financial leverage position .............................................................................................	17
Ratings ...................................................................................................................................	18
Other developments .....................................................................................................	19
Changes to the Group Executive Committee ..........................................................	19
Group Partial Internal Model ..........................................................................................	19
Sale of shares in NOBA Group .......................................................................................	19
Changes in the Group’s financial debt ........................................................................	19
Conversion of Sampo’s Swedish Depositary Receipts .........................................	20
Proposals to the AGM of 2026 ......................................................................................	20
Shares, share capital and shareholders .................................................................	21
Shares and share capital ..................................................................................................	21
Shareholders ........................................................................................................................	23
Holdings of the Board and Executive Management ..............................................	24
Share buyback programmes ..........................................................................................	24
Events after the end of the reporting period ......................................................	25
Update to Sampo’s distribution policy .......................................................................	25
Share buyback programme ............................................................................................	25
Issuance of new Restricted Tier 1 notes .....................................................................	25
Reduction of ownership in NOBA Group ...................................................................	25


Corporate Governance Statement ..........................................................................	26
Governance in Sampo plc ...............................................................................................	27
Changes in Group structure ...........................................................................................	28
General meeting .................................................................................................................	30
Board of Directors ..............................................................................................................	32
Board-appointed committees ........................................................................................	38
Audit Committee ...........................................................................................................	39
Nomination and Remuneration Committee .........................................................	40
Sampo Group CEO ............................................................................................................	41
Sampo Group Executive Committee ...........................................................................	42
Remuneration ......................................................................................................................	47
Personnel ...............................................................................................................................	48
Internal control in Sampo Group ..................................................................................	49
Reporting .........................................................................................................................	49
Risk management .........................................................................................................	50
Principles for related party transactions ..............................................................	54
Internal audit ...................................................................................................................	55
External auditor .............................................................................................................	55
Sustainability Statement ............................................................................................	56
General information ...........................................................................................................	57
ESRS 2 General disclosures .......................................................................................	57
Environmental information .............................................................................................	72
EU Taxonomy .................................................................................................................	72
E1 Climate change .........................................................................................................	77
E5 Resource use and circular economy ................................................................	91
Social information ..............................................................................................................	94
S1 Own workforce .........................................................................................................	94
S2 Workers in the value chain ..................................................................................	107
S4 Consumers and end-users ...................................................................................	113
Governance information ..................................................................................................	121
G1 Business conduct ....................................................................................................	121
Annexes .................................................................................................................................	125
Key figures .......................................................................................................................	132
Calculation of key figures ...........................................................................................	135


	BOARD OF DIRECTORS’ REPORT 2025	4

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Board of Directors’ Report 2025

Review of the 2025 financial year

Sampo Group delivered strong results in 2025,

supported by broad-based growth across private

and SME lines and disciplined underwriting in a

favourable claims environment. The underwriting

result strengthened by 12 per cent on a currency

adjusted basis to EUR 1,485 million, driving an

operating EPS growth of 7 per cent.

Gross written premiums (GWP), including brokerage

income, grew by 8 per cent both on a like-for-like basis

and a reported basis to EUR 10,738 million (9,931) in

2025. Insurance revenue, including brokerage income,

stood at EUR 9,078 million (8,386), representing 8 per

cent growth.

The Group’s private businesses both in the Nordics and

the UK continued to perform well, more than offsetting

softer development seen within large corporates. Private

Nordic delivered like-for-like GWP growth of 8.5 per

cent on the back of high retention, rate actions, and

continued positive development across growth areas.

Personal insurance grew by 11 per cent, while private

property increased by 6 per cent. Motor recorded 10 per

cent growth, benefiting from a recovery in Nordic new

car sales, albeit from low levels. Digital sales continued

to show strong momentum, growing by 15 per cent and

hitting the EUR 175 million operational ambition a full

year ahead of schedule, originally set for 2026.

Geographically, Norway stood out, with 16 per cent

growth, driven by strong new sales and high retention.

Private UK reported solid development, delivering 13.0

per cent top-line growth on a like-for-like basis,

supported by growth in home insurance, selective

expansion in higher premium motor segments, and

stronger retention in a softer pricing environment. UK

live customer policy (LCP) count increased to 4.5

million, up 16 per cent, driven by growth in telematics,

bike, van, and home insurance.

Nordic Commercial reported like-for-like GWP growth of

5.9 per cent. The growth was supported by continued

strong development in personal insurance and SME.

Personal insurance grew by 13 per cent and SME

increased by 7 per cent. Meanwhile, retention remained

high and broadly stable with solid renewals and a

growing customer base. Digital sales increased by 15 per

cent. In Nordic Industrial, the intentional de-risking of

large property exposures, combined with more

competitive market conditions and lower project

insurance, led to a -3.0 per cent like-for-like GWP decline.

The Group combined ratio improved by 0.7 percentage

points to 83.6 per cent (84.3), supported by lower large

and weather claims. In the Nordics, the claims

environment was favourable throughout the first nine

months of 2025, reflecting benign weather conditions

and a large claims outcome better than budget. In the

fourth quarter, severe storm activity led to elevated

claims. As a result, severe weather and large claims had

a positive effect of 0.7 percentage points on the Nordic

risk ratio, representing a material benefit compared to

the 3.4 percentage points negative effect in the

comparison period. Further, the underlying trend

remained positive with a 0.3 percentage points

improvement in the Nordic underlying risk ratio. In the

UK, underwriting margins were affected by the softer

pricing environment but in line with target levels.

The Group cost ratio increased by 0.1 percentage points

to 25.4 per cent (25,3). Meanwhile, the Nordic operating

cost ratio improved by 0.1 percentage points, or by 0.4

percentage points if corporate centre costs in

Topdanmark had been fully included in the prior year,

hence improving in line with targets. The Topdanmark

integration has been progressing well, and synergies

have emerged somewhat ahead of schedule. Following

a detailed assessment, the estimated run-rate synergies

were increased from the original EUR 95 million to EUR

140 million pre-tax for 2028 on 7 May 2025. By the end

of 2025, EUR 37 million of the targeted synergies were

realised.

The underwriting result increased by 12 per cent on a

currency adjusted basis and by 13 per cent on a

reported basis to EUR 1,485 million (1,316), supported by

solid top-line growth, a favourable claims experience,

and the successful delivery of Topdanmark synergies.

The net financial result increased to EUR 1,210 million

(636), driven by net investment income, primarily due

to a EUR 540 million net gain, including FX effects, on

the Group’s ownership in NOBA, as well as the

insurance finance income or expense being materially

better than in the comparison period.


	BOARD OF DIRECTORS’ REPORT 2025	5

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Operating EPS increased by 7 per cent to EUR 0.50 (0.47) on the back of a higher

underwriting result.

The Group Solvency II coverage, net of the proposed dividend, stood at 174 per cent,

down from 177 per cent at the end of 2024. Financial leverage amounted to 23.6 per

cent at the year-end, down from 26.9 per cent at the end of 2024. Sampo targets a

solvency ratio of 150–190 per cent and a financial leverage of below 30 per cent.

On 2 July 2025, following the legal merger of If and Topdanmark, Sampo filed an

application to the Swedish FSA (Finansinspektionen) to extend the Group’s Partial

Internal Model to include the operations previously under Topdanmark. The update in

the Group’s Partial Internal Model is expected to be approved in the spring 2026, and it

is estimated to reduce the group-level solvency capital requirement by around EUR

60-90 million.

On 5 November, Sampo’s Board of Directors decided to raise the Group’s operating

EPS growth target to more than 9 per cent from more than 7 per cent annually on

average for 2024-2026. The increase reflected Sampo’s strong operational

performance and execution of its P&C focused strategy since the start of 2024, but

also the confidence in the outlook into 2026.

On 5 February 2026, Sampo plc’s Board of Directors proposed a regular dividend of

EUR 0.36 per share for 2025 to the Annual General Meeting to be held on 22 April

2026. This represents an increase of 6 per cent compared with the prior year regular

dividend of EUR 0.34 per share.

In 2025, Sampo repurchased its own A shares under two different buyback

programmes based on the authorisation granted by the Annual General Meeting of

2025. In total, Sampo repurchased 29.4 million shares for EUR 290 million in 2025,

corresponding to approximately 1.1 per cent of cent of all shares based on the share

count prior to the start of the programmes.

In its outlook for 2026, Sampo expects to deliver insurance revenue of EUR 9.5-9.8

billion, representing growth of 5-8 per cent and an underwriting result of EUR

1,485-1,600 million, implying a growth of 0-8 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 9 per cent on average over 2024-2026.

Key figures

Sampo Group


EURm	2025	2024	Change, %
Gross written premiums	10,738	9,931	8
Insurance revenue, net	9,078	8,386	8
Underwriting result	1,485	1,316	13
Net financial result	1,210	636	90
Profit before taxes	2,436	1,559	56
Net profit	1,998	1,154	73
Operating result	1,343	1,193	13
Earnings per share (EUR)	0.74	0.45	65
Operating EPS (EUR)	0.50	0.47	7

	2025	2024	Change
Risk ratio, %	58.3	59.0	-0.7
Cost ratio, %	25.4	25.3	0.1
Combined ratio, %	83.6	84.3	-0.7
Solvency II ratio (incl. dividend accrual), %	174	177	-3

Gross written premiums (GWP) and insurance revenue include broker revenues. Like-for-like GWP

growth is calculated by using constant currency rates and it is adjusted to exclude potential

technical items affecting comparability, such as portfolio transfers, changes in inception dates for

large contracts, and changes in accounting methods. Net profit for the comparison period refers to

Net profit for the equity holders. Per share figures for the comparison period are adjusted for the

share split in February 2025.


	BOARD OF DIRECTORS’ REPORT 2025	6

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Financial overview


		2025	2024
Gross written premiums (incl. brokerage)	EURm	10,738	9,931
Insurance revenue (incl. brokerage), net	EURm	9,078	8,386
Claims incurred, net	EURm	-5,290	-4,948
Operating expenses and claims handling costs	EURm	-2,302	-2,122
Underwriting result	EURm	1,485	1,316
Net investment income	EURm	1,285	888
Net insurance finance income or expense	EURm	-74	-252
Net financial result	EURm	1,210	636
Other items	EURm	-259	-392
Profit before taxes	EURm	2,436	1,559
Net profit	EURm	1,998	1,154

Key figures
Earnings per share	EUR	0.74	0.45
Operating EPS	EUR	0.50	0.47
Risk ratio	%	58.3	59.0
Cost ratio	%	25.4	25.3
Combined ratio	%	83.6	84.3
Nordic operating cost ratio	%	22.6	22.7
Like-for-like GWP growth	%	8	12
Solvency II ratio (incl. dividend accrual)	%	174	177
Financial leverage	%	23.6	26.9
Return on equity own funds	%	32.3	29.5
Number of shares (end of reporting period)	Millions	2,662	2,691
Average number of shares	Millions	2,685	2,561


		2025	2024
Nordic underlying development
Risk ratio	%	59.8	61.0
-Large claims	%	-1.1	1.2
-Severe weather	%	0.4	2.2
-Prior year development, risk adjustment and other technical effects	%	-0.1	-3.5
-Discounting effect, current year	%	-2.9	-2.8
Underlying risk ratio	%	63.5	63.8

Segments
Private Nordic
Insurance revenue, net	EURm	3,995	3,667
Underwriting result	EURm	715	628
Combined ratio	%	82.1	82.9
Private UK
Insurance revenue (incl. brokerage), net	EURm	2,000	1,659
Underwriting result	EURm	216	190
Combined ratio	%	89.2	88.5
Live customer policies	Millions	4.5	3.9
Nordic Commercial
Insurance revenue, net	EURm	2,201	2,128
Underwriting result	EURm	376	352
Combined ratio	%	82.9	83.5
Nordic Industrial
Insurance revenue, net	EURm	584	657
Underwriting result	EURm	109	74
Combined ratio	%	81.3	88.7


	BOARD OF DIRECTORS’ REPORT 2025	7

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Outlook

Operating environment and

assumptions

Operating conditions across Sampo’s business footprint

remain broadly stable with increasing customer

adoption of digital solutions across sales, service, and

claims both in direct channels and partnerships. This

enables the Group to continue to execute on its organic

growth strategy. In general, competitive dynamics in

the private businesses remain supportive albeit with

some variation by markets, with Norway still the most

favourable, while the UK has continued to see falling

market pricing that makes growth at target margins

increasingly challenging in the short-term. Competitive

conditions in the Nordic SME market remains stable,

while the large commercial segment saw an increase in

price competition over 2025, which is expected to carry

into 2026.

Following several years of relatively high levels of

claims inflation, underlying claims cost trends have

returned to long-term average levels across Sampo’s

major markets, with only Norway still somewhat

elevated. However, the Nordics have seen wintry

weather conditions at the beginning of 2026, creating

some uncertainty around severe weather claims costs

for the first quarter. Sampo’s outlook is based on a

range of assumed outcomes on weather, large claims,

prior year development, and discount rates around

expected budget levels with the lower end representing

a materially adverse outcome on one or several

variables.

Sampo remains a disciplined underwriter, firmly

committed to reflecting expected claims cost

development in its pricing. Underwriting margins in

2026 are expected to benefit from synergies related to

the integration of Topdanmark into the Group, driving

profit and Nordic cost ratio improvements in line with

communicated operational ambitions.

Outlook for 2026

The outlook for Sampo Group’s 2026 financial

performance is:

• Group insurance revenue: EUR 9.5–9.8 billion,

representing growth of 5–8 per cent year-on-year.

• Group underwriting result: EUR 1,485–1,600 million,

representing growth of 0-8 per cent year-on-year.

Any forecast of Sampo’s underwriting result is subject

to estimates for weather claims, large claims, prior year

development, and certain other items that may vary

periodically and are out of Sampo’s control, meaning

regular updates of the forecast are needed to reflect

actual outcomes. Moderate deviations against normal

and budget levels are typical on a quarterly basis, and

Sampo intends to broadly reflect these in the outlook

statement in its quarterly reports. In addition to the

underwriting result, Sampo derives a material share of

its earnings from returns on its investment portfolio and

insurance finance income and expense, meaning

changes in the outlook cannot be assumed to translate

one-for-one into net profit. Sampo does not provide an

outlook for its net financial result.

The outlook for 2026 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 9 per cent annually on average. The

outlook is subject to uncertainty related to occurrence

and estimation of the cost of P&C claims, 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 currency exchange rates as of the latest reporting

date.

A full explanation of the alternative performance

metrics used in the Outlook can be found in the section

Calculation of key figures.


	BOARD OF DIRECTORS’ REPORT 2025	8

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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, the 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.

Euro area inflation is currently expected to stay close to

the central bank target. However, the future

development of consumer prices is uncertain. The

impact of trade restrictions on inflationary pressures has

remained muted but may intensify again, and energy

prices continue to be vulnerable to geopolitical events.

Furthermore, domestic price pressures could continue

to keep inflation elevated unless labour markets

continue to loosen as currently expected. This in turn

creates uncertainty on the future path for interest rates.

At the same time, trade disputes are expected to

depress economic growth in Europe as investments and

consumption are held back. These developments 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, geopolitical risks may have major

economic effects. 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.

Other sources of uncertainty are unforeseen structural

changes in the business environment and already

identified trends and potential wide-impact events,

sometimes also driven by regulatory uncertainty. 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 2025	9

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Dividend proposal

Sampo plc’s dividend policy, that was applied for 2025,

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 2025 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 2025 amounted to

EUR 1,343 million. The parent company’s distributable

capital and reserves totalled EUR 8,150 million of which

profit for the financial year 2025 was EUR 1,504 million.

Based on the policies outlined above, the Board

proposes to the Annual General Meeting that a total

dividend of EUR 0.36 per share be paid, except for any

shares held by Sampo plc on the dividend record date

of 24 April 2026. The Board proposal to the Annual

General Meeting corresponds to a total dividend of EUR

956 million in the aggregate, equating to a payout ratio

of 71 per cent of the Group’s operating result for the

financial year 2025. The remainder of the distributable

funds are left in the company’s equity capital. After

adjusting for the proposed dividend, the parent

company’s 2025 year-end distributable funds amounted

to approximately EUR 7,194 million and Group Solvency

II ratio to 174 per cent. The Group’s 2025 year-end

financial leverage was 23.6 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 in Finland,

Euroclear Sweden AB in Sweden or VP Securities A/S in

Denmark as at the record date of 24 April 2026. For

shareholders whose shares are registered with

Euroclear Finland Oy, the payment date is on 5 May

2026.

For shareholders whose shares are registered outside

Finland, the dividend is paid in accordance with the

practices of Euroclear Sweden AB and VP Securities

A/S, and may occur at a later date.

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 2025	10

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Operating environment

Nordic countries

Historically, the Nordic P&C market has delivered strong

profitability and lower combined ratios than other

European markets, a trend that continued in 2025

supported by a disciplined competitive environment.

After several years focused on managing elevated

claims inflation, several major insurers are now placing

clearer emphasis on profitable growth, backed by

strong underwriting performance and ample capacity.

As part of this shift, insurers are increasingly directing

growth efforts toward selected segments, particularly

SME and personal lines continued to be focus areas for

many players.

The Nordic P&C market remains highly concentrated,

with a small number of large insurers holding strong

cross‑Nordic positions and contributing to stable

competitive dynamics. In both Sweden and Norway, the

four largest companies account for more than 80 per

cent of the non-life market, while in Finland the top four

control 90 per cent. Even after recent mergers and

acquisitions, the Danish market remains less

concentrated than its Nordic peers. It is still dominated

by a limited number of major insurers, with the top four

controlling around 70 per cent.

After several years of elevated claims inflation,

underlying claims costs in the Nordic markets have

begun moving back toward longer run averages.

Although overall inflation declined, claims trends

differed between markets and product segments, with

Norway remaining somewhat higher than the rest.

Property claims inflation was moderate, while motor

claims inflation stabilised and began to ease during the

year, supported by favourable currency exchange rate

movements. Despite the more favourable claims

inflation environment, price increases aimed at

addressing the higher cost levels of recent years

continued, with insurers implementing notable

adjustments in areas where rate adequacy had

previously lagged.

The claims environment across the Nordics was

favourable through the first three quarters of 2025.

After a very harsh winter in 2024, weather conditions

were largely typical for the season in 2025, with only

localised severe events in the last quarter of the year

with several storms affecting the region. The most

notable were Storm Amy in October, which primarily

impacted Norway, and Storm Johannes (referred to as

Hannes in Finland) in late December, which hit Finland

the hardest. Despite this relatively benign year,

climate‑related risks remain a growing concern for

Nordic insurers, as the increasing frequency of severe

weather events is expected to place long‑term upward

pressure on property claims and premiums.

During the year, competitive dynamics in both private

and commercial segments remained supportive,

although there were some market‑specific differences,

with Norway still the most favourable. Retention

remained strong among larger players, supported by

high brand loyalty and stable customer demand.

Historically strong Nordic retention levels between 85

and 90 per cent were maintained in 2025.

The large corporate market continued to soften during

the year, driven by ample capacity and improved

reinsurance conditions. Competition intensified as

insurers sought high‑quality risks, while underwriting

discipline remained firmly applied in higher‑risk

segments.

The Nordic region remains one of the most digitally

advanced insurance markets with insurers continuing to

invest in technology and innovation. Digitalisation and

automation further strengthened the customer

experience and retention, while AI‑driven tools became

even more deeply embedded in underwriting and

claims processes. Throughout the year, the region

sustained its position as a frontrunner in adopting

advanced digital solutions, reflecting ongoing progress

in operational efficiency and service quality.

Nordic new car sales increased by 10 per cent during

the year but remained comparatively modest. Sales

developments varied across the countries, with weaker

economic conditions, cautious consumer sentiment,

delivery challenges, and product‑portfolio shifts among

certain manufacturers contributing to subdued

underlying demand. In Norway, sales strengthened

toward year‑end as consumers brought forward

purchases amid uncertainty about potential changes to

EV incentives. Across the region, the ageing vehicle

fleet remains a challenge, as several years of low

new‑car sales have shifted the mix toward older

vehicles with implications for claims trends.


	BOARD OF DIRECTORS’ REPORT 2025	11

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

United Kingdom

The UK motor claims environment was broadly neutral

during 2025. Claims cost inflation reduced slightly

during the year and is now broadly in line with historical

average trends, and below the peak seen in 2023.

Claims frequency has seen a small uptick from 2024,

which was a benign year, but is still below the long-term

average partially due to driving behaviour. Whilst motor

experienced frequency benefit from mild weather,

home claims did see an uptick in subsidence claims as a

result of the prolonged dry summer.

As result of these claims cost patterns, premiums in the

competitive UK market continued to soften during

2025, as insurers passed on the benefits 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.


	BOARD OF DIRECTORS’ REPORT 2025	12

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Segments

Private Nordic

Sampo operates in the Nordic private insurance market through a number of

brands including If, Topdanmark, Volvia, and other white-label partnerships. Its

business model is based on high customer satisfaction and leveraging the

benefits from digital sales and service capabilities. In total, the Group serves

around 3.7 million households in Sweden, Denmark, Norway, and Finland.

Results

Private Nordic, 2025


EURm	2025	2024	Change, %
Gross written premiums	4,183	3,872	8
Insurance revenue, net	3,995	3,667	9
Claims incurred, net	-2,431	-2,226	9
Operating expense (incl. claims handling costs)	-849	-814	4
Underwriting result	715	628	14

Key ratios	2025	2024	Change
Like-for-like GWP growth, %	8.5	—	—
Risk ratio, %	60.9	60.7	0.2
Cost ratio, %	21.2	22.2	-1.0
Combined ratio, %	82.1	82.9	-0.8

All key figures in the table above are calculated on a net basis. Education and development costs

are included in the cost ratio.

Premium development

In 2025, Private Nordic delivered GWP growth of 8.5 per cent on a like-for-like basis.

The growth was primarily driven by high customer retention, rate actions to cover

claims inflation, and continued positive development in growth areas. Personal

insurance saw growth of 11 per cent year-on-year, while private property grew by 6 per

cent, meaning both product lines performed ahead of the operational ambition.

In motor insurance, GWP grew by 10 per cent, benefiting from the rebound in Nordic

new car sales, albeit from low levels. Nordic new car sales rose 10 per cent in 2025,

driven by strong year-end demand in Norway due to the announced VAT changes.

Meanwhile, Sweden, Private Nordic’s largest market for mobility, remained stagnated

and saw only 1 per cent growth.

Geographically, all countries recorded positive GWP growth during the year. Norway

led the development with a 16 per cent increase, driven by rate adjustments combined

with strong new sales and high retention, resulting in growth in both customer

numbers and insured objects.

The momentum in digital sales continued to be strong over the year with growth of 15

per cent year-on-year. This led to achieving the operational ambition of EUR 175 million

for 2026 a full year ahead of schedule. Meanwhile, the share of online claims increased

to 66 per cent in December, compared with 64 per cent for 2024.

Despite rate actions to mitigate the effects of claims inflation, the retention rate

remained at the target level of >89 per cent (89), with a growing customer base.

Throughout the year, customer satisfaction for Private Nordic remained consistently

high, reflecting a solid and consolidated trend.

Underwriting performance

The underwriting result increased by 14 per cent to EUR 715 million (628) in 2025, and

the combined ratio improved to 82.1 per cent (82.9). The positive development was

supported by a stable risk ratio of 60.9 per cent (60.7). The year was characterised by

favourable weather conditions and claims frequency development, except for the

fourth quarter, which was impacted by two storms. The cost ratio for 2025 improved

to 21.2 per cent (22.2) supporting the targeted efficiency improvements at Nordic level

for the year.


	BOARD OF DIRECTORS’ REPORT 2025	13

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Private UK

Sampo operates in the UK private insurance market through its brand Hastings,

which is one of the leading digital P&C insurance providers focused on UK car,

van, bike, and home insurance. The Group serves over 4 million UK customers

and is specialised in price comparison distribution, advanced pricing, anti-fraud,

and digital capabilities.

Results

Private UK, 2025


EURm	2025	2024	Change, %
Gross written premiums	2,865	2,565	12
Insurance revenue, net	2,000	1,659	21
Claims incurred, net	-1,073	-868	24
Operating expense (incl. claims handling costs)	-712	-601	19
Underwriting result	216	190	13

Key ratios	2025	2024	Change
Like-for-like GWP growth, %	13.0	—	—
Risk ratio, %	53.6	52.3	1.3
Cost ratio, %	35.6	36.2	-0.6
Combined ratio, %	89.2	88.5	0.7

Gross written premiums and insurance revenue include broker revenues. All key figures in the table

above are calculated on a net basis.

Premium development

Private UK recorded a 13.0 per cent year like-for-like growth in GWP (including

brokerage), with a higher policy count being offset against the earned impact of lower

market-wide rates. Growth in home products and selective expansion in higher

premium motor segments supported new customer acquisition, while reduced

consumer movement within a declining‑price environment contributed to stronger

policy renewal levels.

Insurance revenue rose by 21 per cent year-on-year, driven by the combined effect of

growth in the customer base and continued earning through pricing increases from the

prior year. In total, live customer policies increased to 4.5 million, representing 16 per

cent growth year-on-year. This was driven by motor growing by 13 per cent, while

home recorded a policy growth of 27 per cent.

Underwriting performance

The underwriting result increased by 13 per cent to EUR 216 million (190) in 2025,

reflecting a modest increase in the combined ratio on higher net insurance revenue.

The risk ratio increased by 1.3 percentage points year-on-year to 53.6 per cent (52.3),

with claims frequencies and severities tracking broadly in line with historically

observed rates, and with common seasonal variances in the fourth quarter. The Group

continued to adopt a highly conservative reserving approach during the year.

Operating costs increased by 19 per cent compared with the previous year. This was

primarily driven by higher acquisition outflows linked to new policy growth, together

with continued investment in service infrastructure and digital development. These

investments have contributed towards record-high levels of customer satisfaction and

reduced levels of customer complaints. In addition, the cost ratio reduced by 0.6

percentage points to 35.6 per cent (36.2) for the year as operating leverage begins to

be visible. As a result of the above movements in the risk ratio and the cost ratio, there

was a slight increase in the combined ratio for the period from 88.5 per cent to 89.2

per cent.


	BOARD OF DIRECTORS’ REPORT 2025	14

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Nordic Commercial

Sampo operates in the Nordic commercial insurance market through its brands

If, Topdanmark, and Dansk Sundhedssikring (Oona Health) with a particular

focus on SMEs. In total, the Group serves around 460,000 commercial

customers in Sweden, Denmark, Norway, and Finland.

Results

Nordic Commercial, 2025


EURm	2025	2024	Change, %
Gross written premiums	2,391	2,173	10
Insurance revenue, net	2,201	2,128	3
Claims incurred, net	-1,285	-1,254	3
Operating expense (incl. claims handling costs)	-539	-522	3
Underwriting result	376	352	7

Key ratios	2025	2024	Change
Like-for-like GWP growth, %	5.9	—	—
Risk ratio, %	58.4	58.9	-0.5
Cost ratio, %	24.5	24.5	—
Combined ratio, %	82.9	83.5	-0.5

All key figures in the table above are calculated on a net basis. Education and development costs

are included in the cost ratio.

Premium development

In 2025, Nordic Commercial delivered like-for-like GWP growth of 5.9 per cent. The

positive development was supported by solid renewals and rate actions to mitigate

claims inflation but was partly offset by effects from de-risking and adjustment

premiums related to workers’ compensation. The top-line development was supported

by continued strong development in personal insurance, and growth of 7 per cent in

the SME portfolio. Growth was particularly strong in Norway driven by repricing and

volume. The retention rate remained high and largely stable throughout the year,

accompanied by a growing customer base.

In 2025, digital sales increased by 15 per cent year-on-year, in line with the ambition.

There was also strong momentum in online claims and self-service solutions as

customers continued to increasingly engage through digital channels.

Underwriting performance

During 2025, the underwriting result increased by 7 per cent to EUR 376 million (352),

and the combined ratio improved to 82.9 per cent (83.5). This positive development

for the year was supported by an improved risk ratio of 58.4 per cent (58.9), reflecting

less frequency claims and favourable large claims development relative to budget. The

cost ratio was unchanged compared to last year and stood at 24.5 per cent (24.5).


	BOARD OF DIRECTORS’ REPORT 2025	15

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Nordic Industrial

Sampo is the leading insurer of large corporates in the Nordics through the If

brand. Corporates with turnover of more than SEK 500 million (approx. EUR 45

million), or more than 500 employees, are classified as Industrial customers. In

total, the segment serves around 1,200 companies.

Results

Nordic Industrial, 2025


EURm	2025	2024	Change, %
Gross written premiums	1,046	1,070	-2
Insurance revenue, net	584	657	-11
Claims incurred, net	-341	-455	-25
Operating expense (incl. claims handling costs)	-134	-128	4
Underwriting result	109	74	48

Key ratios	2025	2024	Change
Like-for-like GWP growth, %	-3.0	—	—
Risk ratio, %	58.4	69.2	-10.8
Cost ratio, %	22.9	19.5	3.4
Combined ratio, %	81.3	88.7	-7.4

All key figures in the table above are calculated on a net basis. Education and development costs

are included in the cost ratio.

Premium development

Nordic Industrial reported a GWP decline of -3.0 per cent on a like-for-like basis for

2025, while insurance revenue decreased by -11.0 per cent. The top-line development

was impacted by softening market conditions, with lower new sales, combined with

weaker year-on-year retention. The targeted de-risking measures introduced earlier in

the year to ensure lower large claims volatility have now been largely implemented.

While project insurance premiums were subdued for most of the year, they recovered

in the fourth quarter.

Underwriting performance

The underwriting result increased by 48 per cent to EUR 109 million (74) in 2025 and

the combined ratio improved to 81.3 per cent (88.7). The positive development was

driven by a strong risk ratio of 58.4 per cent (69.2), reflecting a favourable large claims

outcome and benign frequency development throughout the year.

In 2025, the cost ratio deteriorated to 22.9 per cent (19.5), primarily due to lower

premium volumes, while nominal cost development remained in line with targets.


	BOARD OF DIRECTORS’ REPORT 2025	16

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Net financial result and other items


EURm	2025	2024	Change, %
Fixed income	541	559	-3
Equities	28	37	-24
Funds	23	16	49
Interest and dividend income	592	612	-3

Fixed income	41	147	-72
Equities	648	81	700
Funds	83	70	20
Net gains or losses	772	298	159
Other items	-80	-22	259
Net investment income	1,285	888	45

Unwind of discounting, net	-240	-238	1
Changes in discount rates, net	183	-25	—
Indexation of annuities, net	-17	11	—
Insurance finance income or expense	-74	-252	-71
Net financial result	1,210	636	90

Other income or expense	-48	-210	-77
Non-operational amortisations	-128	-79	62
Finance expenses	-83	-103	-20
Total	-259	-392	-34

Key figures	2025	2024	Change
Investment return, %	7.6	5.5	2.1
Fixed income mark-to-market yield, %	3.6	4.2	-0.6
Fixed income running yield, %	3.9	3.9	—
Fixed income duration, years	2.3	2.3	—

The Group’s net investment income increased by 45 per cent to EUR 1,285 million

(888) in 2025. The increase was primarily driven by EUR 540 million net gain, including

FX effects, on NOBA. Meanwhile, interest and dividend income came in at EUR 592

million (612).

The fixed income running yield stood stable at 3.9 per cent (3.9) at the end of 2025.

Meanwhile, the mark-to-market yield decreased to 3.6 per cent (4.2), driven by lower

rates but also partly by the inclusion of Topdanmark’s assets into the calculation

following the legal merger of If and Topdanmark on 1 July 2025.

The Group’s investment portfolio amounted to EUR 17.8 billion (16.5) at the end of

2025. Of this, 87 per cent (88) was allocated to fixed income, 13 per cent (8) to

equities, and less than 1 per cent (4) to alternative investments. The increase in equity

exposure over the year was mainly driven by the IPO of NOBA in September 2025,

after which the stake was moved from alternatives to equities.

Insurance finance income or expense (IFIE) was EUR -74 million (-252), supported by

positive effect from changes in discount rates over the year. As a result of both

materially higher investment income and IFIE, the net financial result increased to EUR

1,210 million (636) for 2025.

The non-operational amortisations included a negative one-off effect of EUR -26

million related to the Ballerup office in Denmark, and finance expenses included a

positive one-off effect of EUR 20 million from the Tier 2 tender offer in September

2025.


	BOARD OF DIRECTORS’ REPORT 2025	17

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Financial position

Group solvency

Sampo Group’s Solvency II ratio, net of the proposed dividend of EUR 0.36 per share,

amounted to 174 per cent (178) at the end of 2025, based on own funds of EUR 6,059

million (5,368) and solvency capital requirement of EUR 3,490 million (3,040).

The increase in own funds over the year was driven by strong operating performance

and robust investment returns. At the same time, the increase in the solvency capital

requirement was driven by the market value gain of the NOBA investment, combined

with materially higher symmetric adjustment compared to the end of 2024. Sampo

targets a Solvency II ratio of 150–190 per cent.

Solvency position


EURm	2025	2024
Own funds	6,059	5,368
Solvency capital requirement	3,490	3,040
Solvency II ratio, %	174	177

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 (excluding Tier 1 instruments) amounted to EUR

7,794 million (7,059) and financial debt to 2,402 million (2,596) at the end of 2025,

translating into a financial leverage of 23.6 per cent (26.9).

The increase in shareholders’ equity was driven by strong results. Meanwhile, the

decrease in financial debt was driven by the maturity of Sampo plc’s EUR 162 million

outstanding senior bond in May and the repurchase of Topdanmark’s DKK 150 million

external hybrid debt prior to the legal demerger of If and Topdanmark.

More information on Sampo Group’s outstanding debt issues is available at

www.sampo.com/debtfinancing.

Financial debt


EURm	2025	2024
Sub/Hybrid	1,615	1,642
Senior bonds	787	954
Total financial debt	2,402	2,596
IFRS equity (excl. Tier 1 instruments)	7,794	7,059
Financial leverage, %	23.6	26.9


	BOARD OF DIRECTORS’ REPORT 2025	18

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Ratings

Relevant ratings for Sampo Group companies on 31 December 2025 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


	BOARD OF DIRECTORS’ REPORT 2025	19

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Other developments

Changes to the Group

Executive Committee

On 18 June 2025, Sampo’s Board of Directors appointed

Morten Thorsrud, CEO of If P&C, as Sampo Group CEO

to succeed Torbjörn Magnusson, who had informed the

Board of his intention to retire from the role. Thorsrud

assumed the position of Group CEO on 1 October 2025.

At the same time, on 1 October, Ricard Wennerklint

was appointed Deputy CEO, and Poul Steffensen, Head

of Nordic Industrial, and Tiina Halmesmäki, Chief Legal

Officer, joined Sampo’s Group Executive Committee

(GEC). Further, Group CFO Knut Arne Alsaker

announced his decision to resign. He will continue as

Group CFO until 31 March 2026. Lars Kufall Beck, COO

of If P&C, was appointed as his successor and will take

over the role on 1 April 2026.

To reflect the simplification of Sampo into a pure P&C

insurance group in recent years, Morten Thorsrud will

lead a more operationally focused GEC, actively

engaged in the running of the business. To facilitate this,

certain responsibilities previously held by the If P&C

CEO role were integrated into the Sampo Group CEO

role, aligning leadership with the Group’s operational

structure across its four customer segments.

Group Partial Internal Model

On 2 July 2025, Sampo announced that it had filed an

application to the Swedish FSA (Finansinspektionen) to

extend the Group’s Partial Internal Model to include the

operations formerly under Topdanmark. Sampo expects

that the application process will be completed in spring

2026. Sampo estimates that the extended model could

reduce the Group-level solvency capital requirement by

around EUR 60-90 million.

Sale of shares in NOBA

Group

The Swedish specialist bank NOBA Group completed its

initial public offering in late September 2025. In

connecting with the IPO, Sampo sold part of its holding

in NOBA, reducing the Group’s ownership in NOBA to

14.9 per cent. The sale of shares generated around EUR

155 million in proceeds for Sampo.

Together with the value gain on the remaining stake,

this had a positive effect of EUR 540 million, including

FX effects, on net investment income in the annual

result for 2025. The effect was excluded from the

operating result.

Sampo’s NOBA stake was valued at EUR 814 million at

the end of December 2025.

NOBA is now treated as a public equity investment and

valued on a mark-to-market basis. However, any

realised gains or losses will be treated as extraordinary

items and thus, excluded from the operating result.

Changes in the Group’s

financial debt

In 2025, the Group’s financial debt decreased due to the

maturity of Sampo plc’s EUR 162 million outstanding

senior debt in May and the repurchase of Topdanmark’s

DKK 150 million external hybrid debt prior to the legal

merger of If and Topdanmark.

In September 2025, Sampo launched a EUR 300 million

tender offer for its Tier 2 notes. As a result, Sampo

repurchased EUR 316 million in aggregate nominal value

of its Tier 2 notes due 2052 for EUR 295 million. In

connection with the tender offer, Sampo issued EUR

300 million of new restricted Tier 1 notes with a coupon

rate of 5.25 per cent and a first call date in 2035. The

restricted Tier 1 instrument is accounted as part of

shareholders equity, but treated as debt for certain key

figures such as financial leverage.


	BOARD OF DIRECTORS’ REPORT 2025	20

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Conversion of Sampo’s

Swedish Depositary Receipts

On 5 November 2025, Sampo announced that it will

request the termination of its Swedish Depositary

Receipt (SDR) arrangement for the Sampo A share on

Nasdaq Stockholm and will submit an application for its

A Shares to be admitted to trading on Nasdaq

Stockholm. All issued and outstanding SDRs were to be

delisted and converted into A Shares in connection with

the listing, in accordance with the terms and conditions

of the SDRs.

The advantages for Sampo and its shareholders,

similarly to the listings on Nasdaq Helsinki and Nasdaq

Copenhagen, include increasing the maximum available

liquidity pool in the Swedish market to cover all issued

A Shares, a smaller tick size on Nasdaq Stockholm in

comparison to the one applicable for the SDRs, and the

possibility for current SDR holders to exercise

shareholder rights without the involvement of SEB as an

intermediary.

The applications to Nasdaq Stockholm for the delisting

of the SDRs and the admission to trading of the A

Shares were submitted after the end of the reporting

period on 26 January 2026 and approved on 28

January 2026. The last trading day for SDRs was 13

February 2026 and the first trading day for Sampo A

was 16 February 2026.

Proposals to the AGM of

2026

On 4 February 2026, 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 of the

Board of Directors proposes to the Annual General

Meeting to be held on 22 April 2026 that the number of

Board members remain unchanged and that eight

members be elected to the Board. The Committee

proposes that the current members of the Board Steve

Langan, Sara Mella, Risto Murto, Antti Mäkinen, Markus

Rauramo, Astrid Stange and Annica Witschard be re-

elected for a term continuing until the close of the next

Annual General Meeting. Of the current members,

Christian Clausen is not available for re-election.

The Committee proposes that Andreas Brandstetter,

CEO of UNIQA Insurance Group, be elected as a new

member to the Board. Andreas Brandstetter has close

to three decades of experience in the P&C insurance

industry, marked by a distinguished and steadily

advancing career at UNIQA Insurance Group.

The Nomination and Remuneration Committee will

propose to the Board that it elects Antti Mäkinen as the

Chair of the Board and Risto Murto as the Vice Chair.

The Nomination and Remuneration Committee of the

Board of Directors proposes to the Annual General

Meeting that the following annual fees be paid to the

members of the Board of Directors until the close of the

next Annual General Meeting:

• EUR 250,000 for the Chair of the Board (prev. EUR

243,000);

• EUR 144,000 for the Vice Chair of the Board (prev.

EUR 140,000);

• EUR 111,000 for each member of the Board (prev. EUR

108,000);

• EUR 30,000 for the Chair of the Audit Committee as

an additional annual fee (prev. EUR 30,000);

• EUR 15,000 for each member of the Audit Committee

as an additional annual fee (prev. EUR 6,800);

• EUR 20,000 for the Chair of the Nomination and

Remuneration Committee as an additional annual fee

(new committee fee); and

• EUR 10,000 for each member of the Nomination and

Remuneration Committee as an additional annual fee

(new committee fee)

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 Andreas Brandstetter are

available at www.sampo.com/boardproposals.


	BOARD OF DIRECTORS’ REPORT 2025	21

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Shares, share capital and shareholders

Shares and share capital

At the end of 2025, Sampo’s total share count stood at

2,670,754,027 shares, which were divided into

2,669,754,027 A shares and 1,000,000 B shares. The

total number of votes attached to the shares was

2,674,754,027. 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.

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 amounted

to 2,691,238,860 shares.

In November 2025, Sampo cancelled 20,484,833 of its

own A shares that were repurchased under the buyback

programme launched in August 2025.

At the end of 2025, Sampo plc’s share capital amounted

to EUR 98 million (98) and the Group’s equity capital in

total to EUR 8,902 million (7,059).

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 (SDRs) were

traded on Nasdaq Stockholm from November 2022 to

February 2026. Approximately 2.7 million SDRs were

issued at the end of 2025, with each SDR representing

one underlying Sampo A share.

In February 2026, all SDRs were converted to Sampo A

shares. The last trading day for the SDRs was 13

February 2026, and the first trading day for the Sampo

A shares was 16 February 2026.

Shareholders by the number of shares held

Sampo plc, 31 December 2025


Number of shares	Shareholders, number	Share- holders, %	Shares, number	Shares, %	Voting rights, number	Voting rights, %
1–100	35,905	18.41	1,836,519	0.07	1,836,519	0.07
101–500	69,622	35.69	19,600,287	0.73	19,600,287	0.73
501–1,000	30,759	15.77	23,378,895	0.88	23,378,895	0.87
1,001–5,000	44,285	22.70	101,416,561	3.80	101,416,561	3.79
5,001–10,000	7,554	3.87	54,457,573	2.04	54,457,573	2.04
10,001–50,000	5,981	3.07	119,101,654	4.46	119,101,654	4.45
50,001–100,000	506	0.26	34,752,287	1.30	34,752,287	1.30
100,001–500,000	354	0.18	71,128,557	2.66	71,128,557	2.66
500,001–	95	0.05	2,245,081,694	84.06	2,249,081,694	84.09
Total	195,061	100	2,670,754,027	100	2,674,754,027	100
of which nominee registered	11		1,725,438,250	64.60	1,725,438,250	64.51


	BOARD OF DIRECTORS’ REPORT 2025	22

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Share price performance

Sampo plc, 2021–2025

EUR

Share price performance adjusted for the partial demerger in 2023 and share split in 2025.

Monthly trading volume

Sampo plc, 2021–2025

Volumes adjusted for the share split in 2025.


	BOARD OF DIRECTORS’ REPORT 2025	23

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Shareholders

The number of Sampo’s Finnish-registered shareholders decreased during 2025 by 421

shareholders to 195,061, as at 31 December 2025. The holdings of nominee and foreign

shareholders increased to 64.8 per cent (64.5) of the shares. At the end of 2025,

Sampo owned in total 8,945,503 Sampo A shares. The deviation from the figure in the

following table is explained by the repurchases during the last two trading days of the

year, which were not included in the year-end shareholder register due to the T+2 days

settlement time for stock trades.

In 2025, 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 HPS Investment Partners (“HPS”). The

latest notifications are available at www.sampo.com/flaggings.

Shareholders by sector

Sampo plc (A and B shares), 31 December 2025


Sector	Number of shares	%
Corporations	85,287,485	3.19
Financial institutions and insurance corporations	81,818,856	3.06
Public institutions	364,675,140	13.65
Non-profit institutions	56,409,319	2.11
Households	351,807,492	13.17
Foreign ownership and nominee registered	1,730,755,735	64.80
Total	2,670,754,027	100

Shareholders

Sampo plc, the largest shareholders registered in Finland, 31 December 2025


A and B shares	Number of shares	% of share capital	% of votes
Solidium Oy	164,392,900	6.16	6.15
Varma Mutual Pension Insurance Company	111,242,100	4.17	4.16
Ilmarinen Mutual Pension Insurance Company	43,405,100	1.63	1.62
Oy Lival AB	21,160,000	0.79	0.79
Elo Mutual Pension Insurance Company	19,488,000	0.73	0.73
The State Pension Fund	14,000,000	0.52	0.52
Sampo plc	8,680,586	0.33	0.32
OP Life Assurance Company Ltd	7,817,835	0.29	0.29
Nordea Nordic Fund	6,995,477	0.26	0.26
OMX Helsinki 25 Exchange Traded Fund	6,264,000	0.23	0.23
OP-Finland Fund	6,213,801	0.23	0.23
Nordea Pro Finland Fund	5,637,561	0.21	0.21
Svenska litteratursällskapet i Finland r.f.	5,627,300	0.21	0.21
OP-Finland Index Fund	5,372,101	0.20	0.20
Keva	5,046,500	0.19	0.19
Samfundet folkhälsan i Svenska Finland rf	4,320,325	0.16	0.16
Nordea Life Assurance Finland Ltd.	3,916,190	0.15	0.15
Sigrid Jusélius Foundation	3,107,750	0.12	0.12
Nordea Finnish Index Fund	2,891,602	0.11	0.11
Föreningen Konstsamfundet rf	2,750,000	0.10	0.10
Foreign and nominee registered total	1,730,755,735	64.80	64.71
Other total	491,669,164	18.41	18.38
Total	2,670,754,027	100	100


	BOARD OF DIRECTORS’ REPORT 2025	24

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025, members of Sampo plc’s Board of

Directors and their close family members owned either

directly or indirectly 247,200 (1,000,195) Sampo A

shares. Their combined holdings constituted 0.01 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

1,238,052 (1,175,265) Sampo A shares representing 0.05

per cent (0.04) of shares and related votes.

Share buyback programmes

In 2025, Sampo repurchased its own A shares under

two different buyback programmes based on the

authorisation granted by the Annual General Meeting of

2025.

On 6 August 2025, Sampo’s Board of Directors

announced to launch a EUR 200 million share buyback

programme. The repurchases of shares started on 7

August 2025 and ended on 31 October 2025. Sampo

repurchased 20,484,833 of its own shares at an average

price per share of EUR 9.76. The amount corresponded

to 0.76 per cent of all Sampo plc’s shares based on the

share count prior to the start of the programme. The

repurchased shares were cancelled on 5 November

2025.

On 5 November 2025, the Board announced to launch a

new EUR 150 million buyback programme. The

repurchases of shares started on 6 November 2025 and

continued after the end of the reporting period. The

buyback programme was completed on 30 January

2026, when at market close, the company held in total

15,079,201 Sampo A shares representing 0.56 per cent

of the total number of shares in Sampo plc. The

repurchased shares were cancelled on 5 February 2026.

In total, Sampo repurchased 29,4 million shares in 2025,

corresponding to approximately 1.1 per cent of all shares

based on the share count prior to the start of these

programmes.

Further details on the company’s share buyback

programmes are available at

www.sampo.com/sharebuyback.


	BOARD OF DIRECTORS’ REPORT 2025	25

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Events after the end of the reporting period

Update to Sampo’s

distribution policy

On 5 February 2026, Sampo updated its distribution

policy to enable the Group to continue to deliver an

attractive mix of dividends and share buybacks as it

moves forward as a focused P&C insurer. From 2026

onward, Sampo will gradually move to complementing

its progressive dividend with share buybacks that

represent up to one-third of distributions from

operating earnings in a typical year. The update affects

only the mix of capital returned and has no impact on

the total volume of capital distributed to shareholders.

Given Sampo’s high financial strength and its resilient

and cash generative business profile, the Board of

Directors continues to believe that it is appropriate to

return around 90 per cent of the Group’s operating

result to shareholders annually. While implementing the

increase in annual allocation toward share buybacks,

Sampo remains committed to delivering progressive

dividend per share development, broadly in line with

recent years. In adverse years, the Group intends to

keep the regular dividend per share stable.

Sampo Group’s updated distribution policy (applied

from 2026 onwards)

Sampo aims to return capital through a reliable and

progressive regular dividend complemented by share

buybacks. To ensure that the Group’s balance sheet

remains both strong and efficient, as defined by its

capital management framework, Sampo may take

additional action to return excess capital or to protect

the balance sheet.

In a typical year, Sampo expects to return around 90

per cent of its operating result to shareholders through

dividends and share buybacks, of which its annual

dividend is expected to represent more than two-thirds.

Share buyback programme

Sampo’s EUR 150 million share buyback programme

announced on 5 November 2025 continued after the

end of the reporting period and was completed on 30

January 2026. Sampo repurchased 15,079,201 shares

through the programme at an average price of EUR

9.95 per share. This corresponds to 0.56 per cent of the

total share count prior to the start of this programme.

The repurchased shares were cancelled on 5 February

2026.

The buyback programme was based on the

authorisation granted by the Annual General Meeting

held on 23 April 2025.

Further details on the company’s share buyback

programmes are available at

www.sampo.com/sharebuyback.

Issuance of new Restricted

Tier 1 notes

On 10 February 2026, Sampo issued SEK 1.5 billion of

new floating rate Restricted Tier 1 notes with an interest

rate of three-month STIBOR plus 1.80 per cent. The

notes are perpetual and may be redeemed or

repurchased by Sampo in accordance with the

applicable terms and conditions. The first call date is in

2031.

The restricted Tier 1 instrument is accounted as part of

shareholders equity, but treated as debt in the financial

leverage ratio.

Reduction of ownership in

NOBA Group

On 11 February 2026, Sampo announced that it had sold

10.0 million shares in NOBA to institutional investors in

an accelerated bookbuilding process that was

conducted together with Nordic Capital. The share sale

generated approximately EUR 95 million in gross

proceeds for Sampo. Following the transaction, the

Group’s ownership in NOBA decreased from 14.9 per

cent to 12.9 per cent.

SAMPO PLC

Board of Directors


	BOARD OF DIRECTORS’ REPORT 2025	26

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Corporate Governance Statement


Governance in Sampo plc ...........................................................................................	27
Changes in Group structure .......................................................................................	28
General meeting .............................................................................................................	30
Annual General Meeting ...................................................................................................	30
Attending a shareholders’ meeting ..............................................................................	31
Shares and shareholders ..................................................................................................	31
Board of Directors .........................................................................................................	32
Board of Directors’ duties ...............................................................................................	32
Election and term of office of Board members .......................................................	33
Diversity of the Board .................................................................................................	33
Board members .............................................................................................................	33
Shares and share-based rights held by the Board members .............................	37
Board-appointed committees ...................................................................................	38
Audit Committee ................................................................................................................	39
Nomination and Remuneration Committee ..............................................................	40
Sampo Group CEO .........................................................................................................	41
Sampo Group Executive Committee ......................................................................	42
Shares and share-based rights held by the Group CEO and the members of the Executive Committee ...........................................................................................	46
Remuneration ..................................................................................................................	47
Personnel ...........................................................................................................................	48


Internal control in Sampo Group .............................................................................	49
Reporting ..............................................................................................................................	49
Financial reporting ........................................................................................................	49
Non-financial reporting (Sustainability) ................................................................	50
Risk management ...............................................................................................................	50
Risk management system ..........................................................................................	50
Sampo Group’s steering framework ......................................................................	50
Risk management process .........................................................................................	51
Risk management reporting and governance framework .............................	52
Compliance .....................................................................................................................	53
Insider administration ..................................................................................................	54
Whistleblowing ..............................................................................................................	54
Principles for related party transactions ....................................................................	54
Internal audit ........................................................................................................................	55
External auditor ..................................................................................................................	55


	BOARD OF DIRECTORS’ REPORT 2025	27

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Corporate Governance Statement

This Corporate Governance Statement, as provided by

Chapter 7 Section 7 of the Finnish Securities Markets

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

29_1_26_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 Recommendations 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.

The Danish Code issued by the Danish Committee on Corporate Governance (Komitéen for god Selskabsledelse) is available at corporategovernance.dk/recommendations-corporate-governance.


	BOARD OF DIRECTORS’ REPORT 2025	28

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 made 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. The merger

of If and Topdanmark was completed on 1 July 2025.

Sampo Group structure

31 December 2025

15_12_25_Group_structure_Sampo_Group_31-December-2023.svg


	BOARD OF DIRECTORS’ REPORT 2025	29

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo Group organisation

31 December 2025


	BOARD OF DIRECTORS’ REPORT 2025	30

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 Annual General Meeting (“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 2025, Sampo plc’s AGM was held on 23 April at the

Helsinki Expo and Convention Centre and a total of

3,464 shareholders representing 1,746,933,448 shares

and 1,750,933,448 votes were represented at the

meeting.

The AGM decided to distribute a dividend of EUR 0.34

per share for 2024. The record date for the dividend

payment was 25 April 2025 and the dividend was paid

to Sampo shareholders on 6 May 2025 and to Sampo

SDR holders on 8 May 2025. The AGM adopted the

financial accounts for 2024 and discharged the Board

of Directors and the CEO from liability for the financial

year. The AGM adopted Sampo plc’s Remuneration

Report for Governing Bodies. The resolution was

advisory.

The minutes of the AGM are available for viewing at

www.sampo.com/agm and at Sampo plc's head office

at Fabianinkatu 21, 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 and the Sustainability Reporting Assurance Provider. ► Elects the members of the Board of Directors as well as the Auditor and the Sustainability Reporting Assurance Provider. ► 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.

The AGM of 2025 also authorised the Board of Directors

to resolve to repurchase a maximum of 250,000,000

Sampo plc’s A shares.

All resolutions of the AGM of 2025 were made without

separate voting.


	BOARD OF DIRECTORS’ REPORT 2025	31

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025, the total number of Sampo

plc’s shares, including both 2,669,754,027 A shares and

1,000,000 B shares, equalled to 2,670,754,027 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

2,674,754,027.

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 2025, a total number of 195,050

Finnish registered shareholders held 945,315,777 shares

representing approximately 35.4 per cent of all shares.

In addition, 11 nominee registers held 1,725,438,250

shares representing approximately 64.6 per cent of all

shares.


	BOARD OF DIRECTORS’ REPORT 2025	32

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 charter of the Board

of Directors. 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-level 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 Model and applying for supervisory approval		► 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 • in 2025, the evaluation was conducted as a self-evaluation, as it was conducted by an external facilitator in 2024, the results of which were thoroughly discussed and analysed • the Board members evaluated the performance of the Board and its Committees in relation to their respective duties and responsibilities, the Board and Committee compositions and structure, the Board culture, the effectiveness of the Board and Committee meetings, the individual performance of Board members, as well as the performance of the Chair of the Board.


	BOARD OF DIRECTORS’ REPORT 2025	33

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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. As at 31

December 2025, the share of women in Sampo plc’s

Board of Directors was 37.5 per cent and the share of

men was 62.5 per cent. Thus, the composition of the

Board fulfilled the requirements set for gender diversity.

Board members

As proposed by the Nomination and Remuneration

Committee, the number of Board members was

decreased to eight members at the AGM of 2025.

Christian Clausen, Steve Langan, Risto Murto, Antti

Mäkinen , Markus Rauramo , Astrid Stange and Annica

Witschard were re-elected to the Board. In addition,

Sara Mella 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 2025:


	BOARD OF DIRECTORS’ REPORT 2025	34

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Antti Mäkinen

Chair of the Board

Male, born 1961, LL.M.

Finnish citizen

Positions of trust

Nokian Tyres plc, Board Member

Chair of the Board since 17 May 2023. Also served as a

member of the Board of Directors of Sampo plc in

2018–2021.

Risto Murto

Vice Chair of the Board

CEO and President, Varma Mutual Pension Insurance

Company

Male, born 1963, Ph.D. (Econ.)

Finnish citizen

Positions of trust

Finance Finland, Board Member

Nordea Bank Abp , Board Member

Securities Market Association, Chair of the Board

The Finnish Cultural Foundation, Member of the

Supervisory Board

The Finnish Pension Alliance TELA, Board Member

Member of the Board of Directors of Sampo plc since 16

April 2015 and Vice Chair of the Board since 23 April

2025.

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 2025. The CVs of members of the Board of Directors can be viewed at www.sampo.com/board.


	BOARD OF DIRECTORS’ REPORT 2025	35

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 of the Board

Hepworth Wakefield, Chair of the Board

Member of the Board of Directors of Sampo plc since

18 May 2022.

Sara Mella

Member of the Board

Head of Personal Banking, Executive Vice President,

Nordea Bank Abp

Female, born 1967, M.Sc.

Finnish citizen

Positions of trust

Finance Finland, Vice Chair of the Board

Nordea Asset Management Holding, Board Member

Nordea Art Foundation, Board Member

Member of the Board of Directors of Sampo plc since

23 April 2025.

Markus Rauramo

Member of the Board, Chair of the Audit Committee

CEO, Fortum Corporation

Male, born 1968, M.Soc.Sc.

Finnish citizen

Positions of trust

Eurelectric, President

Member of the Board of Directors of Sampo plc since 19

May 2021, and Chair of the Audit Committee since 23

April 2025.

Information as at 31 December 2025. The CVs of members of the Board of Directors can be viewed at www.sampo.com/board.


	BOARD OF DIRECTORS’ REPORT 2025	36

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Astrid Stange

Member of the Board

Female, born 1965, Doctorate in Economics

German citizen

Positions of trust

Moody's Investors Service, Independent Director of the

EU/UK Supervisory Boards

Lufthansa Group, Member of the Supervisory Board

Member of the Board of Directors of Sampo plc since

25 April 2024.

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.

Georg Ehrnrooth

Member of the Board

Male, born 1966, Studies in forestry and agriculture

Finnish citizen

Member of the Board of Directors of Sampo plc

2 June 2020 - 23 April 2025

Jannica Fagerholm

Vice Chair of the Board

Female, born 1961, M.Sc.

Finnish citizen

Member of the Board of Directors of Sampo plc

18 April 2013 - 9 April 2019 and Vice Chair of the Board

9 April 2019 - 23 April 2025.

Information as at 31 December 2025. The CVs of members of the Board of Directors can be viewed at www.sampo.com/board.


	BOARD OF DIRECTORS’ REPORT 2025	37

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 eleven times in 2025. The meeting attendance of Sampo plc’s

current Board members in Board meetings from 1 January–31 December 2025 is

presented in the below table:


	Attendance (%)	Meetings attended
Antti Mäkinen (Chair of the Board)	100	11/11
Jannica Fagerholm (Vice Chair until 23 April 2025)	100	3/3
Christian Clausen	100	11/11
Georg Ehrnrooth (member until 23 April 2025)	100	3/3
Steve Langan	100	11/11
Sara Mella (member since 23 April 2025)	87.50	7/8
Risto Murto	100	11/11
Markus Rauramo	100	11/11
Astrid Stange	100	11/11
Annica Witschard	100	11/11

Shares and share-based rights held by

the Board members

On 31 December 2025, 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 2025 and 31 December 2024


Board of Directors	31 Dec 2025	31 Dec 2024
Antti Mäkinen	48,664	42,750
Jannica Fagerholm¹		43,755
Christian Clausen	92,395	192,395
Georg Ehrnrooth¹		651,725
Steve Langan	15,201	11,650
Sara Mella²	14,137
Risto Murto	33,178	29,345
Markus Rauramo	19,494	15,505
Astrid Stange	12,013	4,445
Annica Witschard	12,118	8,625
Total	247,200	1,000,195
Board of Directors ownership of shares, %	0.01	0.04
Board of Directors share of votes, %	0.01	0.04

Holdings at the end of 2024 adjusted for the share split.

¹Member of the Board of Directors member until 23 April 2025

² Member of the Board of Directors since 23 April 2025

The Board members did not have holdings in any Sampo plc share-based rights.


	BOARD OF DIRECTORS’ REPORT 2025	38

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

The AGM decided to pay the following annual fees to

the members of the Board of Directors until the close of

the 2026 AGM:

• EUR 243,000 for the Chair of the Board

• EUR 140,000 for the Vice Chair of the Board

• EUR 108,000 for each member of the Board

• EUR 30,000 for the Chair of the Audit Committee as

an additional annual fee

• EUR 6,800 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 2025	39

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025, the chair of the Audit Committee was Jannica

Fagerholm until 23 April 2025 and Markus Rauramo as

of 23 April 2025, and the other members were Steve

Langan, Markus Rauramo, Astrid Stange and Annica

Witschard until 23 April 2025 and Steve Langan, Sara

Mella, Astrid Stange, and Annica Witschard thereafter.

As at 31 December 2025, 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 2025. The

meeting attendance of Sampo plc’s current Audit

Committee members in Committee meetings from 1

January–31 December 2025 is presented in the

following table:


	Attendance (%)	Meetings attended
Jannica Fagerholm (Chair until 23 April 2025)	100	1/1
Markus Rauramo (Chair since 23 April 2025)	100	4/4
Steve Langan	100	4/4
Sara Mella (member since 23 April 2025)	100	3/3
Astrid Stange	75	3/4
Annica Witschard	100	4/4


	BOARD OF DIRECTORS’ REPORT 2025	40

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025 the Chair of the Nomination and Remuneration

Committee was Antti Mäkinen, and the other members

were Christian Clausen, Georg Ehrnrooth and Risto

Murto until 23 April 2025 and Christian Clausen and

Risto Murto since 23 April 2025. As at 31 December

2025, the share of men in the Nomination and

Remuneration Committee was 100 per cent.

The Committee convened five times in 2025. The

meeting attendance of Sampo plc’s Nomination and

Remuneration Committee members in Committee

meetings from 1 January–31 December 2025 is

presented in the below table:


	Attendance (%)	Meetings attended
Antti Mäkinen (Chair)	100	5/5
Christian Clausen	100	5/5
Georg Ehrnrooth (member until 23 April 2025)	100	2/2
Risto Murto	100	5/5


	BOARD OF DIRECTORS’ REPORT 2025	41

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo Group CEO

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. Morten Thorsrud, Master of Business and

Economics, is the Managing Director of the company

and the Group CEO. His Group CEO contract is in force

until further notice, and the notice period for

terminating the contract is 6 months mutually, and

Thorsrud is entitled to salary during the notice period. In

addition, Thorsrud is entitled to a severance

compensation corresponding to 12 months’ fixed salary,

if the company terminates the contract.


	BOARD OF DIRECTORS’ REPORT 2025	42

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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

2025, the Group Executive Committee convened 11

times at the invitation of the Group CEO.

As at 31 December 2025, the share of women in the

Group Executive Committee was 25 per cent and the

share of men was 75 per cent.

The following persons served on the Group Executive

Committee in 2025:


	BOARD OF DIRECTORS’ REPORT 2025	43

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Morten Thorsrud

Group CEO, Sampo Group

Male, born 1971, M.Sc. (Econ.)

Norwegian citizen

Positions of trust

If P&C Insurance Holding Ltd, Chair of the Board

Topdanmark A/S, Chair of the Board

Hastings Group, Board Member

Euronext, Member of the Supervisory Board

Member of Sampo Group Executive Committee since

2006.

Ricard Wennerklint

Deputy CEO, Sampo Group

Male, born 1969, Executive Education, Advanced

Management Programme

Swedish citizen

Positions of trust

Hastings Group, Board Member

NOBA Bank Group AB (publ) (former Nordax Bank AB

(publ)), Board Member

If P&C Insurance Holding Ltd, Board Member

Member of Sampo Group Executive Committee since

2005.

Knut Arne Alsaker

Group CFO, Sampo Group

Male, born 1973, M.Sc. (Econ.)

Norwegian citizen

Positions of trust

Hastings Group, Board Member

If P&C Insurance Holding Ltd, Board Member

Member of Sampo Group Executive Committee since

2014 until 31 March 2026.

Information as at 31 December 2025. The CVs of members of the Group Executive Committee can be viewed at www.sampo.com/management.


	BOARD OF DIRECTORS’ REPORT 2025	44

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Tiina Halmesmäki

Chief Legal Officer, Sampo plc

Female, born 1978, Master of Laws, MBA (Finance)

Finnish citizen

Positions of trust

If P&C Insurance Ltd, Board Member

Member of Sampo Group Executive Committee since

2025.

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.

Poul Steffensen

Head of BA Industrial, If P&C Insurance

Holding Ltd (publ)

Male, born 1964, Certificate of Business Administration

Danish citizen

Positions of trust

Forsikring & Pension (Danish Insurance Association),

Board Member

Kapitalselskabet BLS Invest, Board Member

Oona Health A/S, Board Member

Member of Sampo Group Executive Committee since

2025.

Information as at 31 December 2025. The CVs of members of the Group Executive Committee can be viewed at www.sampo.com/management.


	BOARD OF DIRECTORS’ REPORT 2025	45

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Klas Svensson

Head of Business Area Commercial, If P&C Insurance

Holding Ltd (publ)

Male, born 1985, MBA

Swedish citizen

Positions of trust

Oona Health A/S, Board Member

Member of Sampo Group Executive Committee since

2024.

Ville Talasmäki

Group CIO, Sampo Group

Male, born 1975, M.Sc. (Econ.)

Finnish citizen

Positions of trust

Topdanmark 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.

Information as at 31 December 2025. The CVs of members of the Group Executive Committee can be viewed at www.sampo.com/management.


	BOARD OF DIRECTORS’ REPORT 2025	46

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Shares and share-based rights held by the Group CEO

and the members of the Executive Committee

On 31 December 2025, 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 2025 and 31 December 2024


Group Executive Committee	31 Dec 2025	31 Dec 2024
Morten Thorsrud	450,204	367,850
Ricard Wennerklint	172,947	138,010
Knut Arne Alsaker	287,556	247,245
Tiina Halmesmäki ¹	0
Ingrid Janbu Holthe	90,791	54,335
Poul Steffensen¹	74,855
Klas Svensson	42,764	23,805
Ville Talasmäki	118,935	102,245
Torbjörn Magnusson²		241,775
Total	1,238,052	1,175,265
Group Executive Committee's ownership of shares, %	0.05	0.04
Group Executive Committee's share of votes, %	0.05	0.04

Holdings at the end of 2024 adjusted for the share split.

¹Member of the Executive Committee since 1 October 2025

² Member of the Executive Committee until 30 September 2025

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 2025	47

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Remuneration

The Board of Directors has established the Sampo

Group Remuneration Principles, which apply to all

Sampo Group companies. The Remuneration Principles

are part of Sampo Group's internal governance

framework and 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 do their best and surpass 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, remuneration

mechanisms shall not generate conflicts of interest and

shall not entice or encourage employees to excessive or

unwanted risk-taking.

The different forms of remuneration used in Sampo

Group are the following:

(a) Fixed compensation

(b) Variable compensation

(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 2025, a total of EUR 16.5 million (11) 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 2025, 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 2025 Remuneration Report for Governing Bodies

for further information on the new Sampo Group long-

term incentive scheme 2025.

Moreover, the third and final instalment of the long-term

incentive scheme 2020:1, the second instalment of the

long-term incentive scheme 2020:1/2 and the first

instalment of the long-term incentive scheme 2020:1/3

vested in 2025. 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.

All 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 89 million (62), including social costs,

was paid as short-term incentives in January–December

2025 in Sampo Group. In the same period, a total of

EUR 60 million (43) was paid as long-term incentives.

The costs of the long-term incentive schemes in force in

Sampo Group amounted to EUR 25 million (14).


	BOARD OF DIRECTORS’ REPORT 2025	48

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

The Remuneration Report for Governing Bodies 2024 was presented to and adopted

by the Annual General Meeting in 2025. 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 approximately 94 per cent of votes represented at the meeting.

Sampo plc publishes the 2025 Remuneration Report for Governing Bodies in

connection with the Board of Directors’ Report at www.sampo.com/year2025. 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.

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/remuneration.

Personnel

Number of personnel

Sampo Group, 2025

The average number of employees (FTE) in Sampo Group’s P&C operations in 2025

was 15,003 (14,280). As at 31 December 2025, the total number of employees in the

Group’s P&C operations was 15,224 (14,779).


Country	Average personnel (FTE) 2025	%	Average personnel (FTE) 2024	%
United Kingdom	4,439	30	3,710	26
Denmark	2,824	19	2,971	21
Finland	1,975	13	1,973	14
Sweden	2,537	17	2,486	17
Norway	1,695	11	1,680	12
Other countries	1,534	10	1,460	10
Total	15,003	100	14,280	100

At the end of 2025 the total personnel (FTE) at Sampo plc amounted to 68 (66), of which 56 (57)

worked at the headquarters in Finland, 8 (9) at the branch office in Sweden, 3 (0) at the branch

office in Denmark and 1 (0) at the branch office in Norway.


	BOARD OF DIRECTORS’ REPORT 2025	49

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 of Directors 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

the 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 of Directors, and its

Audit Committee. Group solvency calculations are also

delivered on a quarterly basis to the Group Executive

Committee, the Board of Directors, and its Audit

Committee.


	BOARD OF DIRECTORS’ REPORT 2025	50

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 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. The Group CFO,

who is a member of the Sampo Group Executive

Committee, directs Sampo plc’s Sustainability unit. The

Group CFO also ensures that adequate reporting on

sustainability matters is provided to the Group CEO.

The Sustainability unit of Sampo plc is responsible for

the development and coordination of sustainability at

group level. The unit prepares the group level

Sustainability Statement and the sustainability

programme, which sets the direction for the Group’s

sustainability work. In addition, the unit sets schedules,

requests, and group level guidance to the Group

companies.

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 unit. 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

Directors of Sampo plc decides on the Group’s balance

sheet targets and the parent company’s liquidity reserve.


	BOARD OF DIRECTORS’ REPORT 2025	51

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 plc 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 customers. 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:

• Customer 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.

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.


	BOARD OF DIRECTORS’ REPORT 2025	52

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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, The 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 its 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

coordinate reinsurance-related topics across various

group companies and align interest on the 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

More detailed information on Sampo’s risk management

is available in Sampo Group’s Solvency and Financial

Condition Report 2025 which will be disclosed in May

2026 at www.sampo.com/year2025.


	BOARD OF DIRECTORS’ REPORT 2025	53

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025	54

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025, 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.

Sampo had no significant related party transactions

during the reporting year. More information in the

Group’s note 29 and Sampo plc’s note 4.


	BOARD OF DIRECTORS’ REPORT 2025	55

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Internal audit

Internal Audit is a function independent of business

operations, which evaluates the efficiency and

effectiveness, as well as the maturity of the system of

governance, and the system of internal control 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 Internal Audit function is

organised under the Board of Directors of Sampo plc

and it reports to Sampo plc’s Board of Directors and its

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. According to the Policy, the

Sampo Group Internal Audit function is committed to

adhering to the mandatory elements of the Global

Internal Audit Standards.

Internal audit plans are established annually by the

Internal Audit function and consider both short- and

long-term aspects. The plans are approved by the

Board of Directors of each relevant Sampo Group

company and presented to Sampo plc’s Audit

Committee for information. A risk-based approach is

applied, and the internal audits cover all significant

activities of the operations to ensure coverage of the

system of internal control, as well as other parts of the

system of governance. 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 identified severe internal control

deficiencies and potential follow-up issues yet to be

remedied according to the agreed action plans. In

addition, an annual internal audit report is issued for

each sub-group and legal entity, and for Sampo Group.

The Group Chief Audit Executive is responsible for

having an external and internal quality assurance and

improvement program in place covering all aspects of

the internal audit function’s conformance with the

Global Internal Audit Standards. The results are

reported to the 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 acted as Sampo plc’s as well as If

Group’s, Topdanmark’s and Hastings Group’s Auditor in

2025.

The fees paid by Sampo Group companies to audit firm

Deloitte for statutory audit services in 2025 totalled

approximately EUR 4,055,000. In addition, Sampo

Group companies paid audit firm Deloitte a total of

approximately EUR 827,000 in fees for non-audit

services, which is at most approximately 20.4 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 2025 totalled approximately

EUR 460,000 and approximately EUR 105,000 for

sustainability reporting assurance. In addition, Sampo

plc paid Deloitte Ltd a total of approximately EUR

208,000 in fees for non-audit services.

Sampo plc’s AGM held on 23 April 2025 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 and authorised

sustainability auditor since April 2024.


	BOARD OF DIRECTORS’ REPORT 2025	56

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sustainability Statement


General information ......................................................................................................	57
ESRS 2 General disclosures ............................................................................................	57
Basis for preparation ...................................................................................................	57
Governance .....................................................................................................................	57
Strategy ............................................................................................................................	62
Impact, risk and opportunity management .........................................................	69
Environmental information ........................................................................................	72
EU Taxonomy ......................................................................................................................	72
Underwriting activities ...............................................................................................	73
Investment activities ....................................................................................................	75
E1 Climate change ..............................................................................................................	77
Strategy ............................................................................................................................	78
Impact, risk and opportunity management .........................................................	81
Metrics and targets .......................................................................................................	84
E5 Resource use and circular economy .....................................................................	91
Impact, risk and opportunity management .........................................................	92
Metrics and targets .......................................................................................................	93


Social information ..........................................................................................................	94
S1 Own workforce ..............................................................................................................	94
Strategy ............................................................................................................................	95
Impact, risk and opportunity management .........................................................	95
Metrics and targets .......................................................................................................	98
S2 Workers in the value chain .......................................................................................	107
Strategy ............................................................................................................................	108
Impact, risk and opportunity management .........................................................	108
Metrics and targets .......................................................................................................	112
S4 Consumers and end-users ........................................................................................	113
Strategy ............................................................................................................................	114
Impact, risk and opportunity management .........................................................	114
Metrics and targets .......................................................................................................	118
Governance information ..............................................................................................	121
G1 Business conduct ..........................................................................................................	121
Impact, risk and opportunity management .........................................................	122
Metrics and targets .......................................................................................................	124
Annexes ..............................................................................................................................	125


	BOARD OF DIRECTORS’ REPORT 2025	57

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sustainability Statement

General information

ESRS 2 General disclosures

Basis for preparation

BP-1 – General basis for preparation of the

sustainability statement

This Sampo Group Sustainability Statement 2025 has

been prepared in accordance with the European Union’s

(EU) 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) 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 chains as

described under the heading SBM-1 – Strategy, business

model and value chain (p. 62).

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 the Group used the exemption as provided

for in articles 19a(3) and 29a(3) of Directive 2013/34/

EU.

In accordance with appendix C in the Delegated

Regulation (EU) 2025/4812, Sampo Group has used the

phase-in option to omit the information prescribed by

ESRS 2 SBM-3 paragraph 48(e), ESRS E1-9, and ESRS

E5-6 (anticipated financial effects).

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 EU legislation.

BP-2 – Disclosures in relation to specific

circumstances

Sampo Group reports the disclosures in relation to

specific circumstances (e.g. sources of estimation,

outcome uncertainty, changes compared to previous

reporting periods, errors in prior reporting periods)

alongside the disclosures to which they refer (e.g. in the

calculation principles of the respective metric), when

applicable.

The metrics presented in this Sustainability Statement

have not been validated by an external body other than

the assurance provider of this Sustainability Statement.

Governance

GOV-1 – The role of the administrative,

management, and supervisory bodies

Composition and diversity

Sampo Group’s administrative, management and

supervisory bodies consists of eight 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 aims to ensure that the

Board of Directors embodies a well-balanced mix of

knowledge, skills, diversity, and experience, 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

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.

To promote gender balance, both genders shall always

be represented on the Board, with a target that each

represents at least 40 per cent of the Board’s members.

However, some deviations may be applied if deemed


	BOARD OF DIRECTORS’ REPORT 2025	58

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

reasonable due to the number of Board members. The

number of the Directors and the composition of the

Board shall enable the Board of Directors to perform its

duties efficiently. As at 31 December 2025, the share of

women on Sampo’s Board of Directors was 37.5 per

cent and the share of men was 62.5 per cent. Sampo’s

Nomination and Remuneration Committee regularly

evaluates progress towards the gender diversity target

and takes action as necessary when preparing the

proposal to the next Annual General Meeting (AGM).

Roles and responsibilities

Sampo’s Board of Directors is responsible for and has

the ultimate oversight of group level sustainability,

containing the entire range of environmental, social, and

governance (ESG) matters. The Board has assigned its

Audit Committee to monitor Sampo Group’s

sustainability reporting and activities, such as reporting

in accordance with the CSRD, the double materiality

assessment (DMA), and the Group’s sustainability

programme. Both the regulatory sustainability reporting

and the Sampo Group sustainability programme enable

the Board and the top management to monitor overall

sustainability work and related targets. The annually

published sustainability statement, including the double

materiality assessment, and the annually updated

Sampo Group Code of Conduct are reviewed by the

Audit Committee and approved by the Board of

Directors.

Sampo’s Board of Directors elects and releases the

Group CEO and appoints the Sampo Group Executive

Committee (GEC). The Group CEO is in charge of the

daily management of Sampo. The GEC supports the

Group CEO in the preparation of strategic issues

relating to Sampo Group, in the handling of operational

matters that are significant or involve questions of

principle, and in ensuring a good internal flow of

information.

Sampo Group’s Chief Financial Officer (CFO), who is a

member of the GEC, directs Sampo’s Sustainability unit.

The Group CFO also ensures that adequate reporting

on sustainability matters is provided to the Group CEO.

Sampo’s Sustainability unit is responsible for the

development and coordination of sustainability at

group level. The Group CFO and the Sustainability unit

report to the Board of Directors and the Audit

Committee on material impacts, risks, and opportunities

and associated targets, when needed.

Skills and expertise

Sampo has identified materially important areas of

expertise which have to be sufficiently covered by the

Board members’ range of skills and experience. These

include, for example, risk management, regulatory

framework and legal requirements, system of

governance, and material impacts, risks, and

opportunities related to the insurance and financial

markets. Sampo has an externally disclosed Board skills

matrix, which shows all materially important areas of

expertise, and the number and percentage of Board

members who have strong experience in each area

(self-assessment).

In addition to the above mentioned topics, non-financial

experience has been identified as a materially important

area of expertise in the Board skills matrix. It is defined

as the ability to interpret a company's non-financial

information (including information related to ESG

matters), identify key issues, set appropriate controls,

and take necessary measures based on this information.

It also includes understanding of a listed company's

non-financial reporting requirements and auditing

arrangements and ability to oversee them. In addition to

the existing expertise the Board members possess, the

Board of Directors has access to training on material

topics, as needed. The Board members can also

leverage knowledge, for example, through Board and/

or management positions they hold in other companies.


	BOARD OF DIRECTORS’ REPORT 2025	59

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sustainability organisation and reporting structure

Sampo Group

GOV-2 – Information provided to and

sustainability matters addressed by the

undertaking’s administrative, management,

and supervisory bodies

At Sampo Group, sustainability is seen as a business risk

driver, and sustainability-related risks are a part of the

Group’s overall risk management. This means that

sustainability considerations have been incorporated

into overall business and business practices (e.g.

insurance and investment operations). Sampo’s Board

of Directors is responsible for ensuring that the Group’s

risks are properly managed and controlled, while the

Audit Committee prepares Sampo Group’s risk

management principles and other guidelines.

Additionally, the Board of Directors oversees material

impacts and opportunities related to strategy and major

transactions together with the operative management.

The Group CFO and Sampo’s Head of Sustainability

report to the Board of Directors and the Audit

Committee on sustainability matters at least twice a

year, and more frequently when necessary. In 2025,

sustainability as a standalone topic was on the agenda

at Board and/or Audit Committee meetings every other

quarter. The impacts, risks, and opportunities identified

in Sampo Group’s double materiality assessment are

presented to the Board and its Audit Committee as part

of regular Board reporting. The materiality assessment

is reviewed annually, as required by the legislation, and

any material changes are communicated to the Board.

In addition to Sampo’s Sustainability unit, other units,

such as Compliance, Risk Management, Investment

Management and Operations, and Human Resources

(HR), provide regular reporting to the Board and/or its

committees and the GEC. This reporting may also

include sustainability matters, as sustainability is an

integral part of operations. The Board and its


	BOARD OF DIRECTORS’ REPORT 2025	60

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

committees receive meeting materials before each

Board and/or committee meeting and have time to

provide feedback. During the meeting, a presentation

on the topic in question is given prior to the discussion

and any potential decision-making.

In 2025, the Board of Directors addressed the material

sustainability topics as part of the double materiality

assessment review. The material sustainability topics

are presented in this Sustainability Statement under the

heading SBM-3 – Material impacts, risks, and

opportunities, and their interaction with strategy and

business model (p. 67). In addition, examples of topics

addressed at the Board and/or Audit Committee

meetings in 2025 include annual policy updates (e.g.

Sampo Group Code of Conduct, Sampo Group

Responsible Investment Policy), sustainability reporting

(e.g. climate transition plan, EU Taxonomy, employee

engagement, customer satisfaction), internal control,

and regular compliance, governance, and risk reporting.

GOV-3 – Integration of sustainability-related

performance in incentive schemes

At Sampo Group, variable compensation is used to

ensure the competitiveness of the total remuneration

package and can be either short term or long term.

Sampo's Board of Directors resolves all group level

remuneration matters. The Nomination and

Remuneration Committee supports the Board of

Directors by preparing the proposals to the Board on

the remuneration of the GEC members, Sampo Group's

long-term incentive schemes (LTIs), maximum pay-outs

based on short-term incentive programmes (STIs), as

well as the actual payments to be made to the members

of the GEC.

Sampo’s Remuneration Policy for Governing Bodies

states that the performance measures of the STIs and

LTIs of the Group CEO may include, for example,

shareholder value creation, financial or operative key

performance indicators (KPIs), and sustainability

performance criteria. The Board members are

independent of the companies and do not participate in

variable compensation programmes.

Torbjörn Magnusson retired from his position as

Sampo’s Group CEO on 30 September 2025. In June

2025, the Board of Directors appointed Morten

Thorsrud as the new Group CEO effective from 1

October 2025. Detailed information on the

remuneration of both Magnusson and Thorsrud, based

on the time they worked as Group CEO of Sampo in

2025, is available in Sampo plc’s Remuneration Report

for Governing Bodies 2025.

The Group CEO participates in a one-year STI

programme, where the payout is triggered by an

underlying performance criterion and the outcome is

determined on the basis of key financial and non-

financial performance criteria related to Sampo Group

and its subsidiaries. The maximum amount that can be

paid to the Group CEO from the 2025 programme

corresponds to 12 months' fixed salary. Part of the

payout shall be deferred for at least three years as

required in the regulatory framework applicable to

Sampo.

Both Magnusson and Thorsrud also participate in the

LTI scheme 2025 for Sampo Group’s key employees.

The Group CEO has been allocated 117,847 (former

Group CEO 196,284) performance incentive units with a

value equivalent to 150 per cent of his annual base

salary at the time of allocation. The number of

performance incentive units that will vest ranges from

0–117,847 (0–196,284 as regards the former Group CEO)

and is dependent on performance criteria related to the

development of the total shareholder return,

operational performance, and sustainability. In addition,

the performance incentive units are subject to Sampo A

share price movements over the performance period.

The scheme has a three-year performance period and at

pay-out from the 2025 scheme, the Group CEO is

obliged to purchase Sampo A shares with 50 per cent

of the pay-out after deducting income tax and other

comparable charges. The shares are subject to disposal

restrictions for three years, after which the Board of

Directors shall decide on the possible release.

10 per cent of the reward from the LTI scheme 2025 is

subject to the performance of Sampo Group’s work

related to sustainability. The sustainability performance

criterion consists of Group and subsidiary balanced

scorecards relating to the development,

implementation, and execution of science-based targets

(SBTs). In addition to the LTI criterion, Sampo Group

did not factor further greenhouse gas (GHG) emission

reduction targets into remuneration in 2025.

GOV-4 – Statement on due diligence

The main aspects and steps of Sampo Group’s due

diligence process are described under the applicable

disclosure requirements in this Sustainability Statement.

The table Main aspects and steps of the due diligence

process (p. 61) lists the reported information.


	BOARD OF DIRECTORS’ REPORT 2025	61

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Main aspects and steps of the due diligence process

Sampo Group


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


	BOARD OF DIRECTORS’ REPORT 2025	62

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

GOV-5 – Risk management and internal

controls over sustainability reporting

Sampo Group’s risk management and internal control

systems related to the sustainability reporting process

are part of the Group’s overall risk management. As part

of internal control framework, Sampo Group has

comprehensive risk management procedures in place to

ensure the functioning of the reporting processes,

including sustainability reporting. Risk management

procedures include risk identification, assessment,

measurement, monitoring, and reporting.

Sampo Group identifies and assesses risks related to its

operations on a regular basis. The process takes into

account the causes and consequences of the risks and

the existing controls. In addition to assessing the

likelihood and impact of the risk realisation, Sampo

Group assesses the need for possible additional

measures. Based on the assessment, the risks are

arranged in the order of their significance. During the

risk identification and assessment, an owner is

appointed for all identified risks. The owner is

responsible for taking action and developing measures

in relevant internal functions based on the findings.

Risks related to the sustainability reporting process are

mainly linked to the accuracy or completeness of the

data and information presented. Sampo Group controls

these risks, for example, through internal policies and

guidelines, well-defined responsibilities and duties, the

use of the four-eyes principle, and other controls (e.g.

access rights, reporting systems).

The most significant risks and related mitigation

measures are regularly discussed, for example, in the

Group’s risk committees. Chief Risk Officers (CROs)

report risks to the respective senior management and

the Board of Directors.

Strategy

SBM-1 – Strategy, business model, and value

chain

Sampo Group’s strategy focuses on P&C insurance;

investing in and developing its P&C insurance

operations in the Nordic and Baltic regions and the UK.

The strategy is based on disciplined underwriting,

strong operational capabilities, and customer centricity.

Combined with careful risk management, this enables

Sampo Group to deliver growth at attractive margins

and strong financial resilience, both of which the Group

considers essential to value creation.

Sampo Group’s insurance operations are conducted

through If and Hastings. The subsidiaries are responsible

for pricing their products and services, organising their

sales and implementation processes, ensuring the

profitability, efficiency, quality, security, and continuity

of their operations, as well as for liabilities towards their

customers. The subsidiaries are also responsible for the

management of assets and liabilities, risks, and

capitalisation on the business area and company level.

Sampo Group provides safety to customers through its

high-quality P&C insurance products. Safety is enabled

by a detailed understanding of various risks that the

Group underwrites. By pooling risks, Sampo Group

balances the various risks of the customer base and

provides insurance coverage for events that can be

complex for customers to prepare for without P&C

insurance products.

Safety and value creation are achieved through the

expertise of Sampo Group’s employees and

collaboration with suppliers and other business

partners. The value created for customers flows in the

form of compensation to the Group's employees and

suppliers, and as potential returns to shareholders. This

safety also benefits society at large, enabling other

sectors to continue creating value through their value

chains, which are insured for perils with Sampo Group’s

P&C insurance solutions.

Sampo Group’s activities are divided into own

operations, and an upstream and downstream value

chain. The Group’s own operations are focused on P&C

insurance operations, with an emphasis on underwriting

and managing risk, customer support, and investment

operations. Sampo Group’s upstream value chain

includes suppliers of office products and services (e.g.

ICT suppliers, external data providers) who support the

running of the business. In the downstream value chain,

Sampo Group has a large network of suppliers and

business partners, of which suppliers in claims handling

and loss prevention (e.g. vehicle and property repair

contractors), and partners in health and travel services

form a major part. The main features of Sampo Group’s

value chain are described in the figure Value chain

(p. 63).


	BOARD OF DIRECTORS’ REPORT 2025	63

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Value chain

Sampo Group

Significant groups of products, services and markets

Sampo Group’s operations are diversified by

geography, line of business, and customer segment. The

Group operates in Denmark, Sweden, Norway, Finland,

the UK, and the Baltic countries. Sampo Group’s largest

customer group is private individuals in the Nordics and

the UK. The key product categories for private

individuals are motor and home insurance, but the

Group also offers other insurance covers in the Nordics,

such as travel insurance and personal accident covers.

Sampo Group’s second largest business segment is

Nordic commercial insurance. While property and

motor insurance risks dominate in the commercial

segment, certain liability covers are also prominent.In

addition, Sampo Group is a leading provider of

industrial lines P&C insurance in the Nordic region.

As at 31 December 2025, Sampo Group’s total

employee headcount was 16,157. The number of

employees by geographical areas is presented under

the disclosures related to own workforce in the section

S1 – Own Workforce (p. 100).

Sampo Group’s insurance revenue totalled EUR 10,272

million in 2025. More information on the breakdown of

revenue in accordance with operating segments is

available under the heading Result by segment for

twelve months ended 31 December 2025 (p. 160) in the

Financial Statements.


	BOARD OF DIRECTORS’ REPORT 2025	64

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sustainability programme

Sampo Group

Integration of sustainability into business

Sampo Group’s strategy and purpose link to

sustainability. The Group creates value and provides

safety to its stakeholders and society through high-

quality P&C insurance solutions, which are developed

by understanding risks and managing them responsibly.

Sustainability is integrated into the Group’s core

business operations. In terms of insurance operations,

this means, for example, that the Group takes ESG

considerations into account in underwriting (e.g. setting

expectations for corporate customers to respect

international norms and standards, integrating

sustainability considerations into underwriting principles

and other relevant policies), provides loss prevention

services (e.g. risk management services), handles claims

in a sustainable manner, and develops products and

services in accordance with relevant legal requirements

as well as customers’ needs and preferences.

Sampo Group has a sustainability programme (see the

figure), which supports the Group’s overall business and

strategy, as well as drives group level sustainability

work. The programme consists of three strategic

sustainability themes: Climate and environment, People

and communities, and Business management and

practices, which are in turn divided into more specific

topics relevant for the Group’s sustainability work. The

sustainability programme addresses the regulatory

demands, while also including areas that are critical

especially for a company operating in the P&C

insurance sector and important to the Group’s various

stakeholders. The group level programme is put into

practice by various business areas, operational

departments, and units, and the work is monitored

continuously.

Sampo Group has set general objectives for each

sustainability theme. Additionally, metrics and targets

are in place to monitor the progress in more detail.

Performance against the set targets is presented, for


	BOARD OF DIRECTORS’ REPORT 2025	65

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

example, in this Sustainability Statement. Science-based

climate targets are disclosed under the E1 Climate

change standard, metrics related to circular economy

are disclosed under the E5 Resource use and circular

economy standard, employee engagement is covered

under the S1 Own workforce standard, customer

satisfaction falls under the S4 Consumers and end-users

standard, and metrics related to supplier codes of

conduct can be found under the S2 Workers in the

value chain standard. Compliance with internal policies

and guidelines is discussed under multiple standards, as

many of them focus on describing material policies and

guidelines. Screening of investments and corporate

customers is also addressed under several standards.

SBM-2 –Interests and views of stakeholders

Sampo Group’s key stakeholder groups are customers,

investors, employees, suppliers and other business

partners, investee companies, and local communities.

Each key stakeholder group has several subcategories

as described in the table Stakeholder engagement and

dialogue (p. 66). Sampo Group’s stakeholders include

potential and actual affected stakeholders (i.e., those

affected by the Group’s business activities), and users

of the Group’s Sustainability Statement.

Sampo Group engages with all its stakeholder groups

through a number of forums and on multiple topics. The

intention is to engage in activities and dialogue that are

best aligned with the needs of the Group and its

stakeholders. Sampo Group seeks to ensure meaningful

engagement with stakeholders, for example, by

identifying relevant stakeholders, ensuring continuous

and regular communication, and providing suitable

forums for dialogue.

The purpose of stakeholder engagement is to build

trust between Sampo Group and its stakeholders and to

seek common benefits. The stakeholder engagement

helps the Group to proactively consider the needs and

wishes of its stakeholders. By focusing on stakeholder

engagement, Sampo Group can mitigate potential risks,

including uncertainty and dissatisfaction of its key

stakeholder groups. Stakeholder engagement helps the

Group foster its reputation, trust, and buy-in for the

company’s key initiatives. In addition, Sampo Group

considers stakeholder engagement to be a valuable

source of information. The different stakeholders are

experts in their own fields and can offer knowledge and

expertise for the purposes of the Group. When relevant,

Sampo Group can also offer its time and expertise to

support the stakeholders.

As a result of the continuous dialogue, Sampo Group's

key stakeholders can influence the Group's chosen

strategy and business model over time. The views and

interests of stakeholders are considered, where

possible, when developing the strategy. As a result of

stakeholder engagement, Sampo Group aims to

advance its operations and relationship with

stakeholders further. Examples of actions taken include

improved external communications, customer service,

and internal and external reporting, as well as

developing processes according to best practices.

Sampo Group’s Board of Directors is informed about

the views and interests of stakeholders as part of

regular Board reporting and when considered

necessary.

Engagement with own workforce, workers in the

value chain, and customers and end-users

The interests, views, and rights of Sampo Group’s own

workforce inform and support the Group’s strategic

decisions. For instance, employee engagement surveys

are conducted at least annually, and the results are

reported to the respective management teams. The

Group strives for a constructive, trustful, and open

dialogue with employees and their elected

representatives with the purpose of developing the

company and safeguarding the correct treatment of all

employees. The Group recognises the importance of

workforce engagement, health, safety, wellbeing, work-

life balance, diversity, equity and inclusion (DEI), and

professional development, among other factors.

Sampo Group indirectly engages with value chain

workers on material topics through its suppliers,

investee companies, and corporate customers. The

perspectives of these workers provide important

insights for identifying and understanding the Group’s

impacts on human rights and labour practices across its

activities and business relationships. Engagement with

value chain workers is integrated into daily business

operations, for example, through due diligence

processes.

For Sampo Group, the needs, preferences, and

wellbeing of consumers and end-users is a key input

informing strategy, and the Group’s business model is

primarily shaped based on the interests of its

customers. Sampo Group’s employees who develop and

deliver insurance products and services are constantly

monitoring and taking customers’ interests into

consideration. The recognition of the interests of

customers is complemented by the inputs and views of

Sampo Group’s employees, suppliers, and other

business partners in shaping the Group business model

and strategy.


	BOARD OF DIRECTORS’ REPORT 2025	66

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Stakeholder engagement and dialogue

Sampo Group


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

Sampo Group engages indirectly with value chain workers through its suppliers, investee companies, and corporate customers.


	BOARD OF DIRECTORS’ REPORT 2025	67

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

SBM-3 – Material impacts, risks, and

opportunities, and their interaction with

strategy and business model

Sampo Group has conducted a double materiality

assessment as required by the CSRD. The results of the

assessment are presented in the figure Double

materiality matrix. In 2025, Sampo Group reviewed its

double materiality assessment. Based on the review, the

Group reports no major changes to the material topics

covered by the Sustainability Statement. Only minor

adjustments were made in the reported impacts, risks,

and opportunities to improve internal documentation,

incorporate best practices (e.g. renaming and

combining sustainability topics for clearer alignment

with the ESRS standards), and enhance alignment of

reporting across the Group. The adjustments are related

to the topics E1 Climate change, S1 Own workforce, S2

Workers in the value chain, S4 Consumers and end-

users, and G1 Business conduct.

All the impacts, risks, and opportunities reported in the

Sustainability Statement 2025 are covered by the ESRS

disclosure requirements, as Sampo Group does not

include entity-specific disclosures in the statement.

However, Sampo Group has introduced entity-specific

metrics to complement the disclosure requirements

related to the ESRS standards E1 Climate change, E5

Resource use and circular economy, S1 Own workforce,

S2 Workers in the value chain, and S4 Consumers and

end-users. Based on the identified risks and

opportunities in the double materiality assessment,

Sampo Group does not anticipate any material

adjustments to the carrying amounts of assets and

liabilities reported in the related financial statements

within the next annual reporting period.

Double materiality matrix

Sampo Group


	BOARD OF DIRECTORS’ REPORT 2025	68

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

At Sampo Group, resilience to sustainability issues is

ensured by continuous adaptation of risk assessment

and pricing strategies to account for emerging

sustainability factors, thereby ensuring long-term

profitability and stability of the business. Adapting the

strategy and business model according to sustainability

issues is critical for Sampo Group in terms of

maintaining customer confidence and reducing financial

risks, and the Group continuously invests in its people

and technology to ensure that it maintains its

competitive edge. Combined with careful risk

management, this enables Sampo Group to deliver

quality customer experience, attractive margins, and

strong financial resilience. Resilience towards material

impacts, risks, and opportunities is assessed as a part of

Sampo Group’s processes for sustainability

management, risk management, and strategy

development. More information on how the Group’s

strategy and business model interact with material

impacts, risks, and opportunities is available in the

Strategy section under the topical ESRS standards.

A short summary of the material sustainability topics is

presented next. A more thorough specification of the

material topics, related impacts, risks, and opportunities,

as well as Sampo Group’s approach to managing them

is presented at the beginning of each topical ESRS

standard of this Sustainability Statement.

Climate change

The climate impact of Sampo Group’s own operations is

minor, as the direct GHG emissions are relatively low.

When considering the whole value chain, including

investments, insured assets, and suppliers, the negative

impact of GHG emissions is more significant.

Sampo Group has recognised both climate-related

physical risks and transition risks. Physical risks include

more frequent and severe natural disasters and

changing weather patterns, which can translate into

increased claims due to damages caused, for example,

by storms and floods. Transition risks, on the other

hand, emerge during the shift to a low-carbon

economy. These risks are driven by changes in the

regulatory environment, new technology, changing

customer behaviour, and increased interest in and

concern for environmental matters.

Climate-related physical risks are already relevant in the

short term and are likely to grow in the medium to long

term. At Sampo Group, the risks are managed through a

combination of pricing, diversification, and reinsurance.

The insurance solutions provide customers with

coverage against natural hazards and provide support

and incentives for loss prevention measures and claims

handling. There can also be some climate-related

opportunities in areas such as loss prevention.

Resource use and circular economy

Sampo Group uses resources in its business operations,

particularly in claims handling. Resource use inherently

causes negative environmental impacts, which the

Group can mitigate by adopting and expanding circular

practices in product development and claims handling.

These practices can also lead to long-term cost

reductions for Sampo Group by decreasing the use of

virgin materials.

Own workforce

Sampo Group strives to create an engaging work

environment that fosters creativity, innovation, and

wellbeing, promotes DEI, and encourages employees on

their career paths, thereby generating positive social

impact. When employees feel a sense of belonging

within an organisation, they are more likely to stay

longer. Failing to meet these expectations can lead to

increased employee turnover and challenges in

recruiting a competent workforce, which, in turn, may

pose a financial risk.

Workers in the value chain

Sampo Group has an impact on workers in the value

chain, especially through its downstream suppliers (e.g.

suppliers within claims handling), business partners,

corporate customers, and investees. The risk of

negative impacts related to human rights and labour

practices can be mitigated through strong policies and

governance structures, but due to the complexity of the

value chain and the limits of engagement, they cannot

be entirely eliminated. Due to increasing regulation and

potential reputational issues, such negative impacts

may also lead to financial risks.

Consumers and end-users

Through careful risk management and disciplined

underwriting, Sampo Group can have a positive impact

on the health and safety of consumers and end users,

creating business opportunities for the Group. Failing to

meet customer expectations related to issues such as

data privacy or sales practices can negatively affect

customers and, consequently, pose financial and

reputational risks.

Business conduct

At Sampo Group, good corporate governance is seen as

a baseline. By promoting high standards related to

topics such as anti-corruption, anti-bribery, responsible

business practices, and sustainable partnerships and

supply chain, the Group can contribute to the overall

security of society.


	BOARD OF DIRECTORS’ REPORT 2025	69

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Impact, risk and opportunity

management

IRO-1 – Description of the process to identify

and assess material impacts, risks, and

opportunities

The purpose of Sampo Group’s double materiality

assessment is to identify sustainability matters that

could trigger risks or opportunities influencing the

Group’s ability to create and protect value (financial

materiality), as well as sustainability matters related to

the Group’s business that could have positive or

negative impacts on society, people, or the environment

(impact materiality). The double materiality assessment

serves as a basis for identifying the information to be

included in the Sustainability Statement. The

methodology used in the assessment follows the

legislative requirements and supporting guidance

provided by the European Financial Reporting Advisory

Group (EFRAG).

Sampo Group’s first double materiality assessment,

completed in 2024, was conducted in collaboration with

an external partner. Since then, the Group has

continued to develop and carry out the assessment

internally. As required by legislation, Sampo Group

annually reviews its double materiality assessment and

reports any changes to the process or results as part of

the sustainability statement. In 2025, there were no

major changes in the Group’s operations, and

consequently, there are no changes in the reported

material sustainability topics. During the 2025 review,

Sampo Group enhanced its assessment process based

on EFRAG’s additional methodological guidance and

industry best practices. The following process

description has been updated to reflect the adjustments

made during the review.

The double materiality assessment began with the

identification of an initial list of impacts, risks and

opportunities associated with sustainability topics

potentially material to Sampo Group. This list was

compiled based on, for example, the sustainability

topics and sub-topics included in the ESRS standards,

GRI Standards, the SASB Standards for the insurance

sector, industry benchmarking, media and megatrend

analysis, Sampo Group’s previous materiality

assessment, ESG ratings and reports, information on the

Group’s investments, as well as investor meetings and

feedback.

Representatives from different parts of the Group

participated in workshops to identify and validate

impacts, risks, and opportunities associated with the

sustainability topics. In the workshops, impacts, risks,

and opportunities were mapped according to their

expected location within Sampo Group’s value chain.

The expected time horizons during which the impacts,

risks, and opportunities may materialise were also

defined: short term (less than 1 year), medium term (1–5

years), and long term (over 5 years).

In assessing impacts, Sampo Group drew on regular

dialogue with stakeholders and documentation of

affected stakeholders’ perspectives, which are collected

continuously through the Group’s existing channels. For

social impacts specifically, findings from Sampo Group’s

human rights impact assessment were utilised to ensure

the inclusion of affected stakeholders’ perspectives.

Sampo Group’s main stakeholders and forums for

stakeholder dialogue are presented as a part of this

Sustainability Statement under the heading SBM-2 –

Interest and views of stakeholders (p. 65).

When assessing impact materiality, each identified

impact was categorised based on whether its effect on

society, people, or the environment was positive or

negative, and whether it was actual or potential. The

criteria used to determine the impact materiality score

for each impact included scale and scope. For negative

impacts, the irremediable character of the impact was

also considered. For potential positive and negative

impacts, Sampo Group estimated the likelihood of the

impact occurring. In the event of a potential negative

human rights impact, the severity was assumed to take

precedence over likelihood, in accordance with the

requirement in the ESRS 1.

When evaluating financial materiality, each risk and

opportunity was assessed based on its financial impact

on the business and value creation, including financial

performance and potential effects on Sampo Group’s

reputation and share price, for instance. The identified

impacts on society, people, and the environment and

dependencies on natural, human and social resources of

Sampo Group's business model served as the starting

point for the risk and opportunity identification. The

criteria used to assess financial materiality for each risk

and opportunity were the potential magnitude of its

financial effects and the likelihood of occurrence.

Thresholds were set based on the quantitative

assessment of severity of impact/size of financial effect

and likelihood, using the expertise and perspectives of

involved stakeholders. An impact, risk, or opportunity

was determined to be material, if its total score,

consisting of the assessed severity/financial effect and

likelihood exceeded the threshold value. If at least one

impact, risk or opportunity was determined to be

material, the associated sustainability topic was

assessed to be material. Sampo Group assessed each

applicable criterion for a specific impact, risk, and

opportunity on the same scale. The quantitative

thresholds were used in order to facilitate the


	BOARD OF DIRECTORS’ REPORT 2025	70

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

judgement of materiality, and the comparability

between topics and sub-topics. However, the

assessment is primarily qualitative.

Sustainability-related risks are part of Sampo Group’s

overall risk management and follow the same process

as the Group’s other risks. The sustainability risks

identified through overall risk management were taken

into account in the double materiality assessment.

Identified impacts are considered and addressed

indirectly through the Group’s risk management process

when they relate to the Group’s risks. The Group’s

process for identifying, assessing, and managing

sustainability-related opportunities is embedded in its

management protocols, ensuring strategic alignment

with business objectives and operational decisions.

Sampo’s Board and its Audit committee validate the

final results of the double materiality assessment as a

part of the reporting on this Sustainability Statement.

Climate change

In addition to conducting the double materiality

assessment, Sampo Group uses GHG emissions

calculations, climate-related scenario analyses, and

various risk management practices, such as internal

models, price analyses, stress tests, and sensitivity

analyses, to identify and evaluate climate-related

impacts, risks, and opportunities. Both the Group’s own

operations and its value chain are considered in the

process.

Climate-related impacts are assessed by calculating the

GHG emissions from the Group’s own operations

(Scopes 1 and 2) as well as from its value chain, which

includes investments, insured assets, and suppliers

(Scope 3). The climate impact of Sampo Group’s Scope

1 and 2 GHG emissions is minor, as the amount of

emissions is relatively low. When considering the Scope

3 GHG emissions from the whole value chain, the impact

is more significant. The scope, methodology, and results

of these calculations are described in this Sustainability

Statement under the heading E1-6 – Gross Scopes 1, 2,

and 3 and total GHG emissions (p. 86).

Sampo Group assesses climate-related physical and

transition risks in its own operations and value chain as

part of the existing risk management practices. These

include, for example stress tests and scenario analyses,

in which the severity of natural catastrophes is assumed

to increase. The scope, methodology, and results of the

Group’s scenario analysis are described in this

Sustainability Statement under the heading

SBM-3 – Material impacts, risks, and opportunities and

their interaction with strategy and business model

(p. 78). In the short term, physical climate risks arise in

the form of changes in claims frequencies and/or

severity of the climate-related extreme weather events

that are already relevant in the current climate in the

Nordics, such as windstorms, floods, heavy rainfall,

hailstorms, landslides, erosion, and heatwaves. In the

medium to long term, increased weather-related losses

will likely increase the exposure for P&C insurers.

Climate-related transition risks are associated with

changes in the regulatory environment, new

technologies, shifting customer behaviour, and

increased stakeholder concern. Companies insured by

Sampo Group may be exposed to litigation under new

climate-related regulations, which may lead, for

example, to higher claims costs in liability insurance.

Increased concern from stakeholders, such as investors,

customers, and reinsurers, can result in increased due

diligence costs and the need to discontinue business

relationships with certain suppliers or customers.

Sampo Group has also identified some potential

opportunities related to climate change, such as those

associated with loss prevention and the potential to

invest in new green technologies. An increase in

climate-related physical risks can drive greater demand

for loss prevention services that offer protection against

such risks and support climate change adaptation. The

development of new products and services is part of

Sampo Group's ongoing business development and

innovation. Risk management services are already

included in the Group’s offering for both corporate and

private customers.

Pollution, and Water and marine resources

Sampo Group has assessed that pollution, and water

and marine resources are not material sustainability

topics for a company operating in the P&C insurance

industry. Therefore, the Group has not screened its

assets, business activities, and site locations or

conducted consultations with affected communities

regarding these topics.

Biodiversity and ecosystems

As a P&C insurance company, the impact of Sampo

Group’s own operations on biodiversity and ecosystems

is limited. Therefore, the Group has not screened its site

locations or conducted consultations with affected

communities regarding the topic. Sampo Group’s most

relevant impacts, dependencies, risks, and opportunities

related to biodiversity and ecosystems are linked to its

value chain, primarily through underwriting and

investment operations. The Group has conducted an

initial screening of its investments and corporate

customers to assess exposure to sectors associated

with high biodiversity impacts and dependencies. Based

on the initial findings, Sampo Group will further deepen

the screening, by also considering sensitive geographic

locations and actions to mitigate the impacts, in

accordance with the recommendations of the Taskforce

on Nature-related Financial Disclosures (TNFD). In

addition, the Group will further develop its monitoring

and reporting practices. In the coming years, Sampo

Group will re-evaluate the materiality of this topic as

part of the annual double materiality assessment.


	BOARD OF DIRECTORS’ REPORT 2025	71

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Resource use and circular economy

The process for identifying material impacts, risks, and

opportunities related to resource use and circular

economy is primarily based on information already

available within Sampo Group, particularly regarding

claims handling operations, where the Group’s impacts,

risks, and opportunities related to this topic are largely

concentrated. Affected communities were not

specifically consulted in relation to resource use and

circular economy due to the Group's industry, business

model, and the limited use of resources in its own

operations. Sampo Group has several channels for

stakeholder dialogue where topics such as circular

economy and resource use can be raised (p. 66).

Business conduct

When identifying and assessing material impacts, risks,

and opportunities, Sampo Group has evaluated the

geographical context of its operations, taking into

account the regulatory landscape that may influence

these impacts. Operating within the P&C insurance

sector, Sampo Group has also recognised industry-

specific risks and opportunities, and considered the

Group specific operations, including the product

offerings and service delivery methods.

IRO-2 – Disclosure Requirements in ESRS

covered by the undertaking’s sustainability

statement

Based on the results of the double materiality

assessment, Sampo Group reports material disclosure

requirements related to the ESRS topical standards E1

Climate change, E5 Resource use and circular economy,

S1 Own workforce, S2 Workers in the value chain, S4

Consumers and end users, and G1 Business conduct as

part of this Sustainability Statement. A full list of

disclosure requirements complied with in preparing this

Sustainability Statement is presented in the ESRS

content index in Annex 1 (p. 125). A list of data points

deriving from other EU legislation can be found in

Annex 2 (p. 127).

According to the double materiality assessment, Sampo

Group does not report disclosure requirements related

to the ESRS standard E4 Biodiversity and ecosystems.

Currently the topic is not material based on the Group’s

internal analysis and external stakeholder feedback.

Additionally, the disclosure requirements laid out by the

ESRS standard are in many cases not applicable to

insurance companies. Nevertheless, biodiversity and

ecosystems is a topic Sampo Group will closely follow

and work on, and it is also connected to the Group’s

climate work and reporting. Sampo Group will re-

evaluate the materiality and reporting requirements

related to the topic annually as part of the double

materiality assessment.

The disclosure requirements related to the ESRS

standard S3 Affected communities were also excluded

from this Sustainability Statement. As a P&C insurance

company operating mainly in the Nordic countries,

Sampo Group’s direct impacts on topics such as

adequate housing and freedom of expression are

considered limited. However, the Group reports on its

stakeholder engagement as part of the ESRS 2

standard, and considers topics related to affected

communities where relevant.

Sampo Group does not report on disclosure

requirements related to the ESRS standards E2

Pollution and E3 Water and marine resources, as the

impacts, risks, and opportunities related to these topics

are not considered material for the Group.


	BOARD OF DIRECTORS’ REPORT 2025	72

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Environmental information

EU Taxonomy

The EU Taxonomy (Taxonomy) is a classification system

that translates the EU’s climate and environmental

objectives into criteria for specific economic activities

for investment purposes. The basic principle of the

Taxonomy is that for an economic activity to be

recognised as environmentally sustainable (Taxonomy-

aligned), it must make a substantial contribution to at

least one of the EU’s climate and environmental

objectives, which are climate change mitigation; climate

change adaptation; sustainable use and protection of

water and marine resources; transition to a circular

economy; pollution prevention and control; and

protection and restoration of biodiversity and

ecosystems. In addition, the economic activity cannot

significantly harm any of these objectives and must

meet the minimum safeguards criteria. The Taxonomy

Delegated Acts establish and maintain criteria (i.e.

technical screening criteria) for activities which have a

substantial positive environmental impact.

Companies are required to report on Taxonomy

eligibility (i.e. reporting on whether the economic

activity is included in the Taxonomy Delegated acts)

and Taxonomy alignment (i.e. reporting on whether the

economic activity meets the technical criteria for i)

substantial contribution, ii) do no significant harm, and

iii) comply with minimum safeguards). Insurance

companies are required to report KPIs on sustainable

underwriting activities and sustainable investments. The

first one refers to the proportion of the non-life gross

written premiums (GWP) – in relation to total non-life

GWP – corresponding to insurance activities identified

as environmentally sustainable in the Taxonomy, and

the second one to the proportion of the insurer’s or

reinsurer’s investments – in relation to total insurer’s or

reinsurer’s investments – that are directed at or

associated with funding economic activities that qualify

as environmentally sustainable.

Sampo Group’s Taxonomy disclosures for the year 2025

are based on the Delegated Regulation (EU) 2026/73,

which adopted a set of measures to simplify the

application of the Taxonomy. The effect of amended

regulation on the Group’s reported figures are explained

under the headings Underwriting activities (p. 73) and

Investment activities (p. 75).

In 2025, the weighted averages of Sampo Group’s

Taxonomy-aligned activities concerning both

underwriting and investments were 1.8 per cent

(turnover-based) and 2.1 per cent (capital expenditures-

based).


	BOARD OF DIRECTORS’ REPORT 2025	73

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Underwriting activities

Non-life insurance and reinsurance are recognised by

the Taxonomy as enabling economic activities that can

make a substantial contribution to the environmental

objective of climate change adaptation. At the time of

writing this Sustainability Statement, the Taxonomy

does not define other environmental objectives for

insurance activities. The non-life insurance activities

listed in the Taxonomy Delegated Acts are medical

expense insurance, income protection insurance,

workers’ compensation insurance, motor vehicle liability

insurance, other motor insurance, marine, aviation, and

transport insurance, fire and other damage to property

insurance, and assistance.

Methodology

To be Taxonomy-eligible, a non-life insurance activity

must provide coverage against climate-related perils

(e.g. floods, landslides, heat stress). Sampo Group

follows in its methodology the European Commission

Notice on the interpretation of certain legal provisions

of the Disclosures Delegated Act under Article 8 of the

Taxonomy Regulation, published on 21 December 2023.

This means that solely the share of insurance premiums

that pertain to the coverage of climate-related perils is

reported as eligible. The premiums for which Sampo

Group has not been able to obtain the necessary data

related to climate-related perils are reported as non-

eligible.

For an eligible insurance activity to be classified as

Taxonomy-aligned, it must fulfil the technical screening

criteria of:

• Substantial contribution to climate change

adaptation:

– Leadership in modelling and pricing of climate risks

– Product design

– Innovative insurance coverage solutions

– Data sharing

– High level of 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 Organisation for Economic Co-operation and

Development (OECD) Guidelines for Multinational

Enterprises and the UN Guiding Principles on Business

and Human Rights. Sampo Group has implemented the

required policies and taken actions to be compliant with

the safeguards. Sampo Group has, for example,

conducted a human rights impact assessment, and

continues to ensure that the adequate human rights due

diligence processes are maintained and constantly

developed across the Group.


	BOARD OF DIRECTORS’ REPORT 2025	74

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Underwriting KPIs

The analysis, which is based on the above-mentioned

interpretations, shows that 3.9 per cent (3.0 per cent in

2024) of Sampo Group’s total non-life GWP were

Taxonomy-eligible and 1.1 per cent (1.3 per cent in 2024)

were Taxonomy-aligned in 2025. All the Taxonomy-

aligned premiums are related to fire and other damage

to property insurance. In 2025, Sampo Group’s share of

Taxonomy-eligible and -aligned premiums remained at

the same level compared to the previous year, and no

new Taxonomy-aligned products were introduced.

Sampo Group reports the underwriting KPIs in

accordance with the simplified reporting template as

presented in the Delegated Regulation (EU) 2026/73. In

2025, the Group did not utilise the option to omit

assessing the Taxonomy eligibility and alignment for

non-material premiums (premiums which cumulatively

constitute less than 10 per cent of total non-life gross

written premiums).

Sampo Group does not report eligibility or alignment

related to nuclear and fossil gas activities. Breakdown of

the underwriting eligibility and alignment figures in

nuclear and gas activities cannot be derived as being

covered by the applicable regulatory specifications, as

these activities do not form constituents of the

underwriting KPI.

Going forward, Sampo Group monitors the

development of the legislation as well as the market

expectations and customer needs in this area. In the

coming years, Sampo Group aims to increase the share

of Taxonomy-aligned underwriting activities in its

insurance portfolio if considered material.

Taxonomy-eligible and Taxonomy-aligned non-life insurance and reinsurance activities

Sampo Group


Non-life insurance and reinsurance underwriting activities	Absolute premiums, 2025	Proportion of premiums, 2025	Absolute premiums, 2024	Proportion of premiums, 2024
	EURm	%	EURm	%
Taxonomy-aligned activities	109	1.1%	127	1.3%
Nuclear activities	N/A	N/A	N/A	N/A
Fossil gas activities	N/A	N/A	N/A	N/A
Taxonomy-eligible activities	400	3.9%	289	3.0%
Nuclear activities	N/A	N/A	N/A	N/A
Fossil gas activities	N/A	N/A	N/A	N/A
Non-assessed activities considered non-material	–	–%	N/A	N/A
Total	10,199	100.0%	9,504	100.0%


	BOARD OF DIRECTORS’ REPORT 2025	75

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Investment activities

The Taxonomy requires insurance companies to report

the proportion of underlying investments that are

Taxonomy-eligible and -aligned. To facilitate this type

of reporting at portfolio level, all holdings need to be

screened and analysed in relation to the economic

activities of the Taxonomy.

Methodology

As required by the legislation, Sampo Group analysed

all underlying investments to the counterparties, which

are subject to Articles 19a or 29a of Directive 2013/34/

EU, and Article 8 of the Taxonomy Regulation (so called

Non-Financial Reporting Directive, NFRD,

undertakings), as well as investment property.

Exposures to counterparties which are not subject to

the above mentioned articles and for which it is not

possible to carry out an assessment of Taxonomy-

eligibility or Taxonomy-alignment (e.g. derivatives, cash

and cash equivalents, on demand bank loans, goodwill,

commodities and sovereign exposures) were left out of

the analysis and are excluded from the denominator of

the investment KPIs.

Reporting requirements also obligate insurance

undertakings to distinguish the proportion of the

investments held in respect of life insurance contracts,

where the investment risk is borne by the policyholders,

and the proportion of remaining investments. Sampo

Group has no investments held in respect of life

insurance contracts where the investment risk is borne

by the policyholders.

The Taxonomy analysis of Sampo Group’s investments

was performed with the use of data from an external

data provider, Bloomberg Finance LP (Bloomberg).

Bloomberg identified companies engaged in economic

activities covered by the Taxonomy and produced all

Taxonomy indicators directly based on the respective

investee companies’ own reporting of Taxonomy

eligibility and alignment. The indicators were provided

based on both underlying companies’ revenue and

capital expenditures. As security-specific (e.g. mortgage

bonds) eligibility and alignment data is still scarce, most

of the securities’ eligibility and alignment data was

matched to the issuer’s reported data. Companies’

reported eligibility and alignment data was not modified

in any way by the data provider or by Sampo Group,

and therefore it includes some discrepancies (e.g.

breakdown of alignment to environmental objectives

does not correspond to total alignment).

The relevant investment assets were analysed

according to the Taxonomy reporting requirements by

using both data provided by Bloomberg and data

gathered based on each individual security's issuer. The

investments in the NFRD and non-NFRD undertakings

were identified by using data provided by Bloomberg.

Similarly, investments in undertakings categorised as

financial and non-financial were identified by using

Bloomberg. As Bloomberg does not cover all NFRD

undertakings, some unidentified NFRD undertakings

may have been included in the assets not covered by

the analysis. Fund investments were analysed using

fund look-through (FLT) data where available. Some

FLT data is updated in longer cycles and thus the most

recent available FLT data was used for the Taxonomy

calculations.

For Sampo Group’s investment property, no activities

with Taxonomy eligibility or alignment were found. All

investments in associated companies were in non-NFRD

undertakings.

Investment KPIs

According to the analysis, the turnover and capital

expenditures-based Taxonomy eligibility of Sampo

Group’s covered assets as at 31 December 2025 was

30.9 per cent and 35.6 per cent, respectively. The

turnover-based and capital expenditures-based

Taxonomy alignment of the Group’s covered assets was

7.7 per cent and 9.9 per cent, respectively.

Due to the changes in the Taxonomy and the related

reporting requirements, Sampo Groups’ investment

KPIs for 2025 are not comparable with figures reported

in the previous years. The most significant factor is the

change of the scope of investments included in the

reporting. As the covered assets (denominator of the

KPIs) now only includes NFRD undertakings and

investment property, the reported eligibility and

alignment figures have increased.

As Sampo Group’s Taxonomy reporting for the financial

year 2025 is mainly based on investee companies’ 2024

reporting, the Group could not include in the disclosures

information on non-assessed exposures of the investee

companies. Sampo Group has not assessed any of its

exposures to be non-material.


	BOARD OF DIRECTORS’ REPORT 2025	76

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Taxonomy-eligible and Taxonomy-aligned investment activities

Sampo Group, 31 December 2025


Exposures	%	EURm
Total AUM	100.0%	17,160
Assets covered by the KPI	38.5%	6,607


% of covered assets	% Turnover based	% CapEx based
Taxonomy-eligible	30.9%	35.6%
Nuclear activities	1.0%	0.9%
Fossil gas activities	0.2%	0.1%
Taxonomy-aligned	7.7%	9.9%
Undertakings subject to Article 19a and 29a of Directive 2013/34/EU	7.7%	9.9%
of which non-financial undertakings	6.2%	8.3%
of which financial undertakings	1.5%	1.6%
Other covered counterparties and real estate assets	–%	–%
Investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders	–%	–%
Exposures included on a voluntary basis	–%	–%
Transitional activities	1.3%	1.4%
Enabling activities	3.8%	4.5%
Nuclear activities	1.0%	0.9%
Fossil gas activities	0.0%	0.0%


Taxonomy-aligned per objective	% Turnover based	% CapEx based
Climate Change Mitigation (CCM)	7.5%	9.5%
Climate Change Adaptation (CCA)	1.6%	1.5%
Water and marine resources (WTR)	0.0%	0.0%
Circular economy (CE)	0.1%	0.2%
Pollution (PPC)	0.1%	0.1%
Biodiversity and Ecosystems (BIO)	–%	–%
Non-assessed exposures	–%	–%
Exposures financing non-assessed non-material activities of counterparties	–%	–%
Exposures financing counterparties reporting in accordance with Article 7(9) to this Regulation	–%	–%
Non-assessed exposures considered non-material by the reporting entity	–%	–%


Breakdown of covered assets	%	EURm
Undertakings subject to Article 19a and 29a of Directive 2013/34/EU	100.0%	6,606
of which Non-financial undertakings	49.1%	3,243
of which Financial undertakings	50.9%	3,364
Other covered counterparties and real estate assets	0.0%	0
Investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policy holders	–%	–
Exposures included on a voluntary basis	–%	–


	BOARD OF DIRECTORS’ REPORT 2025	77

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

E1 Climate change


Topic	Impacts	Risks and opportunities	Strategy and actions
Climate change mitigation	↓ 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, investments and customers, the impact is more material. • Time-horizon: short, medium, and long term • Value chain location: own operations, upstream value chain, downstream value chain	↓ Sampo Group can face potential reputational risks related to GHG emissions or if it fails to achieve its set emission reduction targets. ↓ Sampo Group can face financial and reputational risks arising from increasing climate-related legislation (e.g. compliance costs, possible fines). ↓ Transition risks related to insuring new technology, changes in customer behaviour, and increased stakeholder concern can have a negative effect on Sampo Group’s underwriting, as well as claims costs and frequency.* • Time-horizon: short, medium, and long term • Value chain location: own operations, upstream value chain, downstream value chain	• Commitments to reduce GHG emissions (e.g. SBTi) • Internal policies and guidelines (e.g. responsible investment policies, underwriting principles, codes of conduct) • Effective governance structures and processes (e.g. risk management, screening, engagement) • Sustainable claims handling and development of the handling of new types of claims • Internal training, competence development programmes, and awareness raising • Metrics and targets (e.g. SBTs related to own operations, investments, and suppliers) • Sampo Group’s transition plan for climate change mitigation
Climate change adaptation	↑ Sampo Group has potential positive impact through its insurance solutions which provide extensive coverage against natural hazards, support and incentives for loss prevention measures, and a high level of service in post disaster situations. The pricing of the products properly reflects climate change risk. Additionally, Sampo Group participates in research on climate change adaptation. Non-life insurance and reinsurance are recognised by the EU Taxonomy as enabling economic activities that can make a substantial contribution to the environmental objective of climate change adaptation. • Time-horizon: short, medium, and long term • Value chain location: own operations, upstream value chain, downstream value chain	↓ The increasing scale and frequency of physical climate-related risks, such as storms, floods, heavy rains, landslides, erosion, hailstorms, and heat waves, can cause financial risks for Sampo Group (e.g. increased claims costs and decreased investment returns). ↑ Development of sustainable products and services may provide some opportunities for Sampo Group (e.g. related to loss prevention and risk management). • Time-horizon: short, medium, and long term • Value chain location: own operations, upstream value chain, downstream value chain	• Development of sustainable products and services based on customers’ needs and applicable legislation • Consideration of climate-related risks in underwriting, pricing of the products and services, and in reinsurance • Diversification (e.g. by geographical areas and lines of business) • Loss prevention and risk management services • Claims handling and support in post-disaster situations • Consideration of climate-related risks in investment operations (e.g. scenario analysis) • Training and awareness raising among stakeholders (e.g. employees and customers) • Support for research on loss prevention

The table presents Sampo Group’s material impacts, risks, and opportunities related to climate change identified in the double materiality assessment and their connection to Sampo Group’s strategy and

actions .

* IRO has been added as part of the 2025 DMA review.


	BOARD OF DIRECTORS’ REPORT 2025	78

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Strategy

SBM-3 – Material impacts, risks, and

opportunities and their interaction with

strategy and business model

Sampo Group’s underwriting operations are exposed to

both physical risks and transition risks. Physical risks are

risks related to the physical impacts of climate change

and transition risks are risks related to the transition to a

low-carbon economy. Physical climate-related risks

include storms, floods, heavy rains, landslides, erosion,

hailstorms, and heat waves. The scale or frequency of

these natural disasters can increase claims costs.

Transition risks , on the other hand, relate to changes in

the regulatory environment, the introduction of new

technologies, changes in customer behaviour, and

increased stakeholder concern for climate and

environmental matters, for example.

Sampo Group’s investments can also be impacted by

both physical risks and transition risks, depending on

the investment in question. Investments can be exposed

to physical risks in the form of losses incurred from

extreme weather events. The transition to a low-carbon

society with potentially increasing environmental and

climate regulation, more stringent emission

requirements, and changes in market preferences could

in turn cause transition risks for the Group’s investments

and possible revaluation of assets as operating models

in carbon intense sectors change.

Sampo Group’s capital planning, a forecast of own

funds and capital requirements over a three-year

planning period, and own risk and solvency assessment

(ORSA) processes include scenario analyses, stress

tests, sensitivity analyses, and reverse stress tests,

including scenarios related to natural catastrophes.

Climate scenario analysis

Sampo Group has together with the external service

provider ORTEC Finance analysed the Group’s

investment portfolio's exposure to systemic economic

and financial climate risks in four different climate

scenarios over the next 40 years. The impact on the

insurance result was also analysed based on the impact

on macroeconomic variables as well as the potential

effect on claims related to natural catastrophes,

including the consequences for the pricing of insurance

contracts.

The four scenarios analysed are the following:

• Net-Zero (NZ), average global warming of 1.5°C by

2100: This scenario describes an easy and smooth

transition where political and social organisations act

quickly and predictably to achieve net-zero CO2

emissions by 2050. The scenario corresponds to

Intergovernmental Panel on Climate Change’s (IPCC)

‘very low emissions’ scenario: SSP1-RCP1.9.

• Net-Zero Financial Crisis (NZFC), average global

warming of 1.5°C by 2100: In this scenario, the

transition to a greener economy happens in a

disorderly manner. Sudden divestments to align

portfolios to the Paris Agreement goals in 2026 have

disruptive effects on financial markets with sudden

repricing followed by stranded assets and a sentiment

shock. The scenario corresponds to IPCC’s ‘very low

emissions’ scenario: SSP1-RCP1.9.

• Limited Action (LA), average global warming of 2.8°C

by 2100: In this scenario, policymakers implemented

limited nationally determined contributions (NDCs)

but fall short of meeting the Paris Agreement goals.

Global warming reaches 2.8°C, and this causes high

physical impact. The scenario corresponds to IPCC’s

‘intermediate emissions’ scenario: SSP2-RCP4.5.

• High Warming (HW), average global warming of

4.2°C by 2100: In this scenario, the world fails to meet

the Paris Agreement goals, and global warming

reaches 4.2°C above pre-industrial levels. Physical

climate impacts cause large reductions in economic

productivity and increased impacts from extreme

weather events. This scenario focuses on physical risk

as the green transition does not happen. The scenario

corresponds to IPCC’s ‘high emissions’ scenario:

SSP3-RCP7.0.

The methodology used to assess systemic climate

change risks and opportunities related to Sampo

Group’s investments combines climate science with

econometric and financial modelling. The methodology

relies on the following key assumptions:

• The scenarios used are climate science informed

scenarios. Each scenario differs in terms of

assumptions about policy and technology changes,

physical risks, and pricing-in mechanisms. The

scenarios are chosen to explore a range of plausible

outcomes.

• The E3ME model by Cambridge Econometrics models

the world’s economic and energy systems and the

environment. It is a quantitative framework for

analysing the impacts of Energy-Environment-

Economy (E3) policies over the short, medium and

long term. It is widely used globally for policy

assessment as well as for forecasting and research. In

this context, it is used to model the impact of

transition risk on the evolution of macroeconomic

variables. Currently, the E3ME model does not

explicitly account for physical risk factors and is,

therefore, complemented by methods to account for

the impact of gradual physical risks and extreme

weather events on the evolution of macroeconomic

variables.

• Stochastic financial modelling that translates shocks

to macroeconomic variables to risk-return metrics for

different geographies, sectors, and asset classes is

used in the last step to translate the climate-informed

outputs from the previous steps (i.e. the impact of


	BOARD OF DIRECTORS’ REPORT 2025	79

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

transition risks and physical risks on the evolution of

macroeconomic variables in the different scenarios).

In addition, assumptions about pricing-in and

sentiment shocks in financial markets, and how they

impact asset returns and risk for a large number of

economic and financial market variables are made.

Impact on investment result

The climate scenario analysis was first conducted in

2023, and the results were reweighted based on the

investment allocation as at 30 September 2025. The

results of the scenario analysis form a set of data that

can be analysed from various perspectives. The results

are presented relative to a baseline that does not take

into account any specific assumptions about climate

change. Instead, the baseline relies on historical

relationships and long-term views shaped by current

market conditions.

According to the results of the climate scenario

analysis, Sampo Group’s current investment portfolio is

relatively resilient to climate change risk in all four

scenarios. This is due to the significant allocation to

fixed income instruments, which tend to be less

affected than equities, as well as the geographical

allocation towards mainly the Nordics and other

European countries where the effects of climate change

are expected to be lower than in other parts of the

world. According to the analysis, in the short run, the

main risk is related to the pricing-in shock in the NZFC

scenario. In the long run, there will be a negative impact

on the returns in all scenarios, due to increased physical

risks. In addition, returns from high GHG emitting

sectors are particularly affected in both net-zero

scenarios (NZ and NZFC).

Impact on insurance result

To assess the impact of the climate scenarios on the

insurance results, Sampo Group used the forecasts for

macro variables (gross domestic product, GDP, and

inflation) and their direct effect on insurance results in

combination with assumptions for effects on natural

catastrophe claims and repricing of insurance contracts

under the different climate scenarios. The sensitivity to

increased physical risk was assessed by including

increased natural catastrophe claims in the HW

scenario, and separately considering repricing due to

increased claims cost. The analysis has been performed

across the relevant insurance operations throughout

Sampo Group.

According to the scenario analysis, the combined effect

of changes in GDP and inflation in the HW scenario

compared to the NZ scenario leads to a relatively

limited impact on the insurance result. This is mainly

due to offsetting effects stemming from how different

economies are affected in the Nordic and UK region.

However, the assumed impact on natural catastrophe

claims is more material, in particular in the scenario

without repricing and the apparent offsetting effect of

repricing actions. The scenario analysis hence indicates

that although the direct impact from macroeconomic

impacts is relatively limited, increased claims costs

could materially influence the insurance results, and

appropriate repricing of the insurance contracts will be

particularly important in such a scenario. With P&C

insurance contracts almost exclusively being renewed

on a yearly basis within Sampo Group, the resilience

towards trends in claims for whatever reason is typically

high given the focus on financial control, clear financial

targets, and general underwriting focus within the

Group.

E1-1 – Transition plan for climate change

mitigation

During 2025, Sampo Group continued to develop its

transition plan for climate change mitigation. The

Group’s transition plan is based on its SBTs and related

decarbonisation levers for own operations, investments,

and suppliers, as well as the processes and resources

needed to implement these. Sampo Group has aligned

its transition plan with its overall strategy and business

model, particularly through its investment and claims

handling operations. In the coming years, the Group will

continue to develop the transition plan, for example by

investigating decarbonisation efforts related to

underwriting activities. As a transition enabler, Sampo

Group can reduce GHG emissions from its value chain

especially by engaging with corporate customers,

investee companies, and suppliers and encouraging

them to set SBTs.

Sampo Group has not been excluded from the EU Paris-

aligned benchmarks. As a company operating in the

financial sector, locked-in emissions from own

operations (Scopes 1 and 2) are not relevant for Sampo

Group, as these operations are not GHG intensive.

Additionally, the Group has estimated that its insurance

products and investments do not contain sources for

significant locked-in emissions due to the nature of

these assets. For instance, insurance contracts are

usually renewed annually, and the investment portfolio

can be adjusted as it consists mostly of highly liquid

assets, such as credit bonds, money market instruments,

government bonds, and direct equities.

Sampo Group’s commitment to the Science Based

Targets initiative (SBTi), the related targets, and the

transition plan have been approved by the Group’s

management and the Board of Directors. Sampo Group

is committed to developing its transition plan in

accordance with applicable regulation and frameworks,


	BOARD OF DIRECTORS’ REPORT 2025	80

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

and reports on the development annually as part of the

regulatory sustainability reporting.

Science-based targets

Sampo Group’s transition plan builds on its near-term

SBTs, which were set in accordance with the SBTi’s

methodology for the financial sector and validated by

the SBTi in November 2024. The targets are compatible

with limiting global warming to 1.5°C in line with the

Paris Agreement. In addition to the mandatory group

level SBTs set for the Group’s own operations (Scope 1

and 2) and investments (Scope 3, category 15), Sampo

Group has, on a voluntary basis, set a supplier

engagement target on subsidiary level.

Sampo Group initiated quarterly internal monitoring of

its progress against the mandatory targets in 2025.

External reporting is done annually as part of the annual

sustainability statement. The voluntary target for

suppliers is monitored internally regularly and reported

on an annual basis. Sampo Group’s SBTs and progress

against them are presented in detail in the table

Science-based targets (p. 85).

Sampo Group has started assessing long-term

decarbonisation pathways aligned with the SBTi’s

Financial Institutions Net-Zero Standard, published in

July 2025. The aim is to ensure that possible future net-

zero targets are realistic, science-aligned, and

supported by actionable plans. Sampo Group intends to

formalise its plans related to net zero before the

renewal of its current near-term targets in 2029.

Decarbonisation levers

To reach its SBTs, Sampo Group has identified relevant

decarbonisation levers related to its own operations,

investments, and suppliers, and actions to be taken in

the coming years. The most important levers to achieve

the SBTs for own operations are switching to renewable

energy, reducing energy use in offices, and electrifying

the car fleet. For investments, the main decarbonisation

levers include regular monitoring using screenings,

engagement with investee companies (e.g. direct

dialogue, investor events, AGMs), monitoring investee

companies' temperature scores and the percentage of

investees who have set SBTs, development of the

Group’s coal phase-out plan, and portfolio turnover. To

reach its voluntary SBTs for suppliers, the key lever is

engagement with suppliers to set SBTs. In addition to

its existing SBTs and related decarbonisation levers that

form the basis for Sampo Group’s transition plan, the

Group has identified underwriting and claims handling

operations as areas to further assess and expand when

updating the climate transition plan in the coming years.

The decarbonisation levers and related actions are

described in more detail under the heading E1-3 –

Actions and resources in relation to climate change

policies. (p. 81).

Investments and funding

Sampo Group is committed to allocating sufficient

resources to the development and implementation of its

transition plan. In 2025, the Group assessed the key

costs related to the implementation of the plan. As a

financial company not requiring major industrial

investments for the climate transition, Sampo Group’s

funding needed to implement the transition plan is

mainly related to renewable energy contracts and

certificates, energy efficiency measures in the offices,

and the ongoing shift away from fossil-based energy

sources in the offices as well as the car fleet. Therefore,

based on the current assessment, the implementation of

the Group’s transition plan is not expected to require

allocation of specific investments or funding beyond

normal costs related to business development.

Sampo Group’s insurance and investment activities are

covered by the EU Taxonomy. The Group’s Taxonomy

disclosures, including the description of future plans, are

presented in the section EU Taxonomy (p. 72).


	BOARD OF DIRECTORS’ REPORT 2025	81

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Impact, risk and opportunity

management

E1-2 – Policies related to climate change

mitigation and adaptation

The group level p olicy regarding climate change

mitigation and adaptation is the Sampo Group Code of

Conduct, which is reviewed annually and approved by

Sampo’s Board of Directors. The Code of Conduct

states that the Group complies with climate-related

legislation, is committed to combatting climate change,

and supports the Paris Agreement. The policy is also

supported by Sampo Group’s commitment to the SBTi

and involvement in various initiatives (e.g. UN Global

Compact). The Code of Conduct covers all Sampo

Group’s own operations. The Group also expects its

suppliers and other business partners to comply with

the principles of the Code of Conduct throughout their

own operations and supply chains.

In addition to the Group’s Code of Conduct, Sampo

Group has supplementary policies, guidelines, and

processes for specific purposes to guide the work

related to climate change mitigation and adaptation on

a more detailed level. These include, for example,

sustainability policies, supplier codes of conduct,

responsible investment policies, and underwriting

principles.

The Sampo Group Code of Conduct and other policies

address climate change mitigation and adaptation,

energy efficiency, and renewable energy deployment.

These matters have been incorporated into Sampo

Group’s own operations, investment operations,

insurance underwriting, supply chain management,

claims handling, and loss prevention services. Through

its own actions and engagement with its value chain,

the Group strives to reduce the consumption of

resources, increase reuse and recycling, and prioritise

the use of renewable energy. The Group encourages its

customers, investee companies, suppliers, and other

business partners to uphold similar environmental and

climate commitments, and consults and cooperates

with its stakeholders on environmental and climate

matters.

E1-3 – Actions and resources in relation to

climate change policies

Climate change mitigation

Sampo Group has assessed that it has a negative

impact on climate change through the GHG emissions

of its own operations and value chain. However, the

Group has GHG emission reduction targets and planned

actions to reduce the emissions and mitigate the

negative impact.

Own operations

Sampo Group has set an SBT to reduce its total Scope 1

and 2 emissions by 42 per cent by 2030 compared to

the 2022 base year. This corresponds to an emission

reduction of 2,847 tCO₂e. In accordance with the SBTi’s

methodology, the target is a combined target and does

not have separate target levels for Scope 1 and Scope 2.

Sampo Group has identified switching to renewable

energy, reducing energy use in offices, and electrifying

the car fleet as the main decarbonisation levers to

achieve the target. Key actions to be taken include

purchasing renewable electricity, switching to biogas

and district heating, changing to LED lighting,

optimising the use of office space, and transitioning the

car fleet to electric and hybrid vehicles. Sampo Group

has estimated that switching to renewable energy in the

offices will contribute to 68–80 per cent of the required

emissions reductions. Reducing energy use in the

offices and electrifying the car fleet are estimated to

contribute to 13–22 per cent and 7–11 per cent of the

required emissions reductions, respectively. The

expected quantitative contributions to achieve the GHG

emissions reduction target for Sampo Group’s own

operations (Scope 1 and 2) were estimated using

modelled interventions towards 2030 based on

reduction potentials within each identified

decarbonisation lever and assumed adoption rate to all

emissions sources.

In 2025, Sampo Group’s climate change mitigation

actions focused on the identified decarbonisation

levers. During the year, several locations in the Nordics

switched to renewable electricity and one location from

natural gas to district heating. In addition, solar panels

were installed in one location. The car fleet is gradually

being electrified as leases are renewed, and as at 31

December 2025, 87.9 per cent of Sampo Group’s

company car fleet consisted of electric and hybrid

vehicles. Measures related to reducing energy

consumption in offices included, among others,

reducing the indoor temperature, replacing windows,

switching to LED lighting, and installing intelligent

lighting and sensor activated taps. During 2026, Sampo

Group will continue its emission reduction actions and

initiatives, and monitor progress against the Scope 1

and 2 targets.

Investments

To achieve its SBTs for investments (p. 85), Sampo

Group has adopted a strategy that builds on strategic

asset allocation and proactive investee engagement.

This means that investments in companies and assets

that offer strong financial returns and align with the

Group’s climate objectives are prioritised.

Decarbonisation levers related to investments include

regular monitoring using screenings, engagement with

investee companies, monitoring the percentage of

investees who have set SBTs, development of the

Group’s coal phase-out plan, and portfolio turnover.


	BOARD OF DIRECTORS’ REPORT 2025	82

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

In 2025, Sampo Group started monitoring the

temperature scores for its investee companies and the

share of investees that have set SBTs validated by the

SBTi. Through these metrics, Sampo Group can monitor

the progress of its investment portfolio in setting

credible GHG emission reduction targets, thereby

contributing to the Group’s SBTs for investments.

Sampo Group reports the percentage annually as part

of its sustainability statement.

During the year, Sampo Group also developed its

engagement activities to include direct, proactive

engagement with investee companies with no SBTs or

other similar credible transition plans or climate goals.

The investees Sampo Group plans to engage with were

selected based on their significance within the

investment portfolio and the potential to drive

meaningful change through engagement. This direct

engagement process will be launched in 2026.

Information regarding pooled engagements is provided

in this Sustainability Statement under the heading

S2-4 – Taking action on material impacts on value chain

workers, and approaches to managing material risks

and pursuing material opportunities related to value

chain workers, and effectiveness of those actions

(p. 111).

During 2025, to complement and guide each

subsidiary’s existing responsible investment policies,

Sampo Group introduced a group level policy that

outlines the principles of responsible investment applied

to the investment activities of Sampo plc and its

subsidiaries holding investment assets. Additionally, If’s

Responsible Investment Policy was updated to consider

changes in its investment portfolio following the

integration with Topdanmark.

In 2025, Sampo Group continued to perform sector-

based and norm-based screenings for its direct

investment portfolio to identify and make decisions

regarding investees that are involved in certain

industries as well as investees’ adherence to

international norms concerning environmental

protection. In addition, to ensure quality monitoring of

investments from a sustainability perspective going

forward, Sampo Group reviewed its ESG data service

providers during the year.

Share of investees with science-based

targets

Sampo Group


Metric	31 Dec. 2025
Share of investees with SBTs	25.5%

Calculated based on the market value (EUR) of financial assets

(excluding Hastings’ loans to customers), and therefore also

includes investments that are out of scope for the Group’s SBTs,

such as sovereigns and alternative investments.

Suppliers

To reach its voluntary supplier engagement target on a

subsidiary level (p. 85), the key decarbonisation lever is

to engage with and encourage suppliers to set SBTs.

Supplier engagement offers a way to influence

decarbonisation efforts within the supply chain when

granular emissions data is challenging to track or

unavailable. The Group’s subsidiary level target for

suppliers applies to all If’s suppliers. The engagement

actions focus especially on suppliers in claims handling,

as they represent a major part of supplier spend and

emissions.

In 2025, If continued to monitor how many of its

suppliers within motor and property claims have set

SBTs or equivalent to be able to support and incentivise

remaining suppliers to set targets going forward. If also

developed an engagement programme to create a

cohesive organisation-wide approach for supplier

engagement. In 2026, If plans to launch a pilot phase

with selected suppliers and refine engagement

approaches before broader implementation. The pilot

will focus on establishing assessment frameworks,

working with procurement teams to evaluate supplier

relationships, and initiating open dialogue with suppliers

about potential support activities.

Underwriting

Sampo Group recognises the impact of the GHG

emissions it enables through its underwriting activities.

In 2025, the Group conducted a project with an external

service provider to calculate its insurance-associated

emissions in accordance with the standard developed

by the Partnership for Carbon Accounting Financials

(PCAF) to gain an understanding of the calculation

process, data availability, and scale of emissions.

Business lines in scope of the calculations following

PCAF’s methodology are personal motor insurance and

commercial insurance. Sampo Group’s insurance-

associated emissions (Scope 1 and 2) from personal

motor insurance amounted to 723,262 tCO₂eq and from

commercial insurance to 436,660 tCO₂eq. The

calculations are based on insurance policies in force as

at 31 December 2024.

Measuring insurance-associated emissions (to be

accounted for separately from financed emissions under

Scope 3, category 15) is a critical first step in identifying

the carbon intensive hotspots of the Group’s

underwriting activities and guiding decarbonisation

efforts. Going forward, Sampo Group will develop the

calculation process and data quality with the intent to

report insurance-associated emissions annually. The

Group also plans to align reporting on insurance-

associated emissions in accordance with PCAF’s

guidance. In the coming years, Sampo Group will assess

the possibility of defining metrics and setting targets

based on available methodologies and standards for

financial companies.


	BOARD OF DIRECTORS’ REPORT 2025	83

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Claims handling

Sampo Group can contribute to climate change

mitigation by emphasising energy and resource

efficiency, and use of renewable energy in claims

handling operations. This is done, for example, by

setting additional sector-specific environmental

requirements on vehicle and property suppliers

covering transportation, as well as material and

energy usage.

In 2025, Sampo Group continued to support customers

through its Sustainable Building module. The module,

available in Sweden, Norway and Finland, provides

commercial customers with concrete advice, guidance,

and financial support for sustainable measures, such as

the use of solar panels and energy efficiency measures,

in the reconstruction after major damage. The module is

based on the BREEAM certification systems.

Sampo Group also acknowledges the GHG emissions

associated with its claims handling activities, and has

therefore calculated emissions from vehicle and

property claims in the Nordics. The calculations were

conducted in 2022 using data from 2021, and the

estimated emissions from vehicle and property repairs

at that time amounted to a total of 88,618 tCO2eq. In

2025, Sampo Group started a project to update the

calculations to reflect changes in claims management

since then, such as cost inflation, improvements in

sustainability practices, changes in the Group structure,

and variations in claim types. The project will be

finalised during 2026. Going forward, the Group will

assess the possibility to include emissions from claims

handling in its GHG inventory (Category 11 Use of sold

products) as reporting and data quality develop.

Climate change adaptation

Climate change will lead to severe consequences for

society unless sufficient adaptation measures are

implemented. Sampo Group takes actions related to

climate change adaptation especially through its

underwriting processes and loss prevention services.

Underwriting

Sampo Group continually develops the underwriting

and pricing of extreme weather and climate-related

physical risks. Pricing is typically based on historical

claims data and portfolio results, and trends in claims

will automatically have an effect on the price. Forward-

looking scenarios, including natural hazards scenarios,

on a one-year basis are also part of the annual capital

allocation process that in turn affects the pricing of all

products. Reinsurance is used to manage the

aggregated exposure to natural catastrophes. In 2025,

Sampo Group further developed the climate risk pricing

in the Nordics by exploring new data sources that

reflect existing and future risks related to climate

change.

Loss prevention

Sampo Group works actively with loss prevention,

including mitigating the losses from climate-related

events. The service offered by the Group depends on

the customer type, insurance policy, and operating

country. In 2025, Sampo Group continued to offer large

corporate customers risk management services, where

risk engineers conduct on-site risk assessments and

identify preventive measures to avoid damage and

enable a stable operation. Customers are advised on

natural hazards, such as coastal flooding, tornados,

hailstorms, and wildfires. During the year, in cooperation

with an external partner, Sampo Group offered house

assessments in Finland, Norway, and Sweden to private

customers who own their house and hold top-level

coverage insurance policies. The assessments provide

the customer with advice on maintenance and loss

prevention measures, including climate-related damage.

For SME customers in Norway and Finland, Sampo

Group continued to offer building checks. In the UK,

Sampo Group also provided guidance to its customers

on loss prevention during 2025, including winter car

check reminders and recommendations on how to

mitigate issues at home, such as frozen pipework.

Sampo Group participates in various research projects

together with universities, research institutes, and

customers. The aim of this work is to better understand

risks and to support the customers in their risk

management, but also to contribute to a more

sustainable society. For example, If publishes extreme

weather reports biannually in Norway, with the latest

published in autumn 2025. The reports are prepared in

cooperation with CICERO Center for Climate Research

and IVL Swedish Environmental Research Institute, and

they analyse the work conducted by Norwegian

municipalities on climate change adaptation. In 2025, If

published a similar report for the first time in Finland,

together with Syke, the Finnish Environment Institute

and IVL. The reports also identify challenges the

municipalities are facing and showcase good examples.

During the year, If also participated in a research project

related to water management in Gavleån, Sweden, with

IVL and several local actors. The project aimed at

creating more collaboration between different public

and private actors to prevent heavy rainfalls from

causing flooding.


	BOARD OF DIRECTORS’ REPORT 2025	84

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Metrics and targets

E1-4 –Targets related to climate change

mitigation and adaptation

Sampo Group’s climate targets are aligned with the

SBTi’s methodology, which supports the Paris

Agreement. This approach is in line with the policy

objectives stated in the Sampo Group Code of Conduct.

Sampo Group’s target for own operations (Scope 1 and

2 emissions) follows the absolute contraction approach.

The Group’s target boundary includes all Sampo Group

companies. The market-based approach was used to

calculate the Scope 2 GHG emissions included in the

target.

The targets for the listed equity, corporate bond, fund,

ETF, and corporate loan investment portfolio have been

set using the temperature rating approach and the

target for the commercial real estate portfolio using the

sectoral decarbonisation approach (SDA). Sampo

Group’s portfolio targets cover 57.9 per cent of its total

investment and lending by total assets as of 2022. As of

that year, required activities made up 57.9 per cent of

Sampo Group’s total investment and lending by total

assets, while optional activities made up 5.6 per cent

and out-of-scope activities (e.g. sovereign bonds,

securitised fixed income, money market instruments,

derivatives, and cash) made up 36.5 per cent.

The above mentioned SDA, used for Sampo Group’s

SBT for its real estate portfolio, is a method for setting

physical intensity targets that uses convergence of

emissions intensity. The real estate holdings represent a

very limited portion of Sampo Group’s investment

portfolio as their market value accounts for less than 0.5

per cent of the total financial assets. In accordance with

the SBTi’s methodology, the target is an emission

intensity target and does not have separate target

levels for absolute emissions.

Sampo Group engaged in dialogue with several

stakeholders when committing to the SBTi and setting

the climate targets. These included, for example,

investors, large corporate customers, and the

company’s management and boards of directors.

Progress against the Group’s targets is monitored

internally regularly and reported externally in the

sustainability statement published annually.

There were no changes in the group level targets during

the reporting year. Topdanmark’s company-specific

target related to suppliers reported in 2024 was

discontinued due to the integration with If. The Scope 1

and 2 GHG emissions for years 2022–2024 were

recalculated following the merger of If and

Topdanmark. The aim was to ensure that the

calculations apply a common methodology as well as

consistent assumptions across the Group and provide a

solid base for the decarbonisation roadmap.

Based on the recalculations, Scope 1 emissions

increased by 679 tCO2eq in 2022 and 530 tCO2eq in

2024 mainly due to an increase of the annual mileage,

which is used in calculation assumptions. Scope 2

market-based emissions increased by 115 tCO2eq in

2022 and 88 tCO2eq in 2024 due to the availability of

new consumption data and adjustments of emissions

factors. Scope 2 location-based emissions increased by

374 tCO2eq in 2022 and 710 tCO2eq in 2024. The

changes also affected Scope 3 category 3 (Fuel and

energy-related activities), which increased by 329

tCO2eq in 2022 and 317 tCO2eq in 2024. In addition,

emissions for Scope 3 category 1 (Purchased goods and

services) were adjusted for 2024 due to improved data

quality. Reporting on biogenic emissions has been

updated to include only Scope 1 and 2 emissions as

Scope 3 emissions are insignificant. Scope 3 biogenic

emissions for 2024 have been removed for consistency

in reporting.


	BOARD OF DIRECTORS’ REPORT 2025	85

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Science-based targets

Sampo Group


Scope	Target	31 Dec. 2025
Own operations (Scope 1 and 2)	• Sampo Group commits to reduce absolute Scope 1 and 2 GHG emissions by 42 per cent by 2030 from a 2022 base year.	-55.8%
Investments* (Scope 3, category 15)	• Sampo Group commits to align its Scope 1 and 2 portfolio temperature score by invested value of its listed equity, corporate bond, fund, ETF and corporate loan portfolio from 2.78°C in 2022 to 2.09°C by 2029.	2.00
	• Sampo Group commits to align its Scope 1, 2, and 3 portfolio temperature score by invested value of its listed equity, corporate bond, fund, ETF and corporate loan portfolio from 2.91°C in 2022 to 2.29°C by 2029.	2.35
	• Sampo Group commits to reduce its real estate direct investment and corporate loan portfolio GHG emissions by 57.7 per cent per square metre by 2029 from a 2022 base year.	-42.3%
Suppliers** (Scope 3, category 1–14)	• 30 per cent of If’s suppliers by spend, covering purchased goods and services, will have science-based targets by 2028.	23.8%

* The CDP-WWF Temperature Scoring Methodology tool, recommended by SBTi, has generated temperature scores outside the range defined by the methodology, with values below 1.5°C and above 3.2°C.

To ensure consistency and transparency, Sampo Group tracks two sets of targets: one based on the tool’s unadjusted calculations (as approved by the SBTi and presented in the table above) and another

adjusted with a minimum threshold of 1.5°C. The adjusted targets and corresponding progress are detailed below:

Scope 1 and 2: The temperature score by invested value decreased from 2.85°C in 2022 to 2.26°C in 2025, showing progress toward the target of 2.12°C by 2029.

Scope 1, 2, and 3: The temperature score by invested value decreased from 2.94°C in 2022 to 2.48°C in 2025, showing progress toward the target of 2.30°C by 2029.

** Sampo Group has set SBTs in accordance with the SBTi’s sector-specific guidelines for the financial sector, which require companies to set targets for own operations (Scopes 1 and 2) and investments

(Scope 3, category 15). In addition, Sampo Group has a voluntary climate target for its supply chain through its subsidiary If.


	BOARD OF DIRECTORS’ REPORT 2025	86

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

E1-6 – Gross Scopes 1, 2, and 3 and total GHG emissions


	Retrospective				Milestones and target years
	2022 (Base year)	2024	2025	% 2025/2024	2025	2030	(2050)	Annual % target / base year
Scope 1 GHG emissions
Gross Scope 1 GHG emissions (tCO2eq)	1,876	1,412	1,569	11.1%		-42%*
Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%)	-	-	-	-
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions (tCO2eq)	2,856	2,597	1,953	-24.8%
Gross market-based Scope 2 GHG emissions (tCO2eq)	4,903	3,657	1,424	-61.1%		-42%*
Significant Scope 3 GHG emissions
Total gross indirect Scope 3 GHG emissions (tCO2eq)	353,383	326,634	422,945	29.5%
1 Purchased goods and services	2,017	14,435	12,607	-12.7%
2 Capital goods	111	2,843	5,630	98.0%
3 Fuel and energy-related activities (not included in Scope 1 or Scope 2)	1,884	1,560	1,172	-24.9%
4 Upstream transportation and distribution	-	456	847	85.6%
5 Waste generated in operations	273	260	246	-5.4%
6 Business travelling	5,592	6,318	7,178	13.6%
7 Employee commuting	5,141	6,860	6,849	-0.2%
8 Upstream leased assets	-	-	-	-
9 Downstream transportation	-	-	-	-
10 Processing of sold products	-	-	-	-
11 Use of sold products	-	-	-	-
12 End-of-life treatment of sold products	-	-	-	-
13 Downstream leased assets	-	41	-	-100.0%
14 Franchises	-	-	-	-
15 Investments	338,364	293,860	388,417	32.2%
Total GHG emissions
Total GHG emissions (location-based) (tCO2eq)	358,115	330,643	426,468	29.0%
Total GHG emissions (market-based) (tCO2eq)	360,162	331,704	425,939	28.4%

The figures for 2022 and 2024 were recalculated to align calculation methodologies due to the integration of If and Topdanmark.

Category 15 Investments concerns Sampo Group’s financed emissions for Scopes 1 and 2. Investment categories included in the calculations are direct equity and fixed income investments and fund

investments. The coverage was 83.6 per cent of Sampo Group’s financial assets (including associated companies). Sampo Group’s Scope 3 financed emissions were 6,014,897 tCO2eq in 2025.

* Sampo Group has a combined near-term target for Scope 1 and Scope 2 (market-based) emissions. Sampo Group’s emission reduction targets and results are disclosed in detail in the table Science-based

targets (p. 85).


	BOARD OF DIRECTORS’ REPORT 2025	87

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

GHG emissions intensity (total GHG emissions per net revenue)

Sampo Group


GHG emissions intensity	2025	2024	% 2025/2024
Total GHG emissions (location-based) per net revenue (tCO2eq/EURm)	42	35	18.7%
Total GHG emissions (market-based) per net revenue (tCO2eq/EURm)	41	35	18.1%

The denominator used when calculating the GHG emissions intensity is the Total insurance revenue

(Sampo Group’s Financial Statements, Statement of profit and other comprehensive income (p.

139) and Note 1 Insurance service result (p. 165)).

Biogenic emissions

Sampo Group


Metric	2025	2024
Scope 1 (tCO2eq)	158	170
Scope 2, market-based (tCO2eq)	4,217	2,768
Total biogenic emissions	4,376	2,938

Biogenic emissions arise from direct combustion of biomass or biodegradation. In Sampo Group’s

reporting these emissions are accounted for in Scope 1 and 2 in cases where the combusted fuel is

assumed to have a portion of biomass. The biogenic emissions are not included in the GHG

emissions reported on page 86.

Share of Scope 2 energy consumption covered by contractual

instruments

Sampo Group


Metric	2025
Share of procured energy covered by bundled contractual instruments	50.6%
Share of procured energy covered by unbundled contractual instruments	9.1%
Share of total procured energy covered by contractual instruments	59.7%

Bundled contractual instruments include both purchased electricity bundled with instruments (e.g.

green tariffs proving the delivery of renewable electricity) and purchased energy (i.e. heating and

cooling) bundled with attributes about energy generation, e.g. Guarantees of Origin (GOs).

Unbundled contractual instruments refer to tradeable Energy Attribute Certificates (EACs)

purchased by the company.


	BOARD OF DIRECTORS’ REPORT 2025	88

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Emission factors and calculation details

Sampo Group


Activity	Calculation details	Emission factor reference
Stationary combustion	Stationary combustion includes combustion of natural gas, biogas, gas oil, and diesel at applicable locations.	DESNZ, 2025
Mobile combustion	Mobile combustion is calculated based on litres of fuel or kilometres driven, depending on the availability of data. If data is unavailable, the data is extrapolated based on the number and type of vehicles and annual mileage. The estimated fuel consumption per vehicle is based on national statistics.	DESNZ, 2025; MITECO, 2024; South Pole derived based on Swedish Energy Agency 2019 and 2024, Swedish EPA 2023
Refrigerants	The calculation is based on the consumption of refrigerants at applicable locations.	DESNZ, 2025
Electricity	The calculation is based on purchased electricity (MWh). For smaller offices, the electricity consumption is extrapolated based on average consumption per FTE or office area (m²).	DESNZ, 2025; Finland Energy, 2024; Grexel Systems, 2024; IEA, 2024; NVE, 2024; South Pole derived emission factors
District heating	The calculation is based on purchased district heating (MWh). For smaller offices, district heating is extrapolated based on average consumption per FTE or office area (m²).	Euroheat & Power, 2023; national statistics; supplier-specific emission factors
District cooling	The calculation is based on purchased district cooling (MWh). For smaller offices, district cooling is extrapolated based on average consumption per FTE or office area (m ²).	South Pole derived average based on suppliers, 2023; supplier-specific emission factors
Purchased goods and services	Purchased goods and services includes water (m ³), paper (tonnes), cloud services (number of users), and, depending on data availability, also food services. Hastings reports the financial records of its purchased goods and services.	CEDA, 2025; Cloud Carbon Footprint, 2021; DESNZ, 2023, 2024, 2025; ecoinvent v.3.3.8, 2021; IPCC, 2014; Amazon, 2021; Google, 2012, 2021; Microsoft, 2021; Salesforce, 2021
Capital goods	Capital goods includes purchased IT equipment (number and model of devices) and larger renovations (spend).	CEDA, 2025; DESNZ, 2025; ecoinvent v. 3.11, 2024; supplier-specific emission factors
Fuel and energy-related activities	Fuel and energy-related activities are calculated with the supplier-specific method, average method, and hybrid method.	DESNZ, 2025; IEA, 2024; national statistics; South Pole derived emission factors; supplier-specific emission factors
Upstream transportation and distribution	Upstream transportation includes letters sent to customers. The calculation is based on averages and spend.	CEDA, 2025; DESNZ, 2025
Waste generated in operations	Waste data is only available for larger offices. For smaller offices, data is extrapolated based on average consumption per FTE or office area (m²).	ADEME 2023; BC V8.9; DESNZ, 2025; ecoinvent v3.9.1
Business travelling	Business travelling includes travel by air, train, ferry, bus, staff cars, rental cars, and taxis, as well as hotel accommodation. The calculations are based on activity or spend data. Emissions from hotel stays are calculated with country or city-specific emission factors.	CEDA, 2025; Cornell Hotel Sustainability Benchmark Index 2024; DESNZ, 2025; RDC flight data, 2024
Employee commuting	Emissions for employee commuting are based on surveys conducted in 2024 and 2025, which were either sent out to all employees or targeted groups and extrapolated to represent all employees. The category Employee commuting also includes remote working.	DESNZ, 2025; South Pole derived emission factor
Downstream leased assets	The lease ended in June 2024. There are no other leased assets.


	BOARD OF DIRECTORS’ REPORT 2025	89

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Calculation principles and assumptions

Own operations

Sampo Group’s GHG emission calculations include its

operations in the Nordics, Baltics, the UK, Gibraltar, and

Spain. Only offices in France, Germany, the Netherlands

and the United States have been excluded from the

boundary as emissions from these small offices with less

than 10 employees are deemed insignificant. An

external service provider, South Pole, conducts the

calculations based on data provided by Sampo Group.

The data inventory, emission factors, and assumptions

are based on the GHG Protocol, and include the main

greenhouses gases CO2, CH4, N2O, SF6, HFCs, PFCs, and

NF3 converted to CO2 equivalents. The selection of

assumptions and emission factors follows a

conservative approach. Where activity or spend data

for the inventory is lacking, extrapolations and

estimations are used.

Sampo Group purchases renewable energy through

contractual instruments such as green tariffs and

Guarantees of Origin (GOs). The share of purchased

energy covered by contractual instruments is calculated

by dividing the energy consumption (MWh) covered by

contractual instruments with the total Scope 2 energy

consumption (MWh).

The data behind Sampo Group’s Scope 3 category 1–14

emissions consists of 43.1 per cent primary data and

56.9 per cent secondary data. Primary data includes

data from directly reported activities (e.g. fuel

consumption), supplier-specific data (e.g. GHG data for

IT equipment reported by the supplier), and the

employee commuting survey. Secondary data includes

spend-based (e.g. services) and extrapolated data (e.g.

office waste).

Scope 3 categories 8 Upstream leased assets, 9

Downstream transportation, 10 Processing of sold

products, 12 End-of-life treatment of sold products, and

13 Downstream leased assets are not considered

relevant for Sampo Group, as the energy use for leased

assets (vehicles and IT equipment) is accounted for in

Scopes 1 and 2, its operations do not include activities

where non-paid transportation and distribution apply,

the Group does not sell tangible products, and there are

currently no leased assets. In the coming years, Sampo

Group plans to further develop its Scope 3 GHG

emission reporting, especially related to categories 1

Purchased goods and services and 14 Franchises.

Investments

The calculation methodology for GHG emissions from

Sampo Group’s investments follows the GHG Protocol’s

investment-specific method. The emissions from

investments are allocated to Sampo Group based on its

proportional share of investments in investee

companies. The proportional share is calculated by

using Enterprise Value Including Cash (EVIC) to

represent the total value of each investee company. The

absolute GHG emissions of investee companies are

collected using an external service provider, Bloomberg

L.P., where the primary source used is company

reported emissions followed by estimated emissions.

The scope of investments' GHG emissions includes

Sampo Group’s financial assets and investments in

associates. Out of all investments covered by the data

provider, 64.7 per cent is based on primary data (i.e.

emissions reported by investees) and 35.3 per cent is

based on secondary data (i.e. estimations).

Due to the lack of reliable data and calculation

methodology, Sampo Group has not obtained GHG

emissions data for its sovereign exposure, derivatives,

and loans to customers. Moreover, the data provider

does not cover all investment assets (e.g. some private

companies). The data coverage for Sampo Group’s

investments’ GHG emissions is 83.6 per cent of the

Group’s total financial assets. The majority of financial

assets not covered are sovereign, derivatives, and

municipality exposures. In 2025, Sampo Group

improved its data coverage for financed emissions

mainly by ensuring better alignment between its

investments and data provider records. The Group has

not used its own estimations for financed emissions as

the data coverage by the external data provider has

been considered good and using estimates would

decrease the data quality.

The increase in financed emissions is driven by

improved data coverage and by significant

contributions from a small subset of investee companies

with high emissions. Although these companies account

for only a marginal portion of the portfolio’s market

value, their emissions profile had a notable impact on

the total results.


	BOARD OF DIRECTORS’ REPORT 2025	90

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Underwriting

The calculation of insurance-associated emissions is

based on PCAF’s Global GHG Accounting and

Reporting Standard for the Insurance Industry.

Emissions calculations from Sampo Group’s personal

motor insurance include policies in the Nordics and the

UK. Emissions from personal motor vehicles are

calculated using activity data, such as fuel consumption

or distance travelled and the emissions intensity of the

vehicle multiplied with the industry attribution factor.

The industry attribution factor supplied by PCAF

determines the share of the vehicle’s absolute emissions

that should be allocated to the insurer. Estimations and

averages are used if actual emissions-related data is not

available for the insured vehicle.

Commercial insurance includes Sampo Group’s Nordic

Commercial and Industrial segments. Emissions for

commercial insurance are calculated by multiplying an

attribution factor based on PCAF’s standard with the

reported Scope 1 and 2 emissions of the insured

customers. The attribution factor for Sampo Group’s

share of its customers’ emissions was calculated by

dividing gross written premium by customer revenue.

Emissions were estimated for customers that do not

report their emissions.

Claims handling

Emissions from vehicle and property claims in the

Nordics have been calculated by a third party following

a life cycle assessment (LCA). The emissions were

calculated for a limited number of claims and then

extrapolated using spend to incorporate the full claims

portfolio. The calculations do not include the former

Topdanmark’s operations. These emissions are not

currently included in Sampo Group’s Scope 3 inventory

(category 11 Use of sold products) due to the level of

uncertainty and the lack of a standardised calculation

methodology.


	BOARD OF DIRECTORS’ REPORT 2025	91

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

E5 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, the Group can limit its negative environmental impact. • Time-horizon: short, medium and long term • Value chain location: own operations, downstream value chain	↑ 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 • Value chain location: own operations, downstream value chain	• Internal policies and guidelines (e.g. supplier codes of conduct) • Effective governance structures and processes (e.g. recycling, reuse and repair in claims handling, sustainable supply chain management) • Metrics and targets (e.g. reused parts, glass repairs)

The table presents Sampo Group’s material impacts, risks, and opportunities related to resource use and circular economy identified in the double materiality assessment and their connection to Sampo

Group’s strategy and actions. The topic Resource use and circular economy is related to the ESRS sub-topic Resource inflows, including resource use.


	BOARD OF DIRECTORS’ REPORT 2025	92

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Impact, risk and opportunity

management

E5-1 – Policies related to resource use and

circular economy

The group level policy regarding resource use and

circular economy is the Sampo Group Code of Conduct,

which is reviewed annually and approved by Sampo’s

Board of Directors. The Code of Conduct states that

Sampo Group should reduce the consumption of

resources (e.g. energy, water) and improve resource

efficiency, as well as reduce pollution, emissions, and

waste generated from business operations, while

incorporating the concepts of reduction, reuse, and

recycling. The Sampo Group Code of Conduct covers all

of the Group’s own operations. Additionally, Sampo

Group expects its suppliers and other business partners

to comply with the principles of the Code of Conduct

throughout their own operations and supply chains.

In addition to the Code of Conduct, Sampo Group has

supplementary and more detailed policies, guidelines,

and processes that support resource use and circular

economy. These include, for example, sustainability

policies to direct the work related to office space

upgrades and supplier codes of conduct, which outline

the expectations placed on suppliers with regards to

environmental considerations. The boards of directors

or other governing bodies of Sampo Group approve the

policies, and executive management is responsible for

the implementation.

Sampo Group’s supplier codes of conduct are publicly

available and are based on the 10 principles of the UN

Global Compact. The codes of conduct require

suppliers to further the development and diffusion of

low emission technologies that protect the

environment, are less polluting, use resources in a more

sustainable manner, recycle more of their waste and

products, and handle residual waste in a more

acceptable manner than the technologies for which

they were substitutes. Suppliers are expected to

continuously improve their climate and environmental

efforts, reduce the consumption of resources and

ensure the efficient use of these resources, and reduce

pollution, emissions and waste from business activities.

The supplier codes of conduct apply to suppliers with

whom Sampo Group conducts business, including the

suppliers’ subsidiaries and sub-suppliers. The codes also

apply to all of the suppliers’ employees, whether

permanent or temporary.

E5-2 – Actions and resources related to

resource use and circular economy

The most significant impacts, risks, and opportunities

regarding resource use and circular economy for

Sampo Group are related to suppliers in the Group’s

downstream value chain. Sampo Group does not

produce, sell, or handle physical products requiring

natural resources, but can instead affect the resource

use in its value chain via insurance policies and claims

handling processes. P&C insurance products and

services affect the amount of resources used mainly

through the policyholders’ claims related to vehicles,

and property. Sampo Group’s suppliers and business

partners are central to the claims handling process, and

the Group is committed to taking environmental and

climate considerations into account, for example, by

encouraging and supporting circular efforts in these

processes.

In 2025, Sampo Group cooperated with its suppliers in

claims handling to increase material reuse, recycling,

and repairs related to property and vehicle claims. The

Group also focused on specific requirements it has set

for its suppliers to promote circular economy. In the

Nordics and Baltics, property and vehicle repair

partners must comply with the sector-specific

Additional Environmental Requirements (AER), which

are incorporated into the purchasing agreements

together with the Supplier Code of Conduct. These

include requirements to repair instead of using new

parts, reuse spare parts, reduce material usage,

demolish less, increase remote work using video and

sensors, and use materials with environmental

certification when available. In the UK, Sampo Group

encourages its glazing suppliers to repair rather than

replace materials in home claims.

In addition, Sampo Group has set expected levels of

plastic repairs and used parts for selected vehicle repair

contractors, and these are monitored regularly. As a

consequence, the vehicle repair contractors reuse metal

and plastic instead of using new materials. Within

vehicle claims, Sampo Group works closely with the

dismantling industry and selected partners to promote

recycling and repair in the claims handling processes.

This includes a focus on using spare parts for repairs,

repairing windscreens instead of replacing them, and

repairing bumpers. The performance of dismantling

partners is monitored in order to obtain as many spare

parts as possible for the claims handling. Sampo Group

aims to steer towards the selected partners since these

solutions reduce the material usage and GHG emissions.

In 2025, Sampo Group performed a pilot study with

several partners in the Nordics to look into creative

ways to decrease material use in property claims, for

instance by repairing floors instead of installing new

ones. The pilot results showed that the maturity levels

and partner readiness differ between countries. Based

on the findings, the aim is to encourage more traditional

partners to increase repairs as well as identify potential

claims during the reporting phase and direct them to

partners with the necessary expertise.


	BOARD OF DIRECTORS’ REPORT 2025	93

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Metrics and targets

E5-3 – Targets related to resource use and

circular economy

For the time being, Sampo Group has not set

quantitative targets for its resource use and circular

economy actions on a group level. The circular

economy solutions in claims handling operations are

developing, but continue to also be subject to several

uncertainties and challenges, such as limited availability

of recycled parts (e.g. the UK market for recycled parts

is still in its early stages) and the time-sensitive nature

of the repair work. Therefore, Sampo Group has

evaluated that setting group level targets at this stage

is not justifiable from an environmental or financial

viewpoint. However, Sampo Group reviews processes

to manage impacts, risks, and opportunities related to

resource use and circular economy regularly, and in

case it is assessed that a group level externally

disclosed target is a valuable addition, the decision will

be revisited.

Metrics related to resource use and circular

economy

Sampo Group measures the progress of its resource use

and circular economy efforts, for instance, with the

metrics presented in the table Circular economy in

claims handling (vehicle repairs). The share of reused

parts and the share of glass repairs in vehicle repair

claims have been selected as key metrics, as they

reflect Sampo Group’s goals of promoting circular

economy and reducing resource use. The Group has

chosen to initially focus on vehicle repairs, as the

maturity of reused parts market in this area is higher

compared to property repairs, for instance. Sampo

Group measures the share of reused parts and glass

repairs based on the monetary amount spent on parts

and the number of glass repair claims.

In 2025, Sampo Group was able to increase both the

share of reused parts and the share of glass repairs in

claims handling. The increase was mainly achieved by

working together with the workshops and dismantlers

to get more orders and deliveries of used parts in the

Nordics.

Circular economy in claims handling

(vehicle repairs)

Sampo Group


Metric	2025	2024
Share of reused parts	5.0%	4.5%
Share of glass repairs	37.3%	35.3%

Figures are excluding the operations in the Baltics.


	BOARD OF DIRECTORS’ REPORT 2025	94

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Social information

S1 Own workforce


Topic	Impacts	Risks and opportunities	Strategy and actions
Employee health, wellbeing, and competence	↑ Through Sampo Group’s wellbeing initiatives, the mental and physical health of its employees can be improved. Competence development programmes can have a potential positive impact on the employees’ motivation and facilitate their professional growth and skills advancement. Prioritising employee wellbeing and competence development helps foster motivated and engaged employees. ↓ Sampo Group can have a negative impact on its employees' human and labour rights related to working time, adequate wage, freedom of association, collective bargaining, and privacy. Such impacts may result from unethical labour practices or breaches of the Group’s internal policies on employment, health, and wellbeing, for example. ↓ Failing to provide sufficient work-life balance, occupational health services, support, and competence development opportunities to employees can have a negative impact on Sampo Group's employees' mental and physical health, professional growth, competence, and motivation.* • Time-horizon: short term • Value chain location: own operations	↓ A lack of competent workforce can pose a financial risk for Sampo Group. If employees are not engaged and see no opportunities for professional development, talented but dissatisfied employees might leave, taking their skill set with them. ↓ 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). ↓ 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 their dedication drives results through positive customer experiences every day. Investing in personnel practices and an empowering work environment is essential for sustaining strong performance. • Time-horizon: short term • Value chain location: own operations	• Internal policies and guidelines (e.g. codes of conduct, HR policies) • Effective governance structures, processes and employee benefits (e.g. comprehensive occupational healthcare services, activities to support physical and mental health, workplace initiatives, quality offices, attractive remuneration packages) • Internal training, competence development programmes, and awareness-raising • Employee engagement (e.g. reporting channels, forums for dialogue, employee engagement surveys, freedom of association and collective bargaining) • Metrics and targets (e.g. employee engagement metrics, absence due to illness, employee turnover)
Diversity, equity, and inclusion (DEI)	↑ Through its own actions, Sampo Group can have a positive impact on DEI in its own workforce, which can cultivate a sense of belonging amongst employees. ↓ Failing to ensure equal treatment and opportunities for all can have a negative impact on Sampo Group's employees (e.g. discrimination, harassment, neglecting DEI, unequal pay).* • Time-horizon: short term • Value chain location: own operations	↓ 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. ↓ New and tightening legislation related to DEI (e.g. related to equal pay) can increase Sampo Group's costs (e.g. compliance, reporting, fines) and potential reputational issues related to non-compliance can affect the Group's financial results negatively.* • Time-horizon: short term • Value chain location: own operations	• Internal policies and guidelines (e.g. codes of conduct) • Effective governance structures and processes (e.g. diversity models/programmes, employee initiatives, reporting channels) • Internal training, competence development programmes, and awareness-raising • Metrics and targets (e.g. related to gender diversity and equal pay)

The table presents Sampo Group’s material impacts, risks, and opportunities related to own workforce identified in the double materiality assessment and their connection to Sampo Group’s strategy and

actions. The topic Employee health, wellbeing, and competence is related to the ESRS sub-topics Working conditions and Other work-related rights. The topic Diversity, equity, and inclusion is related to the

ESRS sub-topics Equal treatment and opportunities for all.

*IRO has been added as part of the 2025 DMA review.


	BOARD OF DIRECTORS’ REPORT 2025	95

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Strategy

SBM-3 – Material impacts, risks, and

opportunities and their interaction with

strategy and business model

Engaged employees are an essential part of Sampo

Group’s strategy and business model. The Group’s

business activities depend on its ability to create an

empowering work environment and on employees’

motivation to contribute to its goals. The dedication

and expertise of the workforce drive customer

satisfaction and form the foundation of the Group’s

competitive advantage. The interests, views, and rights

of Sampo Group’s employees inform strategic decisions

and help shape the corporate culture.

When assessing material impacts on its own workforce,

Sampo Group considers all types of employees who

may be significantly affected by the Group’s own

operations or value chain. This includes permanent,

temporary, full-time, and part-time employees, as well

as non-employees. For example, the double materiality

assessment, human rights impact assessment, and

employee engagement surveys help Sampo Group

identify which types of employees or employee groups

within its workforce may be particularly vulnerable to

negative impacts. These may include underrepresented

groups (e.g. based on ethnic background, gender,

sexual orientation, disabilities) and employees working

in high-pressure environments (e.g. contact centres).

Within Sampo Group, potential negative impacts on

employees are more likely to result from individual

incidents rather than systemic human rights issues.

Sampo Group has identified potential business and

operational risks stemming from a lack of diversity (e.g.

under-representation of minority groups),

discrimination, as well as higher illness rates and

employee turnover in certain parts of the Group (e.g.

contact centres). These factors may limit Sampo

Group’s ability to serve a diverse customer base

effectively, cause reputational damage or regulatory

sanctions, and increase recruitment costs, and may

therefore impact the Group’s financial performance.

Impact, risk and opportunity

management

S1-1 – Policies related to own workforce

Sampo Group’s policy related to its own workforce is

the Sampo Group Code of Conduct, which is reviewed

annually and approved by the Board of Directors. The

Code of Conduct covers topics such as human rights

and labour practices, employee health, wellbeing,

competence development, and DEI. It prohibits forced

and compulsory labour, child labour, and human

trafficking, and requires the Group companies to take

measures to identify, avoid, and/or address such human

rights violations in their own operations and value chain.

When developing the Code of Conduct, Sampo Group

consults both internal (e.g. employees, management)

and external stakeholders (e.g. investors, rating

agencies, authorities, external consultants), depending

on the need.

The Code of Conduct applies to all Sampo Group

companies and in all countries of operation. The

operative management in each Group company is

responsible for its implementation, and it is the personal

responsibility of every Sampo Group employee to

comply with it. Sampo Group offers regular training

(e.g. e-learning, workshops) on the topics covered by

the Code. The Code of Conduct is available to all

stakeholders on the Group’s website. In addition to the

Code of Conduct, each Group company has adopted

supplementary policies and guidelines for its own

purposes.

Sampo Group complies with all applicable human rights,

labour rights, and employment legislation. In addition to

national laws and regulations, the Group is committed

to respecting human rights as set out in the

International Bill of Human Rights including the

Universal Declaration of Human Rights, the International

Covenant on Civil and Political Rights, the International

Covenant on Economic, Social and Cultural Rights, and

those stated in the core conventions of the International

Labour Organization (ILO). Sampo Group is a

participant in the UN Global Compact and respects its

principles related to human and labour rights.

Sampo Group’s policies and related training are part of

its commitment to maintaining open channels of

communication with its own workforce and to

objectively addressing potential human rights impacts

within its operations, ensuring the provision of suitable

remedial actions when necessary. Remedies may

include, for example, support from HR, employee

representatives, and health and safety delegates, as well

as insurance cover and rehabilitation, depending on the

type of adverse impact and local regulations. Sampo

Group engages with its own workforce regularly and

has multiple channels for this purpose. More information

is available under the headings S1-2 – Processes for

engaging with own workers and workers’

representatives about impacts (p. 96) and SBM-2 –

Interests and views of stakeholders (p. 65).


	BOARD OF DIRECTORS’ REPORT 2025	96

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Employee health, wellbeing, and competence

Sampo Group has health and safety policies in place to

address workplace accident prevention, and provides

occupational healthcare in accordance with the

legislation in each operating country. The Group

investigates health and wellbeing risks regularly and

takes preventive action to mitigate them when relevant.

All Sampo Group companies perform risk assessments,

and any detected incidents or risks are handled

accordingly and reported using the appropriate incident

reporting tools. Together with employee surveys, the

risk assessments and incident reports provide valuable

insights for further developing business processes and

the work environment.

Sampo Group has work environment committees (or

similar) in place in accordance with local legislation.

These committees are responsible for monitoring the

work environment, developing health and safety

procedures, and ensuring a high quality of physical and

psychosocial wellbeing. The duties of the committees

can vary between the Group companies.

Sampo Group offers a comprehensive range of learning

opportunities to all employees, beginning with the

onboarding process. The Group provides mandatory

training (e.g. training required by the Insurance

Distribution Directive), voluntary training (e.g. digital

skills, language courses), and training delivered in

collaboration with external partners. The available

training options may vary depending on the employee’s

role or part of the organisation. Some trainings, such as

Code of Conduct, compliance, information security, and

data privacy, are mandatory for all employees, while

others are included in annual training cycles. In addition,

employees have the opportunity to develop their

expertise in various areas in line with their interests and

the requirements of their job role.

Diversity, equity, and inclusion

Sampo Group respects each individual’s human rights

and does not tolerate any kind of discrimination,

bullying, harassment, or any other type of abusive

behaviour. The Code of Conduct states that

discrimination is strictly prohibited, for example, on the

grounds of age, disability, national extraction or social

origin, racial and ethnic origin, colour, family

commitments, gender, gender identity, political opinion,

employees’ representative activities, religion, sensitive

medical conditions, sexual orientation, or any other

personal characteristics. In addition, discriminatory

practices regarding recruitment, job assignment,

training and development, promotion, remuneration

and other benefits, or general conduct in the workplace

are not tolerated. Reported cases related to

discrimination and harassment are investigated and

corrective action is taken.

At Sampo Group, it is important that all employees feel

included and can be themselves at work. The Group has

DEI policies and/or programmes and has taken action

to raise awareness and address DEI and vulnerable

groups within its own workforce. DEI topics are

advanced, for example, through internal employee

communities, internal committees, setting diversity

targets, as well as promoting DEI in recruitment and the

leadership pipeline.

S1-2 – Processes for engaging with own

workers and workers’ representatives about

impacts

Sampo Group engages regularly and directly with

employees and their representatives to gain insight into

employees’ perspectives, gather feedback, and identify

development needs. The CEOs of Sampo Group have

the overall responsibility for the engagement with

employees. Forums for dialogue include, for example,

leader-employee discussions, work environment

councils, meetings with union representatives, exit

interviews, and employee engagement surveys. In

addition, employees can raise concerns through internal

reporting and whistleblowing channels.

The employee engagement surveys cover both the

physical and psychosocial work environment. The

surveys include questions related to wellbeing and DEI,

and the results are also examined according to

demographic groups, including minority groups.

Aggregated survey data enables management to

identify development areas, set targets, and measure

the effectiveness of implemented actions. Leaders

discuss the results with their teams, supported by HR

when needed, and take appropriate action. In addition

to the employee engagement surveys, Sampo Group

seeks to gain insight into the perspectives of vulnerable

groups through various company and employee-driven

initiatives focused on topics, such as disabilities, women

in the workforce, language, and the inclusion of

different cultures and religions.


	BOARD OF DIRECTORS’ REPORT 2025	97

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S1-3 – Processes to remediate negative

impacts and channels for own workers to

raise concerns

Sampo Group strives for a constructive and trust-based

dialogue with employees and their elected

representatives, such as unions. The aim is to develop

the Group and ensure the fair treatment of all

employees. Sampo Group promotes a culture of open

discussion, where grievances can be aired and

addressed proactively. Employees are encouraged to

report unethical practices or possible violations of laws,

regulations, or internal policies directly to a leader, HR,

employee representative, compliance units, or through

the designated reporting channels.

Sampo Group systematically monitors employee

feedback received through, for example, employee

surveys and reporting channels. The Group ensures that

actionable insights are addressed through formalised

HR processes and leadership reviews. In addition to

internal reporting channels, Sampo Group has externally

managed whistleblowing channels through which

employees and other stakeholders can raise concerns

anonymously.

Any incident that breaches the Code of Conduct is

investigated, and the need for corrective action is

assessed on a case-by-case basis. Information about the

various reporting channels is available on intranet pages

and communicated to employees during onboarding

and regularly through internal communications

campaigns.

The effectiveness of the different channels and

employees’ willingness to openly voice opinions or

report misconduct can, to some extent, be assessed

through employee engagement surveys. However,

Sampo Group does not have formal processes to assess

its own workforce’s awareness of the procedures for

raising concerns. Reporting channels have, nevertheless,

been used by the Group’s own workforce, indicating

that they are accessible to the relevant parties. The

processes for handling whistleblowing cases are

discussed in the section G1 Business conduct (p. 122).

S1-4 – Taking action on material impacts on

own workforce, and approaches to

mitigating material risks and pursuing

material opportunities related to own

workforce, and effectiveness of those actions

Through the policies and processes described earlier,

such as the Sampo Group Code of Conduct and the

whistleblowing procedures, Sampo Group aims to

ensure that its employees are not subject to material

negative impacts. If negative impacts occur, the Group’s

remediation processes are followed. Sampo Group

investigates all suspected breaches on a case-by-case

basis to determine the appropriate response. The Group

engages relevant internal stakeholders (e.g. HR, Legal,

Compliance) in developing an action plan to address

potential negative impacts, assess the root cause of the

incident, and identify preventive measures to be taken

going forward.

Sampo Group aims to be an attractive and responsible

employer and invests in creating a corporate culture

that promotes health and wellbeing, work-life balance,

and career development. The Group offers, for example,

flexible working hours and hybrid work arrangements,

sports and volunteering opportunities, occupational

health services, and training and career development.

Sampo Group monitors the effectiveness of these

measures through regular employee engagement

surveys, turnover rates, and other health and safety

metrics disclosed in this Sustainability Statement. The

primary responsibility for managing material impacts

lies with management and is enforced by HR. The aim is

to work closely with different units to ensure that

employees are not negatively impacted and to maintain

or enhance positive impacts.

Employee health, wellbeing, and competence

Employee health and wellbeing remained a high priority

for Sampo Group in 2025. The focus was primarily on

mental health awareness and incorporated several local

activities related to mental health, such as workshops,

awareness raising campaigns, leader training, and

resource groups. In 2026, Sampo Group will continue to

raise awareness on mental health and support

employees in building resilience to manage possible

mental health challenges.

In 2025, the integration of Topdanmark into the If

organisation impacted the employees of both

companies. Employees can be adversely impacted by

organisational changes, and mitigating this risk was a

key priority throughout the year, for instance through

regular communication across multiple channels.

Leaders were trained to support employees in the

change process and to ensure equal treatment of all

employees. This work will continue in 2026.

Sampo Group’s employee development programmes

aim to provide positive impacts across its own

workforce. In 2025, the Group’s key activities related to

competence development included improving

information about new learning offerings, aligning job

profiles and learning opportunities, and arranging

competence development days. In the UK, Sampo

Group continued its early careers programme, offering

apprenticeships, graduate positions, and other scheme

opportunities. The Leadership Excellence programme

was also delivered with department-level programmes,

providing leaders with tools, techniques, and confidence

to support their teams. The programme focused


	BOARD OF DIRECTORS’ REPORT 2025	98

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

particularly on developing communication and

feedback skills. In 2026, Sampo Group will continue its

efforts to promote possibilities for employees to

develop their knowledge and roles.

An artificial intelligence (AI) ambassador programme

was launched in the Nordics and Baltics in 2025. The

programme educates ambassadors around the Group in

AI and enables them to train and support colleagues in

AI-related matters. In addition, awareness sessions on

responsible AI usage were held across Sampo Group

throughout the year and supporting guidance is

available on the intranet pages. AI was also a topic of

mandatory and voluntary training.

In 2025, Sampo Group provided training on the topics

covered by the Code of Conduct and other company-

specific policies to all new and existing employees. The

aim is to ensure that all Sampo Group employees are

aware of and act in accordance with the Group’s

policies.

Diversity, equity, and inclusion

Sampo Group has taken several actions to reduce the

risks of unequal treatment and to promote fair

opportunities and good working conditions for all

employees. During the year, the Group continued

several projects related to equal pay, which included,

for example, reviews of job architecture and pay grades,

improvement of existing systems, and development of

policies and recruitment practices. The projects aim to

ensure Sampo Group's ability to comply with the EU

regulation on Equal Pay for Equal Work or Work of

Equal Value Between Men and Women in 2026. The

Group also conducts equal pay analyses annually to

identify, address, and prevent pay differences that may

directly or indirectly be derived by gender.

In 2025, Sampo Group supported neurodiversity, for

example, through training leaders and key employees

on diversity and inclusion, and through the provision of

resources for neurodiverse employees and their leaders.

This reflects the increased awareness and

understanding of neurodiversity across society. In 2026,

the Group will work on supporting neurodiverse talents

and increasing employees’ understanding of

neurodiversity.

In the UK, Hastings achieved Disability Confident

Employer Level 2 status in 2025. This UK government

scheme helps employers improve their processes for

attracting, recruiting, and retaining workers with

disabilities. As a part of this scheme, Hastings has

introduced new and improved ways of working,

guidance, and resources to better support employees

with disabilities or conditions. As a Disability Confident

Employer, Hastings guarantees that they will interview a

fair and proportionate number of applicants with a

disability, whose application meets the minimum criteria

for the advertised job role.

During the year, Sampo Group launched a new policy

and e-learning in the UK in response to the new

legislative requirement to prevent sexual harassment in

the workplace. These initiatives have increased

employees’ awareness of what constitutes harassment

and encouraged them to speak up if they encounter it

at work.

Metrics and targets

S1-5 – Targets related to managing material

negative impacts, advancing positive

impacts, and managing material risks and

opportunities

Sampo Group has set targets for Board diversity and

employee engagement results to address impacts, risks,

and opportunities related to DEI, employee health,

wellbeing, and competencies, among other areas. These

targets and themes align with the policy objectives

outlined in the Sampo Group Code of Conduct and the

Sampo plc Board Diversity Policy that aim to provide

encouraging and rewarding working conditions, as well

as fair and equal treatment.

The Board diversity target supports the Group’s internal

ambitions, and reflects the Finnish Corporate

Governance Code, and other related legislation. More

information on the topics is available under the heading

GOV-1 – The role of the administrative, management,

and supervisory bodies (p. 57).

The employee engagement results are based on

employee engagement surveys completed by

employees to assess their experience of working at

Sampo Group. The surveys are conducted at the

subsidiary level, rather than the group level, to ensure

they are suited to each Group company’s specific needs

and characteristics. Employee engagement surveys are

sent to all employees with an active employment

contract at the time of the survey. They are conducted

at least annually, and the results are reported to the

respective management teams.

Sampo Group has set employee engagement targets

using, for instance, internal and external benchmarking,

as well as historical data. To assess performance, the

Group monitors internal trends and, when possible,


	BOARD OF DIRECTORS’ REPORT 2025	99

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

compares results with industry averages in its operating

countries. Achieving the set targets is considered an

indicator of excellent performance.

In addition to the top management of the Sampo Group

companies, representatives from various parts of the

Group have been involved in drafting the employee

engagement targets. The targets are also discussed

with union representatives, and feedback from external

stakeholders is considered where relevant. The results

of the employee engagement surveys, along with other

data related to the Group’s own workforce, are used by

the management teams as input into the organisational

development processes.

In H1/2025, If’s eNPS (excluding Topdanmark) declined

following the introduction of updated hybrid work

guidelines (i.e. a minimum requirement of three days

per week in the office). In anticipation of the

organisational changes related to the integration of

Topdanmark in mid-2025, If set a slightly lower target

for the H2/2025 survey. As expected, the eNPS result

dropped, with notable variations between countries and

organisational units. Going forward, the ambition is to

reverse the negative trend. Team leaders have analysed

the results with their teams and discussed necessary

actions. If will follow up on the results of the H1/2026

survey and plan further actions based on them if

needed. In the UK, Hastings took action based on

feedback from the 2024 employee engagement survey,

which helped keep employee engagement stable

throughout 2025.

Employee engagement surveys

Sampo Group


Survey	Scale	Target	2025		2024
Survey	Scale	Target	H1	H2	H1	H2
If: HeartBeat	-100–100	2025: 45	36	23	52	54
Hastings: Your Voice	0–100	2025: 75	80	79	77	78
Sampo plc: Work Life Survey	-100–100	-	-	46	-	42

The surveys are company-specific and not comparable to each

other. Sampo’s survey is conducted annually in the autumn. For

If and Sampo, the scale is from -100 to 100. In general, scores

above zero can be considered good/positive, while those above

50 can be considered excellent. However, score levels can vary

according to industry and type of organisation, for example. For

Hastings’ survey, results above 70 can be considered high.

If’s 2024 and H1/2025 figures are excluding Topdanmark.

Sampo plc does not have a target related to its employee

engagement survey.

Board diversity

Sampo plc


Gender	31 Dec. 2025	31 Dec. 2024
Female	37.5%	33.3%
Male	62.5%	66.7%
Total	100.0%	100.0%

Both genders shall be represented on the Board, with a target

that each represents at least 40 per cent of the Board’s

members. However, some deviations may be applied if deemed

reasonable due to the number of Board members.

Calculation principles

Metrics related to the own workforce are reported in

accordance with the requirements of the ESRS.

Calculations are based on either headcount or full-time

equivalent (FTE), and the method used is disclosed with

each metric. Hourly paid employees, summer workers,

non-employees, and trainees are excluded from the

headcount and FTE calculations. For FTE, working time

is adjusted for employees on extended leave, such as

parental leave. Year-end figures are used in reporting

unless otherwise specified. Sampo Group collects data

only on binary gender due to legal restrictions and

system limitations. Therefore, reporting includes

information on women and men only. More specific

calculation principles are described alongside the

metrics. There are no figures related to own workforce

in the Sampo Group Financial Statements.


	BOARD OF DIRECTORS’ REPORT 2025	100

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S1-6 – Characteristics of the undertaking’s

employees

As at 31 December 2025, the total number of

employees at Sampo Group was 16,157. The number of

employees increased slightly compared to the previous

year. In 2025, the majority of Sampo Group’s employees

worked in the UK, Denmark, Sweden, Finland, and

Norway. The share of women was slightly higher

compared to men, but overall the binary gender

balance was relatively equal. Sampo Group’s employees

were mainly employed full-time on permanent contracts

at the end of the year.

Headcount is used for calculating the total number of

employees, non-guaranteed hours employees, full and

part-time employees, and permanent and temporary

employees. A small number of employees work in what

is called ‘Other countries’ in Group reporting. These

countries have been combined in reporting due to the

size of operations in these countries. The ‘Other

countries’ reporting category includes Spain, Gibraltar,

France, Germany, the Netherlands, and the United

States.

In 2025, Sampo Group’s turnover rate and the number

of terminations decreased compared to the previous

year. Turnover in ‘Other countries’ is relatively high due

to the small number of employees in these locations.

Even a single personnel change can have a notable

impact on the results. The turnover rate is calculated by

dividing the number of employees who have left Sampo

Group during the reporting year by average headcount.

The figure includes external voluntary and involuntary

turnover.

Total number of employees by gender

Sampo Group


Gender	31. Dec 2025	31. Dec 2024
Female	8,384	8,134
Male	7,773	7,447
Other	-	-
Not reported	-	-
Total employees	16,157	15,581

Total number of employees by country

Sampo Group


Country	31. Dec 2025	31. Dec 2024
United Kingdom	4,878	4,314
Denmark	2,866	2,977
Sweden	2,789	2,770
Finland	2,150	2,130
Norway	1,786	1,827
Latvia	577	573
Estonia	542	514
Spain	323	230
Lithuania	189	190
Gibraltar	34	32
Netherlands	8	8
France	7	7
Germany	7	8
United States	1	1
Total employees	16,157	15,581

Number of terminations and turnover rate

Sampo Group


	2025		2024
Country	Termi- nations	Turnover rate	Termi- nations	Turnover rate
United Kingdom	749	16.1%	776	19.9%
Denmark	246	8.5%	416	13.7%
Sweden	312	11.2%	312	11.4%
Finland	151	7.1%	130	6.1%
Norway	181	9.9%	143	8.1%
Baltic countries	92	7.2%	93	7.4%
Other countries	113	33.6%	102	36.8%
Sampo Group, total	1,844	11.6%	1,972	13.1%


	BOARD OF DIRECTORS’ REPORT 2025	101

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Information on employees by gender

Sampo Group


	31 Dec. 2025					31 Dec. 2024
	Female	Male	Other	Not disclosed	Total	Female	Male	Other	Not disclosed	Total
Number of employees	8,384	7,773	-	-	16,157	8,134	7,447	-	-	15,581
Number of permanent employees	8,302	7,732	-	-	16,034	8,016	7,384	-	-	15,400
Number of temporary employees	82	41	-	-	123	118	63	-	-	181
Number of non- guaranteed hours employees	92	66	-	-	158	168	126	-	-	294
Number of full- time employees	7,361	7,509	-	-	14,870	7,125	7,170	-	-	14,295
Number of part- time employees	1,022	265	-	-	1,287	1,007	279	-	-	1,286

Information on employees by country

Sampo Group


	31 Dec. 2025								31 Dec. 2024
	United Kingdom	Denmark	Sweden	Finland	Norway	Baltic countries	Other countries	Total	United Kingdom	Denmark	Sweden	Finland	Norway	Baltic countries	Other countries	Total
Number of employees	4,878	2,866	2,789	2,150	1,786	1,308	380	16,157	4,314	2,977	2,770	2,130	1,827	1,277	286	15,581
Number of permanent employees	4,847	2,852	2,774	2,137	1,763	1,282	379	16,034	4,268	2,940	2,754	2,111	1,791	1,250	286	15,400
Number of temporary employees	31	14	15	13	23	26	1	123	46	37	16	19	36	27	0	181
Number of non- guaranteed hours employees	0	15	60	0	83	0	0	158	0	142	93	0	59	0	0	294
Number of full- time employees	4,258	2,661	2,622	1,980	1,710	1,271	368	14,870	3,741	2,766	2,576	1,955	1,736	1,245	276	14,295
Number of part- time employees	620	205	167	170	76	37	12	1,287	573	211	194	175	91	32	10	1,286


	BOARD OF DIRECTORS’ REPORT 2025	102

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S1-7 – Characteristics of non-employee

workers in the undertaking’s own workforce

As at 31 December 2025, the total number of non-

employees at Sampo Group was 3,200, representing a

slight decrease compared to the previous year. The

number of non-employees is reported as headcount at

the end of the reporting period. Non-employees refer to

individuals working in Sampo Group’s workforce who

are not directly employed by the Group (e.g.

consultants, freelancers, other independent contractors,

employees employed by staffing companies). At Sampo

Group, non-employees typically work in areas such as IT

and contact centres.

Non-employee workers

Sampo Group


Metric	31. Dec 2025	31. Dec 2024
Number of non-employees	3,200	3,283

S1-8 – Collective bargaining coverage and

social dialogue

As at 31 December 2025, 58.7 per cent (60.9 per cent in

2024) of Sampo Group’s employees were covered by

collective bargaining agreements. The small decrease

compared to the previous year is due to an increase in

the total number of employees in the UK. In 2025, there

were no major changes in social dialogue coverage at

Sampo Group compared to 2024.

The collective bargaining coverage is calculated by

dividing the number of employees covered by collective

bargaining agreements by the total number of

employees, using headcount. The figure only includes

employees who are fully covered by collective

bargaining agreements in locations where trade unions

are formally recognised. Nevertheless, the terms of

these agreements apply to most employees (excluding

top management), even if they are not formally covered

by the agreements. Within Sampo Group’s operations in

the European Economic Area, several collective

bargaining agreements are in place, depending on

geographic location and national practices. In the

Group’s UK operations, trade unions are not formally

recognised. However, employment terms are regularly

benchmarked against market practices. Estimates were

used to calculate workplace representation.

Sampo Group has no Global Framework Agreements.

However, If has established an agreement on an

information and consultation procedure with workers’

representatives, which is based on the European Works

Councils’ stipulation. The highest level of engagement

with workers’ representatives takes place in the

Communication Council, chaired by the Head of HR. The

Communication Council meets quarterly to discuss

topics that concern more than one country or business

area.

Collective bargaining coverage and social dialogue

Sampo Group, 31 December 2025


	Collective bargaining coverage		Social dialogue
Coverage rate	Employees – EEA	Employees – Non-EEA	Workplace representation (EEA only)
0–19%	-	United Kingdom	-
20–39%	-	-	-
40–59%	-	-	-
60–79%	-	-	Denmark, Sweden
80–100%	Denmark, Sweden, Finland, Norway	-	Finland, Norway

The table includes countries with more than 50 employees, representing over 10 per cent of total employees.


	BOARD OF DIRECTORS’ REPORT 2025	103

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S1-9 – Diversity metrics

Age distribution within Sampo Group has historically

been stable, and remained so also in 2025. The age

distribution is calculated by headcount at year-end.

In 2025, the definition of the top management levels 2–

4 was updated due to changes in the Group structure.

Therefore, years 2024 and 2025 are not comparable

regarding those levels. Starting 2025, Sampo Group

defines top management as the Sampo Group CEO

(level 1), leaders reporting to the Group CEO (level 2),

leaders reporting to level 2 (level 3), and leaders

reporting to level 3 (level 4). The number of leaders on

levels 2–4 has increased from 2024 to 2025 due to a

change in level definitions.

As at 31 December 2025, the binary gender distribution

at the four highest management levels of Sampo Group

shows that there is still room for diversity at the very

top. However, at the levels immediately below top

management, the balance between women and men is

more equal.

Gender distribution at top management levels

Sampo Group


Gender	31 Dec. 2025								31 Dec. 2024
Gender	Level 1 (the Group CEO)		Level 2 (reporting to the Group CEO)		Level 3 (reporting to level 2)		Level 4 (reporting to level 3)		Level 1 (the Group CEO)		Level 2 (the CEOs of Sampo plc’s subsidiaries)		Level 3 (reporting to any of the CEOs)		Level 4 (reporting to level 3)
Female	0	0.0%	3	27.3%	18	31.6%	95	41.5%	0	0.0%	0	0.0%	9	25.7%	77	40.8%
Male	1	100.0%	8	72.7%	39	68.4%	134	58.5%	1	100.0%	3	100.0%	26	74.3%	112	59.2%
Sampo Group, total	1	100.0%	11	100.0%	57	100.0%	229	100.0%	1	100.0%	3	100.0%	35	100.0%	189	100.0%

Distribution of employees by age group

Sampo Group


Age group	31 Dec. 2025		31 Dec. 2024
Under 30 years old	3,374	20.9%	3,264	20.9%
30–50 years old	8,827	54.6%	8,730	56.0%
Over 50 years old	3,956	24.5%	3,587	23.0%
Sampo Group, total	16,157	100.0%	15,581	100.0%


	BOARD OF DIRECTORS’ REPORT 2025	104

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S1-10 – Adequate wages

At Sampo Group, remuneration is based on objective

criteria such as work experience, competence, position,

and responsibilities. All employees are paid an adequate

wage that aligns with applicable benchmarks. Pay and

additional benefits are not determined by, nor

influenced by, gender or any other non-professional

factors. Sampo Group uses, for example, structured job

titles and job positions to ensure that employees in the

same role are employed under consistent conditions.

Internal and external benchmarks are also used to set

salary ranges.

S1-11 – Social protection

All Sampo Group employees are covered by social

protection against loss of income due to major life

events such as sickness, unemployment, employment

injury, acquired disability, parental leave, and

retirement.

S1-12 – Persons with disabilities

Sampo Group does not collect data on personal

characteristics such as disabilities due to legal

restrictions.

S1-13 – Training and skills development

metrics

At Sampo Group, all employees are eligible to

participate in regular career development reviews. In

2025, the percentage of employees who participated in

regular performance and career development reviews

decreased. This was due to reviews of former

Topdanmark employees being postponed to 2026. The

percentage of employees who participated in

performance and career development reviews is

calculated by dividing the number of participating

employees by the year-end headcount, broken down by

gender.

Sampo Group offers employees a variety of internal and

external training opportunities. In 2025, the Group

started strengthening its reporting processes for skills

development and is now able to report the average

training hours by gender for the first time. Further

development is needed also in the coming years to

improve reporting processes and alignment across the

Group. Currently, the average training hours by gender

includes mandatory internal training and leadership

training. The training hours are calculated by dividing

the total number of training hours with the average

headcount.

Percentage of employees who

participated in regular performance and

career development reviews by gender

Sampo Group


Gender	2025	2024
Female	61.1%	66.2%
Male	57.3%	64.0%
Sampo Group, total	59.3%	65.1%

Average training hours by gender

Sampo Group


Gender	2025
Female	7
Male	6
Sampo Group, total	7


	BOARD OF DIRECTORS’ REPORT 2025	105

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S1-14 – Health and safety metrics

All Sampo Group’s employees continued to be covered

by a health and safety management system as at 31

December 2025. The system refers to the occupational

healthcare services provided by the employer, which

may be either statutory or voluntary. The percentage of

employees in Sampo Group’s own workforce covered

by a health and safety management system is

calculated based on headcount.

In 2025, there were no fatalities resulting from work-

related injuries at Sampo Group, and the number of

work-related accidents remained at the previous year's

level. The rate of recordable work-related accidents is

calculated by dividing the number of cases by the

estimated total hours worked, then multiplying by one

million. This rate represents the number of cases per

one million hours worked. The disclosed metrics apply

to employees in Sampo Group’s own workforce.

Sampo Group does not collect data on work-related ill

health, fatalities due to work-related ill health, or days

lost due to work-related ill health due to legal

restrictions.

Percentage of employees covered by

health and safety management system

Sampo Group


Metric	31 Dec. 2025	31 Dec. 2024
Percentage of employees who are covered by health and safety management system	100.0%	100.0%

Work-related injuries and fatalities

Sampo Group


Metric	2025	2024
Number of fatalities as a result of work-related injuries	0	0
Number of recordable work- related accidents	47	49
Rate of recordable work- related accidents	1.9	2.1

The number and rate of recordable work-related accidents in

2024 were recalculated due to a clerical error in the compilation

of data. The originally reported figures were 80 and 3.4.

S1-15 – Work-life balance metrics

At Sampo Group, all employees are entitled to family-

related leave through social policy or collective

bargaining agreements. In 2025, the share of employees

who took family-related leave remained stable

compared to 2024, with a minor shift towards a more

equal gender distribution. Family-related leave includes

maternity, paternity, parental, carer’s and adoption

leave. The percentage of employees who took family-

related leave is calculated by dividing the number of

employees who were on family-related leave divided by

year-end headcount, broken down by gender.

Percentage of employees who took

family-related leave

Sampo Group


Gender	2025	2024
Female	9.6%	10.2%
Male	6.8%	6.3%
Sampo Group, total	8.3%	8.3%


	BOARD OF DIRECTORS’ REPORT 2025	106

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S1-16 – Remuneration metrics

In 2025, the gender pay gap remained stable. The pay

gap is a development area in Sampo Group and

monitored continuously through regular pay gap

analyses. The gender pay gap describes the difference

in actual paid compensation between men and women.

Differences in pay can be explained by factors such as

position in the company, job tasks, responsibilities, and

leaves of absence. Pay gap-related metrics are

calculated using FTE averages.

Due to the high payment of the long-term incentive

scheme LTI 2020, the pay of the former Group CEO was

higher in 2025 compared to the previous year. This

impacted the annual total remuneration ratio of the

highest paid individual to the median annual

remuneration. The pay data to calculate the median

annual remuneration used in the annual total

remuneration ratio of the highest paid individual to the

median annual remuneration is collected from Sampo

Group’s HR systems. The data includes annual

contractual fixed compensation before tax and all

variable compensation elements and bonuses. The

median annual remuneration figure is based on the

monthly paid employees in an employment relationship

with Sampo Group (excluding the highest paid

individual) at the end of the reporting year. In 2025, the

data collection process was updated due to the

integration of If and Topdanmark and the related

changes in payroll systems. Therefore, the 2024 and

2025 figures are not comparable.

Exchange rates may have an impact on the

remuneration figures presented in this Sustainability

Statement.

Gender pay gap

Sampo Group


Metric	2025	2024
Fixed remuneration	19.7%	19.8%
Fixed and variable remuneration	24.9%	24.5%

Annual total remuneration ratio of the

highest paid individual to the median

annual remuneration

Sampo Group


Metric	2025	2024
Pay ratio	111.5	89.6

S1-17 – Incidents, complaints, and severe

human rights impacts

In 2025, no severe human rights incidents, defined as

severe violations of human rights and labour rights

legislation concerning Sampo Group’s own workforce,

were reported. 19 incidents of discrimination and

harassment were reported and corrective action was

taken on a case-by-case basis according to internal

processes and guidelines. The figure includes incidents

of discrimination and harassment as defined in the

Sampo Group Code of Conduct that have led to formal

consequences (e.g. warning or dismissal) during the

reporting year. None of the incidents reported during

the year resulted in fines, penalties, or compensation for

damages for Sampo Group.

The total number of complaints filed through Sampo

Group’s channels for people in own workforce was 23

(excluding incidents of discrimination and harassment

reported above). These are complaints reported by

employees through grievance mechanisms and

whistleblowing channels, concerning social, human

rights, and labour rights matters. The figure includes all

applicable complaints filed during 2025 regardless of

their status at the end of the reporting year.

Number of severe human rights incidents

Sampo Group


Metric	2025	2024
Number	0	0

Number of incidents of discrimination

and harassment

Sampo Group


Metric	2025	2024
Number	19	2


	BOARD OF DIRECTORS’ REPORT 2025	107

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S2 Workers in the value chain


Topic	Impacts	Risks and opportunities	Strategy and actions
Human rights and labour practices	↓ Potential negative impacts related to human rights and labour practices can occur across Sampo Group's entire value chain. Potential negative impacts can be mitigated, but due to the large number of suppliers, business partners, corporate customers, and investee companies it is not possible to completely remove the risk of negative impacts (e.g. related to working conditions and equal treatment). ↑ Sampo Group can have a potential positive impact on the sustainability of its suppliers, business partners, corporate customers, and investee companies through its own actions, such as robust due diligence processes and responsible investment and underwriting practices. This can also improve the working conditions (e.g. job stability and health aspects) and equal treatment of its value chain workers. • Time-horizon: short to medium term • Value chain location: own operations, upstream value chain, downstream value chain	↓ 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. ↓ 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. ↓ Sampo Group can face a financial risk due to increasing and tightening legislation related to human rights and labour rights (e.g. reporting costs, possible fines, reputational damage). • Time-horizon: short to medium term • Value chain location: own operations, upstream value chain, downstream value chain	• Policies and guidelines (e.g. supplier codes of conduct, responsible investment policies, underwriting principles) • Effective governance structures and processes (e.g. supplier risk assessments, audits, questionnaires, screening, engagement) • Commitments to responsible investment and underwriting (e.g. PRI, SBTi) • Internal training and competence development programmes • Metrics and targets (e.g. Supplier Code of Conduct included in existing supplier agreements)

The table presents Sampo Group’s material impacts, risks, and opportunities related to workers in the value chain identified in the double materiality assessment and their connection to Sampo Group’s

strategy and actions. The topic Human rights and labour practices is related to the ESRS sub-topics Working conditions, Equal treatment and opportunities for all, and Other work-related rights.


	BOARD OF DIRECTORS’ REPORT 2025	108

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Strategy

SBM-3 – Material impacts, risks, and

opportunities and their interaction with

strategy and business model

Sampo Group has an impact on workers in the value

chain through its suppliers and business partners,

corporate customers, and investee companies. For

example, based on the double materiality assessment

and the human rights impact assessment, the Group has

identified that especially workers in its downstream

value chain (e.g. workers of claims handling suppliers)

could be negatively affected. These workers may face

risks inherent to their roles and operating contexts. The

risks are mitigated, amongst other things, by the

suppliers' adherence to the required health and safety

standards outlined in Sampo Group's supplier codes of

conduct.

Ensuring that human and labour rights are respected by

the suppliers is important for Sampo Group to mitigate

financial risks and seize opportunities. Suppliers

breaching human and labour rights may face legal,

reputational, and operational consequences, which may,

in turn, become an operational risk for Sampo Group. A

stable business relationship with a responsible supplier

is a competitive advantage and can, therefore, be seen

as an opportunity, too.

Sampo Group develops its understanding of particularly

vulnerable value chain workers for instance through

self-assessment questionnaires completed by suppliers

and engagement with investee companies, corporate

customers, and suppliers. Examples of particularly

vulnerable groups within Sampo Group’s value chain

include different minorities and migrant workers.

Sampo Group includes all value chain workers who may

be materially impacted by its operations, products,

services, and business relationships in its disclosures.

However, the main focus is on direct suppliers (Tier 1)

where the Group is expected to have the largest impact.

In addition, the impacts Sampo Group may have

through its corporate customers and investees are also

considered.

Sampo Group’s upstream value chain encompasses

suppliers of office supplies and services (e.g. software

and hardware companies), as well as providers of other

business services (e.g. consultants, external data

providers) that support the running of the business. The

downstream value chain includes, for example, suppliers

such as vehicle and property repair contractors and

healthcare providers. Key activities related to the

Group’s products and services that are carried out by

suppliers include property, vehicle, and content repairs,

health and hospital services, and travel services. Sampo

Group acknowledges the varying levels of human and

labour rights risks associated with different industries

and regions connected to its business, particularly in

sectors such as construction and vehicle repair.

The majority of Sampo Group’s suppliers in claims

handling are based in the Nordics, where the general

risk for human rights violations is considered lower than

in many other regions globally. However, value chains

can be long and complex, and certain sectors such as

construction, mining, transportation, and electronics are

particularly associated with human and labour rights

risks. Workers may be exposed to unhealthy or unsafe

working conditions, including, for example, long hours

and exposure to hazardous substances. Other risks

include forced labour, child labour, discrimination, and

violations of privacy. These risks can be considered

systemic.

Sampo Group’s downstream value chain also includes

the workforce and supply chains of its corporate

customers and investee companies, through which the

Group can impact workers beyond its own operating

countries. This may involve risks such as forced labour,

child labour, unsafe working conditions, or

discrimination and harassment, as these risks can exist

in industries or regions where corporate customers or

investee companies operate. As these risks arise further

down the value chain, Sampo Group’s ability to mitigate

their impacts is limited.

Impact, risk and opportunity

management

S2-1 – Policies related to value chain workers

Sampo Group’s policy related to workers in the value

chain is the Sampo Group Code of Conduct, which is

reviewed annually and approved by Sampo’s Board of

Directors. The Code of Conduct applies to all Sampo

Group companies and must be personally upheld by

every Group employee. The Code of Conduct states

that Sampo Group complies with all applicable human

rights, labour rights, and employment legislation. In

addition, the Group is committed to respecting human

rights as set out in the International Bill of Human Rights

including the Universal Declaration of Human Rights,

the International Covenant on Civil and Political Rights,

the International Covenant on Economic, Social and

Cultural Rights, and those stated in the core

conventions of the ILO. Sampo Group also adheres to

the principles of the UN Global Compact and follows

internationally recognised standards on business and

human rights, such as the UN Guiding Principles on

Business and Human Rights and the OECD Guidelines

for Multinational Enterprises. As such, Sampo Group is


	BOARD OF DIRECTORS’ REPORT 2025	109

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

committed to fulfilling its human rights obligations and

continuously developing related practices (e.g. human

rights due diligence processes) that cover both its own

operations and its value chain.

Sampo Group has due diligence processes aligned with

the OECD Guidelines for Multinational Enterprises.

These processes allow the Group to identify, avoid and

address possible adverse impacts on human rights,

labour rights, the environment and anti-corruption

commitments associated with its suppliers as well as

underwriting and investment operations.

As stated in the Code of Conduct, Sampo Group

condemns all forms of forced and compulsory labour as

well as child labour and modern slavery (e.g. human

trafficking) in its own operations and value chain. In

addition to the Group’s Code of Conduct, each Group

company has adopted supplementary and more

detailed policies, guidelines, and processes for its own

purposes.

Sampo Group has not been made aware of severe

confirmed cases of non-adherence to global standards

for value chain workers in its upstream and downstream

value chain during the reporting year. This includes

direct suppliers (Tier 1), corporate customers, and direct

investments.

Suppliers and business partners

In addition to the Sampo Group Code of Conduct, the

Group has supplier codes of conduct that set the

minimum requirements that suppliers are expected to

meet on topics such as fair and equal treatment,

privacy, employment terms, working hours, fair wages,

health and safety, and freedom of association and

collective bargaining. The supplier codes of conduct are

based on the UN Global Compact and its underlying

conventions and apply to both suppliers and sub-

suppliers. They are approved by the boards of directors

or other governing bodies of the respective Sampo

Group companies. The ultimate responsibility for

implementation lies with the top management of each

Group company. These policies are available on Sampo

Group’s websites and are communicated to suppliers.

Sampo Group engages with its suppliers, for example,

through dialogue, self-assessment questionnaires,

reviews, and site visits. In the event of a breach of a

supplier code of conduct, the Group engages with the

supplier to promote improvements in the supplier’s

business conduct. Sampo Group monitors the situation,

and further actions depend on the corrective measures

taken by the supplier. The Group may terminate the

supplier contract if the supplier fails to take steps to

remediate the situation within a reasonable timeframe.

Corporate customers and investee companies

Sampo Group provides insurance to corporate

customers in accordance with its underwriting

principles and manages its investments in line with its

responsible investment policies. The Group reviews its

insurance and investment-related policies annually, and

they are approved by the boards of directors of each

Sampo Group company. These policies include, among

other things, guidance on how to take sustainability

risks and criteria into account in insurance and

investment activities.

Sampo Group conducts norm-based screening of direct

investments and corporate customers against

international norms and standards (e.g. the UN Global

Compact principles, the OECD Guidelines for

Multinational Enterprises, the ILO Tripartite Declaration

of Principles concerning Multinational Enterprises and

Social Policy, the Guiding Principles on Business and

Human Rights, the Paris Climate Agreement) using

external service providers. If Sampo Group detects a

violation of these norms or standards, the response may

vary depending on the severity, nature, and extent of

the breach. Measures may include direct dialogue or

other forms of engagement. As a last resort, the

insurance contract may be terminated or the

investment sold if the corporate customer or investee

company fails to take corrective action.

In addition to norm-based screening, Sampo Group

applies sector-based screening to its corporate

customers and direct investments, and excludes certain

sectors from direct investments unless pre-defined

criteria are fulfilled. Examples of such sectors include

tobacco, coal, and controversial weapons, due to

potential human rights risks, labour rights risks,

reputational risk, and/or regulatory risks.


	BOARD OF DIRECTORS’ REPORT 2025	110

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S2-2 – Processes for engaging with value

chain workers about impacts

Sampo Group does not engage directly with its value

chain workers or their legitimate representatives or

credible proxies. However, indirect engagement occurs

through suppliers, corporate customers, or investee

companies. The engagement can be part of formal due

diligence processes or regular monitoring of business

relationships. These processes allow Sampo Group to

understand and manage impacts on the workers in its

value chain.

The frequency and method of engagement depends on

assessed risk, which links, for example, to the type and

size of the business partner in question. The

effectiveness of engagement is monitored through

follow-up meetings with suppliers and corporate

customers or through external partners during

engagement with investee companies, for instance.

Different individuals are responsible for carrying out

engagement activities, depending on which business

unit oversees the partnership. For example,

procurement specialists and business developers (or

similar) handle dialogues with claims partners, while the

investment management teams focus on investee

companies.

Sampo Group gains insight into the perspectives of its

value chain workers mainly through human rights due

diligence processes. These include, for example,

conducting human rights impact assessments,

evaluating suppliers' adherence to sustainability criteria,

as well as screening corporate customers and

investments.

Sampo Group assesses the effectiveness of its actions

and initiatives related to workers in its value chain by

maintaining dialogue, continuously monitoring its

processes, and revising practices when needed. This

may involve, for example, updating policies or adapting

materials (e.g. questionnaires) that are misinterpreted,

in order to improve understanding of the conditions

faced by value chain workers.

S2-3 – Processes to remediate negative

impacts and channels for value chain workers

to raise concerns

The Sampo Group Code of Conduct, supplier codes of

conduct, and responsible underwriting and investment

practices set clear requirements related to value chain

workers. If non-compliance with these requirements is

detected, Sampo Group will engage with the supplier,

corporate customer, or investee company in question to

rectify the situation and align their practices with the

Group’s policies, including plans to review and follow up

on the corrective actions. If the violation or contract

breach is significant, or if the party is unwilling to make

improvements within a given timeframe, the Group may

terminate the contract or divest.

Most of Sampo Group’s whistleblowing channels are

available to all stakeholders, including value chain

workers, for reporting suspected violations of legislation

or unethical conduct. The channels are externally

managed, and allow for anonymous reporting. In

addition, the majority of Sampo Group’s supplier codes

of conduct or related contracts require suppliers to

provide channels for reporting grievances. Suppliers are

also required to report any breaches of the principles

outlined in the codes of conduct to Sampo Group.

Sampo Group does not have formal processes for

assessing value chain workers’ awareness of the

procedures for raising concerns. However, supplier

codes of conduct state that suppliers shall inform their

employees about whistleblowing channels, and ensure

that relevant policies and channels are available to value

chain workers. Sampo Group’s reporting channels have

been used by external stakeholders, indicating that they

are accessible to the relevant parties.

Incidents reported through Sampo Group’s

whistleblowing channels are investigated promptly in

accordance with applicable legislation. Sampo Group

ensures the effectiveness of these channels through

internal and external communications and training. The

Group is also committed to further developing its

approach. The whistleblowing channels are discussed in

detail in the section G1 Business conduct (p. 122).


	BOARD OF DIRECTORS’ REPORT 2025	111

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S2-4 – Taking action on material impacts on

value chain workers, and approaches to

managing material risks and pursuing

material opportunities related to value chain

workers, and effectiveness of those actions

In 2025, based on a group-wide human rights impact

assessment first conducted in 2024, as well as other

sources for identifying potential human rights impacts,

Sampo Group developed its processes to detect,

prevent, and mitigate potential negative impacts on

human and labour rights affecting workers in the

Group’s value chain. Additionally, Sampo Group

continued its regular cooperation with all relevant

suppliers, business partners, corporate customers, and

investees to ensure compliance with the Group’s

policies. The Group applies continuous processes to

assess whether engagement or other additional actions

with a given supplier, corporate customer, or investee

company are required to address potential negative

impacts on value chain workers. Sampo Group’s

policies, screening, and engagement activities also

support the mitigation of risks and the pursuit of

opportunities related to workers within the Group’s

value chain.

Sampo Group has not identified actual material

negative impacts on its value chain workers and no

severe human rights issues or incidents were reported

to Sampo in the Group’s upstream or downstream value

chain in 2025. Potential negative impacts on value chain

workers are monitored, for example, through supplier

self-assessment questionnaires, surveys, site visits,

meetings, and other engagement activities. Suppliers’,

corporate customers’ or investees’ non-compliance with

Sampo Group’s sustainability requirements can lead to

the termination of the business relationship.

If any material negative impacts on value chain workers

were to occur, Sampo Group has processes in place for

reporting and addressing grievances, as well as for

taking corrective action. Responsibility for managing

such impacts is allocated to the respective departments

within each Group company, such as Procurement,

Investment Management, Insurance Operations (e.g. If’s

Business Area Industrial), and Sustainability.

Suppliers and business partners

In 2025, Sampo Group strengthened the integration of

its supplier codes of conduct into processes, developed

related due diligence practices, and monitored

suppliers’ alignment with sustainability criteria. In

addition, a process was initiated to integrate

Topdanmark’s practices into If’s due diligence

processes. Other actions to enhance the cooperation

with suppliers included reviewing ESG questionnaires,

as well as providing a digital platform and external

consultancy to support purchasers in conducting the

due diligence. These actions are meant to support

Sampo Group’s work in preventing negative impacts

and promoting positive impacts to workers across the

value chain.

Corporate customers and investee companies

Sampo Group updated the Group’s responsible

investment policies again during 2025. The changes

were linked, for example, to If and Topdanmark’s

integration, the SBTs, and sector-based screening. The

development of the Group’s responsible investment

practices continues during the coming years based on

internal sustainability ambitions, external stakeholder

feedback, and overall market development.

Sampo Group aims to engage with investee companies

through pooled engagement with other investors, when

it is considered an effective means of achieving a

desired change within the investee. In 2025, the Group

participated in nine pooled engagements regarding the

environment, corruption, and human and labour rights-

related topics.

During the year, Sampo Group’s investments in funds

were managed by asset managers who are signatories

of the UN Principles for Responsible Investment (PRI). A

significant portion of these funds is managed by asset

managers committed to respecting the UN Global

Compact principles.

In 2025, Sampo Group continued to screen its direct

investments and large corporate customers for

breaches of the UN Global Compact principles. Based

on the screenings, no severe and confirmed norm

violations were identified among the Group’s corporate

customers. Screenings of direct investments identified

one portfolio company with a confirmed severe breach

regarding anti-competitive practices. The situation is

monitored continuously.

In 2025, Sampo Group continued to screen its direct

investments for sensitive sectors to detect and manage

any possible risks related to human and labour rights.

The Group also initiated sector-based screening of its

corporate customers at group level during the year. This

internal monitoring supports the management of

sustainability risks, including those related to human

rights, labour rights, reputation, and/or regulation. The

sectors used in the screening of corporate customers

align with those monitored on the investment

management side.


	BOARD OF DIRECTORS’ REPORT 2025	112

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Metrics and targets

S2-5 – Targets related to managing material

negative impacts, advancing positive

impacts, and managing material risks and

opportunities

For the time being, Sampo Group has not set group

level targets for the metrics related to workers in the

value chain. However, the Group’s long-term aim is for

all suppliers to sign a supplier code of conduct. Sampo

Group regularly reviews its processes for managing

impacts, risks, and opportunities related to workers in

the value chain. If it is assessed that an externally

disclosed, group level target would add value, the

decision will be revisited.

Metrics related to Supplier Code of Conduct

In order to evaluate its effectiveness in mitigating the

risk of potential negative impacts on value chain

workers and their human and labour rights, Sampo

Group measures the inclusion of supplier codes of

conduct in its supplier agreements. Tracking this

inclusion also supports the Group in managing financial

risks related to such negative impacts and in pursuing

opportunities through business relationships with

responsible partners.

The share of suppliers that have signed a supplier code

of conduct is calculated by dividing the number of

suppliers that have signed one of Sampo Group’s codes

of conduct (including those with their own codes,

provided these have been approved by Sampo Group)

by the total number of suppliers. Group company-

specific adjustments are made to the methodology due

to differences in supply chain structures. This metric

applies to both upstream suppliers (e.g. suppliers of

office equipment as well as IT hardware and software)

and downstream suppliers (e.g. suppliers in claims

handling). Although supplier codes of conduct are

implemented across the whole Group, the structures are

not yet in place for measuring the progress in all units.

Additionally, some suppliers, such as large IT companies

and consultancies, are excluded from the metric. In the

future, Sampo Group aims to improve the data quality

to include all supplier contracts signed within the Group

in the metric.

In 2025, the share of supplier codes of conduct included

in existing supplier agreements increased. This was

mainly due to the implementation of Hastings’ Supplier

Code of Conduct in 2024, which resulted in higher

group level inclusion of supplier codes of conduct in

2025.

Supplier Code of Conduct included in

existing supplier agreements

Sampo Group


Metric	31 Dec. 2025	31 Dec. 2024
Share of suppliers	89.7%	75.6%


	BOARD OF DIRECTORS’ REPORT 2025	113

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S4 Consumers and end-users


Topic	Impacts	Risks and opportunities	Strategy and actions
Customer health and safety	↑ Customer health and safety are at the core of the insurance business and, therefore, also at the core of Sampo Group’s operations. As Sampo Group’s strategy focuses on disciplined underwriting and careful risk management, the Group has an actual positive impact on consumers’ and end-users' health by providing insurance products, thereby helping its customers manage risks. • Time-horizon: short to medium term • Value chain location: own operations, downstream value chain	↑ 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. ↓ Failing to provide suitable products and services that meet customers' needs (e.g. insurance related to health and safety) can affect Sampo Group's financial results.* • Time-horizon: short to medium term • Value chain location: own operations, downstream value chain	• Internal policies and guidelines (e.g. codes of conduct, underwriting principles, risk management principles) • Effective governance structures and processes (e.g. feedback channels, loss prevention, risk management) • Internal training and competence development programmes • Metrics and targets (e.g. NPS, EPSI, Trustpilot)
Sales and marketing practices	↓ Sampo Group can have negative societal impact through possible irresponsible sales and marketing practices (e.g. inaccessible, discriminating, misleading). ↑ Sampo Group can have a positive impact on people's health and safety through responsible sales practices and by providing insurance to a diverse customer base.* • Time-horizon: short to medium term • Value chain location: own operations, downstream value chain	↓ Irresponsible sales and marketing practices can cause a financial risk for Sampo Group through possible legislative consequences (e.g. fines) and reputational damage. • Time-horizon: short to medium term • Value chain location: own operations, downstream value chain	• Internal policies and guidelines (e.g. codes of conduct) • Effective governance structures and processes (e.g. feedback channels, quality communications, responsible remuneration practices) • Internal training and competence development programmes
Data privacy, information security, and cybersecurity	↓ 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 incidents, cybersecurity attacks, and data breaches, leading to potential negative impacts on consumers and end-users. • Time-horizon: short to medium term • Value chain location: own operations, downstream value chain	↓ Sampo Group is exposed to data privacy, information security, and cybersecurity risks due to the high quantity of sensitive data the Group handles and processes. In the case of incidents related to privacy and data security, negative financial risks, such as fines and reputational damage, may be significant. • Time-horizon: short to medium term • Value chain location: own operations, downstream value chain	• Internal policies and guidelines (e.g. codes of conduct, data privacy statement, information security principles, risk management principles) • Effective governance structures and processes (e.g. frameworks and reporting structures, screenings, impact assessments, security measures, data processing agreements, risk analyses, continuity planning, quality systems and infrastructure) • Internal training and competence development programmes

The table presents Sampo Group’s material impacts, risks, and opportunities related to consumers and end-users identified in the double materiality assessment and their connection to Sampo Group’s

strategy and actions. The topic Customer health and safety is related to the ESRS sub-topic Personal safety of consumers and/or end-users. The topic Sales and marketing practises is related to the ESRS

sub-topics Social inclusion of consumers and/or end-users. The topic Data privacy, information security, and cybersecurity is related to the ESRS sub-topic Information-related impacts for consumers and/

or end users.

* IRO has been added as part of the 2025 DMA review.


	BOARD OF DIRECTORS’ REPORT 2025	114

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Strategy

SBM-3 – Material impacts, risks, and

opportunities and their interaction with

strategy and business model

Sampo Group provides insurance products and services

to three main customer groups: private, commercial,

and industrial customers, and can therefore have an

impact on them. In addition to these groups, Sampo

Group can have an impact on potential customers and

end-users of insurance policies, who themselves are not

the Group’s customers (e.g. beneficiaries). When

assessing material impacts, Sampo Group considers all

types of consumers and end-users who may face

material impacts from the Group’s own operations or

through its value chain.

Sampo Group does not offer products or services that

are inherently harmful to consumers or end-users’

health, safety, or freedom of expression. Instead, Sampo

Group has an actual positive impact on consumers and

end-users’ health and safety, among other things by

providing insurance products and services, thereby

helping customers with loss prevention, risk

management, and in cases of loss, accident, or injury.

Sampo Group’s sales and marketing practices can have

a potential negative impact on consumers and end-

users, for example, through inaccessibility of products

and services, or if the needs of underserved groups are

not fulfilled in a satisfactory manner. As an insurance

provider, there is also the potential for Sampo Group to

be associated with discrimination due to risk

assessments that can in certain cases (e.g. due to legal

restrictions) exclude customers from accessing

insurance protection. For example, certain insurances

may not be available to customers with specific risk

profiles, or carry a higher premium.

As an insurance company, Sampo Group is required to

handle large amounts of customers' personal data and

can therefore negatively impact consumers and end-

users through issues related to data privacy,

information security, and cybersecurity. The privacy of

customers can be jeopardised if Sampo Group’s data

privacy or information security measures are breached

as a result of a cyber attack, for instance. Due to

digitalisation and the increasing use of AI, for instance,

the risk of information security and cybersecurity

attacks can increase, leading to a higher risk of potential

negative impacts.

When offering insurance to consumers and end-users

who can be more vulnerable to health, privacy, or

accessibility impacts (e.g. elderly people, people with

disabilities, people lacking financial literacy) and to

beneficiaries who themselves are not Sampo Group’s

customers (e.g. children), it is especially important that

Sampo Group offers accurate and accessible

information about their insurance policies and coverage.

To increase understanding of which stakeholders,

including consumers and end-users, are particularly at

risk of harm from negative human rights impacts,

Sampo Group has conducted a human rights impact

assessment. In addition, the Group’s stakeholder

dialogue and customer feedback channels serve as a

way to engage with affected consumers and end-users

and understand potential human rights risks.

Risks and risk management are inherent elements of

insurance companies’ business activities and operating

environment. At Sampo Group, the balance between

risks, capital, and earnings requires that risks affecting

profitability, as well as other material risks, are

identified, assessed, and analysed. This means that

underwriting risks are priced to reflect their inherent risk

levels based on each individual customer’s specific risk

profile, which may, for instance, increase the potential

negative impact on consumers and end-users through

sales and marketing practices.

Impact, risk and opportunity

management

S4-1 – Policies related to consumers and end-

users

Sampo Group has several policies to manage its

material impacts, risks, and opportunities related to

consumers and end-users. The group level guiding

principles include Sampo Group’s Code of Conduct,

Data Privacy Statement, and Information Security

Principles. These are all reviewed annually, approved by

Sampo’s Board of Directors, and available on Sampo’s

website. In addition to the group level principles, Sampo

Group has supplementary and more detailed policies

(e.g. underwriting principles. distribution policies, data

privacy statements), guidelines, and processes (e.g. due

diligence) for specific purposes. The ultimate

responsibility for the implementation of the group level

principles and other policies lies with the management

of each Sampo Group company. To ensure compliance

with laws, regulations, and internal policies, the Group

has training programmes which guide personal conduct

and increase the competence of employees.

The Sampo Group Code of Conduct states that the

Group complies with the International Bill of Human

Rights, including the Universal Declaration of Human

Rights and the two covenants, the Core Conventions of

the ILO, the OECD Guidelines for Multinational

Enterprises, and the UN Global Compact. The Code of

Conduct also describes that Sampo Group is committed

to the obligations related to human rights and the

continuous development of related practices (e.g.

human rights due diligence processes). Sampo Group’s

due diligence processes cover both the Group’s own

operations and its value chain, including consumers and

end-users.


	BOARD OF DIRECTORS’ REPORT 2025	115

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

The Code of Conduct applies to all companies

belonging to Sampo Group and it is each employee’s

responsibility to comply with its contents. The Code of

Conduct obligates employees to ensure that human

rights are respected and upheld through all operations,

including the downstream value chain. Sampo Group

communicates on the topics covered by the Code of

Conduct to consumers and end-users, for example,

through its websites, sustainability reporting, and other

customer communication materials. The engagement

with stakeholders is described in more detail under the

heading SBM-2 – Interests and views of stakeholders

(p. 65).

Sampo Group has not been made aware of any severe

confirmed cases of non-adherence to global standards

related to consumers and end-users in its downstream

value chain during the reporting year.

Customer health and safety and Sales and marketing

practices

The Sampo Group Code of Conduct sets the group level

requirements for products and services (i.e. customer

health and safety) at Sampo Group. The Code of

Conduct states that Sampo Group strives to act in the

best interest of its customers, offering products and

services that customers need and want. The products

and services should be fair, comprehensible, and

designed to help meet the evolving needs of all

customers. In addition, ESG considerations are to be

taken into account in insurance underwriting.

The Code of Conduct specifies that Sampo Group’s

sales, marketing, and product information must be

professional, comprehensive, accurate, balanced, and

never misleading. Sampo Group takes appropriate care

to ensure that customers are given transparent and

easily accessible and understandable information about

the costs, risks, and conditions relating to the product

or service in question, as well as the reasons leading to

an underwriting or claim decision. In addition, at Sampo

Group all customers are to be treated fairly and no

individual customer is given preferential treatment at

the expense of other customers. Insurance premiums

are only based on relevant data and not on

discriminating factors, such as sexual orientation,

religious belief, or ethnic background. Sampo Group

expects its suppliers to uphold the same standards in

their own operations.

Sampo Group has controls in place to ensure that the

information provided to customers is accessible,

relevant, and timely before a customer commits to any

purchase, and that the company satisfies all regulatory

and conduct obligations. The Group aims to clearly

inform customers of their complaint options, as well as

to ensure a fair and transparent complaint process.

Possible measures to provide remedy to consumers and

end-users depend on the nature of the impact. Sampo

Group takes action on a case-by-case basis and

according to established internal processes. When

evaluating the effectiveness of mitigation approaches,

the Group also uses information obtained through

stakeholder dialogue.

Data privacy, information security, and cybersecurity

Sampo Group’s policies on data privacy, information

security, and cybersecurity lay out how the Group is

committed to processing personal data in a lawful, fair,

and transparent manner, while respecting human rights

in all aspects of data management. The policies

highlight how Sampo Group protects information and

upholds cybersecurity. These policies also state that

high levels of data privacy, information security, and

cybersecurity are top priorities for the Group.

S4-2 – Processes for engaging with

consumers and end-users about impacts

Sampo Group has customer experience programmes

(or similar) which are spread across the organisation

and the different customer touchpoints. The

programmes enable the Group to both collect customer

data and monitor the related results. Sampo Group

engages with consumers and end-users at several

stages during the customer journey (i.e. before, during,

and after a customer transaction). Customers are, for

example, offered the possibility to leave feedback on

the customer journey or based on a certain transaction.

Customer feedback is collected daily, weekly, or

monthly depending on the situation and the method

used. Feedback is reviewed and any questions or

comments are followed up with the customer where

relevant. Customer feedback is collected, for example,

by phone, email, SMS, and chat. The operational

responsibility for engagement with consumers and end-

users lies with the top management of the Sampo

Group companies.

Sampo Group gains insight into the effectiveness of its

engagement through multiple channels, such as

customer satisfaction surveys (e.g. NPS, EPSI,

Trustpilot) and customer contact points (e.g. phone,

email, SMS, chat, meetings). Feedback can reduce the

risk of losing the customer, and it is also used to find

areas of improvement, for example regarding service,

products, processes, and systems. In addition, the

Customer Ombudsman engages with customers who

have a complaint, and may, based on the engagement,

suggest changes to, for example, the customer handling

processes, claims procedures, or product terms and

conditions.


	BOARD OF DIRECTORS’ REPORT 2025	116

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

In addition to the channels mentioned above, Sampo

Group gathers the perspectives of affected consumers

and end-users through the Group’s human rights impact

assessment. This assessment includes an analysis of

existing data and the use of credible proxies as part of

desktop research. Impacts on vulnerable groups are

also considered in the assessment.

When a customer or insured is not able to manage their

own interests due to, for example, age, sickness, injury,

or disability, Sampo Group ensures in accordance with

local regulatory requirements that there is a trustee or

guardian that can look after their interests. Sampo

Group also has guidelines on how to engage with

customers in vulnerable situations (e.g. managing

serious incidents with a caring attitude, ensuring privacy

when communicating with customers with hearing

disabilities, handling indemnities to an insured under

guardianship).

S4-3 – Processes to remediate negative

impacts and channels for consumers and

end-users to raise concerns

Sampo Group offers multiple channels for customers to

raise concerns or needs. Customers can be directly in

contact with the company through, for example,

customer service (e.g. phone, website, app, chat),

customer surveys, and the company’s Customer

Ombudsman. Indirect contact with the company is

possible through the external Customer Ombudsman,

whistleblowing channels, and external complaints

boards. The whistleblowing channels are externally

managed.

Sampo Group encourages its suppliers, for example

through supplier codes of conduct and contract

discussions, to provide similar platforms for their

customers to raise concerns. Some of Sampo Group’s

reporting channels, such as whistleblowing channels,

are also available for the consumers and end-users of

suppliers and business partners.

Sampo Group monitors and measures customer

satisfaction continuously. Both positive and negative

feedback is carefully analysed and used to develop

products and services and improve customer

experience. Quality assurance based on customer

feedback is also important. Sampo Group follows the

customer journey to find the root causes of the

feedback, and to restore the customer relationship, if

needed. The insight gained is utilised in training and in

improving processes and the overall customer journey.

By encouraging dialogue, Sampo Group can identify

and address dissatisfaction among consumers and end-

users. To foster transparency and build trust, Sampo

Group has a list of its most material and publicly

available principles and policies on its website.

Furthermore, Sampo Group upholds non-retaliation

policies to safeguard individuals who come forward

with concerns, ensuring they can do so without fear of

reprisal. The mechanisms to ensure that users can trust

the whistleblowing channels to raise concerns and are

protected from retaliation are described in the section

G1 Business conduct (p. 122).

Sampo Group has several processes for providing

remedy or contributing to remedy, depending on the

situation in question. In case of a customer complaint

related to sales and marketing of products and

services, the priority is to discuss with the customer to

find a solution that is satisfactory to both parties. In

addition, the Group has different kinds of customer

representative functions that the customer can contact

to submit a complaint. If a consensus cannot be

reached, the customer is entitled to appeal to external

complaints boards (or similar), in accordance with local

practices in each Sampo Group country. Regardless of

the outcome of appeal cases, Sampo Group always

analyses how it can improve its practices.

Sampo Group has procedures for investigating

breaches and processes for corrective actions to

protect the personal data of consumers and end-users.

Data breaches and information security incidents are

analysed and handled according to fixed processes, and

they are assessed and reported in a timely manner to

the local authorities, when applicable. If the risk to

consumers and end-users is considered high, they are

notified of the incident.

Sampo Group evaluates the effectiveness of the

remedies it provides to ensure that negative impacts on

consumers and end-users are addressed when needed.

This is achieved through systematic follow-up

procedures that include monitoring customer

satisfaction post-resolution, analysing patterns in

complaints and resolutions, and conducting reviews of

remediation processes to identify areas for

improvement. Sampo Group also follows up on every

data breach or information security incident to assess

how similar incidents can be avoided in the future to

ensure the rights and freedoms of data subjects.


	BOARD OF DIRECTORS’ REPORT 2025	117

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

S4-4 – Taking action on material impacts on

consumers and end-users, and approaches to

managing material risks and pursuing

material opportunities related to consumers

and end-users, and effectiveness of those

actions

Sampo Group adheres to the Code of Conduct and

supplementary policies to prevent irresponsible sales

and marketing practices, ensuring that all customer

communication is clear, relevant, and timely. The Group

regularly assesses the products for appropriateness and

compliance with regulatory obligations, supported by

continuous training programmes that enhance the

conduct and competence of customer-facing teams.

Sampo Group actively collects customer feedback, and

has transparent complaint processes in place, with

options for review through external complaints boards.

Sampo Group allocates resources across product and

service development, sales and marketing, IT, and risk

management, among other things, to further improve

its sales and marketing practices, as well as its

customers’ privacy, health, and safety. The Group also

collaborates with authorities and regulators and works

with relevant networks (e.g. related to customer

experience, cybersecurity, and data security), industry

associations (e.g. Finance Finland, Insurance Sweden,

Finance Norway, Insurance and Pension Denmark,

Association of British Insurers), and forums for

knowledge sharing. These collaborations provide

Sampo Group the opportunity to share knowledge and

experiences regarding topics such as climate change

adaptation, loss prevention, risk management, health,

and safety.

Sampo Group ensures effective complaints handling

and remediation processes for any material negative

impacts on consumers and end-users by closely

monitoring customer feedback, results of the customer

satisfaction surveys, and cases raised with external

complaints boards. When a negative impact originates

from the Group’s actions, appropriate remedies are

based on the nature of the breach. In instances where

customers are negatively impacted, Sampo Group has

established incident management processes to oversee

and ensure that remediation activities are both

appropriate to the situation and as effective as possible.

Governance frameworks, including product reviews and

customer forums, facilitate proactive identification of

systemic risks.

No severe human rights issues or incidents connected

to Sampo Group’s consumers or end-users were

reported to the Group during the reporting year.

Customer health and safety and Sales and marketing

practices

During 2025, Sampo Group continued to provide loss

prevention services to consumers and end-users. The

main purpose of loss prevention is to prevent damage

from occurring, but it also increases safety and reduces

risk and economic cost. Together with an external

partner, Sampo Group offered house assessments to

private customers who own their house and hold top-

level coverage insurance policies. The house

assessments provide the customers with a report that

helps them to both plan the maintenance of the

property and minimise the risk of unforeseen events.

For SME customers that own residential buildings in

Norway and Finland, Sampo Group offered building

checks. Following a physical inspection, the customers

receive help to identify where maintenance and fire

safety measures are most needed, for example. Through

the building checks and hands-on advice offered to

larger SME customers, Sampo Group’s customers are

made aware of risks and are provided with suggestions

for mitigating actions. Large corporate customers

continued to be offered on-site risk management

services during the year.

Health insurance is an important supplement in meeting

the increasing demand for healthcare, and through it,

Sampo Group helps its customers across the Nordics

when they face health issues. The Group is, for example,

supporting corporate customers in mapping the work

environment requirements, and by offering their

employees preventative health services. When it comes

to private customers, Sampo Group provides support

not only when customers face health challenges, but

also when preventive measures can make a difference,

thereby contributing to improved overall wellbeing. To

raise awareness and increase knowledge about the

topic, If published the Nordic Health Report in 2025 for

the third consecutive year. The report is based on a

Nordic-wide survey and provides insights into stress,

factors that support work-life balance, and the role of

social insurance and healthcare systems across the

Nordic countries.

As data from cars and car usage become more readily

available, Sampo Group is continually looking into ways

to incentivise safer driving. Usage-based insurance

(UBI) programmes utilise data from cars and

smartphones to enable the identification of

improvement potential for each individual driver and

may offer incentives to improve the driving behaviour.

In the UK, Sampo Group continued to encourage safer

driving habits through one of its car insurance policies

during 2025. Safe drivers are rewarded with lower

premiums and provided with personalised tips to help

improve their driving habits.

Continuously improving the quality of its services in

both digital and analogue channels is important to

Sampo Group. During 2025, the Group aimed to

enhance the ways customers communicate with the

company through various initiatives. This included,

among other things, further development of digital

platforms and testing of new communication channels.

Additionally, understanding customer experiences


	BOARD OF DIRECTORS’ REPORT 2025	118

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

through different channels remained one of Sampo

Group’s focus areas, as it enables the identification

opportunities for enhancements to customer journeys

and customer satisfaction.

Data privacy, information security, and cybersecurity

During 2025, Sampo Group took a series of measures to

bolster data protection and ensure compliance with

industry standards and regulations. This included, for

example, raising awareness within the organisation

about the importance of data privacy, information

security, and cybersecurity, providing training to

employees on the latest developments, new laws, and

regulations (e.g. Digital Operational Resilience Act

DORA), and hiring an external company to attempt to

breach organisational defences and identify

vulnerabilities. In addition, Sampo Group monitored the

processing of personal data to ensure it is carried out

transparently and with respect for individuals’ privacy.

Key actions included Data Protection Impact

Assessments and documentation of Records Processing

Activities before new processing activities were

initiated or changes to existing ones made, for instance.

In 2025, focus was directed toward the integration of

Topdanmark into If and the need to align processes

ensuring compliance with data protection regulations. A

key activity was to integrate data processing activities

in the respective Group companies in a way that

ensures continued compliance with privacy regulations

and mitigates the potential risks to consumers and end-

users.

Sampo Group regularly updates its policies, guidelines,

and training materials to stay current with the evolving

landscape of data privacy, information security, and

cybersecurity. The Group conducted an annual policy

review in 2025, which included, for example,

strengthening its principles, policies, and guidelines

related to AI. During the year, all Group employees were

also offered training in the use of AI tools.

Sampo Group has several actions planned for 2026 to

improve and strengthen the protection of personal

data. These include, for example, new initiatives to

improve procurement and monitoring of data

processors (third-party service providers).

Metrics and targets

S4-5 – Targets related to managing material

negative impacts, advancing positive

impacts, and managing material risks and

opportunities

Customer health and safety and Sales and marketing

practices

In accordance with the Sampo Group Code of Conduct,

Sampo Group strives to act in the best interests of its

customers. This means that the aim is to provide

products and services that are fair, comprehensible, and

designed to help meet the evolving needs of customers.

Sampo Group uses the Net Promoter Score (NPS) to

measure customer satisfaction, which allows the Group

to advance positive impacts on consumers and end-

users. Using NPS also supports the monitoring of

potential negative impacts and risks and acting on

them. The NPS is an index ranging from -100 to 100 that

measures the willingness of customers to recommend a

company’s products or services to others. It is used as a

proxy for measuring the customer’s overall satisfaction

with a company’s product or service, and the

customer’s loyalty to the brand. Transactional Net

Promoter Score (tNPS) is an overall metric that

assesses the customer’s opinion on a certain business

transaction and captures a wide range of customer

experiences related to, for example, price, product,

billing, brand, and marketing. The tNPS score shows

whether customers want to recommend the company

to others after they have been in contact with the

company. It is calculated as the net result of the share

of promoters (who replied 9–10) minus the share of

detractors (who replied 0–6) on the question of to what

extent they would recommend the company to others.

Sampo Group has set targets for customer satisfaction.

The targets are specific to each individual Sampo Group

company, and their scope differs between the Group

companies due to company-specific characteristics (e.g.

size, structure, operating countries). External

stakeholders have not been directly involved in target

setting. However, consumers and end-users have been

indirectly involved, as customer-facing organisational

units have been included in the target setting. The

targets are presented in the table Customer satisfaction

(tNPS) (p. 120).

Sampo Group actively monitors and analyses the tNPS,

and the results are regularly reported to the respective

top managements and internal committees to assess

overall performance. Sampo Group tracks the tNPS

performance internally on a monthly basis and has set

targets to ensure continuous improvement. Sampo

Group also publishes the results and targets externally

on a quarterly basis. Through systematic measurement

of customer satisfaction, Sampo Group wants to both

identify the factors that are valued by the Group’s

customers and recognise the parts of the customer

journey that should be improved. In addition to

improving the customer experience in general, the

results are used in training and in developing products,

services, and customer-related processes. In addition to

the tNPS, Sampo Group collects feedback through

various other channels, including customer complaints

and customer satisfaction surveys. The feedback not

only contributes to tNPS but also provides deeper

insights into the customer experience, enabling Sampo

Group to address concerns proactively.


	BOARD OF DIRECTORS’ REPORT 2025	119

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo Group is committed to actively addressing

customer feedback, and low tNPS scores prompt

engagement with customers to resolve their issues and

inform service enhancements. Examples of

improvements made based on customer feedback

include clarifying terms and conditions and enhancing

customer communications and service. These processes

ensure consistent elevation of service quality and

customer satisfaction.

The NPS methodology can have its limitations, such as

oversimplification of customer sentiment, and a lack of

detailed feedback on specific areas for improvement.

However, follow-up with individual customers can

provide a deeper insight into areas of potential

development.

In 2025, If’s customer satisfaction remained high, and

the tNPS result for the Private business area stabilised

at a strong level, reflecting a consolidated and

consistent trend. In 2026, the work to align If and

Topdanmark’s customer survey set-ups will continue. In

the UK, Hastings continued to invest in technology and

customer service capabilities and exceeded its tNPS

target in 2025. Examples of enhancements supporting

positive customer sentiment included a 24/7 messenger

channel in the mobile app and increased self-service

functionalities.

Data privacy, information security, and cybersecurity

The goal of Sampo Group’s data privacy operations is

to protect the employees’, customers’, and other

stakeholders’ personal data. In addition, information

security and cybersecurity measures ensure protection

of all types and forms of information according to its

sensitivity and importance to the Group, and in

compliance with applicable rules and regulations. The

key metrics used are the number of complaints received

from data subjects and through data protection

authorities (DPAs), data breaches reported to local data

protection authorities, and information security and

cybersecurity incidents reported to the authorities

within the reporting year.

Complaints from data subjects are based on Sampo

Group’s internal systems that capture complaints.

Generally, Sampo Group’s Data Protection Officers

(DPOs) receive complaints directly from customers and

through DPAs. Complaints can be received via different

channels (e.g. email, phone, post/letter) depending on

the Group company and local legislation in question. If a

data subject has contacted the local DPA directly, the

complaint is forwarded to Sampo Group.

Sampo Group’s DPOs (or similar) assess whether

internally reported data breaches require external

reporting to local DPAs. The types of incidents that are

deemed reportable are based on legislation (e.g. the

General Data Protection Regulation, GDPR). According

to the GDPR, a personal data breach is a breach of

security leading to the accidental or unlawful

destruction, loss, alteration, unauthorised

disclosure of, or access to, personal data transmitted,

stored or otherwise processed. However, there are

regional differences in which data breaches are required

to be reported to the local DPAs based on their

individual guidance. In 2025, the number of reported

data breaches decreased in Sampo Group, as the Group

continued to further strengthen controls, and due to a

change of reporting requirements laid down by the DPA

in the UK.

Information security and cybersecurity incidents are

monitored internally. Reporting on severe cases to the

authorities is based on local legislation and is the

responsibility of legal or information security units (or

similar). Sampo Group experienced an information

security incident at the beginning of 2025 when a data

system was temporarily unavailable. The incident was

reported to the Financial Supervisory Authority in

accordance with applicable local regulatory

requirements.


	BOARD OF DIRECTORS’ REPORT 2025	120

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Customer satisfaction (tNPS)

Sampo Group


Metric	Target	2025	2024
If (Business area Private)	2025: 57	57	57
Hastings	2025: 55	64	56

If’s figures are excluding Topdanmark.

Complaints received from data subjects and through data

protection authorities

Sampo Group


Metric	2025	2024
Complaints received from data subjects	208	135
Complaints received through data protection authorities	9	3

Data breaches reported to local data protection authorities

Sampo Group


Metric	2025	2024
Data breaches reported to local data protection authorities	109	414

Information security and cybersecurity incidents reported to the

authorities

Sampo Group


Metric	2025	2024
Information security and cybersecurity incidents reported to the authorities	1	0


	BOARD OF DIRECTORS’ REPORT 2025	121

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Governance information

G1 Business conduct


Topic	Impacts	Risks and opportunities	Strategy and actions
Corruption and bribery	↓ Sampo Group can have a 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 • Value chain location: own operations, upstream value chain, downstream value chain	↓ Sampo Group can face reputational risks, legal risks, business risks, and potential costs if it fails to combat financial crime, corruption, and bribery in all their forms. • Time-horizon: short to medium term • Value chain location: own operations, upstream value chain, downstream value chain	• Internal policies and guidelines (e.g. codes of conduct, responsible investment policies) • Effective governance structures and processes (e.g. general risk management measures, screening of direct investments and corporate customers, encouraging sustainability in supply chains, reporting channels) • Internal training and competence development programmes • Metrics and targets (e.g. reported incidents)
Responsible business practices	↑ Actual positive impact occurs through quality risk management, which is at the core of Sampo Group’s business operations. Risk management ensures that the Group can provide safety and financial security to its customers, investors, and society in general. ↑ Emphasising sustainability and responsible business practices in strategy and business operations may result in positive impacts across Sampo Group’s value chain. ↓ If Sampo Group fails to manage risks effectively, it may weaken the Group's ability to provide security and could therefore have a potential negative impact on its customers and other stakeholders.* ↓ Failing to protect whistleblowers can have a potential negative impact throughout Sampo Group’s value chain, as it may reduce trust and maintain negative impacts related to people or the environment.* • Time-horizon: short to medium term • Value chain location: own operations, upstream value chain, downstream value chain	↓ 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 Group and its value chain, it is not possible to completely eliminate the risk of potential negative impacts (e.g. risk of non-compliance due to increasing regulation or human error). ↓ If sustainability is not an integrated part of Sampo Group’s governance and business management, it can cause a financial risk for the Group due to possible legislative consequences (e.g. fines) and reputational damage, for example. ↑ Integrating sustainability in Sampo Group’s governance and business operations supports preparation for future regulations and the sustainable development of society (e.g. green transformation), which may create financial opportunities for the Group. • Time-horizon: short to medium term • Value chain location: own operations, upstream value chain, downstream value chain	• Internal policies and guidelines (e.g. risk management principles, compliance principles, codes of conduct) • Effective governance structures and processes (e.g. Sampo Group steering framework, risk management governance framework, regulated risk management measures, sustainability reporting and governance structure, whistleblowing channels) • Internal training and competence development programmes
Sustainable partnerships and supply chains	↓ Sampo Group can have potential negative impacts on suppliers and business partners if it fails to manage its supplier relationships according to agreed terms and conditions (e.g. delays in payments).* • Time-horizon: short to medium term • Value chain location: own operations, upstream value chain, downstream value chain	↑ Having stable business relationships with responsible suppliers and business partners can be a competitive advantage and create financial opportunities for Sampo Group.* ↓ Partnering with irresponsible suppliers or business partners can lead to increased costs (e.g. costs related to changing a supplier, delays, poor-quality deliveries) and reputational damage for Sampo Group.* • Time-horizon: short to medium term • Value chain location: own operations, upstream value chain, downstream value chain	• Internal policies and guidelines (e.g. codes of conduct, supplier codes of conduct, sustainability policies, procurement policies) • Effective governance structures and processes (e.g. supplier risk assessments, audits, questionnaires, engagement) • Internal training and competence development programmes • Metrics and targets (e.g. supplier codes of conduct included in existing supplier agreements)

The table presents Sampo Group’s material impacts, risks, and opportunities related to business conduct identified in the double materiality assessment and their connection to Sampo Group’s strategy and

actions. The topic Corruption and bribery is related to the ESRS sub-topic with the same name. The topic Responsible business practices is related to the ESRS sub-topics Corporate culture and Protection

of whistleblowers. The topic Sustainable partnerships and supply chains is related to the ESRS sub-topic Management of relationships with suppliers including payment practices.

* IRO has been added as part of the 2025 DMA review.


	BOARD OF DIRECTORS’ REPORT 2025	122

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Impact, risk and opportunity

management

G1-1 – Business conduct policies and

corporate culture

The group level policy regarding business conduct and

corporate culture is the Sampo Group Code of Conduct,

which is reviewed annually and approved by Sampo’s

Board of Directors. The Code states that Sampo Group

complies with applicable legislation and the rules and

regulations of competent authorities in all its activities.

In addition to the Group’s Code of Conduct, Sampo

Group has supplementary and more detailed policies,

guidelines, and processes for specific purposes (e.g. HR

policies, underwriting principles, responsible investment

policies, supplier codes of conduct). Sampo Group is

also a participant in the UN Global Compact, supporting

its principles on human rights, labour rights, the

environment, and anti-corruption.

The Sampo Group Code of Conduct applies to all

companies belonging to Sampo Group. The Group

offers regular training (e.g. e-learning, workshops) to all

employees on the topics covered by the Code and is

committed to communicating the topics to its

employees (e.g. policy updates on the intranet). The

frequency of the training varies from annual to biennial

depending on the Group company and the topic in

question.

Whistleblowing channels

Sampo Group has whistleblowing channels through

which employees and relevant interest groups can

report anonymously if they have reasonable grounds to

suspect that somebody employed by Sampo Group has

breached the Group’s Code of Conduct, legislation,

regulations, or other rules that are relevant to the

insurance industry. Material whistleblowing notifications

reported through the whistleblowing channels are

reported to the parent company, Sampo, as a part of

regular compliance and sustainability reporting to

ensure group level monitoring of these matters. In

addition to the whistleblowing channels, Sampo Group

encourages its employees to report other work-related

grievances and day-to-day concerns through internal

reporting channels. Grievances can also be reported

directly to a leader, HR, or compliance units, for

example.

Sampo Group has defined structures for processing

whistleblowing notifications. The Group ensures that

the outcomes and remedies related to whistleblowing

systems accord with internationally recognised human

rights.

Information about the whistleblowing channels and

other internal reporting channels is proactively

communicated to employees through intranet pages,

for example. Sampo Group also offers training to its

own employees, including information about the

designation and training of those reviewing the reports.

The employees designated with this task receive

training when they are appointed to the position (e.g.

onboarding, on-the-job training). Maintaining objectivity

is essential for the employees handling the reports.

Sampo Group ensures that those handling the reports

are separate from those whom the report concerns, and

the investigators or investigating committees are

separate from the chain of management involved in the

matter.

All whistleblowing reports are investigated promptly

and in a confidential manner, while always protecting

the identity of the whistleblower. Sampo Group

prohibits any form of retaliation against an employee

who in good faith raises a concern about suspected or

actual misconduct through any reporting channel, or

who cooperates in an investigation of misconduct.

G1-2 – Management of relationships with

suppliers

Sampo Group complies with applicable local legislation

and regulations in its payment practices. In addition, the

Group has internal guidelines in place (e.g. accounting

instructions, claims guidelines) to ensure timely

payment. Automated systems and digital invoicing help

prevent late payments.

Sampo Group is a major procurer of goods and

services, especially in claims handling and, therefore,

has an impact on the economy, environment, and

people. Sampo Group emphasises sustainability factors

when working with suppliers, as sustainability issues can

carry reputational and operational risks if not managed

correctly. The Sampo Group Code of Conduct provides

the group level guiding principles for sustainable supply

chain management. According to the Code of Conduct,

Sampo Group expects its suppliers and other business

partners to comply with the principles of the Code of

Conduct throughout their own operations and supply

chains.

Environmental and social considerations are integral to

Sampo Group’s supplier selection process. In addition to

the Group’s Code of Conduct, Sampo Group has

supplementary policies (e.g. supplier codes of conduct),

guidelines, and processes (e.g. risk assessments) that

guide supplier selection on a more detailed level. Topics

covered in these policies include human rights, labour

rights, environmental considerations, and anti-

corruption. Sampo Group is committed to encouraging

and supporting its suppliers in their efforts to use more

sustainable methods in their operations. By actively

requesting innovative solutions, resource efficiency,

transparency, and responsibility from suppliers, Sampo

Group aims to minimise its negative impact and

stimulate sustainable production and consumption. Set

requirements, in combination with close cooperation

with suppliers, enable Sampo Group to develop its


	BOARD OF DIRECTORS’ REPORT 2025	123

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

business while also contributing to sustainable

development.

G1-3 – Prevention and detection of

corruption and bribery

Sampo Group can be exposed to corruption and bribery

especially through its customer support functions (e.g.

sales, claims handling), investments, as well as suppliers

and business partners (e.g. procurement, claims

handling, IT). Customer support functions are at risk of

corruption, for example due to financial transactions

and handling of personal data. Investment operations

can be vulnerable, for example, due to exposure to

industries and markets with varying levels of corruption

risk. Suppliers and business partners may face risks

associated with the dependency on third-party

partnerships and intricate procurement operations.

Allegations or incidents of corruption and bribery are

generally detected through reporting channels (e.g.

whistleblowing channels), screening of customers and

direct investments, as well as supplier selection and risk

assessment processes. The risks are mitigated by

internal control systems. These include commitments to

international initiatives (e.g. the UN Global Compact),

policies and guidelines (e.g. codes of conduct,

investment policies), employee training, and other

manual and automatic control activities.

Sampo Group’s Code of Conduct sets the overall

guiding principles for preventing corruption and bribery

within the Group. In addition, Sampo Group has

supplementary policies and guidelines for specific and

more detailed purposes. These annually updated

guidance documents contain, for example, rules on

gifts, participation in events, and hospitality, as well as

information on expectations regarding employees, and

roles and responsibilities.

The CEO of each Sampo Group company has the

ultimate responsibility to ensure that sufficient

resources are allocated to the prevention of corruption

and bribery. Each Group company organises duties and

takes other necessary and appropriate measures to

comply with the applicable local rules and various

sanctions regimes, which may be imposed by the UN

and/or the EU.

Reporting on anti-corruption and anti-bribery activities,

as well as on potential incidents, is organised in a

manner that ensures that the applicable management

and boards of directors within Sampo Group receive all

material information without undue delay. All valid

whistleblowing notifications received through the

whistleblowing channels are reported to the parent

company, Sampo, as part of regular compliance

reporting. Sampo’s Risk Management organisation is

responsible for overseeing the reporting of relevant

incidents to Sampo’s Audit Committee and the Board of

Directors.

Sampo Group provides training (e.g. e-learning and

during contract discussions) on business conduct

matters to ensure that employees, suppliers, and other

business partners have sufficient knowledge of these

topics. Related and relevant policies are available to all

Group employees on intranet pages and to other

stakeholders on the Group’s websites.

In addition, all Sampo Group employees and top

management (e.g. CEOs) are offered training (e.g. e-

learning) on anti-corruption and anti-bribery at least

biennially. Hence, also all employees who work in the

functions most at risk for negative impacts (e.g.

customer support functions, investment management,

supply chain management) receive training on the

topic. Anti-corruption and anti-bribery are part of

training programmes covering business ethics and

conduct. In addition, employees are informed, for

example, on the intranet pages, when related policies

have been revised.

In 2025, Sampo Group continued its regular efforts to

ensure that processes related to its business conduct

remain up to date. This involved, for instance,

conducting annual policy updates and providing

relevant training to all employees, as well as integrating

If and Topdanmark’s learning practices. In addition, the

Group strengthened its internal processes by enhancing

process descriptions and related documentation, as well

as harmonising reporting practices.


	BOARD OF DIRECTORS’ REPORT 2025	124

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Metrics and targets

G1-4 – Incidents of corruption or bribery

In 2025, Sampo Group was not convicted for incidents

of corruption or bribery and, therefore, did not pay any

related fines. For the same reason, the Group did not

need to take specific actions related to breaches in

procedures and standards of anti-corruption and anti-

bribery. In 2025, there were no public legal cases

regarding corruption or bribery brought against Sampo

Group either.

Incidents of corruption and bribery included in the

reporting are confirmed incidents that the Group

companies report to Sampo as part of regular

sustainability and compliance and/or risk reporting. The

Group companies receive this information through their

established reporting channels, such as whistleblowing

channels.

Incidents of corruption or bribery

Sampo Group


Metric	2025	2024
Confirmed incidents of corruption or bribery	0	0

G1-6 – Payment practices

Sampo Group is committed to fair and responsible

payment practices. It recognises the importance of

timely payments to suppliers and strives to ensure that

its payment practices are transparent and equitable

throughout its supply chain.

In 2025, the average time to pay an invoice at Sampo

Group was 23 days. The standard payment terms and

the share of payments aligned with the standard terms

are presented in the table Payment practices. 85.9 per

cent of Sampo Group’s total payments were aligned

with the payment terms in 2025. The main reasons for

late payments included delays in invoice review and

approval flow, invoices arriving late to the Group, and

challenges related to new suppliers (e.g. short payment

terms in one-time basis purchases, time required for

supplier validation controls, invoices sent to the wrong

address). However, 62.8 per cent of the late payments

were paid within seven days of the due date.

The payment term has been calculated as the period

between the invoice date and the due date. The

average time to make a payment at Sampo Group has

been calculated based on the period between the

invoice date and the payment date. The reported

information relates to the Group’s upstream suppliers,

as defined by the ESRS, and has been collected for the

entire Sampo Group, subject to minor limitations due to

data availability.

Sampo Group’s payment terms are influenced by

various factors, including the nature of the supplier

relationship, the country or geographical region of

operation, and market standards. Sampo Group is not

able to disclose its standard payment terms by main

category of suppliers due to the diversity of its supplier

base and confidentiality considerations. As at 31

December 2025, Sampo Group was not party to any

legal proceedings due to late payments.

Payment practices

Sampo Group, 2025


Payment term	Share of total payments	Payments aligned with the term
Within 14 days	24.5%	70.2%
Within 15 to 30 days	57.7%	90.7%
Within 31 days or more	17.8%	92.2%
Total	100.0%	85.9%


	BOARD OF DIRECTORS’ REPORT 2025	125

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Annexes

Annex 1: ESRS content index


Disclosure requirement	Location
ESRS 2 General disclosures
BP-1 – General basis for preparation of the sustainability statement	p. 57
BP-2 – Disclosures in relation to specific circumstances	p. 57
GOV-1 – The role of the administrative, management and supervisory bodies	p. 57
GOV-2 – Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies	p. 59
GOV-3 – Integration of sustainability-related performance in incentive schemes	p. 60
GOV-4 – Statement on due diligence	p. 60
GOV-5 – Risk management and internal controls over sustainability reporting	p. 62
SBM-1 – Strategy, business model and value chain	p. 62
SBM-2 – Interests and views of stakeholders	p. 65
SBM-3 – Material impacts, risks, and opportunities and their interaction with strategy and business model	pp. 67, 78, 95, 108, 114
IRO-1 – Description of the processes to identify and assess material impacts, risks, and opportunities	p. 69
IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement	p. 71
ESRS E1 Climate change
E1-1 – Transition plan for climate change mitigation	p. 79
E1-2 – Policies related to climate change mitigation and adaptation	p. 81
E1-3 – Actions and resources in relation to climate change policies	p. 81
E1-4 – Targets related to climate change mitigation and adaptation	p. 84
E1-6 – Gross Scopes 1, 2, 3 and total GHG emissions	p. 86
ESRS E5 Resource use and circular economy
E5-1 – Policies related to resource use and circular economy	p. 92
E5-2 – Actions and resources related to resource use and circular economy	p. 92
E5-3 – Targets related to resource use and circular economy	p. 93


Disclosure requirement	Location
ESRS S1 Own workforce
S1-1 – Policies related to own workforce	p. 95
S1-2 – Processes for engaging with own workers and workers’ representatives about impacts	p. 96
S1-3 – Processes to remediate negative impacts and channels for own workers to raise concerns	p. 97
S1-4 – Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions	p. 97
S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	p. 98
S1-6 – Characteristics of the undertaking’s employees	p. 100
S1-7 – Characteristics of non-employee workers in the undertaking’s own workforce	p. 102
S1-8 – Collective bargaining coverage and social dialogue	p. 102
S1-9 – Diversity metrics	p. 103
S1-10 – Adequate wages	p. 104
S1-11 – Social protection	p. 104
S1-12– Persons with disabilities	p. 104
S1-13 – Training and skills development metrics	p. 104
S1-14 – Health and safety metrics	p. 105
S1-15 – Work-life balance metrics	p. 105
S1-16 – Remuneration metrics	p. 106
S1-17 – Incidents, complaints and severe human rights impacts	p. 106


	BOARD OF DIRECTORS’ REPORT 2025	126

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


Disclosure requirement	Location
ESRS S2 Workers in the value chain
S2-1 – Policies related to value chain workers	p. 108
S2-2 – Processes for engaging with value chain workers about impacts	p. 110
S2-3 – Processes to remediate negative impacts and channels for value chain workers to raise concerns	p. 110
S2-4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions	p. 111
S2-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	p. 112
ESRS S4 Consumers and end-users
S4-1 – Policies related to consumers and end-users	p. 114
S4-2 – Processes for engaging with consumers and end-users about impacts	p. 115
S4-3 – Processes to remediate negative impacts and channels for consumers and end-users to raise concerns	p. 116
S4-4 – Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions	p. 117
S4-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	p. 118
ESRS G1 Business conduct
G1-1 – Business conduct policies and corporate culture	p. 122
G1-2 – Management of relationships with suppliers	p. 122
G1-3 – Prevention and detection of corruption and bribery	p. 123
G1-4 – Incidents of corruption or bribery	p. 124
G1-6 – Payment practices	p. 124


	BOARD OF DIRECTORS’ REPORT 2025	127

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Annex 2: Data points deriving from other EU legislation


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


	BOARD OF DIRECTORS’ REPORT 2025	128

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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


	BOARD OF DIRECTORS’ REPORT 2025	129

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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 2025	130

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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


	BOARD OF DIRECTORS’ REPORT 2025	131

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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


	BOARD OF DIRECTORS’ REPORT 2025	132

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Key figures


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

Private Nordic		2025	2024	2023	2022 (restated)	2022 (published)	2021
Gross written premiums	EURm	4,183	3,872	—	—	—	—
Insurance revenue, net	EURm	3,995	3,667	—	—	—	—
Underwriting result	EURm	715	628	—	—	—	—
Risk ratio	%	60.9	60.7	—	—	—	—
Cost ratio	%	21.2	22.2	—	—	—	—
Combined ratio	%	82.1	82.9	—	—	—	—


	BOARD OF DIRECTORS’ REPORT 2025	133

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


Private UK		2025	2024	2023	2022 (restated)	2022 (published)	2021
Gross written premiums (incl. brokerage)	EURm	2,865	2,565	—	—	—	—
Insurance revenue (incl. brokerage), net	EURm	2,000	1,659	—	—	—	—
Underwriting result	EURm	216	190	—	—	—	—
Risk ratio	%	53.6	52.3	—	—	—	—
Cost ratio	%	35.6	36.2	—	—	—	—
Combined ratio	%	89.2	88.5	—	—	—	—

Nordic Commercial		2025	2024	2023	2022 (restated)	2022 (published)	2021
Gross written premiums	EURm	2,391	2,173	—	—	—	—
Insurance revenue, net	EURm	2,201	2,128	—	—	—	—
Underwriting result	EURm	376	352	—	—	—	—
Risk ratio	%	58.4	58.9	—	—	—	—
Cost ratio	%	24.5	24.5	—	—	—	—
Combined ratio	%	82.9	83.5	—	—	—	—

Nordic Industrial		2025	2024	2023	2022 (restated)	2022 (published)	2021
Gross written premiums	EURm	1,046	1,070	—	—	—	—
Insurance revenue, net	EURm	584	657	—	—	—	—
Underwriting result	EURm	109	74	—	—	—	—
Risk ratio	%	58.4	69.2	—	—	—	—
Cost ratio	%	22.9	19.5	—	—	—	—
Combined ratio	%	81.3	88.7	—	—	—	—


	BOARD OF DIRECTORS’ REPORT 2025	134

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


Per share key figures		2025	2024	2023	2022 (restated)	2022 (published)	2021
Earnings per share	EUR	0.74	0.45	0.52	0.79	0.54	0.93
Earnings per share, continuing operations²	EUR	0.74	0.45	0.42	0.58	—	—
Earning per share, discontinuing operations	EUR	—	—	0.10	0.22	—	—
Operating earnings per share	EUR	0.50	0.47	0.41	—	—	—
Equity per share	EUR	3.04	2.62	2.89	3.74	3.49	4.68
Net asset value per share	EUR	3.04	2.62	3.06	4.00	3.75	5.10
Dividend per share	EUR	0.36	0.34	0.36	0.52	0.52	0.82
Total dividend	EURm	956	915	903	1,321	1,321	2,186
Dividend payout ratio	%	71.2	76.7	86.4	—	—	—
Effective dividend yield	%	3.5	4.3	4.5	5.3	5.3	9.3
Price/operating earnings ratio		20.6	16.9	—	—	—	—
Price/earnings ratio		13.9	17.5	15.1	12.3	18.1	9.5
Number of shares at 31 Dec.⁵	1,000	2,661,809	2,691,239	2,508,984	2,571,847	2,571,845	2,734,060
Average number of shares ⁵	1,000	2,684,637	2,560,572	2,529,695	2,651,481	2,651,480	2,771,585
Market capitalisation ⁴	EURm	27,496	21,196	19,876	25,112	25,112	24,093
A shares		2025	2024	2023	2022 (restated)	2022 (published)	2021
Number of shares at 31 Dec.⁵	1,000	2,660,809	2,690,239	2,507,984	2,570,847	2,570,845	2,728,060
Average number of shares⁵	1,000	2,683,637	2,559,572	2,528,695	2,650,481	2,650,480	2,765,585
Weighted average share price	EUR	9.17	8.02	7.87	8.85	8.85	8.10
Adjusted share price, high⁴	EUR	10.36	8.47	9.04	9.99	9.99	9.47
Adjusted share price, low⁴	EUR	7.70	7.48	6.91	7.17	7.17	6.76
Adjusted closing price	EUR	10.33	7.88	7.92	9.76	9.76	8.81
Share trading volume during the financial year	1,000	787,550	894,548	894,006	1,289,395	1,289,395	1,218,815
Relative share trading volume	%	29.3	34.9	35.4	48.6	48.6	44.1
B shares		2025	2024	2023	2022 (restated)	2022 (published)	2021
Number of shares at 31 Dec.⁵	1,000	1,000	1,000	1,000	1,000	1,000	6,000
Average number of shares ⁵	1,000	1,000	1,000	1,000	1,000	1,000	6,000

1Th e Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC).

2Earnings per share on continuing operations for comparative period 2022 includes the divested operations i.e. Topdanmark Life operations.

3The solvency ratio for 2023 is pro forma figure excluding the effect of Saxo Bank on the Group SCR.

4Share prices have been adjusted to reflect the separation of Mandatum Group in a partial demerger carried out in 2023.

5Both the number of shares used at the reporting date and the average number of shares have been adjusted in the comparative periods to reflect the sharesplit carried out in 2025.

In calculating the key figures the tax corresponding to the result for the accounting period has been taken into account.

In the net asset value per share, the Group valuation difference on the listed subsidiary Topdanmark has been taken into account in the comparison years prior to 2024. At the end of the financial year 2024,

Topdanmark had been delisted.


	BOARD OF DIRECTORS’ REPORT 2025	135

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Calculation of key figures

The key figures have been calculated in accordance with the decree issued by the Ministry of Finance and the specifying regulations and instructions of the Financial Supervisory

Authority. The Group solvency is calculated according to the consolidation method defined in the Solvency II Directive (2009/138/EC) and Insurance Companies Act (521/2008).

Additional information on the Group’s alternative performance measures is on the Group’s website www.sampo.com.


Return on equity own funds, %
+	operating result (annualised)	x 100 %
+	unrestricted Tier 1 Own funds	x 100 %
	(average of values 1 Jan. and the end of reporting period)

Financial leverage¹
	financial debt	x 100%
	equity + financial debt	x 100%
	¹The Group’s financial leverage includes only long-term funding. RT1 instrument included in financial debt (not in equity),

Insurance revenue, net
+	insurance revenue, gross
-	reinsurers' share of insurance revenue
-	quota share premium expense (Private UK)
	insurance revenue, net

Underwriting result
+	insurance revenue, net
+	other income (Private UK)
-	claims incurred
-	operating expenses
	underwriting result


Operating result
+	profit after tax
-	non-controlling interest in P&C operations
-	unrealised gains/losses on investments (excl. derivatives) in P&C operations
-	result effect from changes in discount rates in P&C operations
-	non-operational amortisations in P&C operations
-	non-recurring items
-	adjustment on taxes
	operating result

Combined ratio, %
+	claims incurred
+	operating expenses	x 100%
+	insurance revenue, net	x 100%
+	other revenue (Private UK)

Risk ratio, %
+	claims incurred
–	claims handling costs	x 100%
	insurance revenue, net	x 100%


	BOARD OF DIRECTORS’ REPORT 2025	136

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


Nordic underlying risk ratio, %
(includes Private Nordic, Nordic Commercial, Nordic Industrial and certain minor items from Other operations)
	Risk ratio, %
–	large claims, %
–	severe weather, %
–	prior year development, risk adjustment and other technical effects, %
–	discounting effect, current year, %
	underlying risk ratio, %

Cost ratio, %
+	operating expenses
+	claims handling costs	x 100%
	insurance revenue, net	x 100%

Nordic operating cost ratio, %
(includes Private Nordic, Nordic Commercial, Nordic Industrial and Other operations excluding internal reinsurance)
+	operating expenses
+	claims handling costs	x 100 %
	insurance revenue, net

Per share key figures

Earnings per share
	profit for the financial period attributable to owners of the parent
	adjusted average number of shares

Operating earnings per share
	operating result
	adjusted average number of shares

Equity per share
	equity attributable to owners of the parent
	adjusted number of shares at the balance sheet date


Net asset value per share
+	equity attributable to owners of the parent
±	valuation differences on listed Group companies
	adjusted number of shares at balance sheet date

Market capitalisation
	number of shares at the balance sheet date x closing share price at the balance sheet date

Dividend payout ratio
	total dividend	x 100%
	operating result	x 100%

Effective dividend yield
	dividend per share	x 100%
	adjusted closing price	x 100%

Price/earnings ratio
	adjusted closing price
	earnings per share

Price/operating earnings ratio
	adjusted closing price
	operating earnings per share

Relative share trading volume
	share trading volume during the financial year	x 100%
	average number of A shares	x 100%


	BOARD OF DIRECTORS’ REPORT 2025	137

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Exchange rates used in reporting


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


	FINANCIAL STATEMENTS 2025	138

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Group’s IFRS Financial Statements


Statement of profit and other comprehensive income ...................................	139
Consolidated balance sheet .......................................................................................	140
Statement of changes in equity ...............................................................................	141
Statement of cash flows ..............................................................................................	142


	FINANCIAL STATEMENTS 2025	139

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Statement of profit and other comprehensive income


EURm	Note	1-12/2025	1-12/2024
Insurance revenue		10,272	9,450
Insurance service expenses		-8,126	-7,684
Reinsurance result		-556	-372
Insurance service result	1	1,590	1,394
Net investment income	2	1,285	888
Net finance income or expense from insurance contracts	3	-74	-252
Insurance finance income or expense, gross		-180	-309
Insurance finance income or expense, reinsurance		106	57
Net financial result		1,210	636
Other income	4	369	312
Other expenses	5	-651	-685
Finance expenses	7	-83	-103
Share of associates' profit or loss		0	6
Profit before taxes		2,436	1,559
Income taxes	15,16	-439	-330
Profit from the continuing operations		1,998	1,229
Divested operations, net of tax		—	-26
Net profit		1,998	1,203


EURm	Note	1-12/2025	1-12/2024
Other comprehensive income	8

Items reclassifiable to profit or loss
Exchange differences		-13	-4
Cash flow hedges		-2	1
Total items reclassifiable to profit or loss, net of tax		-16	-3

Items not reclassifiable to profit or loss
Actuarial gains and losses from defined benefit pension plans		24	0
Taxes		-5	0
Total items not reclassifiable to profit or loss, net of tax		19	0

Other comprehensive income total, net of tax		3	-3

Total comprehensive income		2,001	1,200

Profit attributable to
Owners of the parent		1,998	1,154
Non-controlling interests		—	50
Total comprehensive income attributable to
Owners of the parent		2,001	1,151
Non-controlling interests		—	50

Earnings per share (EPS), EUR		0.74	0.45

In February 2025, Sampo carried out a share split by way of a share issue without consideration.

The new shares were issued to shareholders in proportion to their existing holdings, so that four (4)

new shares were issued for each existing share. Earnings per share figure for the comparison

period has been adjusted for the share split. Previously published EPS for comparison period

1-12/2024 was EUR 2.25.


	FINANCIAL STATEMENTS 2025	140

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Consolidated balance sheet


EURm	Note	12/2025	12/2024
Assets
Property, plant and equipment	10	301	284
Intangible assets	11	3,492	3,637
Investments in associates		5	4
Financial assets	12,13,14	17,154	16,090
Deferred income tax	15	2	2
Reinsurance contract assets	19	2,488	2,618
Other assets	17	962	880
Cash and cash equivalents		1,319	962
Total assets		25,723	24,478


EURm	Note	12/2025	12/2024
Liabilities
Insurance contract liabilities	18,19,20,21	12,760	12,286
Subordinated debts	22	1,317	1,642
Other financial liabilities	22	1,413	1,395
Deferred income tax	15	553	535
Other liabilities	23	1,589	1,562
Total liabilities		17,631	17,419

Equity	25
Share capital		98	98
Reserves		3,531	3,531
Restricted Tier 1 notes		298	—
Retained earnings		4,927	4,176
Other components of equity		-762	-746
Total equity		8,092	7,059

Total equity and liabilities		25,723	24,478


	FINANCIAL STATEMENTS 2025	141

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Statement of changes in equity


EURm	Share capital	Legal reserve	Invested unres- tricted equity	Restric- ted Tier 1 notes⁵	Retained earnings¹	Transla- tion of foreign opera-tions	Cash flow hedges	Total	Non- control-ling interest	Total

Equity at 1 January 2024	98	4	1,527	—	6,378	-742	-1	7,263	424	7,687

Changes in equity
Directed share issue ²	—	—	2,000	—	—	—	—	2,000	—	2,000
Acquired non-controlling interests²	—	—	—	—	-1,666	—	—	-1,666	-334	-2,000
Compulsory acquisition of non-controlling interests ²	—	—	—	—	-265	—	—	-265	-59	-325
Transaction costs related to the acquisition of non- controlling interests	—	—	—	—	-31	—	—	-31	—	-31
Dividends³	—	—	—	—	-903	—	—	-903	-69	-972
Acquisition of own shares	—	—	—	—	-475	—	—	-475	—	-475
Other changes in equity	—	—	—	—	-14	—	—	-14	-11	-25
Profit for the reporting period	—	—	—	—	1,154	—	—	1,154	50	1,203
Other comprehensive income for the period	—	—	—	—	—	-4	1	-3	—	-3
Total comprehensive income	—	—	—	—	1,153	-4	1	1,151	50	1,200
Equity at 31 December 2024	98	4	3,527	—	4,176	-746	—	7,059	—	7,059

Equity at 1 January 2025	98	4	3,527	—	4,176	-746	0	7,059	—	7,059

Changes in equity
Dividends³	—	—	—	—	-915	—	—	-915	—	-915
Acquisition of own shares⁴	—	—	—	—	-350	—	—	-350	—	-350
Issue of Tier 1 notes	—	—	—	298	-5	—	—	293	—	293
Other changes in equity	—	—	—	—	4	—	—	4	—	4
Profit for the reporting period	—	—	—	—	1,998	—	—	1,998	—	1,998
Other comprehensive income for the period	—	—	—	—	19	-13	-2	3	—	3
Total comprehensive income	—	—	—	—	2,017	-13	-2	2,001	—	2,001
Equity at 31 December 2025	98	4	3,527	298	4,927	-759	-3	8,092	—	8,092

1 IAS 19 Pension benefits had a net effect of EUR 19 million (-0) on retained earnings.

²The share issue was directed at Topdanmark’s non-controlling interests. For further information, see note 28 .

³Dividend per share EUR 0.36 (0.34)

⁴Acquisition of own shares includes the already purchased shares EUR 290 million and the liability for the remaining shares of the buyback programme EUR 60 million, recognised as a liability against equity.

On 5 November 2025, Sampo plc cancelled 20,484,833 own shares acquired during the financial year 2025.

⁵During the financial year, Sampo issued EUR 300 million of new restricted Tier 1 notes with a coupon rate of 5.25 per cent and an option of a first call date in 2035 for Sampo. The restricted Tier 1

instrument is accounted as equity.


	FINANCIAL STATEMENTS 2025	142

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Statement of cash flows


EURm	1–12/2025	1–12/2024

Operating activities
Profit before tax	2,436	1,533
Adjustments
Depreciation, amortisation & impairments	211	180
Unrealised gains and losses arising from valuation	-667	-227
Realised gains and losses on investments	-68	-58
Change in liabilities for insurance contracts	279	383
Other adjustments	-383	132
Adjustments total	-627	410

Change (+/-) in assets of operating activities
Investments¹	220	-223
Other assets	-45	-98
Total	176	-321

Change (+/-) in liabilities of operating activities
Financial liabilities	201	122
Other liabilities	75	5
Total	276	127

Paid taxes and interests
Paid taxes	-413	-331
Paid interests	-89	-91
Total	-501	-422

Net cash from operating activities	1,759	1,327

Investing activities
Investments in tangible and intangible assets ²	-165	-142
Divestments in equipment and intangible assets	15	17
Net cash used in investing activities	-150	-125


EURm	1–12/2025	1–12/2024
Financing activities
Dividends paid	-915	-903
Dividends paid to non-controlling interests	—	-69
Acquisition of non-controlling interests	—	-325
Transaction costs related to acquisition of non- controlling interests	—	-31
Acquisition of own shares	-290	-475
Increase in debt securities and amounts owed to credit institutions ³	428	194
Payments of debt securities in issue³	-480	-50
Net cash used in financing activities	-1,257	-1,660

Total cash flows	351	-458

Cash and cash equivalents at the beginning of reporting period	962	1,415
Effects of exchange rate changes	5	5
Cash and cash equivalents at the end of reporting period	1,319	962
Net change in cash and cash equivalents	351	-458


Additional information to the cash flow statement	1–12/2025	1–12/2024
Interest income received	562	512
Dividend income received (excl. profit sharing from funds)	42	42
Total out-going cashflows from leases	-39	-39

¹Investments include mainly financial assets.

² The share of investments in tangible assets amounts to EUR -92 million (-37) and the share of

intangibles to EUR -74 million (-105)

³Changes in short-term issues and repayments of debt securities are presented as net amounts.

In 2024, the profit before tax is the total of Group’s profit and the discontinued/divested

operations’ profit before taxes. Subsequently, operating activities include EUR -26 million from

divested activities.

The items of the statement of cash flows cannot be directly concluded from the balance sheets due

to e.g. exchange rate differences, and acquisitions and disposals of subsidiaries during the period.

Cash and cash equivalents include cash at bank and in hand EUR 1,091 million (682) and short-term

deposits (max 3 months) EUR 228 million (280).


	FINANCIAL STATEMENTS 2025	143

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Group’s notes to the financial statements


Summary of material accounting principles ........................................................	144
Segment information ....................................................................................................	159
Geographical information ...........................................................................................	164
Other notes .......................................................................................................................	165
1 Insurance service result .................................................................................................	165
2 Net investment income .................................................................................................	166
3 Net finance income or expense from insurance contracts ..............................	167
4 Other income ...................................................................................................................	167
5 Other expenses ...............................................................................................................	167
6 Auditor's fees ...................................................................................................................	168
7 Finance expenses ...........................................................................................................	168
8 Components of other comprehensive income .....................................................	169
9 Earnings per share .........................................................................................................	169
10 Property, plant and equipment ................................................................................	170
11 Intangible assets .............................................................................................................	171
12 Financial assets ..............................................................................................................	174
13 Determination and hierarchy of fair values ..........................................................	177
14 Movements in level 3 financial instruments measured at fair value ...........	181


15 Deferred tax assets and liabilities ............................................................................	183
16 Taxes ..................................................................................................................................	187
17 Other assets ....................................................................................................................	187
18 Insurance contract liabilities ......................................................................................	188
19 Reconciliation of insurance contract liabilities ...................................................	189
20 Assets for insurance acquisition cash flows .......................................................	192
21 Non-life claims development ....................................................................................	192
22 Financial liabilities ........................................................................................................	195
23 Other liabilities ..............................................................................................................	198
24 Employee benefits .......................................................................................................	199
25 Equity and reserves .....................................................................................................	203
26 Incentive schemes ........................................................................................................	204
27 Investments in subsidiaries .......................................................................................	207
28 Acquisition of Topdanmark’s non-controlling interest ...................................	208
29 Related party disclosures ..........................................................................................	209
30 Contingent liabilities, commitments and legal proceedings ........................	210
31 Subsequent events after the balance sheet date ..............................................	211
32 Risk Management disclosure ....................................................................................	212


	FINANCIAL STATEMENTS 2025	144

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Group’s notes to the financial statements

Summary of material

accounting principles

Sampo plc (business ID 0142213-3) is a Finnish public

company listed in Helsinki Nasdaq. Sampo has a dual

listing in Nasdaq Stockholm and in Nasdaq

Copenhagen. It is domiciled in Helsinki and the

headquarters are at Fabianinkatu 21, 00130 Helsinki,

Finland. The consolidated financial statements of

Sampo Group include Sampo plc together with its

subsidiaries and associates as of 31 December 2025. The

Group subsidiaries have insurance and financing

activities in Finland, Sweden, Norway, Denmark, the

Baltic countries, and the United Kingdom.

A copy of the Group’s financial statements is available

at the internet address www.sampo.com.

Basis of preparation

Sampo Group’s consolidated financial statements are

prepared in accordance with IFRS® Accounting

Standards adopted by the EU. In preparing the financial

statements, Sampo has applied all the standards and

interpretations relating to its business, adopted by the

commission of the EU and effective on 31 December

2024.

The annual improvements or other amendments to the

standards, adopted at the beginning of 2025, had no

material impact on the Group’s financial statements

reporting.

In preparing the notes to the consolidated financial

statements, attention has also been paid to the Finnish

accounting and company legislation and applicable

regulatory requirements.

The going concern accounting assumption has been

assessed by the Board and used in the preparation of

the financial statements.

The consolidated financial statements are presented in

euro (EUR), rounded to the nearest million, unless

otherwise stated.

The Board of Directors of Sampo plc accepted the

financial statements for issue on 12 March 2026. In

accordance with Limited Liability Companies Act, the

Annual General Meeting has the right to approve or

reject the consolidated financial statements or change

the statements after they have been issued.

Consolidation

Subsidiaries

The consolidated financial statements combine the

financial statements of Sampo plc and all its

subsidiaries. Companies in which the Group has control

are consolidated as subsidiaries. Control exists when the

Group has more than half of the voting power or it has

power over the entity together with exposure to

variable returns from its involvement there, and the

ability to use its power to affect the amount of these

returns. Subsidiaries are consolidated from the date on

which control is transferred to the Group and cease to

be consolidated from the date that control ceases.

The acquisition method of accounting is used for the

purchase of subsidiaries. The cost of an acquisition is

allocated to the identifiable assets, liabilities and

contingent liabilities, which are measured at the fair

value of the date of the acquisition. Acquisition-related

costs are recognised through profit or loss. Possible

non-controlling interest of the acquired entity is

measured either at fair value or at proportionate

interest in the acquiree’s net assets. The acquisition-

specific choice affects both the amount of recognised

goodwill and non-controlling interest. The excess of the

aggregate of consideration transferred, non-controlling

interest and possibly previously held equity interest in

the acquiree, over the Group’s share of the fair value of

the identifiable net assets acquired, is recognised as

goodwill.

The accounting policies used throughout the Group for

the purposes of consolidation are consistent with

respect to similar business activities and other events

taking place in similar conditions. All intra-group

transactions and balances are eliminated upon

consolidation.

Non-controlling interests

The technical division of profit for the financial year and

the total comprehensive income to the owners of the

parent and non-controlling interests is presented after

the statement of comprehensive income. The share of

profits is attributed to non-controlling interests even if it

should be negative.

Non-controlling interests are presented in the balance

sheet separately as part of equity.


	FINANCIAL STATEMENTS 2025	145

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Non-controlling interests in an acquiree are measured

either at fair value or as a proportionate share of net

assets of the acquiree. The choice is made for each

acquisition separately.

At the end of the comparative year 2024, due to the

acquisition of non-controlling interests in Topdanmark,

the total equity of consolidated financial statements did

not include the non-controlling interest share. As the

proportion of equity held by non-controlling interests

changed, the carrying amounts of both the equity

owners of the parent and the non-controlling interests

were adjusted to reflect the changes. The difference

between the book value of the NCI and the

consideration paid was recognised directly in equity

(retained earnings), and attributed to the owners of the

parent company.

The NCI’s share of the profit was calculated as weighted

average on their remaining share of ownership.

Foreign currency translation

The consolidated financial statements are presented in

euro, which is the functional and reporting currency of

the Group and the parent company. Items included in

the financial statements of each of the Group entities

are measured using their functional currency, being the

currency of the primary economic environment in which

the Group operates. Foreign currency transactions are

translated into the appropriate functional currency

using the exchange rates prevailing at the dates of

transactions or the average rate for a month. The

balance sheet items denominated in foreign currencies

are translated into the functional currency, at the rate

prevailing at the balance sheet date.

Exchange differences arising from the translation of

transactions and monetary balance sheet items

denominated in foreign currencies into functional

currency are recognised as translation gains and losses

in profit or loss.

The income statements of Group entities whose

functional currency is other than euro are translated

into euro at the average rate for the period, and the

balance sheets at the rates prevailing at the balance

sheet date. The resulting exchange differences are

included in equity and their change in other

comprehensive income. When a subsidiary is divested

entirely or partially, the cumulative exchange

differences are reclassified from equity to profit or loss

and presented under sales gains or losses.

Goodwill and fair value adjustments arising from an

acquisition of a foreign entity are treated as if they were

assets and liabilities of the foreign entity. Exchange

differences resulting from the translation of these items

at the exchange rate of the balance sheet date are

included in equity, and their change in other

comprehensive income.

Exchange rate differences arising from a monetary item,

accounted for as Sampo’s net investment in a foreign

operation (subsidiary), are recognised in other

comprehensive income.

A monetary item included in the net investment in a

foreign operation may be denominated in the functional

currency of Sampo (reporting entity), in the functional

currency of the foreign operation or in a currency other

than the functional currency of either the reporting

entity or the foreign operation. When a foreign

subsidiary is divested entirely or partially, the

cumulative exchange differences are reclassified from

equity to profit or loss.

The following exchange rates were applied in the

consolidated financial statements:


1 euro (EUR) =	Balance sheet date	Average exchange rate
Swedish krona (SEK)	10.8215	11.0680
Danish krona (DKK)	7.4689	7.4635
Pound sterling (GBP)	0.8726	0.8569

Segment reporting

The Group’s segmentation is based on business areas

whose risks and performance bases as well as

regulatory environment differ from each other. The

control and management of business and management

reporting are organised in accordance with the business

segments.

In February 2025, Sampo introduced new reporting

segments to reflect its transformation into a fully-

integrated P&C insurance group following the

acquisition of the non-controlling interest in

Topdanmark in 2024. The Group’s business segments

are Private Nordic, Private UK, Nordic Commercial and

Nordic Industrial. Information presented for the

comparative period 2024 has been restated based on

the new segment structure. For further information on

the new segments, see section Segment information.

In addition to these four reporting segments, Sampo

presents other operations, consisting mainly of the

Group’s Baltic business but also of group eliminations

and other internal items. Other operations are not

considered a separate reporting segment as they do

not fulfil the criteria for reporting segments under

IFRS 8.


	FINANCIAL STATEMENTS 2025	146

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Geographical information has been given on income

from external customers and non-current assets. The

reported areas are Finland, Sweden, Norway, Denmark,

United Kingdom, and the Baltic countries.

In the inter-segment and inter-company pricing, for

both domestic and cross border transactions, market-

based prices are applied. The pricing is based on the

Code of Conduct on Transfer Pricing Documentation in

the EU and OECD guidelines.

Inter-segment transactions, assets and liabilities are

eliminated in the consolidated financial statements.

Income and expense recognition

principles related to insurance

contracts

The insurance service result, comprising of insurance

revenue, insurance service expenses, and reinsurance

result, reflects the result relating to underwriting and

servicing insurance policies. The net financial result

reflects the impacts arising from financial components

of insurance contracts.

Insurance revenue

Insurance revenue reflects the compensation that

Sampo receives from the policyholder in return for the

transfer of risk (insurance contract services) on an

earned basis. The insurance revenue recognised in the

reporting period is based on premium receipts and

expected premium receipts, allocated linearly over the

underlying terms of the insurance contracts, i.e. based

on the passage of time. The liability for remaining

coverage is reduced with a corresponding amount as

the insurance revenue.

Insurance service expenses

The insurance service expenses comprise of both claims

incurred and operating expenses.

Claims incurred for the reporting period include claims

payments during the period and changes in the liability

for incurred claims. The change in liability for the

incurred claims includes the changes in undiscounted

best estimate, discounted risk adjustment, and the

changes in discounting effect due to changes in

underlying best estimate or changes in payment

patterns. The claims incurred also include claims

handling expenses and changes in the loss component.

Operating expenses reported in the insurance service

result relate to administrative expenses arising from the

handling of insurance contracts. Additionally, the

operating expenses include the acquisition cash flows

recognised in profit or loss, where the liability for

remaining coverage changes with a corresponding

amount.

Reinsurance result

Reinsurance result comprises both reinsurance premium

expenses and reinsurer’s share of claims incurred.

Reinsurance premium expenses related to reinsurance

contracts held are recognised similarly to insurance

revenue and reflect the premium payments attributable

to the reporting period for the reinsurance contract

services received. Any commissions received reduce

the reinsurance premium expenses. The reinsurers’

share of claims incurred is reported consistently with

direct insurance expenses, including changes in the risk

of non-performance.

Insurance finance income or expense

The insurance finance income or expenses included in

the net financial result reflect the impacts arising from

financial components. These include changes in the

liability for incurred claims related to changes in

discount rates and time value of money (unwinding).

Therefore, the effect from changes in interest rates, as

well as interest expense, is presented in its entirety as

insurance finance income or expenses. The effect of

changes in indexation of annuities is also presented

within insurance finance income or expenses. Amounts

related to reinsurance contracts are presented

separately. The option to present changes in

discounting effect in other comprehensive income is not

applied.

The change in discounting effect relating to risk

adjustment is allocated between the insurance service

expenses and insurance finance income and expense.

Net investment income

Interest and dividends

Interest income and expenses are recognised in the

income statement using the effective interest rate

method. This method recognises income and expenses

on the instrument evenly in proportion to the amount

outstanding over the period to maturity. Dividends on

equity securities are recognised as revenue when the

right to receive payment is established.

Fees and commissions

The fees and transaction costs of financial instruments

measured at fair value through profit or loss are

recognised in profit or loss when the instrument is

initially recognised.


	FINANCIAL STATEMENTS 2025	147

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Revenue from contracts with

customers

Other income consists of income from insurance-related

services provided, that do not involve a transfer of

significant insurance risk, and are therefore accounted

for under IFRS 15 Revenue from contracts with

customers. Such income is primarily attributable to sales

commission and services for administration, claims

settlement, etc. in insurance contracts on behalf of

other parties.

Furthermore, If Group’s subsidiary Viking Assistance

Group AS provides roadside assistance. Income from

these services is recognised when roadside assistance

has been provided.

The subsidiary Hastings has revenue from broker

activities in accordance with IFRS 15 Revenue from

Contracts with Customers. The revenue consists

principally of fees and commissions relating to the

arrangement of third-party underwritten insurance

contracts and ancillary products.

Revenue from insurance brokerage activities is

recognised at the point of sale to the customer, and

revenue from other retail services is recognised when

the service has been completed. Revenue arising from

insurance broking activities is measured on an agency

basis, net of cost, at the fair value of the income

receivable after adjusting for any allowance for

expected future cancellation refunds. Hastings may also

provide contracts for the provision of other ad hoc,

point-in-time services to customers. Such income is

recognised when the performance obligation has been

satisfied at the expected value of consideration.

In the consolidated financial statements, the fees and

commissions from external broker activities are

included in Other income or Other expenses.

Hastings’ has also revenue from lending business in

accordance with IFRS 15 Revenue from Contracts with

Customers. Other income comprises of loan referral

commission (earned from referring customers to third-

party loan providers), servicer fees and interest earned

on cash in hand. Performance obligation related to

referral commission is to offer the referral service to

customers. For servicer fees the performance obligation

is to collect payments in respect of receivables

transferred into the securisation arrangement and

provide other administrative services. Performance

obligations are satisfied at a point in time.

Financial assets and liabilities

Initial recognition and derecognition

Financial assets and liabilities are measured at the initial

recognition at fair value. If the acquired financial assets

and liabilities are not measured at fair value, transaction

costs directly attributable to acquisition or issue are

added or deducted respectively.

Purchases and sales of financial assets at fair value

through profit or loss are recognised and derecognised

on the trade date, which is the date on which the Group

commits to purchase or sell the asset. Loans and other

receivables are recognised when cash is advanced.

Financial assets and liabilities are offset, and the net

amount is presented in the balance sheet only when the

Group has a legally enforceable right to set off the

recognised amounts, and it intends to settle on a net

basis, or to realise the asset and settle the liability

simultaneously.

Financial assets are derecognised when the contractual

rights to receive cash flows have expired or the Group

has substantially transferred all the risks and rewards of

ownership. Financial liabilities are derecognised when

the obligation specified in the contract is discharged,

cancelled or expired.

Classification and measurement principles of

financial assets

Financial assets are classified as being subsequently

measured either at amortised cost, at fair value through

other comprehensive income (FVOCI), or at fair value

through profit or loss (FVPL). The majority of Sampo

Group’s financial assets are classified at fair value

through profit or loss, and only a limited amount of

financial assets is measured at amortised cost. No

financial assets are classified as FVOCI.

The classification of financial assets into these

measurement categories is based on Sampo Group’s

business model for managing the financial assets and

the contractual cash flow characteristics of the financial

assets. The Group’s business model reflects how the

portfolios of financial assets are managed to achieve

business objectives and to generate cash flows. The

factors considered in determining the portfolio’s

business model include how the financial assets’

performance is evaluated and reported to management,

how risks are assessed and managed, past experience

of how the cash flows have been collected, and how

compensation is linked to performance.

Financial assets at fair value through profit

or loss

Financial assets classified as at fair value through profit

or loss include mainly investments in equity instruments

and funds, debt instruments, and other loans.

Equity instruments are classified and measured at fair

value through profit or loss.

Debt instruments, such as bonds and other interest-

bearing securities, are classified as measured at fair


	FINANCIAL STATEMENTS 2025	148

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

value through profit or loss when the business model

reflects the assets being managed and evaluated on a

fair value basis. The instruments are initially recognised

and subsequently measured at fair value. Transaction

costs that are directly attributable to the issue or

acquisition of the assets are expensed in profit or loss.

Gains and losses arising from changes in fair value, or

realised on disposal, together with related interest

income and dividend, are recognised in the income

statement under net investment income.

Derivative instruments that are not designated as

hedges and do not meet the requirements for hedge

accounting are classified as financial assets at fair value

through profit or loss. Derivatives are initially

recognised at fair value. Derivative instruments are

carried as assets when the fair value is positive and as

liabilities when the fair value is negative. Derivative

instruments are recognised at fair value, and gains and

losses arising from changes in fair value, together with

realised gains and losses, are recognised in the income

statement under net investment income.

Financial assets measured at amortised cost

A financial asset is measured at amortised cost only if

the objective of the business model is to hold a financial

asset in order to collect contractual cash flows, and the

contractual cash flows of the financial asset meet the

SPPI criteria (solely payments of principal and interest -

criteria, SPPI), i.e. it is consistent with the basic lending

arrangement. SPPI criteria is met when the financial

instrument’s contractual cash flows are solely payments

of principal and interest on the principal amount

outstanding. Financial assets measured at amortised

cost comprise mainly debt instruments, loans, and

receivables.

Financial assets measured at amortised costs are

initially recognised at their fair value, including

transaction costs directly attributable to the acquisition

of the asset. Loans and other receivables are

subsequently measured at amortised cost using the

effective interest rate method.

Interest revenue is calculated using the effective

interest rate method. Under IFRS 9, financial assets

subsequently measured at amortised cost are subject to

loss allowance, that is, expected credit losses (ECL)

requirements.

Financial liabilities

Financial liabilities, including subordinated debt

securities, debt securities in issue, and other financial

liabilities, are subsequently measured at amortised cost

using the effective interest rate method. Interest

expenses and gains or losses on derecognition are

recognised in the income statement.

Derivative financial liabilities are measured at fair value

through profit or loss.

If debt securities issued are redeemed before maturity,

they are derecognised and the difference between the

carrying amount and the consideration paid at

redemption is recognised in profit or loss.

Fair value

The fair value of financial instruments is determined

primarily by using quoted prices in active markets.

Instruments are measured either at a bid price or at the

last trade price, if there is an auction policy in the stock

market of the price source. An exception are the

syndicated loans, which are measured at a mid-price

because of the lower liquidity. The financial derivatives

are also measured at the last trade price. If the financial

instrument has a counter-item that will offset its market

risk, the same price source is used in assets and

liabilities to that extent. If a published price quotation

does not exist for a financial instrument in its entirety,

but active markets exist for its component parts, the fair

value is determined based on the relevant market prices

of the component parts.

Fair values of financial assets are based on either

published price quotations or valuation techniques

based on market observable inputs, where available. If

these are not available, the fair value is established by

using generally accepted valuation techniques,

including recent arm’s length market transactions

between knowledgeable, willing parties, reference to

the current fair value of another instrument that is

substantially the same, discounted cash flow analysis,

and option pricing models. For a limited amount of

assets, the value needs to be determined using these

other techniques.

The carrying amount of cash and cash equivalents, as

well as settlement receivables included in other assets is

used as an approximation of fair value.

The fair value of loans and other financial instruments

which have no quoted price in active markets is based

on discounted cash flows, using quoted market rates.

The market’s yield curve is adjusted by other

components of the instrument, e.g. by credit risk.

The financial instruments measured at fair value have

been classified into three hierarchy levels in the notes,

depending on, e.g. if the market for the instrument is

active, or if the inputs used in the valuation technique

are observable. For further information on the

determination of fair value hierarchy, please see note 13.

Impairment of financial assets

Sampo assesses, at the end of each reporting period,

whether there is any objective evidence that a financial

asset, other than those at fair value through profit or

loss, may be impaired. A financial asset is impaired, and


	FINANCIAL STATEMENTS 2025	149

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

impairment losses are recognised based on the

estimated future cash flows of the financial asset if

there is objective evidence of impairment as a result of

one or more loss events that occurred after the initial

recognition of the asset, and if that event has an impact

that can be reliably estimated.

There is objective evidence of impairment if, for

example, an issuer or debtor encounters significant

financial difficulties that will lead to insolvency, and to

estimation that the customer will probably not be able

to meet the obligations to the Group. When there is

objective evidence of impairment of a financial asset

carried at amortised cost, the amount of the loss is

measured as the difference between the receivable’s

carrying amount and the present value of estimated

future cash flows discounted at the receivable’s original

effective interest rate. The difference is recognised as

an impairment loss in profit or loss. In Sampo Group, the

impairment is assessed individually for each asset.

Financial assets measured at amortised cost

In accordance with IFRS 9, Sampo applies a forward-

looking ECL model, which in Sampo Group is mainly

applicable to financial assets measured at amortised

cost. Impairment requirements do not apply to equity

instruments or other financial instruments measured at

FVPL. Expected credit losses reflect past events, i.e.

historical loss experience, current conditions, and

forecasts of future economic conditions.

Sampo applies a general approach for impairment in

which a loss allowance is calculated either for 12-month

expected credit losses or a lifetime expected credit

losses. A three-staged model is used to determine the

ECL at each reporting date. In stage 1, the credit risk has

not increased significantly. Loss allowance is measured

at an amount equal to 12-month expected credit losses.

In stages 2 and 3, the credit risk has increased

significantly since initial recognition and the loss

allowance is measured at an amount equal to the

lifetime expected credit losses. In stage 3, the financial

asset is assessed to be credit-impaired (at default), and

the interest is calculated on the credit-impaired amount

instead of gross carrying amount.

In Sampo Group, the general approach is based on

three components, namely probability of default (PD),

loss given default (LGD), and exposure at default

(EAD).

Derivative financial instruments

and hedge accounting

Derivative financial instruments are classified as those

held for trading and those held for hedging, including

interest rate derivatives, credit risk derivatives, foreign

exchange derivatives, equity derivatives and

commodity derivatives. Derivative instruments are

measured initially at fair value. All derivatives are carried

as assets when fair value is positive, and as liabilities

when fair value is negative.

Derivatives held for trading

Derivative instruments that are not designated as

hedges are treated as held for trading. They are

measured at fair value and the change in fair value,

together with both realised gains and losses and

interest income and expenses, is recognised in profit or

loss.

Hedge accounting

Sampo Group may hedge its operations against interest

rate risks, currency risks, and price risks through fair

value hedging and cash flow hedging. Cash flow

hedging is used as a protection against the variability of

the future cash flows. During the financial year, cash

flow hedging has been applied in Hastings.

Hedge accounting applies to hedges that are effective

in relation to the hedged risk and meet the hedge

accounting requirements of IFRS 9. The hedging

relationship between the hedging instrument and the

hedged item, as well as the risk management objective

and strategy for undertaking the hedge, are

documented at the inception of the hedge.

Cash flow hedging

Cash flow hedging is used to hedge the interest cash

flows of individual floating rate debt securities or other

floating rate assets or liabilities. The hedging

instruments used include currency forward contracts.

Derivative instruments which are designated as hedges

and are effective as such, are measured at fair value.

The effective part of the change in fair value is

recognised in other comprehensive income.

The cumulative change in fair value is transferred from

equity and recognised in profit or loss in the same

period that the hedged cash flows affect profit or loss.

When a hedging instrument expires, is sold, terminated,

or the hedge no longer meets the criteria for hedge

accounting, the cumulative change in fair value remains

in equity until the hedged cash flows affect profit or

loss.

Leases

Group as lessee

All lease contracts are primarily recognised in the

balance sheet in accordance with IFRS 16 Leases. The

only optional exemptions include certain short-term

contracts with a duration under 12 months or low-value

contracts, for which the lease payments can be

recognised as an expense on a straight-line basis over

the lease term.


	FINANCIAL STATEMENTS 2025	150

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

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

The useful life of acquired trademarks is determined

individually per asset. The expected useful life for

trademarks that are amortised is 10 years and

amortisation starts from the time of acquisition on a

straight-line basis during the useful life. Intangible assets

with an indefinite useful life 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.


	FINANCIAL STATEMENTS 2025	151

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 32.

Scope

In the Group’s 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, insurance contract 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, 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

also available for contracts where the PAA would not


	FINANCIAL STATEMENTS 2025	152

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

materially differ from the results of the GMM. In Sampo

Group, 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 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 private business area has

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 has determined the discount rates based

on a bottom-up approach. The interest rate curve

includes a risk-free rate and an illiquidity premium for

each currency. The illiquidity premium is mainly derived

based on spread between benchmark bond yield curve

and swap curve 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

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.


	FINANCIAL STATEMENTS 2025	153

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

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 five valid share-

based incentive schemes settled in cash (the long-term

incentive schemes 2020 I, 2020 II, 2020 III, 2024 and

2025 for the management and key employees).

Topdanmark’s former management had a share-based

incentive scheme that was converted to a phantom

equity plan in 2024. Hastings had two share-based

incentive schemes during the financial year. More

information on the different incentive 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.


	FINANCIAL STATEMENTS 2025	154

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

Liability for the share buyback

programme

Sampo recognised a financial liability against equity

representing Sampo’s commitment under the share

buyback agreement with a financial institution

responsible for share repurchases on Sampo’s behalf.

At the time of recognition, the liability was measured

corresponding to the expected amount of the buyback

programme. At the reporting date, the liability was

measured at the amount that represents the

outstanding share of the share buyback programme.

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.

Sampo Group companies have applied a 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.

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

When a share buyback is initiated, Sampo recognises

the total amount of the buyback upfront as a financial

liability against 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.

Restricted Tier 1 instrument

Accounting treatment of restricted Tier 1 (RT1)

instrument depends on the substance of the contractual

arrangement. The restricted Tier 1 instrument is

accounted as equity as the notes are unsecured and

subordinated, as well as perpetual with no fixed

maturity date. Payment of interest and principal is at

the discretion of Sampo. Therefore, the restricted Tier 1

notes qualify as equity instruments pursuant to IAS 32.


	FINANCIAL STATEMENTS 2025	155

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Transaction costs related to the issue of the notes are

directly recognised in retained earnings. Interest

expense is also recognised as a reduction in retained

earnings.

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 2025	156

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 85 per cent.

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.

During 2025, Sampo reorganised its reporting segments

in accordance with IFRS 8 in a way that changed the

composition of cash generating units (CGUs).

Management assessed that the split of goodwill based

on the actual units or entities, in which the goodwill is

associated with, and in which it is internally monitored,

represents appropriate method for allocation.

Acquisition of Topdanmark’s non-

controlling interest

In 2024, Sampo acquired the remaining non-controlling

shares in Topdanmark. 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

NCI and the owners of the parent.

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


	FINANCIAL STATEMENTS 2025	157

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

level. 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 were under

the 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.

Provisions

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 were

recognised related to the reserve.

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.

The provision contains judgements mainly around the

size of the restructuring costs and the existence of any

additional expenses. The judgements are amongst other

things based on internal information from the financial

planning process.

Tax reserve

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.

Management considers that the most likely outcome

will be that no further tax liability will be due. However,

given the subjective nature of the transfer pricing, there

remains a possibility that a potential liability could

become payable. Therefore, Hastings has recognised a

provision for tax liability based on a probability analysis

of a range of potential outcomes. Any final amount may

differ from the amount provided depending on the

ultimate resolution of such matters.

Application of new or revised IFRS

Accounting Standards in issue but

not yet effective

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. (An amendment marked with * have not

yet been adopted by the EU)

• Amendments to IFRS 9 and IFRS 7 Classification and

measurement of financial instruments (effective 1 Jan

2026)

• Amendments to IFRS 9 and IFRS 7 Contracts

Referencing Nature-dependent Electricity (effective 1

Jan 2026)

• Annual Improvements to IFRS Accounting Standards

– Volume 11 (effective 1 Jan 2026)

• IFRS 18 Presentation and Disclosures in Financial

Statements* (effective 1 Jan 2027)

• IFRS 19 Subsidiaries without Public Accountability:

Disclosures* (effective 1 Jan 2027)

• Amendments to IAS 21 Translation to a

Hyperinflationary Presentation Currency (effective 1

Jan 2027)

The new IFRSs coming into effect in the financial year

2026, will not have any significant influence on the

Group's financial reporting.

IFRS 18 Presentation and Disclosures in

Financial Statements

IFRS 18 Presentation and Disclosure in Financial

Statements was published in April 2024, and will take

effect on 1 January 2027. The standard has not yet been

adopted by the EU.


	FINANCIAL STATEMENTS 2025	158

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

IFRS 18 replaces IAS 1 Presentation of Financial

Statements carrying forward many of the requirements

in IAS 1 unchanged and complementing them with new

requirements. In addition, some IAS 1 paragraphs have

been moved to IAS 8 and IFRS 7. Furthermore, the IASB

has made minor amendments to IAS 7 and IAS 33

Earnings per Share.

IFRS 18 introduces new requirements to, among others:

• present specified categories and defined subtotals in

the statement of profit or loss

• provide disclosures on management-defined

performance measures (MPMs) in the notes to the

financial statements

• improve aggregation and disaggregation.

The amendments to IAS 7 and IAS 33, as well as the

revised IAS 8 and IFRS 7, become effective when an

entity applies IFRS 18. IFRS 18 requires retrospective

application with specific transition provisions.

Sampo has started to analyse the effect of the new

standard and follows the development of how the

standard will be incorporated into Finnish and European

law. Management estimates that the application of IFRS

18 will have an impact on the Group's consolidated

financial statements in future periods.


	FINANCIAL STATEMENTS 2025	159

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Segment information

In February 2025, Sampo introduced new reporting

segments to reflect its transformation into a fully-

integrated P&C insurance group following the

acquisition of the non-controlling interests in

Topdanmark in 2024.

Sampo reports its financial performance based on the

Group’s operational business areas that are regularly

reviewed by a chief operating decision-maker.

Segments’ customer bases, risks, and performance

measures differ from each other. The control and

management of business and management reporting

are organised in accordance with the business

segments. The new segments are Private Nordic,

Private UK, Nordic Commercial, and Nordic Industrial:

• Private Nordic includes the Group’s Nordic private

customer business, previously reported under the If

and Topdanmark segments in Sampo’s accounts.

Sampo operates in the Nordic private insurance

market through its main brand, If, and other brands

including Topdanmark and various white-label

partnerships.

• Private UK includes the Group’s UK business,

previously reported as Hastings in Sampo’s accounts.

Sampo operates in the UK private insurance market

through its customer brand Hastings, which is one of

the leading digital P&C insurance providers focused

on serving UK car, van, bike, and home insurance.

• Nordic Commercial includes the Group’s Nordic

commercial customer businesses, previously reported

under the If and Topdanmark segments in Sampo’s

accounts, as well as Oona Health. The segment

focuses particularly on SMEs.

• Nordic Industrial includes the Group’s Nordic

Industrial customer business, previously reported

under the If segment in Sampo’s accounts.

Corporates with revenues of more than SEK 500

million (approx. EUR 45 million), or more than 500

employees, are classified as Industrial customers.

In addition to these four reporting segments, Sampo

presents other operations, consisting mainly of the

Group’s Baltic business but also of group eliminations

and other internal items. Other operations are not

considered a separate reporting segment as they do

not fulfil the criteria for reporting segments under

IFRS 8.

The chief operating decision-maker (CODM) is

considered to be Sampo Group’s Executive Committee

(GEC).


	FINANCIAL STATEMENTS 2025	160

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Result by segment for twelve months ended 31 December 2025

In each reporting segment, Sampo reports the key profit or loss figures from

insurance revenue to the underwriting result. These key profit or loss figures are

reported regularly to the chief operating decision-maker to assess the reporting

segments performance. Items below the underwriting result, such as net

investment income and insurance finance income or expense, are reported at the

group level.


EURm	Private Nordic	Private UK	Nordic Commercial	Nordic Industrial	Other operations	Sampo Group
Insurance revenue, net (incl. brokerage)	3,995	2,000	2,201	584	298	9,078
Claims incurred, net	-2,431	-1,073	-1,285	-341	-161	-5,290
Operating expenses (incl. claims handling costs)	-849	-712	-539	-134	-68	-2,302
Underwriting result	715	216	376	109	69	1,485

Net investment income						1,285
Net insurance finance income or expense						-74
Net financial result						1,210

Other income or expense						-48
Non-operational amortisations						-128
Finance expenses						-83

Profit before taxes						2,436

Underwriting result has been defined in the section Calculation of key figures.


	FINANCIAL STATEMENTS 2025	161

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Result by segment for twelve months ended 31 December 2024


EURm	Private Nordic	Private UK	Nordic Commercial	Nordic Industrial	Other operations	Sampo Group
Insurance revenue, net (incl. brokerage)	3,667	1,659	2,128	657	275	8,386
Claims incurred, net	-2,226	-868	-1,254	-455	-146	-4,948
Operating expenses (incl. claims handling costs)	-814	-601	-522	-128	-57	-2,122
Underwriting result	628	190	352	74	72	1,316

Net investment income						888
Net insurance finance income or expense						-252
Net financial result						636

Other income or expense						-210
Non-operational amortisations						-79
Finance expenses						-103

Profit before taxes						1,559

Comparative figures have been restated based on the new segments.


	FINANCIAL STATEMENTS 2025	162

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Segment reconciliation

The following tables present reconciliations from the segment reporting’s numbers to

Sampo Group’s reported numbers.

Insurance revenue, gross


EURm	1-12/2025	1-12/2024
Insurance revenue, net (incl. brokerage)
Private Nordic	3,995	3,667
Private UK	2,000	1,659
Nordic Commercial	2,201	2,128
Nordic Industrial	584	657
Reporting segments' total of insurance revenue, net	8,780	8,111

Intra-segment eliminations on insurance operations	-50	-24
Intra-segment eliminations on reinsurance operations	50	23
Other operations	298	275
Sampo Group insurance revenue, net	9,078	8,386

Reinsurance operations and investment component	1,347	1,201
Other items	-153	-138
Sampo Group insurance revenue, gross	10,272	9,450

Insurance service result


EURm	1-12/2025	1-12/2024
Underwriting result
Private Nordic	715	628
Private UK	216	190
Nordic Commercial	376	352
Nordic Industrial	109	74
Reporting segments' total of underwriting result	1,416	1,244

Intra-segment eliminations	0	3
Other operations	69	69
Sampo Group's underwriting result	1,485	1,316

Other items	106	78
Sampo Group insurance service result	1,590	1,394


	FINANCIAL STATEMENTS 2025	163

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Balance sheet by segment at 31 December 2025

In each reporting segment, Sampo reports the key balance sheet figures related to

the segment’s insurance operations. These key balance sheet figures are reported

regularly to the chief operating decision-maker for the assessment of segment

operations. Other balance sheet items are not allocated between the segments

when reporting to the chief operating decision maker, instead they are followed

only on the group level.


EURm	Private Nordic	Private UK	Nordic Commercial	Nordic Industrial	Other operations	Sampo Group
Reinsurance contract assets
Reinsurers' share of remaining coverage	-1	334	-8	17	-10	332
Reinsurers' share of claims incurred	48	1,609	260	297	-59	2,156
Reinsurance contract assets, total	47	1,943	252	314	-69	2,488

Insurance contract liabilities
Liability for remaining coverage	676	668	268	226	50	1,888
Liability for incurred claims	3,126	3,092	3,047	1,436	182	10,884
Acquisition cash flow assets	—	—	-9	-4	—	-12
Insurance contract liabilities, total	3,801	3,760	3,306	1,659	233	12,760

Balance sheet by segment at 31 December 2024


EURm	Private Nordic	Private UK	Nordic Commercial	Nordic Industrial	Other operations	Sampo Group
Reinsurance contract assets
Reinsurers' share of remaining coverage	—	270	-1	20	-14	276
Reinsurers' share of claims incurred	28	1,625	232	469	-12	2,342
Reinsurance contract assets, total	27	1,896	231	490	-26	2,618

Insurance contract liabilities
Liability for remaining coverage	639	713	266	231	48	1,896
Liability for incurred claims	2,888	2,683	3,028	1,634	176	10,409
Acquisition cash flow assets	—	—	-16	-4	—	-20
Insurance contract liabilities, total	3,527	3,396	3,278	1,861	224	12,286


	FINANCIAL STATEMENTS 2025	164

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Geographical information


EURm
2025	Finland	Sweden	Norway	Denmark	UK	Baltic	Total
Revenue from external customers	1,761	2,046	1,948	2,217	2,836	250	11,060
Non-current assets	123	455	181	1,574	1,461	4	3,798


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

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, and

income from broker activities. For Sampo plc, the revenue includes net investment

income and other operating income.

Non-current assets comprise of intangible assets, investments in associates, property,

plant and equipment, and investment property.


	FINANCIAL STATEMENTS 2025	165

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Other notes

1 Insurance service result


EURm	1-12/2025	1-12/2024

Insurance revenue
Insurance contracts measured under PAA
Gross written premiums	10,294	9,527
Change in liability for remaining coverage	-313	-343
Brokerage revenue	291	266
Total insurance revenue	10,272	9,450

Insurance service expenses
Expenses related to claims incurred
Claims paid and benefits	-5,820	-5,827
Claims handling expenses	-581	-518
Change in liability for incurred claims	-57	118
Change in risk adjustment	-150	-80
Change in loss component	-10	21
Insurance service expenses related to claims incurred	-6,618	-6,287

Operating expenses	-1,507	-1,396

Total insurance service expenses	-8,126	-7,684

Reinsurance result
Premiums	-1,003	-909
Claims recovered	448	537
Total reinsurance result	-556	-372

Total insurance service result	1,590	1,394


	FINANCIAL STATEMENTS 2025	166

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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	1-12/2025	1-12/2024
Derivative financial instruments
Interest income	3	4
Interest expense	-12	0
Net gains or losses	-30	13
Derivative financial instruments, total	-38	17

Financial assets at fair value through profit or loss
Debt securities
Interest income	496	493
Net gains or losses	41	147
Equity securities
Dividend income	28	37
Net gains or losses	652	81
Funds
Distributions	14	6
Interest income	10	10
Net gains or losses	83	70
Financial assets at fair value through profit or loss, total	1,325	844

Financial assets at amortised cost
Interest Income	17	39
Expected credit losses	-17	-7
Financial assets at amortised cost, total	0	32

Total income or expenses from financial assets	1,287	892


EURm	1-12/2025	1-12/2024

Other
Expenses from asset management	-33	-21
Other income	44	57
Other expenses	-8	-38
Fee expenses	-5	0
Expenses from investment property	0	-3
Total other	-2	-4

Total net investment income	1,285	888

Net gains or losses for debt securities include exchange differences of EUR -8 million (2).

More information on the expected credit losses on financial assets measured at

amortised cost is presented in note 12 .

The Swedish bank NOBA Group completed its initial public offering in late September

2025. Consequently, Sampo sold part of its holding in NOBA, resulting in a net sales

gain of EUR 58 million. The valuation gain of Sampo’s remaining investment in NOBA

amounted to EUR 487 million during the reporting period.


	FINANCIAL STATEMENTS 2025	167

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

3 Net finance income or expense from

insurance contracts


EURm	1-12/2025	1-12/2024

Insurance contracts
Unwinding of discount rates	-321	-324
Effect of changes in interest rates and other financial assumptions	141	15
Total finance income or expenses from insurance contracts	-180	-309

Reinsurance contracts
Unwinding of discount rates	81	86
Reinsurers' share of effect of changes in interest rates and other financial assumptions	25	-29
Total finance income or expenses from reinsurance contracts	106	57

Net finance result from insurance and reinsurance contracts	-74	-252

4 Other income


EURm	1-12/2025	1-12/2024

Other income	364	300
Income related to brokerage activities	5	12
Total other income	369	312

If’s other income includes approximately EUR 155 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 a total of EUR 159 million (134) 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	1-12/2025	1-12/2024

Other expenses	-337	-465
Depreciation and amortisation	-173	-120
Salaries and other staff costs	-141	-100
Total other expenses	-651	-685


	FINANCIAL STATEMENTS 2025	168

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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	1-12/2025	1-12/2024

Staff costs
Salaries and wages	-1,072	-967
Cash-settled share-based payments	-25	-22
Share-settled share-based payments	—	-7
Pension costs
Pension expenses - defined contribution plans	-104	-101
Pension expenses - defined benefit plans	-15	-9
Other social security costs	-211	-188
Depreciation and impairments on PP&E
Depreciation on plant and equipment	-18	-17
Depreciation IFRS 16	-31	-34
Impairment losses	-7	—
Write-offs	-20	—
Amortisation
Amortisation on customer relations	-94	-72
Amortisation on other intangibles	-60	-57
Write-offs	-8	—
Rental expenses	-30	-35
IT costs	-284	-243
Marketing expenses	-78	-75
Other	-692	-824
Total expenses split by nature	-2,750	-2,653

The main items in line Other include commissions of EUR 209 million (146), other

technical expenses of EUR 239 million (228), acquisition costs of EUR 145 million (125),

and levies EUR 59 million (47).

6 Auditor's fees


EUR thousand	1-12/2025	1-12/2024

Auditing fees
Deloitte	-4,055	-4,322
Sirius	-263	—
Other fees
Deloitte	-827	-712
Total	-5,145	-5,034

7 Finance expenses


EURm	1-12/2025	1-12/2024

Interest expense on financial liabilities	-20	-21
Interest expense on subordinated loans	-47	-52
Other items	-16	-30
Total finance expenses	-83	-103

During the financial year, Sampo launched a EUR 300 million tender offer for its Tier 2

notes. As a result, Sampo repurchased EUR 316 million in aggregate nominal value of

its Tier 2 notes due 2052 for EUR 295 million. This resulted in a positive one-off effect

of around EUR 20 million on finance expenses.


	FINANCIAL STATEMENTS 2025	169

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

8 Components of other comprehensive

income


EURm	1-12/2025	1-12/2024

Other comprehensive income

Items reclassifiable to profit or loss
Exchange differences	-91	-25
Exchange differences arising from net investment in foreign operation	78	21
Cashflow hedges	-2	1
Total items reclassifiable to profit or loss, net of tax	-16	-3

Items not reclassifiable to profit or loss
Actuarial gains and losses from defined pension plans	24	0
Taxes	-5	0
Total items not reclassifiable to profit or loss, net of tax	19	0

Other comprehensive income total, net of tax	3	-3

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 interests.

9 Earnings per share


EURm	1-12/2025	1-12/2024

Profit or loss attributable to the equity holders of the parent company	1,998	1,154
Weighted average number of shares outstanding during the financial year*	2,685	2,561
Earnings per share (EUR per share)	0.74	0.45
Earnings per share, continuing operations	0.74	0.45

* 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.

In February 2025, Sampo carried out a share split by way of a share issue without consideration.

The new shares were issued to shareholders in proportion to their existing holdings, so that four (4)

new shares were issued for each existing share. Non-adjusted and reported earnings per share for

the comparison period was EUR 2.25.


	FINANCIAL STATEMENTS 2025	170

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

10 Property, plant and equipment


	2025
EURm	Right-of- use assets¹	Land and buildings	Plant and equipment²	Total

At 1 January
Cost	294	108	197	599
Accumulated depreciation	-160	-9	-147	-315
Net carrying amount at 1 January	134	100	51	284

Carrying amount at 1 January
Additions	43	19	29	91
Write-offs	0	-19	-2	-21
Depreciation	-31	0	-18	-49
Impairment losses	—	-7	—	-7
Exchange differences	2	—	1	3
Carrying amount at 31 December	148	92	61	301

At 31 December
Cost	339	108	225	672
Accumulated depreciation	-191	-9	-164	-364
Accumulated impairment losses	—	-7	—	-7
Net carrying amount at 31 December	148	92	61	301


	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

1The 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.

2Equipment in different segments comprise IT equipment and furniture.


	FINANCIAL STATEMENTS 2025	171

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

11 Intangible assets


	2025
EURm	Goodwill	Customer relations	Trademark	Work in progress	Other intangible assets	Total


At 1 January
Cost	2,490	719	234	151	777	4,371
Accumulated amortisation	—	-354	—	-1	-378	-733
Accumulated impairment losses	—	—	—	-2	—	-2
Net carrying amount at 1 January	2,490	365	233	149	399	3,637

Net carrying amount at 1 January
Additions	—	—	—	64	56	120
Write-offs	—	—	—	—	-10	-10
Amortisation	—	-94	-1	—	-60	-155
Transfers from WIP	—	—	—	-51	5	-46
Other changes	—	-10	6	1	3	0
Exchange differences	-22	-6	-9	-1	-16	-54
Net carrying amount at 31 December	2,468	254	230	161	377	3,492

At 31 December
Cost	2,468	703	231	164	815	4,381
Accumulated amortisation	—	-448	-1	-1	-438	-888
Accumulated impairment losses	—	—	—	-2	—	-2
Net carrying amount at 31 December	2,468	254	230	161	377	3,492


	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

The useful life for customer relations in the Group is 3–10 years. They are amortised using the

straight-line method.


	FINANCIAL STATEMENTS 2025	172

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Testing goodwill for impairment

Goodwill is tested annually for impairment in accordance with IAS 36 Impairment of

assets. The performed impairments tests at the end of the financial year 2025 do not

indicate a need to recognise an impairment loss.

During 2025, Sampo reorganised its reporting segments in accordance with IFRS 8 in a

way that changed the composition of cash generating units (CGUs) to which goodwill

has been allocated previously. These cash-generating units are reporting segments

Private Nordic, Private UK, Nordic Commercial and Nordic Industrial. In addition, Other

operations, even if not a reporting segment under IFRS 8, carries a small amount of

goodwill and is therefore also subject to testing. For more information on the change

in the reporting structure, please see note Segment information.

As a result of the segment changes, Sampo has reallocated goodwill to the new CGUs.

The reallocation is based on the actual units or entities in which goodwill is associated

with, and in which it is monitored for internal purposes. When relevant, insurance

service revenue is applied as an allocation key.

The allocation of goodwill is presented in the table below:


EUR million	2025	EUR million	2024
Private Nordic	700	If	537
Private UK	872	Topdanmark	1,036
Nordic Commercial	778	Hastings	918
Nordic Industrial	42
Other operations	76
Total	2,468	Total	2,490

For the purpose of testing the goodwill for impairment, Sampo determines the

recoverable amount of its cash-generating units (CGUs), to which goodwill has been

allocated, on the basis of value in use. The recoverable amounts for cash-generating

units 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 capital which for

Private Nordic is 9.5 per cent, Private UK 11.6 per cent, Nordic Commercial 9.7 per cent

and Nordic Industrial 9.5 per cent. The cost of capital is defined based on the CAPM

model from external sources to reflect the risk of each segment relative to the market.

Financial plans for segments, approved by the management and the Boards, cover the

years 2026–2028. The cash flows beyond that have been extrapolated using a 2 per

cent growth rate.

For Private UK, the recoverable amount exceeds its carrying amount by some EUR 530

million. With the calculation method used, e.g. an increase of about 1.7 percentage

points in the cost of capital could lead to a situation where the recoverable amount of

the entity would equal its carrying amount.

As for the rest of the segments, the management believes that any reasonably possible

change in any of the key assumptions would not cause carrying amount to exceed the

recoverable amount.


	FINANCIAL STATEMENTS 2025	173

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sensitivity analysis


Impact on the present value from the following changes (EURbn)	2025
Private Nordic
Long-term Combined ratio +2.5 p.p.	-1.3
Long-term Combined ratio -2.5 p.p.	1.3
Long-term growth rate -1 p.p.	-1.4
Long-term growth rate +1 p.p.	2.0
Cost of capital +1 p.p.	-1.7
Cost of capital -1 p.p.	2.5

Private UK
Long-term growth rate -1 p.p.	-0.2
Long-term growth rate +1 p.p.	0.2
Cost of capital +1 p.p.	-0.4
Cost of capital -1 p.p.	0.5

Nordic Commercial
Long-term Combined ratio +2.5 p.p.	-0.7
Long-term Combined ratio -2.5 p.p.	0.7
Long-term growth rate -1 p.p.	-0.7
Long-term growth rate +1 p.p.	1.0
Cost of capital +1 p.p.	-0.9
Cost of capital -1 p.p.	1.3

Nordic Industrial
Long-term Combined ratio +2.5 p.p.	-0.2
Long-term Combined ratio -2.5 p.p.	0.2
Long-term growth rate -1 p.p.	-0.2
Long-term growth rate +1 p.p.	0.3
Cost of capital +1 p.p.	-0.3
Cost of capital -1 p.p.	0.4


	FINANCIAL STATEMENTS 2025	174

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

12 Financial assets


EURm	12/2025	12/2024
Financial assets

Derivative financial instruments	24	26

Financial assets at fair value through profit or loss
Debt securities	13,867	13,325
Equity securities	1,650	1,288
Funds	982	823
Total financial assets at fair value through profit or loss	16,501	15,436

Financial assets measured at amortised cost
Loans	123	272
Loans and advances to customers	506	356
Total financial assets measured at amortised cost	629	629

Total financial assets	17,154	16,090

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 90 million (101 million).

NOBA Group completed its initial public offering in late September 2025, after which

the valuation of the equity investment is based on quoted prices in active markets (fair

value hierarchy level 1). At the end of the reporting period, Sampo’s remaining NOBA

stake was valued at EUR 814 million. Starting from the commencement of trading in

NOBA’s shares on Nasdaq Stockholm, Sampo has a 180 day lock up on further share

sales.

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 2025	175

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.


2025
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	116	8	—	124
Loans and advances to customers	488	26	29	543
Deposits	1	—	—	1
Loss allowance	-10	-7	-22	-39
Total	595	27	7	629


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

The gross carrying amounts of the financial assets measured at amortised cost was

EUR 668 million (EUR 651 million) and the loss allowance was EUR -39 million (EUR

-23 million). During the reporting period, the expected credit losses recognised in the

income statement was EUR -17 million and in the comparative period EUR -7 million.


	FINANCIAL STATEMENTS 2025	176

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Derivative financial instruments


		2025 Fair value			2024 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	121	2	54	456	2	49
Inflation cover	7	12	18	211	13	18
Total interest rate derivatives	128	14	72	667	15	68

Foreign exchange derivatives
OTC derivatives
Currency forwards	5,149	10	31	2,760	10	19
Currency options, bought and sold	6	0	—	24	1	0
Total foreign exchange derivatives	5,155	10	31	2,784	11	20

Total derivatives held for trading	5,284	23	102	3,451	26	87


		2025 Fair value			2024 Fair value
EURm	Contract/ Notional Amount	Assets	Liabilities	Contract/ Notional Amount	Assets	Liabilities
Derivatives held for hedging

Fair value hedges
Currency forwards	39	1	—	—	—	—
Total derivatives held for fair value hedging	39	1	—	—	—	—

Cash flow hedges
Currency forwards	15	0	—	5	0	—
Interest rate swaps	961	—	3	576	—	1
Total cash flow hedges	976	0	3	581	0	1

Total derivatives held for hedging	1,015	1	3	581	0	1

Group financial derivatives, total	6,298	24	105	4,032	26	88


	FINANCIAL STATEMENTS 2025	177

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

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 basis.

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 an investment to an

alternative fund.

For 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 2025	178

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


EURm
31 December 2025	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	10	—	10	—	10
Inflation cover derivatives	12	—	12	—	12
Total	24	—	24	—	24

Financial assets at fair value through profit or loss
Debt securities	13,867	7,767	6,094	6	13,867
Equity securities	1,650	1,643	1	6	1,650
Funds	982	612	243	127	982
Total	16,501	10,024	6,338	139	16,501

Total financial assets measured at fair value	16,525	10,024	6,362	139	16,525

Financial assets measured at amortised cost
Loans	123	—	90	33	123
Loans and advances to customers	506	—	—	506	506
Other	1	—	—	1	1
Total	629	—	90	540	629

Total financial assets	17,154	10,024	6,451	679	17,154


EURm
31 December 2025	Carrying amount	Level 1	Level 2	Level 3	Total

Financial liabilities at fair value

Derivative financial instruments
Interest derivatives	57	—	57	—	57
Foreign exchange derivatives	31	—	31	—	31
Inflation cover derivatives	18	—	18	—	18
Total financial liabilities at fair value	105	—	105	—	105

Financial liabilities measured at amortised cost

Subordinated debt securities
Subordinated loans	1,317	1,317	—	—	1,317

Debt securities in issue
Bonds	787	703	84	—	787
Amounts owed to credit institutions	460	—	—	460	460
Liability for the share buyback programme¹	60	—	—	60	60
Financial liabilities measured at amortised cost total	2,624	2,019	84	520	2,624

Group financial liabilities, total	2,730	2,019	190	521	2,730

¹The valuation of the liability for the share buyback programme reflects Sampo’s commitment

under the agreement with a third-party financial institution conducting the share buybacks on

behalf of Sampo.

NOBA Group completed its initial public offering in September 2025, after which the

valuation of the equity investment is based on quoted prices in active markets (fair value

hierarchy level 1). The investment was previously presented on fair value hierarchy level 3

as the investment was measured using other input than observable market data.


	FINANCIAL STATEMENTS 2025	179

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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
Deposits and other	0	—	0	—	0
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 2025	180

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Transfers between levels 1 and 2


EURm	1-12/2025		1-12/2024
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	438	302	192	181

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.


	12/2025	12/2024
EURm	Recognised in profit or loss	Recognised in profit or loss

If
10 percentage point depreciation of all other currencies against SEK	26	17

Hastings
10 percentage point depreciation of all other currencies against GBP	-1	8

Holding
10 percentage point depreciation of all other currencies against EUR	-71	-68

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 2025. 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	370	-356	-459	-61


	FINANCIAL STATEMENTS 2025	181

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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-classifications	Sales	Settlements	Transfers to levels 1 and 2	At 31 Dec 2025

Financial assets at fair value through profit or loss
Debt securities	17	1	—	-4	-9	—	6
Equity securities	432	-57	1	-25	—	-345	6
Funds	157	-33	3	—	—	—	127
Total	606	-89	4	-29	-9	-345	139

NOBA Bank was listed in Nasdaq Stockholm during the reporting year and consequently transferred to level 1 at the value of EUR 345 million.


EURm
Financial assets	At 1 Jan	Total gains/ losses in income statement	Purchases and re- classifications	Sales	Settlements	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 plc. The transaction price was EUR 302 million, representing the price agreed in the

demerger adjusted for dividends received.


	FINANCIAL STATEMENTS 2025	182

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sensitivity analysis of level 3 financial instruments

measured at fair value


	12/2025		12/2024
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	6	0	17	-1
Equity securities	6	-1	432	-86
Funds	127	-25	157	-31
Total	139	-26	606	-118

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 -0 million (-1) for the debt

instruments, and EUR -26 million (-118) 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 3.2 (1.7) per cent.


	FINANCIAL STATEMENTS 2025	183

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

15 Deferred tax assets and liabilities

Changes in deferred tax during the financial year 2025


EURm	At 1 January	Recognised in statement of profit and loss	Recognised in equity	Exchange differences	At 31 December

Deferred tax assets
Tax losses carried forward	1	0	—	0	1
Other deductible temporary differences	156	-14	24	0	166
Total	157	-14	24	1	167

Netting of deferred taxes					-165

Deferred tax assets in the balance sheet, total	157	-14	24	1	2

Deferred tax liabilities
Depreciation differences and untaxed reserves	196	-1	—	4	199
Changes in fair values	228	2	—	3	233
Pension assets	8	1	5	—	13
Other taxable temporary differences	259	-13	24	3	273
Total	690	-11	28	10	718

Netting of deferred taxes					-165

Deferred tax liabilities in the balance sheet, total	690	-11	28	10	553

The presentation of opening balances of deferred tax liability has been aligned as a result of the merger of Topdanmark A/S into If P&C Insurance Holding during the financial year.


	FINANCIAL STATEMENTS 2025	184

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Changes in deferred tax during the financial year 2024


EURm	At 1 January	Recognised in statement of profit and loss	Recognised in equity	Exchange differences	At 31 December

Deferred tax assets
Tax losses carried forward	1	—	—	0	1
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 2025	185

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Tax losses carried forward


EURm
Tax losses carried forward 2025	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 453	453	453	—	—	20.00%	91

If P&C Insurance Ltd (publ)	France	EURm 16	16	16	—	—	25.80%	-*
If P&C Insurance Ltd (publ)	UK	GBPm 10	12	12	—	—	25.00%	-*
Insrt AB	Sweden	—	—	—	—	—	20.60%	—
Viking Sverige AB	Sweden	SEKm 65	6	2	4	1	20.60%	—
Viking Assistance A/S	Denmark	DKKm 18	2	2	—	—	22.00%	1
Viking Membership AB	Sweden	—	—	—	—	—	20.60%	—
Viking Guard AS	Norway	NOKm 11	1	—	1	0	22.00%	—
Viking Assistance A/S	Estonia	EURm 0	0	0	—	—	20.00%	—

Hastings Group Finance plc	UK	GBPm 7	8	8	—	—	25.0%	2
Hastings Holdings Limited	UK	GBPm 1	1	1	—	—	25.0%	0

Total								94

* 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 2025	186

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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

no deferred tax asset can be recognised relating to the foreign branch.


	FINANCIAL STATEMENTS 2025	187

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

16 Taxes


EURm	2025	2024

Profit before tax	2,436	1,559

Tax calculated at parent company's tax rate	-487	-312
Different tax rates in foreign jurisdictions	1	3
Global minimum top-up tax	-5	-4
Income not subject to tax	116	9
Non-deductible expenses	-15	-17
Tax losses for which no deferred tax asset has been recognised	-24	-10
Changes in tax rates	-3	0
Tax from previous years	-21	1
Total	-439	-330

The effective tax rate was 18 per cent (21).

17 Other assets


EURm	12/2025	12/2024

Receivables arising from direct insurance operations	247	233
Receivables arising from reinsurance operations	131	174
Settlement receivables	13	8
Accrued interest	171	155
Net pension asset	66	36
Other	333	274
Total other asset	962	880

Item Other includes, e.g. assets related to patient insurance pool EUR 51 million (56),

collateral receivables EUR 62 million (3), as well as damaged goods and prepaid

expenses.

Other assets include non-current assets EUR 50 million (53).


	FINANCIAL STATEMENTS 2025	188

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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	12/2025	12/2024

Insurance contract liability - contracts measured under PAA
Liability for remaining coverage	1,888	1,896
Liability for incurred claims	10,884	10,409

Acquisition cash flow assets	-12	-20

Total insurance contract liabilities	12,760	12,286

Reinsurance contract assets
Assets for remaining coverage	332	276
Assets for incurred claims	2,156	2,342
Reinsurance contract assets, total	2,488	2,618

Total insurance contracts, net of reinsurance	10,272	9,668

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.


	2025					2024
Currency , %	1 year	5 years	10 years	20 years	30 years	1 year	5 years	10 years	20 years	30 years
DKK	2.43	2.83	3.21	3.56	3.59	2.23	2.13	2.26	2.25	2.38
EUR	2.37	2.77	3.15	3.50	3.54	2.44	2.34	2.47	2.46	2.55
GBP	3.86	4.23	4.88	5.61	5.86	4.70	4.58	4.92	5.41	5.69
NOK	4.34	4.28	4.36	4.19	3.99	4.82	4.52	4.45	4.23	4.01
SEK	2.40	2.90	3.30	3.36	3.34	2.91	3.07	3.29	3.35	3.33


	FINANCIAL STATEMENTS 2025	189

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 recognised in the statement of total

comprehensive income and cash flows. Information

regarding insurance contract liability is presented on

contracts measured under PAA model.

If and Hastings entered into an internal reinsurance

arrangement in 2024. Internal reinsurance arrangement

has been eliminated from the figures presented.

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 recognised in the statement of profit and other

comprehensive income and cash flows.

Change in presentation

In 2025, Sampo Group changed the level of

presentation for the reconciliation of insurance contract

liabilities and reinsurance contracts. Both reconciliations

are presented on Sampo Group level only. The

presentation of comparative information has been

aligned accordingly.


	FINANCIAL STATEMENTS 2025	190

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo Group - Insurance contract liabilities, gross at 31 December 2025 and 31 December 2024


	2025					2024
	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	1,891	6	9,853	557	12,305	1,701	27	9,547	459	11,734
Acquisition cash flow asset					-20					-18
					12,286					11,716
Changes in the statement of comprehensive income
Insurance revenue	-10,272	—	—	—	-10,272	-9,450	—	—	—	-9,450

Insurance service expenses
Incurred claims and other insurance service expenses	—	—	7,011	200	7,211	—	—	6,847	186	7,032
Amortisation of insurance acquisition cash flows	306	—	—	—	306	262	—	—	—	262
Changes that relate to past service (LIC)	—	—	-329	-50	-379	—	—	-174	-100	-274
Changes that relate to future service (LRC)	—	10	—	—	10	—	-21	—	—	-21
Total insurance service expenses	306	10	6,683	150	7,148	262	-21	6,673	85	7,000

Insurance service result	-9,966	10	6,683	150	-3,123	-9,188	-21	6,673	85	-2,450

Insurance finance income or expense	—	—	180	3	182	—	—	307	—	307
Other items (including FX effects)	-305	1	-1	-18	-323	-62	0	24	11	-27
Total changes in the statement of comprehensive income	-10,271	10	6,862	135	-3,264	-9,250	-21	7,004	97	-2,170

Cash flows during the period
Premiums received	10,573	—	—	—	10,573	9,718	—	—	—	9,718
Claims and other insurance service expenses paid	—	—	-6,530	—	-6,530	—	—	-6,703	—	-6,703
Insurance acquisition cash flows paid	-312	—	—	—	-312	-283	—	—	—	-283
Total cash flows during the period	10,261	—	-6,530	—	3,731	9,435	—	-6,703	—	2,732
Transfer to other items in the balance sheet	-9	—	8	—	0	—	—	—	—	—
Other	0	—	—	—	0	5	—	4	0	9

Closing balance - liabilities relating to insurance contracts	1,872	16	10,192	692	12,772	1,891	6	9,853	557	12,305
Acquisition cash flow asset					-12					-20
Closing balance					12,760					12,286


	FINANCIAL STATEMENTS 2025	191

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo Group - Reinsurance contracts at 31 December 2025 and 31 December 2024


	2025				2024
	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	276	2,090	252	2,618	258	1,803	220	2,282

Changes in the statement of comprehensive income
Allocation of reinsurance premiums paid	-1,003	—	—	-1,003	-909	—	—	-909

Amounts recoverable from reinsurers
Recoveries of incurred claims and other insurance service expenses	—	586	89	675	—	521	79	600
Adjustments to assets for incurred claims	0	-187	39	-148	0	21	-52	-31
Effect of changes in non-performance risk of reinsurers	—	0	—	0	—	0	—	0
Net expenses from reinsurance contracts	-1,003	398	128	-477	-909	542	28	-340
Insurance finance income or expenses from reinsurance contracts	—	107	1	108	—	57	—	57
Effect of movements in exchange rates	17	-221	-28	-232	-33	29	4	-1
Reinsurance investment component	—	—	—	—	—	—	—	—
Total changes in the statement of comprehensive income	-986	285	101	-601	-943	628	31	-284
Investment component excluded from the net expenses from reinsurance contracts	-178	178	—	—	-216	216	—	—
Cash flows
Premiums paid	1,220	—	—	1,220	1,176	—	—	1,176
Amounts received	—	-730	—	-730	—	-556	—	-556
Total cash flows	1,220	-730	—	490	1,176	-556	—	620
Other changes	—	-20	—	-20	—	—	—	—
Closing assets	332	1,803	352	2,488	276	2,090	252	2,618


	FINANCIAL STATEMENTS 2025	192

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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	2025	2024
Reconciliation of acquisition cash flow asset
At 1 January	20	18
Cash flows recognised as an asset	1	32
Amounts transferred to liability for remaining coverage	-8	-30
At 31 December	12	20

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


2025	Expected timing of derecognition
EURm	2026	2027-2028	2029-2030	2031-	Total
Acquisition cash flow asset	3	4	1	4	12


2024	Expected timing of derecognition				Total
EURm	2025	2026-2027	2028-2029	2030-
Acquisition cash flow asset	7	6	1	5	20

21 Non-life claims development

Prior-year estimates of the claims expense for individual claims years also represent a

measure of Sampo Group’s ability to foresee final claims expenses. The following

tables present the expense trend for the claims for individual claims, before and after

reinsurance. For earlier years, the information is aggregated into one row. After the

introduction of a new reporting segment structure in 2025, the non-life claims

development is now reported solely on the group level. This approach is aligned with

information presented in the risk management note 32.

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 32.

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

2025. 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 2025	193

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo Group - Claims development before reinsurance


EURm
Claims expense, gross Accident year	2016	2017	2018	2019	2020	2021	2022	2023	2024	2025	Total
Estimated claims expense
at the close of the claims year	4,021	4,145	4,381	4,625	4,704	4,892	5,362	6,311	6,485	6,806
one year later	4,085	4,147	4,476	4,647	4,659	4,999	5,417	6,428	6,410
two years later	4,050	4,147	4,518	4,702	4,659	4,917	5,363	6,459
three years later	4,025	4,148	4,560	4,691	4,593	4,853	5,310
four years later	3,924	4,131	4,541	4,649	4,528	4,861
five years later	3,970	4,107	4,485	4,610	4,539
six years later	3,946	4,082	4,492	4,600
seven years later	3,931	4,101	4,481
eight years later	3,932	4,079
nine years later	3,924

Current estimate of total claims expense	3,924	4,079	4,481	4,600	4,539	4,861	5,310	6,459	6,410	6,806
Total disbursed	-3,706	-3,835	-4,186	-4,262	-4,126	-4,260	-4,498	-5,078	-4,588	-3,122
Liability (gross) reported in the balance sheet	218	244	295	338	412	601	812	1,380	1,822	3,684	9,806

Liability (gross) relating to prior years											2,924

Discounting effect, gross											-2,537
Liability for claims handling expenses and other items											751
Elimination											-60
Total liability for incurred claims											10,884


	FINANCIAL STATEMENTS 2025	194

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo Group - Claims development after reinsurance


EURm
Claims expense, net of reinsurance Accident year	2016	2017	2018	2019	2020	2021	2022	2023	2024	2025	Total
Estimated claims expense
at the close of the claims year	3,756	3,917	4,172	4,387	4,366	4,452	4,930	5,516	5,871	6,141
one year later	3,778	3,941	4,254	4,379	4,296	4,498	4,984	5,592	5,930
two years later	3,771	3,934	4,298	4,413	4,284	4,452	4,955	5,596
three years later	3,742	3,949	4,348	4,444	4,263	4,416	4,935
four years later	3,714	3,941	4,347	4,425	4,224	4,434
five years later	3,736	3,951	4,312	4,396	4,230
six years later	3,737	3,926	4,319	4,390
seven years later	3,706	3,914	4,308
eight years later	3,693	3,897
nine years later	3,691

Current estimate of total claims expense	3,691	3,897	4,308	4,390	4,230	4,434	4,935	5,596	5,930	6,141
Total disbursed	-3,537	-3,721	-4,050	-4,130	-3,922	-4,014	-4,370	-4,739	-4,632	-3,223
Liability (net) reported in the balance sheet	155	175	258	260	307	420	565	858	1,298	2,918	7,215

Liability (net) relating to prior years											2,729

Discounting effect, gross											-1,945
Liability for claims handling expenses											727
Risk of non-performance by reinsurer											2
Total liability for incurred claims											8,728


	FINANCIAL STATEMENTS 2025	195

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

22 Financial liabilities

Group


EURm	12/2025	12/2024

Subordinated debt liabilities
Subordinated loans	1,317	1,642
Total subordinated debt liabilities	1,317	1,642

Other financial liabilities

Derivative financial instruments	105	88

Financial liabilities measured at amortised cost
Debt securities in issue	787	954
Amounts owed to credit institutions	460	353
Liability for the share buyback programme	60	—
Total financial liabilities measured at amortised cost	1,308	1,307

Total other financial liabilities	1,413	1,395

Total financial liabilities	2,730	3,036

The financial liabilities, presented by entity, include subordinated debts, derivatives,

debt securities in issue, and other financial liabilities.


EURm			12/2025	12/2024

Subordinated debt securities
Subordinated loans	Maturity	Interest
Subordinated loan, 2021 (nominal value SEKm 1,500)	30 years	3 month Stibor + 1.30%	139	131
Subordinated loan tier 1, 2022 (nominal value DKKm 400)	perpetual	3 month Cibor + 4.75 %	-	54
Subordinated loan, 2021 (nominal value DKKm 700)	12/2031	3 month Cibor + 1.25 %	-	94
Total subordinated debt securities			139	278

Other financial liabilities
Derivative financial instruments			74	63

Total financial liabilities			212	341

The SEK-denominated subordinated 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).

In 2024, Topdanmark A/S was sold to If P&C Insurance Holding Ltd. The comparative

information regarding financial liabilities of Topdanmark is therefore now included in

If’s table. The subordinated loans denominated in DKK were wholly included in

Topdanmark’s own funds. Approximately EUR 127 million (DKK 950 million) of these

loans were subscribed by If. The comparative information on derivative financial

instruments also includes EUR 43 million derivatives previously reported under

Topdanmark.


	FINANCIAL STATEMENTS 2025	196

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Hastings


EURm	12/2025	12/2024

Other financial liabilities
Derivative financial instruments	3	1
Amounts owed to credit institutions	460	353

Total financial liabilities	464	353

Hastings has a revolving credit facility with a financial institution, totalling EUR 115

million (103), of which EUR 55 million (39) was undrawn at the end of the reporting

period. In December 2025, the RCF was renegotiated with the financial institution and

the amount was increased from GBP 85 to GBP 100 million. The extended revolving

credit facility now matures in December 2027.

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 60 million

(63) . 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 2025.

Hastings also has a securitisation facility arrangement with a financial institution to

refinance the acquisition of loans totalling EUR 430 million (332), of which EUR 25

million (42) was undrawn at the end of reporting period. In November 2025, the

securitisation facility was increased from GBP 350 to GBP 375 million. The

arrangement was extended from November 2026 to November 2027.

Hastings has an undrawn credit facility also with Sampo plc, totalling EUR 86 million

(90) with a maturity date of 29 October 2026.

Holding


EURm			12/2025	12/2024

Subordinated debt securities
Subordinated loans	Maturity	Interest
Subordinated loan, 2020 (nominal value EURm 1,000)	32 years	2.50 %	681	994
Subordinated loan, 2019 (nominal value EURm 500)	30 years	3.38 %	498	497
Total subordinated debt securities			1,178	1,491

Other financial liabilities
Derivative financial instruments			28	25
Debt securities in issue	Maturity	Interest
Bond 2017, (nominal value EURm 500)	8 years	1.25 %	—	162
Bond 2018, (nominal value EURm 500)	10 years	1.625 %	312	312
Bond 2018, (nominal value EURm 500)	12 years	2.25 %	391	395
Bond 2018, (nominal value NOKm 1,000)	10 years	3.10 %	84	85
Total bonds			787	954

Liability for the share buyback programme			60	—

Total financial liabilities			2,054	2,470

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.

During the reporting period, Sampo launched a EUR 300 million tender offer for its

Tier 2 notes. As a result, Sampo repurchased EUR 316 million in aggregate nominal

value of its Tier 2 notes due 2052 for EUR 295 million.

Debt securities in issue have decreased as the senior bond of EUR 162 million issued by

Sampo plc matured in May.


	FINANCIAL STATEMENTS 2025	197

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

Change in liabilities from financing activities


EURm	1 January 2025	Incoming cash flows	Outgoing cash flows	Exchange differences	Other	31 December 2025
Subordinated debt	1,642	—	-315	6	-16	1,317
Bonds	954	—	-165	-1		787
Other loans	353	130	—	-20	-3	460
Tier 1 notes*	—	298	—	—	—	298
Total	2,948	428	-480	-15	-19	2,862

*In the balance sheet, Tier 1 notes are accounted for as equity instruments and not as financial

liabilities.


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	0	353
Total	2,798	194	-50	7	0	2,948


	FINANCIAL STATEMENTS 2025	198

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

23 Other liabilities


EURm	12/2025	12/2024

Liabilities arising out of direct insurance operations	250	176
Liabilities arising out of reinsurance operations	113	126
Settlement liabilities	6	90
Provisions	142	174
Interests	29	29
Tax liabilities	38	14
Lease liabilities	151	134
Employee benefit liability	20	21
Prepayments and accrued income	339	265
Other	501	535
Total other liabilities	1,589	1,562

Item Other includes, e.g. premium taxes of EUR 139 million (148), liabilities related to

patient insurance pool of EUR 46 million (54) and various other tax liabilities EUR 108

million (96).

The non-current share of other liabilities is EUR 107 million (96).

Leases

The total effect of leases on the statement of cash flows was EUR -32 million (-36).

Non-cash flow additions from IFRS 16 leases to the balance sheet items were EUR 25

million (12).


EURm	1-12/2025	1-12/2024

Items recognised in the p/l from lease liabilities
Interest expenses	-3	-2
Expenses from short-term and low-value lease liabilities	-7	-4

Provisions


EURm	2025
At 1 January	174
Provisions utilised during the financial year	-73
Unutilised provisions reversed during the financial year	-7
Provisions added during the fiscal year	47
Translation difference	0
At 31 December	141

In 2024, 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. During the year 2025, the restructuring reserve was reduced by EUR 49

million, which was utilised against incurred expenses. At the end of December 2025,

the reserve amounted to EUR 99 (148) million.

Other restructuring provisions consist of funds amounting to EUR 2 (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.

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. Management

has reviewed current and previous tax filings and consider that the appropriate amount

of tax was paid for each period under review. Therefore, management consider that the

most likely outcome will be that no further tax liability will be due. However, given the

subjective nature of the transfer pricing, there remains a possibility that a potential

liability could become payable. Hastings Group has therefore provided GBP 16 million

(EUR 19 million) in respect of a potential tax liability at 31 December 2025.

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 96 million.


	FINANCIAL STATEMENTS 2025	199

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

24 Employee benefits

Sampo Group’s subsidiary If applies IAS 19 Employee Benefits and recognises 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 recognised as defined-contribution plans. This occurs

because If lacks the information necessary to recognise 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.

Pension obligations


EURm	2025	2024

Defined benefit pension obligations, including social costs	204	213
Fair value of plan assets	255	232
Net asset from defined benefit pension obligations	-51	-19
Other pension obligation, including social costs	4	4
Net asset pension from obligations recognised in balance sheet	-46	-15
of which recognised as Net pension assets in Other assets	66	36
of which recognised as Net pension liabilities in Other liabilities	20	21

The Swedish defined-benefit pension plan, FTP2, is a multi-employer plan and is closed

to new employees born in 1972 or later. In Norway, there are a few smaller defined-

benefit pension plans, mainly unfunded pension plans, for which If Group is responsible

for ongoing payments. These include primarily individual pension agreements for

former personnel. If Group also has a pension plan for current employees with salary

higher than 12 G (G = National Insurance basic amount). This is a contribution-based

plan but a liability is accounted for in the balance sheet. The carried liability for this

plan is handled separately from the defined-benefit pension obligations due to its

defined contribution nature, where the obligation is not based on final salary but rather

on the value of earned contributions and accumulated return as of 31 December.

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 optimise 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 2025	200

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 recognised 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 pension obligations by country


	2025			2024
EURm	Sweden	Norway	Total	Sweden	Norway	Total
Recognised in income statement and other comprehensive income
Current service cost	3	0	3	2	0	3
Total defined benefit pensions costs in insurance service result	3	0	3	2	0	3
Interest expense on net pension liability	-1	1	-1	-1	1	-1
Remeasurement of the net pension liability	-23	-1	-24	-1	1	0
Total net cost (income) in comprehensive income statement	-22	0	-22	0	2	2

Recognised in balance sheet
Defined benefit pension obligations, including social costs	187	18	204	194	19	213
Fair value of plan assets	253	2	255	230	1	232
Net liability (net assets)	-66	16	-50	-36	17	-19

Distribution by asset class

Bonds	40%	—		41%	—
Equities	24%	—		22%	—
Properties	10%	—		9%	—
Other	26%	—		28%	—


	FINANCIAL STATEMENTS 2025	201

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025	31 Dec 2024	31 Dec 2025	31 Dec 2024
Discount rate	4.00%	3.25%	4.25%	4.00%
Future salary increases	3.00%	3.00%	3.00%	3.25%
Price inflation	2.00%	2.00%	2.00%	2.25%
Mortality table	DUS23	DUS23	K2013	K2013
Average duration of defined benefit pension liabilities	16 years	17 years	11 years	11 years
Expected contributions to the defined benefit plans during 2026 and 2025	6	5	-	-


	2025			2024
Sensitivity analysis of effect of reasonably possible changes	Sweden	Norway	Total	Sweden	Norway	Total
Discount rate, +0.50%	-14	-1	-14	-15	-1	-16
Discount rate, -0.50%	15	1	16	17	1	18
Future salary increases, +0.25%	3	0	3	3	0	4
Future salary increases, -0.25%	-3	0	-3	-3	0	-3
Expected longevity, +1 year	6	1	6	7	1	7


	2025			2024
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	188	16	204	196	17	213
Fair value of plan assets	255	—	255	232	—	232
Net pension liability (net assets) from defined benefit obligations	-66	16	-50	-36	17	-19
Other pension obligation, including social costs	—	4	4	—	4	4
Net liability (net asset) recognised in balance sheet	-66	20	-46	-36	20	-15


	FINANCIAL STATEMENTS 2025	202

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Specification of change in defined benefit pension

obligations


EURm	2025	2024

Pension liabilities
At the beginning of the year	210	202
Current cost	3	2
Interest cost	7	7
Actuarial gains (-) / losses (+) on financial assumptions	-23	7
Actuarial gains (-) / losses (+), experience adjustments	0	4
Exchange differences on foreign plans	11	-7
Benefits paid	-6	-6
Defined benefit pension obligations on Dec 31, excl. social security costs	202	210
Social security costs	2	3
Defined benefit pension obligations on Dec 31, incl. social security costs	204	213

Reconciliation of plan assets
At the beginning of the year	232	220
Interest income	8	7
Difference between actual return and calculated interest income	1	11
Contributions paid	6	5
Exchange differences on foreign plans	14	-7
Benefits paid	-5	-5
Plan assets at 31 December	255	232

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 2025 is EUR 108 million.


	FINANCIAL STATEMENTS 2025	203

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

25 Equity and reserves

Equity (1,000 shares)


	12/2025	12/2024

Equity (1,000 shares)	2,661,809	2,691,239

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.

In February 2025, Sampo carried out a share split by way of a share issue without

consideration. The new shares were issued to shareholders in proportion to their

existing holdings, so that four (4) new shares were issued for each existing share.

At the end of the financial year 2025, the number of A shares amounted to 2,661,808

524 shares and B shares to 1,00,000 shares. In 2024, the reported amount of A shares

was 538,247,772 shares and the amount of B shares 200,000.

Treasury shares (1,00 0 shares)


	12/2025	12/2024

Own shares held by Sampo plc (1,000 shares)	8,946	—

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.

Restricted Tier 1 notes

In September 2025, Sampo issued EUR 300 million of new restricted Tier 1 notes with a

coupon rate of 5.25 per cent and an option of a first call date in 2035 for Sampo. The

restricted Tier 1 instrument is accounted for as equity. Transaction costs related to the

issue of the notes were directly recognised in retained earnings.

Accounting treatment of restricted Tier 1 (RT1) instrument depends on the substance

of the contractual arrangement. The restricted Tier 1 instrument is accounted for as

equity as the notes are unsecured and subordinated as well as perpetual with no fixed

maturity date. Payment of interest and principal is at the discretion of Sampo. Interest

expenses are recognised directly in retained earnings. Therefore, the restricted Tier 1

notes qualify as equity instruments pursuant to IAS 32.

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 2025	204

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

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). The value of one

calculated incentive unit is the trade-weighted average price of the Sampo A share 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 8.7-8.95. The maximum value of one incentive unit varies between EUR

12.64-12.89. 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 2024**		5,258	595	790
Granted (1,000) 31 Dec 2025		—	271	553

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**		6.06	6.06	6.06
Starting price EUR/*		6.59	8.70	8.95
Starting price adjusted with dividend, EUR at 31 December 2025**		3.28	5.73	6.80

Sampo A closing price EUR at 31 December 2025	10.33

Total intrinsic value, EURm		—	1	1

Total debt	3
Total cost for the financial period, EURm (excl. social cost)	18

* Grant dates vary

** Sampo’s 1:5 share split on 12 February 2025 taken into account

*** 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 2025	205

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 1,778,495 performance incentive units (out

of a maximum of 1,850,000). 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 per cent 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 per cent 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 per cent 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: 40per cent of the reward is subject to the performance of

Sampo Group’s underwriting profit growth over the performance period.

Sustainability charter: 10 per cent 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 minimise risk.

The fair value of the scheme has been estimated using the Monte Carlo pricing model.

At the end of the period, 75 persons were included in the scheme. The total cost for

the financial period amounted to EUR 4 million and the liability of the scheme

amounted to EUR 5 million.

Sampo’s long-term incentive scheme 2025

On 12 March 2025, 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 2025 were granted 2,058,196 performance incentive units (out

of a maximum of 2,250,000). The performance incentive units have a three-year

performance period covering financial years 2025-2027, 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 per cent 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 2025, excellent financial and operational

performance is required. The performance assessment is based on the same

performance criteria as in LTI 2024. For the criteria, see previous chapter Sampo’s

long-term incentive scheme 2024.

The fair value of the scheme has been estimated using the Monte Carlo pricing model.

At the end of the period, 94 persons were included in the scheme. The total cost for

the financial period and the liability of the scheme amounted to EUR 3 million.


	FINANCIAL STATEMENTS 2025	206

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Long-term incentive scheme of Topdanmark’s former

management

The former deputy CEO and members of Group Management of Topdanmark are

covered by a long-term incentive scheme.

Upon the completion of Sampo’s compulsory acquisition of the remaining Topdanmark

shares in October 2024, the outstanding rights to Topdanmark shares under the LTI

programme were converted so that the LTI participants received phantom share units

tied to the development in the share price of Sampo’s listed A share. These will be

settled in cash when the phantom share units are exercised. The market value of the

LTI option was determined per the completion in accordance with the Black-Scholes

formula.

At the end of the financial period, 16 persons were included in the scheme.

Long-term incentive schemes of Hastings

The total charge for the share-based payments recognised in profit or loss during 2025

was EUR 32 million (29) with a share-based payment liability of EUR 51 million (36)

held at 31 December 2025.

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 16 million (15) were granted in 2025, and EUR 4 million (9)

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 (40) outstanding on 31 December 2025.

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 2025, certain key management personnel were granted cash awards

with a value of EUR 1 million (1) conditional upon continued employment within the

Group. There were cash awards with a value of EUR 3 million (1) outstanding at 31

December 2025.

Capital appreciation plan 2021

In the year ended 31 December 2021, certain key management personnel of the

Company were invited to participate in the Hastings Group’s Capital Appreciation Plan,

under which they may be awarded up to five matching awards of B Ordinary Shares in

Hastings Group Consolidated Limited, for every B Ordinary share that they hold.

Matching awards have the potential to vest in two tranches, with 50 per cent being

conditional upon a total shareholder return (TSR) measured over a four-year period,

and 50 per cent 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 four to six years.

There were no awards in 2025 and 2024. The total number of HGC B Ordinary Shares

allotted to colleagues to be held under the scheme in 2021 was EUR 0.6 million, with a

maximum potential matching award of EUR 2.6 million B Ordinary shares.

The fair value of the matching awards, calculated using the Monte Carlo valuation

model, was estimated to be EUR 1.7 million (1.7), or approximately EUR 3.7 per

matching award (3.7).

Capital appreciation plan 2025

In 2025, the Company introduced a new Capital Appreciation Plan (‘2025 CAP’) for

certain key management personnel of the Company. The terms of the 2025 scheme

are substantively similar with those of the HGCL’s 2021 CAP scheme except for

differences in the quantity of the award and absence of voting rights for the holders.

The total number of B Ordinary Shares purchased and allotted under the scheme at 31

December 2025 was EUR 1.3 million (-), with a maximum potential matching award of

EUR 6.2 million B Ordinary shares.

The fair value of the matching awards is calculated using the Monte Carlo valuation

model. The fair value of the matching shares were EUR 8.8 million, or approximately

EUR 8.1 per matching share.


	FINANCIAL STATEMENTS 2025	207

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

27 Investments in subsidiaries


	12/2025		12/2024
Name	Group holding %	Carrying amount	Group holding %	Carrying amount
If P&C Insurance Holding Ltd	100	4,820	100	4,820
If P&C Insurance Ltd	100	6,380	100	1,441
If P&C Insurance AS	100	41	100	39
Viking Assistance Group AS	100	85	100	80
If IT Services A/S	100	32	100	0
Topdanmark A/S	100	42	100	39
Topdanmark Forsikring A/S	—	—	100	4,614
Topdanmark EDB A/S	100	44	100	41
Topdanmark BidCo A/S*	100	277	100	261
Hastings Group (Consolidated) Ltd	100	2,611	100	2,611
Hastings Group Holdings Limited	100	2,410	100	2,535
Advantage Global Holdings Limited	100	1,442	100	1,518
Advantage Insurance Company Limited	100	269	100	283
Hastings Insurance Services Limited	100	511	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.

Cha nges in subsidiary shares in 2025

Topdanmark Forsikring A/S was merged into If P&C Insurance Ltd on 1 July 2025.

The change in the carrying amount of If IT Services A/S is due to an add-on

capitalisation.

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. Simultaneously 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 2025	208

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

28 Acquisition of Topdanmark’s non-

controlling interest

Background

In 2024, Sampo acquired the remaining non-controlling interests in Topdanmark A/S.

The transaction was completed on 25 October 2024. Following the acquisition of the

NCI, Sampo plc sold all shares in Topdanmark A/S to If P&C Insurance Holding Ltd.

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.

The acquisition costs related to the equity transaction, amounting to EUR 31 million,

were accounted for as a deduction from the equity. Overall, 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.

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 was an intra-group transaction, all

impacts, including the sales gain of the shares, was eliminated at the Sampo Group

level.


	FINANCIAL STATEMENTS 2025	209

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

In the comparative 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	2025	2024
Short-term employee benefits	-11	-8
Post employment benefits	-5	-4
Other long-term benefits	-12	-8
Total	-27	-20

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.


	FINANCIAL STATEMENTS 2025	210

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

30 Contingent liabilities, commitments and

legal proceedings


EURm	12/2025	12/2024

Off-balance sheet items
Guarantees	1	9
Investment commitments	125	40
Other	2	2
Total	129	51

Assets pledged as collateral for liabilities or contingent liabilities


	12/2025		12/2024
EURm	Assets pledged	Liabilities/ commitments	Assets pledged	Liabilities/ commitments

Assets pledged as collateral
Investment securities	390	268	403	294
Subsidiary shares	91	25	91	25
Cash and cash equivalents	66	—	66	43
Total	547	293	559	362

Assets pledged as security for derivative contracts
Cash and cash equivalents	65		66
Assets pledged as security for insurance undertakings
Investment securities	390		403
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.

Other financial commitments

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 1 March 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 21 million (40), 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.

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.

Under the Danish Corporate Income Tax Act, If Group is subject to mandatory joint

taxation in Denmark. Topdanmark A/S is the administration company for the Danish

joint taxation, but the companies have a joint liability for payment.


	FINANCIAL STATEMENTS 2025	211

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

In connection with the implementation of a new customer and core system, If P&C

Insurance Ltd has undertaken to provide support towards specific suppliers to fulfil

Topdanmark EDB IV ApS’ obligations in accordance with the contracts.

Hastings

Advantage Insurance Company Limited has outstanding commitments to private

equity fund totalling EUR 98 million, which is the maximum amount that the company

has committed to invest in the fund. Capital will be called in to this fund over the next

year.

Rental commitments

During the comparative period 2024, Sampo plc signed a rental agreement for new

office premises. The lease period started in June 2025.

Legal proceedings

There are a number of legal proceedings against the Group companies outstanding as

of 31 December 2025, arising in the ordinary course of business. The companies

estimate it unlikely that any significant loss will arise from these proceedings.

31 Subsequent events after the balance sheet

date

Dividend proposal to the AGM

In the meeting on 4 February 2026, the Board of Directors decided to propose for the

Annual General Meeting on 22 April 2026, a divided distribution of EUR 0.36 per share

(totalling approx. EUR 958 million based on the number of outstanding shares at the

balance sheet date). The dividends to be paid will be accounted for in equity in 2026

as a deduction of retained earnings.

Share buyback programme

Sampo’s EUR 150 million share buyback programme announced on 5 November 2025

continued after the end of the reporting period and was completed on 30 January

2026. Sampo repurchased 15,079,201 shares through the programme at an average

price of EUR 9.95 per share. This corresponds to 0.56 per cent of the total share count

prior to the start of this programme. The repurchased shares were cancelled on 5

February 2026.

The buyback programme was based on the authorisation granted by the Annual

General Meeting held on 23 April 2025.

Further details on the company’s share buyback programmes are available at

www.sampo.com/sharebuyback.

Issuance of new Restricted Tier 1 notes

On 10 February 2026, Sampo issued SEK 1.5 billion of new floating rate Restricted Tier 1

notes with an interest rate of three-month STIBOR plus 1.80 per cent. The notes are

perpetual and may be redeemed or repurchased by Sampo in accordance with the

applicable terms and conditions. The first call date is in 2031.

The restricted Tier 1 instrument is accounted for as part of shareholder’s equity, but

treated as debt in the financial leverage ratio.

Reduction of ownership in NOBA Group

On 11 February 2026, Sampo announced that it had sold 10.0 million shares in NOBA to

institutional investors in an accelerated bookbuilding process that was conducted

together with Nordic Capital. The share sale generated approximately EUR 95 million

in gross proceeds for Sampo. Following the transaction, the Group’s ownership in

NOBA decreased from 14.9 per cent to 12.9 per cent.


	FINANCIAL STATEMENTS 2025	212

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

32 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 customers;

• 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 customers and

sound capitalisation, the confidence of the customers

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 2025	213

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

• 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


	FINANCIAL STATEMENTS 2025	214

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 customers, 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

guides group level sustainability work. The programme

is built around 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. These topics are closely linked to Sampo

Group’s strategy, business operations, and risk

management and are considered important by the

Group’s diverse stakeholders.

In drafting the programme, input from both internal and

external stakeholders has been taken into account. This

includes, for example, regulatory requirements related

to sustainability reporting; feedback from investors,

employees, suppliers and other business partners;

industry best practices; guidance from voluntary

reporting frameworks and initiatives; and the

perspectives of various ESG rating agencies.

The business management and practices theme focuses

on topics fundamental to Sampo Group‘s operations.

These include good corporate governance, sustainable

insurance operations and supply chain management,

and responsible investment.

Good governance at Sampo Group involves effective

policies, management practices, and training that

ensure compliance with laws, regulations, and generally

accepted principles, particularly in areas such as anti-

corruption and bribery, anti-money laundering, and

counter-terrorist financing. It also encompasses

comprehensive information security and cybersecurity

governance systems, data privacy activities, and robust

whistleblowing and grievance procedures.


	FINANCIAL STATEMENTS 2025	215

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sustainable insurance operations are essential for

meeting the evolving needs of all customers and for

mitigating potential adverse impacts on the Group’s

reputation. Accordingly, Sampo Group aims to take ESG

considerations into account in product and service

development and insurance underwriting. This

approach helps prevent association with business

activities that conflict with the company’s sustainability-

related policies and supports the offering of products

and services aligned with customers’ needs and

preferences. For example, Sampo Group integrates ESG

considerations, such as expectations for corporate

customers to respect international norms and standards

(e.g. by the UN Global Compact) into underwriting

practices, and embeds sustainability considerations into

underwriting principles and/or other relevant policies.

Sampo group also provides loss prevention services,

handles claims sustainably, and develops products and

services in accordance with relevant legal requirements.

Sampo Group places emphasis on sustainability when

working with suppliers. As a major procurer of goods

and services, especially in claims handling, the company

has an impact on the economy, the environment, and

society. Supply chains are a critical component of the

sustainability of Sampo Group’s products and services,

and poor management of sustainability issues can pose

reputational and operational risks. Therefore, ESG

considerations are integrated into supply chain

management through measures such as supplier codes

of conduct, additional contractual requirements for

specific suppliers (e.g. based on ESG risks, sector, size,

geography, business relevance), supply chain-related

targets, and supplier risk assessments (e.g. audits,

questionnaires). Sampo Group is also committed to

encouraging and supporting suppliers and business

partners adopting more sustainable practices.

Responsible investment management and operations

are vital for managing investment-related risks, and in

mitigating potential adverse impacts on the Group's

reputation. ESG considerations are taken into account

when assessing the security, quality, liquidity, and

profitability of investments. Investment opportunities

are thoroughly analysed before any investments are

made, with ESG considerations evaluated alongside

other factors affecting the risk-return ratio. Depending

on the asset class, Sampo Group applies various ESG

strategies to manage investment risks effectively. These

strategies include ESG integration through rating,

sector-based screening, norms-based screening, and

engagement with investee companies.

The people and communities theme compasses factors

related 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 is committed to providing customers

with the best service in all situations. Skilled and

motivated employees are a key success factor. Losing

talent or being perceived as an unattractive employer

would pose large risks for the businesses. Sampo Group

strives to ensure a healthy and supportive work

environment, not only because it is required by law but

also because it forms the foundation for sustainable

business performance.

Diversity and inclusion are key focus areas, and Sampo

Group is committed to fostering a non-discriminatory,

open, and respectful work environment where everyone

is treated fairly and equally. Risks related to these

themes are managed through internal policies and

governance structures, organisational development

programmes, and by offering employees training,

engaging career opportunities, and attractive

remuneration packages.

A sustainable product and service offering requires

attention to the risks such as inappropriate customer

advice and product sales, errors in claims handling and

complaint processes, and a lack of clarity regarding

conditions, prices, and fees. Sales and marketing

practices focus on meeting customer needs and

providing the customer the information necessary for

well-informed decisions about insurance coverage.

Sampo Group manages these risks through internal

policies and governance structures, as well as

employees training.

The climate and environment theme includes topics,

such as, climate change, circular economy and resource

use, and biodiversity.

Climate change and environmental issues can impact

Sampo Group’s business on short, medium, and long

term. Climate-related risks can be categorised into

physical risks and transition risks.

The financial position and performance of Sampo

Group’s insurance operations are especially affected by

physical risks. Effects on the financial position related to

extreme weather events and natural disasters are

considered in internal risk models, for instance through

the consideration of trends in related insurance claims.

Climate-related risks are also managed effectively with

reinsurance programmes and price assessments.

As climate change may increase the frequency and/or

severity of physical risks, Sampo Group conducts

sensitivity analyses using scenarios that assume

increased severity of natural catastrophes. The Group

also supports its corporate and private customers in

managing climate-related risks. For example, extreme

weather events can damage property, cause crop

failures and disrupt business operations. Loss

prevention is an essential part of insurance services,


	FINANCIAL STATEMENTS 2025	216

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

helping customers reduce economic losses and

mitigates the impacts of climate change.

Sampo Group’s investments may be exposed to both

physical risks and transition risks, depending on the

nature of the investment. Physical risks primarily arise

from losses due to extreme weather events. Transition

risks, on the other hand, may result from the shift to a

low-carbon economy, including stricter environmental

regulations, tighter emission requirements, and

changing market preferences. These developments

could lead to asset revaluations, particularly in carbon-

intensive sectors. To manage these risks investment

opportunities are carefully analysed before any

investment decisions are made. Climate-related risks are

considered alongside other factors influencing the risk-

return ratio of each investments. Sampo Group employs

several methods including analysis of financed

emissions, sector-based screening. ESG integration

using ratings, monitoring the geographical distribution

of investments, and engagement with investee

companies.

In terms of climate change scenario analysis, Sampo

Group has in collaboration with the external vendor

ORTEC Finance analysed the Group’s investment

portfolio exposure to systemic economic and financial

climate risks across four different climate scenarios over

the next 40 years. The effect on the insurance results

have been analysed based on the impact on

macroeconomic variables as well as the potential

effects on the insurance operations stemming from

natural catastrophes.

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 customers 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 customers’ 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,

leverage, and liquidity, as well as on group level

management actions.


	FINANCIAL STATEMENTS 2025	217

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 Group companies, it has been established that If

operates within the Nordic countries, in different

geographical areas, and in different lines of business.

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

2025 by 14 per cent to EUR 1,590 million (1,394). The

table Underwriting performance, 31 December 2025 and

31 December 2024 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 2025 and 31 December 2024


EURm	Insurance revenue		Reinsurance premiums expenses		Insurance service expenses, claims incurred		Insurance service expenses, operating expenses		Reinsurers' share of claims incurred		Insurance service result
EURm	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024
Motor	5,010	4,520	-365	-392	-3,384	-2,989	-743	-680	203	173	720	632
Workers' compensation	327	314	-7	-6	-233	-164	-52	-43	5	5	40	106
Liability	463	460	-69	-71	-245	-213	-75	-68	21	36	96	143
Accident	1,262	1,162	-10	-8	-867	-746	-195	-180	7	6	197	234
Property	3,086	2,796	-528	-406	-1,817	-2,054	-421	-388	199	297	519	244
Marine, aviation, transport	124	136	-24	-24	-72	-75	-22	-21	13	16	18	31
Other	—	62	—	-2	—	-46	—	-16	—	4	—	3
Total	10,272	9,450	-1,003	-909	-6,618	-6,287	-1,507	-1,396	448	537	1,590	1,394


	FINANCIAL STATEMENTS 2025	218

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Key sensitivities

Effects from instant change on profit or loss in year 2025


EURm	Shock	2025
Combined ratio (quarterly effect)	Discount rate +100 bps	-0.65 %
Combined ratio (quarterly effect)	Discount rate -100 bps	0.65%
Insurance finance income and expense, net	Discount rate +100 bps	325
Insurance finance income and expense, net	Discount rate -100 bps	-370
Net investment income	Interest rates +100 bps	-355
Net investment income	Interest rates -100 bps	370
Net investment income	Spreads +100 bps	-355
Net investment income	Equities -10 %	-245

Reserve risk and its management and control

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.

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 segment.

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.

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.


	FINANCIAL STATEMENTS 2025	219

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Net liabilities for incurred claims

Sampo Group, 31 December 2025


	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	835	8.9	196	1.2	595	9.7	308	1.9	116	3.6	1,433	1.7	3,482	4.8
- whereof MTPL	715	10.3	116	1.7	568	10.1	273	2.1	104	4.0	—	—	1,776	8.1
Workers' compensation	—	—	101	2.8	700	9.4	1,116	6.4	—	—	—	—	1,917	7.3
Liability	255	3.5	109	1.6	111	2.7	190	2.1	24	1.9	—	—	689	2.6
Accident	296	6.0	397	6.6	208	6.0	323	1.9	4	0.3	—	—	1,228	5.1
Property	325	1.0	372	0.9	174	0.7	347	0.8	36	0.4	111	0.8	1,364	0.8
Marine, aviation, transport	12	0.5	19	0.7	7	0.9	8	0.7	1	0.7	—	—	48	0.7
Other	—	—	—	—	—	—	—	—	—	—	—	—	—	—
Total	1,724	6.0	1,193	3.1	1,795	7.8	2,291	3.9	181	2.6	1,544	1.6	8,728	4.6


	FINANCIAL STATEMENTS 2025	220

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 31 December

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

Sampo Group, 31 December 2025 and 31 December 2024


Insurance liabilities item	Risk factor	Change in risk parameter	Country	Effect EURm 2025 Gross	Effect EURm 2025 Net	Effect EURm 2024 Gross	Effect EURm 2024 Net
Discounted estimated future cash flows	Inflation increase	Increase by 1 percentage point	Sweden	116	113	110	106
			Denmark	95	92	86	84
			Finland	26	26	29	28
			Norway	20	18	17	16
			UK	73	18	63	11
Annuities and reated INBR	Decrease in mortality	Life expectancy increase by 1 year	Sweden	16	16	15	15
			Denmark	4	4	2	2
			Finland	41	41	49	49
			Norway	0	0	0	0
			UK	4	0	3	0
Discounted liability for incurred claims	Decrease in discount rate	Decrease by 1 percentage point to liquid part of yield curve	Sweden	82	79	79	75
			Denmark	97	94	94	92
			Finland	144	144	169	168
			Norway	35	34	29	28
			UK	60	22	56	16

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.


	FINANCIAL STATEMENTS 2025	221

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

As shown in the graph Breakdown of gross written

premiums by business area, country, and line of

business, Sampo Group, 31 December 2025, the Group

insurance portfolio is well diversified across segments,

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 segment, country, and line of business

Sampo Group, 31 December 2025, total EUR 10,294 million (9,527)

By segment

By country

By line of business


	FINANCIAL STATEMENTS 2025	222

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Premium and catastrophe risk and their

management and control

The main factors affecting Group’s premium risk are

claims volatility, claim inflation, climate change 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, and natural

catastrophes, or an unforeseen increase in the

frequency or the average size of small and medium-

sized claims. Another example is claim inflation, which is

a factor taken into account in the pricing process, which

in turn can affect competitiveness when claim costs

increases.

The principal methods for mitigating premium risks are

by reinsurance and risk sharing, diversification in the

portfolio, 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 (net of reinsurance premium

expense), and claims incurred affect the result before

tax is presented in the table Sensitivity analysis,

premium risk, Sampo Group, 31 December 2025 and 31

December 2024.

Sensitivity analysis, premium risk

Sampo Group, 31 December 2025 and 31 December 2024


	Level 2025		Change in current level	Effect on result before tax (Gross)		Effect on result before tax (Net)
Key Figures	(Gross)	(Net)		2025	2024	2025	2024
Combined ratio, Private Nordic	82.2%	82.1%	+/- 1 percentage point	-/+ 40.4	-/+ 37.1	-/+ 39.9	-/+ 36.7
Combined ratio, Private UK	90.5%	89.2%	+/- 1 percentage point	-/+ 26.2	-/+ 22.3	-/+ 20	-/+ 16.6
Combined ratio, Nordic Commercial	82.7%	82.9%	+/- 1 percentage point	-/+ 23.2	-/+ 22.3	-/+ 22	-/+ 21.3
Combined ratio, Nordic Industrial	56.4%	81.3%	+/- 1 percentage point	-/+ 10.4	-/+ 10.3	-/+ 5.8	-/+ 6.6
Combined ratio, Other operations	75.1%	76.9%	+/- 1 percentage point	-/+ 2.5	-/+ 2.5	-/+ 3	-/+ 2.7
Insurance revenue (net of reinsurance premium expenses EURm)	10,272	9,269	+/- 1 per cent	+/- 102.7	+/- 94.5	+/- 92.7	+/- 85.4
Claims incurred (EURm)	6,618	6,171	+/- 1 per cent	-/+ 66.2	-/+ 62.9	-/+ 61.7	-/+ 57.5


	FINANCIAL STATEMENTS 2025	223

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 Group companies 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 2025, was EUR 18,122 million (16,727)

as presented in the following table, Investment

Allocation, Sampo Group, 31 December 2025 and 31

December 2024.

Investment allocation

Sampo Group, 31 December 2025 and 31 December 2024


	2025			2024
Asset class	Market value, EURm	Weight, %	Average maturity, years	Market value, EURm	Weight, %	Average maturity, years
Fixed income total	15,660	86%	3.4	14,743	88%	3.7
Money market securities and cash	1,775	10%	0.1	1,224	7%	0.1
Government bonds	1,557	9%	3.9	1,597	10%	4.1
Credit bonds, funds and loans	12,328	68%	3.5	11,922	71%	3.9
Covered bonds	3,791	21%	3.7	4,175	25%	4.9
Investment grade bonds and loans	7,339	40%	3.5	6,518	39%	3.4
High-yield bonds and loans	1,198	7%	3.2	1,228	7%	3.3
Listed equity total	2,404	13%	-	1,520	9%	-
Nordic Countries	1,558	9%	-	693	4%	-
Western Europe	446	2%	-	447	3%	-
North America	207	1%	-	204	1%	-
Asia	192	1%	-	176	1%	-
Others	1	0%	-	–	–%	-
Alternative investments total	58	0%	-	465	3%	-
Real estate	0	0%	-	0	0%	-
Private equity	47	0%	-	464	3%	-
Other alternative	10	0%	-	0	0%	-
Asset classes total	18,122	100%	-	16,727	100%	-

The financial assets, as presented in 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 2025	224

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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.

Investment assets of Sampo Group are diversified

across currencies and geographical regions. Sampo

Group's investment assets are mostly in Scandinavian

currencies, euro and pound sterling, which are the

currencies in which the Group has most of its insurance

liabilities. Most of the investment assets are investment

grade fixed income investments. In addition, the Group

has also significant exposures to equities and non-

investment grade fixed income issuers.

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 investments in pound sterling denominated

fixed income bring 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 2025	225

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Exposures by sector, asset class and rating

Sampo Group, 31 December 2025


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 2024
Basic industry	–	–	48	150	28	–	32	258	43	–	–	301	4
Capital goods	41	–	74	288	6	–	60	469	533	–	–	1,002	85
Consumer products	54	53	182	415	21	–	99	824	182	2	–	1,009	39
Energy	–	–	52	5	–	–	42	99	9	–	–	109	-13
Financial institutions	175	1,121	2,310	1,073	72	–	71	4,823	814	–	3	5,639	1,207
Governments	617	153	12	102	–	–	–	884	–	–	–	884	173
Government guaranteed	12	26	6	16	–	–	–	60	–	–	–	60	-20
Healthcare	6	–	16	145	28	–	77	272	3	–	–	275	45
Insurance	–	1	84	243	9	–	–	337	–	2	–	340	15
Media	–	–	–	5	–	–	29	34	–	–	–	34	-24
Packaging	–	–	–	39	–	–	16	54	–	–	–	54	27
Public sector, other	79	436	–	–	–	–	–	515	–	–	–	515	19
Real estate	4	37	136	127	24	5	70	404	–	–	–	404	-103
Services	–	–	57	188	130	–	121	496	–	–	–	496	68
Supranationals	77	–	103	47	–	–	–	227	–	–	–	227	-83
Technology and electronics	–	39	58	70	15	–	111	293	–	1	–	294	100
Telecommunications	–	–	31	336	10	–	–	378	59	–	–	437	96
Transportation	–	88	16	90	25	–	15	233	–	–	–	233	-16
Utilities	–	13	145	423	63	–	88	732	–	–	–	732	210
Others	–	–	36	22	–	–	14	72	–	5	–	77	-45
Covered bonds	3,563	69	86	47	–	–	26	3,791	–	–	–	3,791	-384
Funds	228	–	110	–	–	–	65	404	760	47	–	1,211	-17
Clearing house	–	–	–	–	–	–	–	–	–	–	8	8	-1
Total	4,857	2,035	3,562	3,831	431	5	939	15,658	2,404	58	11	18,131	1,383
Change from 31 Dec 2024	-445	533	198	943	29	2	-373	887	884	-388	–	1,383

Total assets differ from the table Investment allocation due to derivatives.


	FINANCIAL STATEMENTS 2025	226

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025 and 31 December 2024.

Fixed income investments in the financial sector

Sampo Group, 31 December 2025


EURm	Covered bonds	Cash and money market securities	Long-term senior debt	Long-term subordinated debt	Total	%
Sweden	1,655	93	555	168	2,471	28.5%
Denmark	1,647	12	293	173	2,124	24.5%
Finland	51	468	339	121	979	11.3%
Norway	232	–	314	296	842	9.7%
France	–	340	276	30	647	7.5%
United Kingdom	–	90	204	–	294	3.4%
United States	–	5	287	–	291	3.4%
Netherlands	39	–	185	51	274	3.2%
Canada	97	–	152	–	249	2.9%
Switzerland	17	2	84	–	103	1.2%
Australia	55	–	33	–	88	1.0%
Germany	–	–	72	–	72	0.8%
Iceland	–	–	51	–	51	0.6%
Belgium	–	–	49	–	49	0.6%
Spain	–	–	39	–	39	0.5%
Italy	–	–	37	–	37	0.4%
Japan	–	–	25	–	25	0.3%
Austria	–	–	21	–	21	0.2%
Luxembourg	–	–	13	–	13	0.1%
Bermuda	–	–	3	9	12	0.1%
Total	3,791	1,010	3,032	848	8,681	100.0%


	FINANCIAL STATEMENTS 2025	227

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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%

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 2025 and 31 December

2024. 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 2025	228

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Fixed income investments in the public sector

Sampo Group, 31 December 2025


EURm	Governments	Government guaranteed	Public sector, other	Total
Sweden	521	–	79	601
Norway	96	–	436	531
Supranationals	–	–	227	227
United States	129	–	–	129
United Kingdom	114	–	–	114
Germany	–	34	–	34
Finland	–	26	–	26
Faroe Islands	24	–	–	24
Total	884	60	742	1,686

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

The listed equity investments of Sampo Group totalled

EUR 2,404 million at the end of year 2025 (1,520).

The geographical core of Sampo Group’s equity

investments is in Nordic companies. The proportion of

Nordic equities corresponds to 65 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 2025

and 31 December 2024.

Breakdown of listed equity investments

by geographical regions

Sampo Group,

31 December 2025 and 31 December 2024

31 December 2025

Total EUR 2,404 million

31 December 2024

Total EUR 1,520 million


	FINANCIAL STATEMENTS 2025	229

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025 and 31 December 2024.

Largest exposures by issuer and asset class

Sampo Group, 31 December 2025


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	1,130	6%	162	769	199	—	1
NOBA	823	5%	—	—	10	814	—
Nykredit Association	752	4%	—	619	133	—	—
Swedbank	724	4%	—	590	134	—	—
Danske Bank	667	4%	76	435	155	—	—
Svenska Handelsbanken	628	3%	—	492	136	—	—
Sweden	578	3%	111	—	468	—	—
Norway	531	3%	—	—	531	—	—
Skandinaviska Enskilda Banken	425	2%	236	28	161	—	—
BNP Paribas	420	2%	340	—	79	—	—
Total top 10 exposures	6,679	37%	925	2,934	2,005	814	1
Other	11,443	63%
Total investment assets	18,122	100%


	FINANCIAL STATEMENTS 2025	230

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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%

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 2025

and 31 December 2024.

Furthermore, the largest direct listed equity exposures

are presented in the tables Ten largest direct listed

equity investments, Sampo Group, 31 December 2025

and 31 December 2024.


	FINANCIAL STATEMENTS 2025	231

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Ten largest high yield and non-rated fixed income investments and listed equity investments

Sampo Group, 31 December 2025


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+	63	0.4%	NOBA	814	33.9%
Pohjolan Voima Oy	NR	38	0.2%	Volvo	148	6.2%
Visma AS	NR	28	0.2%	Nexi S.p.A. *	124	5.1%
Hexagon AB	NR	28	0.2%	ABB	83	3.5%
Campus Byen A/S	NR	26	0.2%	Veidekke	66	2.7%
Trustly AB	NR	23	0.1%	Autoliv Inc	63	2.6%
Intrum Invest AB	CCC	22	0.1%	Telia Company	59	2.4%
Ica Gruppen AB	NR	22	0.1%	Nederman Holding	55	2.3%
Anticimex AB	B-	21	0.1%	Yara International	41	1.7%
Swedavia AB	BB+	20	0.1%	VBG Group AB	40	1.7%
Total top 10 exposures		292	1.9%	Total top 10 exposures	1,492	62.1%
Other fixed income investments		15,369	98.1%	Other equity investments	912	37.9%
Total fixed income investments		15,660	100.0%	Total equity investments	2,404	100.0%

* 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 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 was not a listed company in 2024, it was a major equity investment in Sampo plc's portfolio and is therefore included in the table.

** Investment in Nexi S.p.A is managed by HF Evergood partners.


	FINANCIAL STATEMENTS 2025	232

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 and from the effect of outstanding debt

in Sampo Plc. Sampo Group benefits when interest

rates rise, as the economic value of insurance liabilities

and outstanding debt in Sampo Plc decreases more

than the value of investment assets.

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 and sensitivity to changes in interest rates in

the net liability for incurred claims is analysed earlier in

the table Sensitivity analysis, reserve risk, Sampo Group,

2025 and 2024.

Currency risk

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

entity/branch level on a regular basis. As UK segment

has GBP as its functional currency and its insurance

operations are solely in the UK there are no transaction

risk exposures in its insurance operations and all figures

on that row represent transaction risk exposures in

Nordic segment. 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.


	FINANCIAL STATEMENTS 2025	233

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Transaction risk position

Sampo Group, 31 December 2025


Base currency EUR (in EURm)	EUR	USD	JPY	GBP	SEK	NOK	DKK	Other	Total, net
Insurance operations	-2,999	-116	0	-107	-3	-2,413	-3,772	-37	-9,447
Investments	3,745	483	0	127	818	1,944	2,697	0	9,814
Derivatives	-829	-358	3	24	-365	431	1,948	18	870
Transaction risk, net position	-83	9	3	44	449	-38	872	-19	1,238
Sensitivity: EUR -10%	-8	1	0	4	45	-4	87	-2	124

Sampo's transaction risk position in EUR represents exposure in foreign subsidiaries / their branches within Sampo Group with base currency other than EUR.

Transaction risk position

Sampo Group, 31 December 2024


Base currency EUR (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	-6,988
Investments	3,261	481	0	71	529	1,855	1,043	1	7,240
Derivatives	-117	-323	12	20	-109	437	976	7	903
Transaction risk, net position	-81	2	12	-3	433	-40	856	-24	1,154
Sensitivity: EUR -10%	-8	0	1	0	43	-4	86	-2	115

Excluding Topdanmark


	FINANCIAL STATEMENTS 2025	234

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

The maturities of cash flows from financial instruments,

insurance liabilities, and reinsurance contracts are

presented in the tables Cash flows, according to

contractual maturity, Sampo Group, 31 December 2025

and 31 December 2024, 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

(3.7).

Cash flows according to contractual maturity

Sampo Group, 31 December 2025


EURm	Carrying amount total	Carrying amount without contractual maturity	Carrying amount with contractual maturity	Cash flows
EURm	Carrying amount total	Carrying amount without contractual maturity	Carrying amount with contractual maturity	2026	2027	2028	2029	2030	2031- 2040	2041-
Financial assets	18,486	3,952	14,535	3,207	3,164	2,686	1,970	1,638	2,994	288
Financial assets (non-derivatives)	18,462	3,952	14,511	3,190	3,164	2,686	1,970	1,638	2,987	282
Interest rate swaps	14	–	14	7	–	–	–	–	7	6
FX derivatives	10	–	10	10	–	–	–	–	–	–
Asset for incurred claims	2,156	2,156	–	707	390	274	179	42	201	363
Financial liabilities	-2,432	–	-2,432	-650	-545	-471	-547	-422	-759	-9
Financial liabilities (non-derivatives)	-2,327	–	-2,327	-614	-541	-448	-543	-418	-718	–
Interest rate swaps	-75	–	-75	-5	-4	-23	-4	-4	-41	-9
FX forwards	-31	–	-31	-31	–	–	–	–	–	–
Lease liabilities	-151	–	-151	-30	-26	-24	-21	-20	-45	–
Liability for incurred claims and other insurance related payables	-11,169	-11,169	–	-4,246	-1,658	-1,093	-770	-454	-1,708	-1,240
Investment commitments	-125	–	-125	-125	–	–	–	–	–	–

Hastings lending business is included in financial assets (non-derivatives).


	FINANCIAL STATEMENTS 2025	235

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Cash flows according to contractual maturity

Sampo Group, 31 December 2024


EURm	Carrying amount total	Carrying amount without contractual maturity	Carrying amount with contractual maturity	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	17,060	3,074	13,987	2,950	2,835	3,247	2,312	1,479	2,361	156
Financial assets (non-derivatives)	17,035	3,074	13,961	2,923	2,834	3,246	2,312	1,479	2,360	156
Interest rate swaps	2	–	2	–	–	–	–	–	1	–
FX derivatives	24	–	24	28	–	–	–	–	–	–
Asset for incurred claims	2,342	2,342	–	892	419	294	93	118	200	326
Financial liabilities	-3,126	–	-3,126	-585	-380	-451	-477	-553	-1,498	-2
Financial liabilities (non-derivatives)	-3,038	–	-3,038	-562	-378	-448	-456	-551	-1,481	–
Interest rate swaps	-68	–	-68	-5	-1	-3	-21	-2	-18	-2
FX forwards	-20	–	-20	-18	–	–	–	–	–	–
Lease liabilities	-134	–	-134	-31	-25	-20	-18	-16	-44	–
Liability for incurred claims and other insurance related payables	-10,704	-10,704	–	-4,054	-1,524	-1,027	-607	-499	-1,719	-1,275
Investment commitments	-40	–	-40	-40	–	–	–	–	–	–


	FINANCIAL STATEMENTS 2025	236

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Counterparty risks at Sampo Group

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 263 million is excluded, which mainly relates to

captives and statutory pool solutions.

Reinsurance recoverables and pooled

solutions

Sampo Group, 31 December 2025


	31 Dec 2025
Rating	Total EURm	% of total
AAA
AA+ - A-	2,354	100%
BBB+ - BBB-	0	0
BB+ - C	0	0%
D
Non-rated	1	—%
Total	2,355	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, 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 2025	237

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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


	FINANCIAL STATEMENTS 2025	238

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 benefits 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 Group

companies are converted from their reporting

currencies to the euro. When the reporting currencies of

the group companies depreciate, the actual amount of

the Group’s capital in euros decreases, and the capital

requirements of the Group 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, the 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.

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 2025, 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 9,007 million. Sampo plc had outstanding senior

debt of EUR 787 million and subordinated debt of EUR

1,178 million. Average remaining maturity of senior debt

was 3.5 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 2025 and 31 December 2024.


	FINANCIAL STATEMENTS 2025	239

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Balance sheet structure

Sampo plc, 31 December 2025 and 31 December

2024


EURm	31 Dec 2025	31 Dec 2024
Assets total	11,121	10,508
Liquidity	881	626
Investment assets	2,754	2,408
Other investments	3	3
Fixed income	1,813	1,826
Equity & private equity	938	580
Subordinated loans	—	—
Equity holdings	7,431	7,431
Subsidiaries	7,431	7,431
Associated	—	—
Other assets	56	44

EURm	31 Dec 2025	31 Dec 2024
Liabilities total	11,121	10,508
CPs issued	—	—
Long-term senior debt	787	954
Private placements	—	0
Bonds issued	787	954
Subordinated debt	1,178	1,491
Capital	9,007	7,989
Undistributable capital	98	98
Issued Tier 1 notes	298	0
Distributable capital	8,612	7,891
Other liabilities	149	75

The amounts in the table are IFRS numbers, including the

internal loan with If.

Regarding liquidity, Sampo plc held EUR 881 million

(626) 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 2025	240

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo plc’s Financial

Statement s


Sampo plc’s income statement ................................................................................	241
Sampo plc’s balance sheet .........................................................................................	242
Sampo plc’s statement of cash flows .....................................................................	243


	FINANCIAL STATEMENTS 2025	241

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo plc’s income statement


EUR	Note	1–12/2025	1–12/2024
Sales		2,145,854	1,613,222

Staff expenses
Salaries and remunerations		-22,346,136	-16,906,640
Social security costs
Pension costs		-2,541,992	-2,309,350
Other		-3,765,951	-3,167,059

Other operating expenses	1	-18,341,415	-21,444,644

Operating profit		-44,849,641	-42,214,471

Financial income and expenses	3
Income from shares in Group companies		1,496,045,592	767,526,733
Income from other shares		6,181,162	—
Other interest and financial income
Group companies		59,422,005	11,947,106
Other		10,429,019	25,818,262
Other investment income and expenses		30,724,265	1,130,378,459
Other interest income		18,086,912	29,609,093
Interest and other financial expenses		-68,462,961	-73,880,226
Exchange result		-3,609,210	13,568,866

Profit before appropriations and taxes		1,503,967,143	1,862,753,823

Income taxes		-144,688	-279,141

Profit for the financial year		1,503,822,455	1,862,474,682


	FINANCIAL STATEMENTS 2025	242

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo plc’s balance sheet


EUR	Note	2025	2024
Assets
Intangible assets		882,373	790,768
Tangible assets		3,512,803	2,578,443
Investments
Shares in Group company	20	7,447,617,854	7,447,617,854
Receivables from Group companies	4	1,723,370,133	1,724,651,817
Other shares and participations	5	400,262,354	523,679,758
Other investments	6	527,591,813	478,899,344
Short-term receivables
Other receivables	7	28,071,266	25,013,998
Prepayments and accrued income	8	17,371,527	17,789,978
Cash and cash equivalents		440,283,787	247,810,114
Total assets		10,588,963,911	10,468,832,075


EUR	Note	2025	2024
Liabilities
Equity	9,10
Share capital		98,113,838	98,113,838
Invested unrestricted equity		3,526,933,999	3,526,933,999
Other reserves		272,662,302	272,662,302
Retained earnings		2,846,436,870	2,188,887,859
Profit for the financial year		1,503,822,459	1,862,474,682

Liabilities
Long-term liabilities	12
Issued Tier 1 notes		299,974,660	—
Subordinated debt securities		1,178,239,915	1,491,077,179
Bonds		787,050,554	791,951,837
Short-term liabilities
Bonds		—	161,807,404
Other liabilities		4,752,135	2,491,086
Accruals and deferred income	11	70,977,179	72,431,889
Total liabilities		10,588,963,911	10,468,832,075


	FINANCIAL STATEMENTS 2025	243

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo plc’s statement of cash flows


EUR	1–12/2025	1–12/2024

Operating activities
Profit before tax	1,503,967,143	1,862,753,823
Adjustments
Realised gains and losses on investments	-57,776,129	-18,106,276
Interest income received and interest expense paid	-19,632,588	11,794,908
Other adjustments¹	16,538,141	-1,129,832,013
Adjustments total	-60,870,577	-1,136,143,381

Change (+/-) in assets of operating activities
Investments	105,351,572	528,843,603
Other assets	86,213,741	47,105,651
Total	191,565,313	575,949,253

Change (+/-) in liabilities of operating activities
Financial liabilities	-1,147,096	-2,079,077
Other liabilities	-2,669,778	3,537,795
Paid interests	-71,204,172	-66,231,611
Paid taxes	393,293	134,472
Total	-74,627,752	-64,638,422

Net cash from operating activities	1,560,034,127	1,237,921,273

Investing activities
Investments in subsidiaries	—	-356,287,346
Other investments	-1,457,544	-11,720
Net cash used in investing activities	-1,457,544	-356,299,066


EUR	1–12/2025	1–12/2024

Financing activities
Dividends paid	-915,021,060	-903,234,154
Purchase of own shares	-289,904,610	-475,189,927
Issue of debt securities	297,750,000	—
Repayments of debt securities in issue	-458,927,238	-2,054,997
Net cash used in financing activities	-1,366,102,909	-1,380,479,077

Total cash flows	192,473,673	-498,856,870

Cash and cash equivalents at 1 January	247,810,114	746,666,984
Cash and cash equivalents at 31 December	440,283,787	247,810,114
Net change in cash and cash equivalents	192,473,673	-498,856,870

Additional information to the statement of cash flows


EUR	1–12/2025	1–12/2024
Interest income received	90,836,760	54,436,703
Interest expense paid	-71,204,172	-66,231,611
Dividend income received	1,502,226,754	767,526,733

¹Other adjustments include a permanent impairment of EUR -26 (-68) million on H&F Evergood SA

private equity fund. The comparative period included the acquisition of the Topdanmark A/S

minority shares and the sale of the Topdanmark A/S shares to If P&C Insurance Holding Ltd.


	FINANCIAL STATEMENTS 2025	244

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo plc’s notes to the financial statements


Summary of significant accounting policies .......................................................	245
1 Other operating expenses ............................................................................................	247
2 Auditors' fees ...................................................................................................................	247
3 Financial income and expense ...................................................................................	247
4 Receivables from Group companies ........................................................................	247
5 Other shares and participations ................................................................................	247
6 Other investments ..........................................................................................................	248
7 Other receivables ............................................................................................................	248
8 Prepayments and accrued income ...........................................................................	248
9 Movements in the parent company's equity ........................................................	249
10 Share capital ...................................................................................................................	250
11 Accruals and deferred income ..................................................................................	250
12 Long-term liabilities ......................................................................................................	250
13 Deferred tax assets and liabilities ............................................................................	250
14 Pension liabilities ...........................................................................................................	250
15 Rental commitments ....................................................................................................	250
16 Other liabilities and commitments ..........................................................................	250
17 Number of personnel ...................................................................................................	250
18 Salaries and remuneration of the Board and the Group CEO .......................	251
19 Pension contributions to the CEO, deputy CEO and the members of the Board ...............................................................................................................................	251
20 Shares held ..................................................................................................................	252


	FINANCIAL STATEMENTS 2025	245

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Sampo plc’s notes to the financial statements

Summary of significant

accounting policies

Sampo plc (business ID 0142213-3) is Sampo Group’s

parent company and a Finnish public company listed in

Nasdaq Helsinki. Sampo has a dual listing in Nasdaq

Stockholm and in Nasdaq Copenhagen. It is domiciled in

Helsinki, and the headquarters are at Fabianinkatu 21,

00130 Helsinki, Finland.

The 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

In 2024, Sampo acquired the remaining interests in

Topdanmark A/S. The transaction was completed on 25

October 2024. Following the acquisition, Sampo plc

sold all shares in Topdanmark A/S to If P&C Insurance

Holding Ltd. The transaction was completed at an arm’s

length basis. 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.

For the transaction between Sampo plc and If P&C

Insurance Holding Ltd. 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.

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

reversed.

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 recognised as a loss for the

period in the income statement and as a liability in the

balance sheet. Positive difference is not recognised.

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.

Liabilities

Financial liabilities, such as subordinated debt securities

and bonds, are initially recognised at nominal value.

Interest expense is accrued.

In 2025, Sampo plc issued Tier 1 notes, which are

accounted for as financial liability under Finnish

Accounting rules. Tier 1 notes are presented as a long-


	FINANCIAL STATEMENTS 2025	246

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

term financial liability in the balance sheet. Interest

expense is accrued and recognised in the income

statement.

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, interest

expense on financial liabilities, as well as impairment

losses recognised 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 32 includes detailed

information on the risk management.


	FINANCIAL STATEMENTS 2025	247

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

1 Other operating expenses


EUR thousand	1–12/2025	1–12/2024

Rental expenses	-804	-1,418
IT expenses	-3,152	-3,341
External services	-7,514	-10,023
Other staff costs	-1,800	-1,435
Other	-5,071	-5,227
Total	-18,341	-21,445

Item Other includes e.g. administration fees.

2 Auditors' fees


EUR thousand	1–12/2025	1–12/2024

Auditing fees	-460	-450
CSRD assurance	-105	-137
Other fees	-208	-204
Total	-773	-791

3 Financial income and expense


EUR thousand	1–12/2025	1–12/2024

Dividend income	1,502,227	767,527
Interest income	87,938	67,374
Interest expense	-70,493	-68,143
Gains on disposal	57,776	1,198,547
Exchange result	-3,609	13,569
Other	-25,022	-73,905
Total	1,548,817	1,904,968

In 2025, gains on disposal include income on the partial sale of shares in NOBA Group,

amounting to EUR 58 million.

In 2025, Sampo repurchased EUR 316 million in aggregate nominal value of its Tier 2

notes due 2052 for EUR 295 million. The positive one-off effect of around EUR 20

million is presented under Other.

In 2024, the gains on disposal consist of the sale gain of 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


EUR thousand	2025	2024

Carrying amount at the beginning of the year	1,724,652	—
Additions	—	1,724,652
Disposals	-1,282	—
Carrying amount at the end of the year	1,723,370	1,724,652

In 2024, as part of the sale of shares in Topdanmark A/S, Sampo granted a loan of EUR

1,724 million to If Holding. The loan consisted of EUR nominated facility of 862 million

and DKK nominated facility of 6,432 million (approx. EUR 862 million). The loans are

unsecured and have no fixed maturity date. The EUR-denominated loan carries interest

at a rate of 3-month EURIBOR plus margin of 1.06%. The DKK-denominated loan

carries interest at a rate of 3-month DKK CIBOR plus margin of 1.20%.

5 Other shares and participations


EUR thousand	2025	2024

Acquisition cost 1 January	523,680	875,672
Increase	561	—
Decrease	-123,978	-351,993
Acquisition cost 31 December	400,262	523,680

In 2025, decrease in acquisition cost include the partial sale of NOBA Group shares

amounting to EUR 98 million. In addition, a permanent impairment of EUR 26 million

was recognised in the investment of H&F Evergood partners SA private equity fund.

In 2024, the decrease in Other shares included the sale of Saxo Bank AS shares

amounting to EUR 284 million and the permanent impairment of EUR 68 million in H&F

Evergood partners SA private equity fund.


	FINANCIAL STATEMENTS 2025	248

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

6 Other investments


EUR thousand	2025	2024

Acquisition cost 1 January	478,899	706,062
Increase	1,505,927	1,659,172
Decrease	-1,457,234	-1,886,335
Acquisition cost 31 December	527,592	478,899


EUR thousand	2025	2024

Bonds	235,525	75,285
Money market	202,258	302,648
Loan receivable	89,810	100,966
Total	527,592	478,899

7 Other receivables


EUR thousand	2025	2024

Derivative guarantees	28,060	24,620
Other	11	394
Total	28,071	25,014

8 Prepayments and accrued income


EUR thousand	2025	2024

Accrued interest	12,779	14,793
Derivatives	30	—
Other	4,563	2,997
Total	17,372	17,790


EUR thousand	2025	Fair value		2024	Fair value
Derivatives	Contract /notional value	Assets	Liabilities	Contract /notional value	Assets	Liabilities

Derivatives held for trading
Interest rate derivatives	84,438	—	23,430	84,782	—	24,791
Foreign exchange derivatives	364,997	—	4,776	—	—	—
Total	449,435	—	28,205	84,782	—	24,791


	FINANCIAL STATEMENTS 2025	249

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

9 Movements in the parent company's equity


	Restricted equity	Unrestricted equity
EUR thousand	Share capital	Invested unrestricted capital	Other reserves	Retained earnings	Total

Carrying amount at 1 January 2024	98,114	1,526,688	272,662	3,567,312	5,464,776
Dividends	—	—	—	-903,234	-903,234
Acquisition of own shares	—	—	—	-475,190	-475,190
Directed share issue	—	2,000,246	—	—	2,000,246
Profit for the year	—	—	—	1,862,475	1,862,475
Carrying amount at 31 December 2024	98,114	3,526,934	272,662	4,051,363	7,949,073

In 2024, 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.


	Restricted equity	Unrestricted equity
EUR thousand	Share capital	Invested unrestricted capital	Other reserves	Retained earnings	Total

Carrying amount at 1 January 2025	98,114	3,526,934	272,662	4,051,363	7,949,073
Dividends	—	—	—	-915,021	-915,021
Acquisition of own shares	—	—	—	-289,905	-289,905
Profit for the year	—	—	—	1,503,822	1,503,822
Carrying amount at 31 December 2025	98,114	3,526,934	272,662	4,350,259	8,247,969

Distributable funds


EUR thousand	2025	2024

Parent company
Profit for the year	1,503,822	1,862,475
Retained earnings	2,846,437	2,188,888
Invested unrestricted capital	3,526,934	3,526,934
Other reserves	272,662	272,662
Total	8,149,856	7,850,959


	FINANCIAL STATEMENTS 2025	250

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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


EUR thousand	2025	2024

Deferred interest	28,523	28,461
Derivatives	28,205	24,791
Other	14,249	19,180
Total	70,977	72,432

Additional information on derivatives is included in the note 8.

12 Long-term liabilities


EUR thousand	2025	2024

Issued Tier 1 notes	299,975	—
Subordinated debt securities	1,178,240	1,491,077
Bonds	787,051	791,952
Total	2,265,265	2,283,029

In September 2025, Sampo issued new restricted Tier 1 notes amounting to EUR 300

million with a coupon rate of 5.25 per cent and an option of a first call date in 2035 for

Sampo. The restricted Tier 1 instrument is accounted for as a financial liability.

Transaction costs related to the issue of the notes were recognised as expense in the

income statement.

During the reporting period, Sampo launched a EUR 300 million tender offer for its

Tier 2 notes. As a result, Sampo repurchased EUR 316 million in aggregate nominal

value of its Tier 2 notes due 2052 for EUR 295 million.

More information can be found in Sampo Group’s consolidated not e 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 2025 or 2024.

14 Pension liabilities

The basic and supplementary pension insurance of Sampo plc’s employees is handled

through insurance policies in pension insurance companies in Finland, Sweden and

Norway.

15 Rental commitments


EUR thousand	2025	2024

Not more than one year	1,273	654
Over one year but not more than ten years	15,017	15,045
Total	16,290	15,699

During the comparative period 2024, Sampo plc signed a ten-year rental agreement

for new office premises. The lease period started in June 2025.

16 Other liabilities and commitments

Sampo plc has granted a credit facility to Hastings Group Holdings Ltd of GBP 75

million (EUR 86 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.

Th e fund comm itments given amounted to EUR 6 (7) million.

17 Number of personnel


	2025 Average during the year	2024 Average during the year

Full-time personnel	67	61
Temporary personnel	3	4
Total	70	65


	FINANCIAL STATEMENTS 2025	251

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

18 Salaries and remuneration of the Board

and the Group CEO


EUR thousand		2025	2024

Group CEO	Morten Thorsrud, as of 1 October 2025	271	—
	Torbjörn Magnusson, until 30 September 2025 ¹	6033	4257
Members of the Board of Directors
Antti Mäkinen		243	235
Christian Clausen		108	104
Georg Ehrnrooth		—	104
Jannica Fagerholm		—	164
Steve Langan		115	111
Risto Murto		140	104
Markus Rauramo		138	111
Annica Witschard		115	111
Astrid Stange		115	111
Sara Mella		115	—

¹Torbjörn Magnusson continued in Sampo as Senior Advisor until 31 December 2025.

In accordance with the decision of the Annual General Meeting in 2025, the company

has compensated the transfer tax related to the acquisition of the company shares, in

total EUR 5.424,23 (EUR 1.818,56 pertaining to the Chairman and EUR 3.605,67 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 accrued during the year

President/CEO¹
Morten Thorsrud, as of 1 October 2025	6	39	45
Torbjörn Magnusson, until 30 September 2025	1,050	877	1,927
Former Chairmen of the Board
Kalevi Keinänen²	14	—	14
Former Presidents/CEO:s
Harri Hollmen³	37	—	37
Total	1,107	916	2,023

¹The Group CEO is entitled to a supplementary pension in accordance with the present pension

contract. Torbjörn Magnusson continued in Sampo as Senior Advisor until 31 December 2025.

²Group 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 2025 is based on a

TyEL index adjustment.

³Group 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 2025 is based on a TyEL index adjustment.


	FINANCIAL STATEMENTS 2025	252

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

20 Shares held


	2025		2024
Company name	Percentage of share capital held	Carrying amount EUR thousand	Percentage of share capital held	Carrying amount EUR thousand

Group undertakings

P&C insurance
If P&C Insurance Holding Ltd, Stockholm, Sweden	100	4,820,130	100	4,820,130
Hastings Group (Consolidated) Plc, London, United Kingdom	100	2,627,488	100	2,627,488

Sampo Plc has branches located in Sweden, Denmark and Norway.

In 2024, Sampo plc sold the shares of Topdanmark A/S to If P&C Insurance Holding

Ltd. For a more detailed description of the transaction, please see Sampo Group

financial statements’ note 28.


	FINANCIAL STATEMENTS 2025	253

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2026

Sampo plc

Board of Directors


Christian Clausen		Steve Langan		Sara Mella

Risto Murto				Markus Rauramo

	Astrid Stange		Annica Witschard

	Antti Mäkinen Chairman		Morten Thorsrud Group CEO


	FINANCIAL STATEMENTS 2025	254

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Auditor’s note

An auditor's report on the audit performed has been issued today.

Helsinki, 13 March 2026

Deloitte Oy

Audit firm

Jukka Vattulainen

APA


	FINANCIAL STATEMENTS 2025	255

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 2025. 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 2025	256

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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 31.12.2025 Sampo Group has insurance contract liabilities totalling EUR 12,760 million (2024: EUR 12,286 million), consisting primarily of property and casualty insurance contract liabilities. The measurement of insurance liabilities consists of the liability for remaining coverage and the liability for incurred claims including both reported but not settled claims as well as incurred but not reported claims. 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 2025	257

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements


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 17,154 million (2024: EUR 16,090 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 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 2025	258

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 the 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 2025	259

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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 5 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 statements based on law

Our responsibility is to, based on our audit, express an

opinion on the registration and publication of the income

tax report required in Chapter 7 b of the Accounting Act.

The Board of Directors and the Group CEO are

responsible for the registration and the publication of

the income tax report.

In our opinion, the company has not been obliged to

Chapter 7 b of the Accounting Act for the financial year

immediately preceding the financial year.

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 2026

Deloitte Oy

Audit Firm

Jukka Vattulainen

Authorised Public Accountant (KHT)


	FINANCIAL STATEMENTS 2025	260

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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

reporting period 1.1.–31.12.2025.

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), and

• 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).

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 requirement in the

absence of requirements for the tagging of

sustainability information in 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.

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 2025	261

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Responsibilities of the Board of

Directors and the Group CEO

The Board of Directors and the Group CEO 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,

• 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, and

• such internal control as the Board of Directors and

the Group CEO 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 Statement, 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 according to

ESRS standards, management is required to prepare the

forward-looking information on the basis of disclosed

assumptions about events that may occur in the future,

possible future actions by the Group, and prepare the

forward-looking information based on these

assumptions. The actual outcome is likely to be different

since anticipated events frequently do not occur as

expected.

The determination of greenhouse gas emissions

involves inherent uncertainty due to incomplete

scientific knowledge used to define the numerical

values for emission factors and the combination of

emissions from different gases.

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.


	FINANCIAL STATEMENTS 2025	262

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

Compliance with the International Standard on

Assurance Engagements (ISAE) 3000 (Revised)

requires that we exercise professional judgment and

maintain professional skepticism 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.

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 company’s internal guidelines and policies relevant to the information

presented in the Sustainability Statement.

• 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 2026

Deloitte Oy

Authorised Sustainability Audit Firm

Jukka Vattulainen

Authorised Sustainability Auditor


	FINANCIAL STATEMENTS 2025	263

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

(Translation of the Finnish Original)

Independent auditor’s report on

the ESEF financial statements of Sampo plc

To the Board of Directors of Sampo plc

We have performed a reasonable assurance

engagement on the financial statements

(743700UF3RL386WIDA22-2025-12-31-1-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 31.12.2025.

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 the 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 2025	264

Board of Directors’ Report

Group’s IFRS Financial Statements

Sampo plc’s Financial Statements

≡

the financial statements

Sampo plc’s notes to

the financial statements

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

(743700UF3RL386WIDA22-2025-12-31-1-fi.zip) for the

financial year ended 31.12.2025 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 31.12.2025 has been expressed in our auditor’s

report dated 13 March 2026. 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 2026

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 21, 00130 Helsinki, Finland. The consolidated

financial statements of Sampo Group include Sampo plc together with its subsidiaries and associates as of 31 December 2025. The group subsidiaries have insurance and financing activities in Finland,

Sweden, Norway, Denmark, the Baltic countries, and the United Kingdom. A copy of Group’s financial statements is available at internet address www.sampo.com. Copyright Sampo plc, Finland.