If P&C Insurance
Material Topics
Sustainability statement, in full
The complete text of If P&C Insurance’s FY2025 sustainability statement is held here – 80 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
Governance roles
Reference: pages 11-13.
The Board of Directors of If P&C Insurance Holding Ltd (publ) had 4 elected members in 2025 (4 in 2024). None is employed by If; the Chair serves as an executive Chair. Women held 0% (0) of Board seats, and all members work for the owner, Sampo plc, so none is independent (page 11).
The Board is the overall governing body. It approves the annual report including the sustainability statement, the double materiality assessment, the climate transition plan and the policy framework, and it monitors progress on key sustainability targets at least annually (page 12). The managing director oversees implementation.
The Sustainability Committee, chaired by the CFO, is an advisory body that meets quarterly. The Chief Sustainability Officer coordinates the work with a sustainability office and core teams (page 12).
On skills, one Board member directs Sampo plc's Sustainability unit. The Board "receives regular training"; in May 2025 the boards of the subsidiaries If P&C Insurance Ltd and If Livförsäkring AB were trained on CSRD, ESRS and climate impacts, risks and opportunities (page 13).
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to the Board
Reference: page 13.
The Board of Directors of If P&C Insurance Holding Ltd (publ) met 14 times in 2025. It discusses sustainability regularly, and reports from the Compliance and Risk Management functions include sustainability matters (page 13).
Sustainability-related risks sit inside the overall risk framework, and the Board is responsible for making sure they are managed and controlled. Meeting materials go out before each meeting.
Topics handled at 2025 Board meetings included policy updates, regulatory developments on sustainability, sustainability reporting, and information security, non-compliance incidents and internal control effectiveness.
In 2025 the Board approved the 2024 annual report including its sustainability statement, so climate mitigation impacts, risks and opportunities and the science-based targets were overseen through that approval.
The due diligence process under the OECD Guidelines for Multinational Enterprises, first built in Norway for the Norwegian Transparency Act, is described in GOV-4.
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Sustainability in incentive schemes
Reference: page 13.
Board members do not take part in any incentive scheme issued by the company. A new managing director was appointed on 1 October 2025, after the previous one became Group CEO of Sampo Group (page 13).
The managing director joins an annual short-term incentive program based on If's key performance indicators, business area results and individual performance. Sustainability-related metrics in the annual programs are customer retention, customer satisfaction and employee engagement.
Both managing directors took part in two long-term incentive schemes in 2025 (LTI 2024 and LTI 2025). Under both, 10% of the reward depends on Sampo Group's sustainability work, measured through group and subsidiary balanced scorecards on developing, implementing and delivering the science-based targets.
The Board approves the Remuneration Policy each year, along with the forms of variable pay and the managing director's maximum variable compensation. The 10% covers Sampo Group's sustainability work as a whole, so no climate-only share of pay is stated.
GOV-3(was GOV-4)Statement on due diligenceReported
Due diligence statement
Reference: pages 14-16.
Sampo Group is a signatory of the UN Global Compact, and If builds its due diligence on the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles and core ILO standards (page 14). A table maps the core due diligence steps to sections of the statement (GOV-4 table, pages 14-15).
By stakeholder group, the report describes: employee channels such as surveys, work environment councils and incident reporting; underwriting screens corporate clients against UN Global Compact principles through an external research provider; investments use an internal ESG traffic light model plus sector and norm-based screening; suppliers get a four-step process with the Supplier Code of Conduct (pages 14-15).
If is also subject to the Norwegian Transparency Act. It is the second largest insurer in Norway, with about 21% market share and about 1,800 employees there (page 16).
Result: no actual negative impact on value chain workers identified. In 2025, 0 (0) severe human rights incidents were reported in the upstream and downstream value chain (page 16).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal control
Reference: page 16.
Risk management over sustainability reporting is part of If's overall framework and uses the three lines model. The first line is the business areas, the Claims unit and corporate functions; the second is the Risk Management, Compliance and Actuarial functions; Internal Audit is the third (page 16).
Risks are assessed on impact and likelihood. The main reporting risks named are inaccurate or incomplete data and inadequate presentation of the sustainability reporting (page 16).
Controls listed: the four eyes principle in production, reconciliation of data to check completeness, and IT controls such as access rights and segregation of duties in the reporting system. Key controls have been built for the most critical reporting risks.
Highly rated risks are followed up by risk owners in the first line and by the second line. The second line reports key findings to the Risk Committee, the managing director and the Board (page 16).
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: pages 16-18.
If sells insurance to individuals, businesses and large industrial companies, with around 4.6 million customers in the Nordic and Baltic countries and branch offices in France, Germany, the Netherlands and the United Kingdom (page 16).
Business areas: Private, Commercial (small and medium-sized companies), Industrial (large corporations) and the Baltics. Private produces more than half of insurance revenue (vehicle, property and personal insurance).
Headcount at 31 December 2025 was 11,178 (11,172). Insurance revenue was MSEK 85,251 (68,045) (page 16).
The strategy rests on a "sustainable business model" with three parts: Best in risk, Scale-driven and Strong team (page 17). The sustainability approach has three commitments: to customers, to employees and to society (page 18).
Value chain: own operations are own offices and employees; upstream is suppliers of office products and services; downstream is claims suppliers, business partners, investees and customers (page 18).
SBM-2Interests and views of stakeholdersReported
Stakeholder interests and views
Reference: pages 19-21.
If names five primary stakeholder groups: customers, employees, partners and suppliers, investee companies, and authorities and local communities (page 19). A stakeholder engagement table (page 20) sets out purpose, forums for dialogue, discussion topics and value created for each group.
Forums include customer meetings, satisfaction surveys and the Customer Ombudsman; leader-employee dialogues, work environment councils, union meetings and engagement surveys; supplier meetings and due diligence; investee meetings and annual general meetings; and meetings with supervisory authorities.
The double materiality assessment identified two stakeholder types: those affected by the business, and users of the statement (page 19).
The Board is informed of stakeholder views through regular reporting. If states it "assumes that the key stakeholders support the chosen strategy and business model" because of continuous dialogue (page 19). Value chain workers are engaged indirectly, through the due diligence process.
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities
Reference: pages 21-23.
The double materiality assessment results table (page 21) marks six topics material: E1 Climate change (impact and financial), E5 Resource use and circular economy (impact only), S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users and G1 Business conduct (all impact and financial). E2, E3, E4 and S3 are not material.
If reports no change to material topics after its 2025 review. It added entity-specific metrics for E1, E5, S1, S2 and S4 (page 21).
If does not expect material adjustments to the carrying amounts of assets and liabilities within the next annual reporting period (page 21).
Climate: physical risks (storms, floods) and transition risks, managed through reinsurance, pricing and diversification. Resilience is assessed within existing risk, strategy and sustainability processes (page 21). Detailed IRO tables sit at the head of each topical chapter (pages 34, 48, 50, 60, 65, 71).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Process to identify and assess IROs
Reference: pages 22-23.
If completed its first double materiality assessment in 2024 and reviews it yearly. In 2025 If P&C Insurance Ltd merged with Topdanmark A/S, with no change to reported topics (page 22).
Process: an initial list of impacts, risks and opportunities from ESRS, the prior assessment and industry benchmarks; mapping to the value chain; interviews and workshops with internal experts; external research. Time horizons are short (one year), medium (up to five) and long (over five) (page 22).
Impacts are scored on severity and likelihood, with severity first for potential human rights impacts. Financial materiality uses magnitude and likelihood. Thresholds were set with Sampo's Sustainability unit, are quantitative but used as a judgment aid, and "the assessment is primarily qualitative" (page 22).
The Sustainability Committee and steering group reviewed results; the Board validates them. Pollution and water were not screened; biodiversity had an initial portfolio screening (page 23).
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
ESRS disclosure requirements covered
Reference: pages 23-24.
If reports on the disclosure requirements for E1, E5, S1, S2, S4 and G1. It does not report on E2, E3 and S3 because their impacts, risks and opportunities were not assessed as material, and not on E4 because the topic "is not material based on internal analysis and external stakeholder feedback" (pages 23-24). It adds that many E4 requirements are "in many cases not applicable" to insurers (page 24).
Responsible investments and responsible underwriting are called material but are not entity-specific topics; they are covered inside E1 and S2 (page 23).
The content index is Appendix 1 (pages 75-76), listing each requirement with a page. Appendix 2 (pages 77-81) maps datapoints from other EU legislation and marks several "Not material" or "Phased-in".
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: page 38.
If committed to the Science Based Targets initiative in October 2021, and the SBTi approved its near-term targets in December 2023. The plan rests on those targets and related action plans; the targets are set under SBTi's financial sector guidance (page 38).
Targets were approved by the Board and validated by executive management. Scope 1 and 2 emissions are tracked quarterly, supplier engagement targets twice a year and investment targets quarterly. In 2025 If began measuring insurance-associated emissions (page 38).
Decarbonization levers: electrifying the car fleet; switching to renewable energy and cutting office energy use; supplier engagement; sustainable claims handling; responsible investments.
If "has not identified any locked-in GHG emissions from key assets and products". A cost assessment found the actions bring increased costs that are "not seen as significant" and hard to separate from normal operations; no amounts are given. If is not excluded from the EU Paris-Aligned Benchmarks (page 38). Targets are detailed in E1-4 (page 43).
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from ESRS 2 SBM-3 (Scenario analysis, pages 35-38) and IRO-1 (page 23), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Reference: pages 35-38.
Risk types (pages 23, 34): physical risks (windstorms, floods, heavy rainfall, landslides, erosion, heatwaves, rising sea levels) and transition risks (regulation, technology, customer behavior, stakeholder concern).
Scenario analysis (page 35): with external vendor ORTEC Finance, If analyzed its investment portfolio over 40 years in four pathways: Net-Zero (net-zero CO2 by 2050), Net-Zero Financial Crisis (disorderly transition), Limited Action (2.8°C warming) and High Warming (4.2°C by 2100, physical risk focus).
For underwriting, GDP and inflation forecasts were used, and a natural catastrophe sensitivity doubled the claims cost share by the end of the forecast period, with and without lagged repricing (page 37). Solvency was assessed qualitatively (page 38).
The report does not say when the analysis was run or name a published scenario set.
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 21 and 35-38). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Reference: pages 21, 35-38.
If states resilience "is assessed as a part of the existing processes for risk management, strategy development and sustainability management" (page 21).
Conclusion: both underwriting and investment returns "are resilient to climate changes" (pages 21, 35).
- Investments: relatively resilient in all four pathways. The main short-term risk is the pricing-in shock in Net-Zero Financial Crisis; long-term returns fall in all pathways from rising physical risk (page 36).
- Underwriting: combined GDP and inflation effects on the insurance result are limited; the natural catastrophe claims assumption has a more material effect, and timely repricing matters (page 37).
- Solvency: assessed qualitatively; pressure could build in Limited Action and High Warming (page 38).
Mitigants named: pricing, reinsurance and diversification (page 34).
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: page 39.
If lists four policies that address climate mitigation and adaptation: the Sustainability Policy, the Responsible Investment Policy, the Supplier Code of Conduct and the Underwriting Policy (page 39). A table shows what each covers. Mitigation and adaptation are marked "Addressed" for all four; energy efficiency is addressed in three (not the Underwriting Policy); renewable energy is addressed in the Sustainability Policy and Supplier Code of Conduct only.
The Sustainability Policy sets out loss prevention services and states If prioritizes renewable energy when possible and a "meeting instead of travelling" approach (page 39).
The Responsible Investment Policy uses ESG ratings, sector screening and norm-based research, and carries the near-term science-based targets for investments (page 39).
The Supplier Code of Conduct requires suppliers to reduce energy use and GHG emissions. The Underwriting Policy expects corporate clients to respect UN Global Compact principles (pages 39-40).
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 40-43.
If says no significant additional costs attach to planned and implemented actions (page 40).
Own operations: 88% (87) of company vehicles are plug-in hybrid or electric; 92.3% (66.5) of electricity came from renewable sources in 2025. If estimates fleet electrification will deliver 7-11% and the switch to renewable energy 66-79% of the Scope 1 and 2 reduction needed by 2030 (page 40).
Supplier engagement: a program built in 2025 around impact analysis, supplier segmentation and a climate maturity framework, with a pilot planned for 2026 (page 41).
Investments: no new coal investments; one existing holding of MSEK 558 (0.4%) with indirect coal involvement. More than MSEK 15,500 sits in green bonds. A pilot engagement with one company started in 2025 (pages 41-42).
Underwriting: insurance-associated emissions first estimated, 436,660 tCO2eq (corporate) and 336,429 tCO2eq (private motor) (page 42). Adaptation covers pricing, loss prevention and claims handling (pages 42-43).
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: pages 43-44.
If's near-term science-based targets, built on SBTi's financial sector guidance (page 43):
- Scope 1 and 2: cut absolute emissions 42.5% by 2030 from 2020, from 7,033 to 4,044 tCO2eq. Status at 31 December 2025: reduction of 58.5%.
- Suppliers (Scope 3, categories 1-14): 30.0% of suppliers by spend to have science-based targets by 2028. Status: 23.8% (property and motor).
- Investments: four portfolio temperature score targets for 2027, for example listed equity and corporate bonds from 2.52°C (2020) to 2.04°C, status 1.89°C; corporate loans 2.91°C to 2.25°C, status 2.65°C.
- Real estate (SDA): cut commercial real estate intensity 57.2% per square meter by 2028, status 80.0%.
Targets cover 85% of assets under management at 2020 (page 44). The 2020 base year was recalculated to include former Topdanmark A/S. Where the CDP-WWF tool gave scores outside its range, If tracks adjusted targets too (page 44). No adaptation target is reported.
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and total GHG emissions
Reference: pages 44-47.
2025 emissions in tCO2eq (2024 comparative, restated) (page 46):
- Scope 1: 1,514 (1,352), +12.0%
- Scope 2 market-based: 1,408 (3,631), -61.2%; location-based 1,578 (2,169)
- Scope 3: 452,818 (355,587), +27.3%. Largest: investments 347,084 (+37.2%) and use of sold products (claims) 88,618, unchanged
- Total market-based: 455,739 (360,570)
Intensity is 0.000005 tCO2eq per SEK of insurance revenue (page 47). If says 2025 was the first full year with former Topdanmark A/S, so 2020 and 2024 were recalculated; 2020 Scope 1 rose from 287 to 2,178 (page 44).
Data quality: 62.1% of Scope 3 categories 1-10 and 12-14 is primary data; 66.2% of investment data is primary, with 85.0% asset coverage (page 45). A footnote reports financed Scope 3 of 5,122,791 tCO2eq (page 46). Scope 3 categories 8, 9, 10 and 12 are not reported because If does not assess them as material.
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: page 48.
If cites two policies for resource use and circularity: the Sustainability Policy and the Supplier Code of Conduct (page 48).
Under the Sustainability Policy, circular economy and resource use are part of If's sustainability commitments. If strives to reduce waste, reuse and recycle resources, and minimize the use of chemicals and hazardous substances. It also aims to use water and energy responsibly. A stated priority is contributing risk research and data that could lower resource use through avoided damage.
The Supplier Code of Conduct requires suppliers to identify, monitor, control and manage emissions to air, water and soil and waste; to reduce waste and reuse and recycle resources "to the greatest extent possible"; to use water responsibly and treat and reuse it where possible.
Vehicle and property repair contractors face extra sector-specific environmental requirements, described in E5-2 (page 48). The report links these policies to E1-2 for further detail.
E5-2Actions and resources related to resource use and circular economyReported
Actions and resources related to resource use and circular economy
Reference: pages 48-49.
If "does not produce, sell or handle physical goods", so its actions work through the value chain, mainly claims handling (page 48). Suppliers in vehicle and property claims must follow the Additional Environmental Requirements written into purchasing agreements.
Property repairs: contractors must repair more, use less material, demolish less, use remote work with video and sensors, and use certified materials when available. A 2025 pilot with several partners on reducing material use when renovating floors found partner readiness differs by country; If has agreements with partners focused on "smart repair" (page 49).
Vehicle repairs: contractors must repair rather than replace parts and reuse spare parts. An estimated 3,374 tonnes of metal and plastics were saved in 2025 by repairing rather than exchanging parts, and more than 71,000 photo inspections replaced workshop visits in the Nordics (page 49).
If works with dismantlers to get used parts and promotes windscreen and bumper repair. Costs are not deemed significant and are hard to separate from day-to-day operations.
E5-3Targets related to resource use and circular economyReported
Targets related to resource use and circular economy
Reference: page 49.
If has not set specific measurable outcome-related targets for its resource use and circular economy actions (page 49). Its reasoning: the main impacts, risks and opportunities sit in claims handling, where circular solutions "are currently evolving" and vary by country in availability, quality and price, so time-bound targets are seen as difficult at this stage.
Instead the Claims unit works with internal goals that are set and followed up yearly, and If reviews the process regularly. If also works with suppliers to limit material use and raise the share of recycled parts.
Progress is tracked through the metric "Circular economy in claims handling (vehicle repairs)", Nordic operations only (page 49):
- Share of reused parts: 5.8% in 2025 (5.2% in 2024)
- Share of glass repairs: 41.2% (38.0%)
If says the focus on vehicle repairs reflects a more mature reused-parts market than for property repairs, and it aims to add metrics later.
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 51-52.
Sampo Group's Code of Conduct, which applies to If, covers human rights, labor practices, diversity, equity and inclusion, well-being and competence development. It condemns forced and compulsory labor, child labor and human trafficking (page 51).
Working conditions: the Sustainability Policy commits If to a healthy, safe and attractive work environment, covering physical and psychological safety. The HR Policy asks for a health-promoting workplace with preventive care and rehabilitation. If is legally required to plan the work environment systematically and sets local work environment plans each year. Employees get health insurance, sick pay, rehabilitation and conversion support after redundancy (page 51).
Equal treatment: the Diversity, Equity and Inclusion Instruction bars discrimination and harassment. A Head of DEI reports to the Head of People Strategy and Culture, and regular pay gap analyses support equal pay (page 52).
Privacy: the Ethics Policy and Personal Data Policy govern employee data, with a process for reporting and handling breaches (page 52).
S1-2(was S1-2 + S1-3)Engagement with own workforce and workers' representatives, existence of channels for own workforce to raise concerns or needs and approaches to remedyReported
Engaging with own workers and their representatives
Reference: page 52.
If engages with employees through leader-employee dialogues, work environment councils, meetings with union representatives and bi-annual employee surveys. The response rate was 85% in both the spring and autumn 2025 surveys.
If does not have a Global Framework Agreement. It has an information and consultation agreement with workers' representatives based on European Works Council rules. The top forum is the Communication Council, chaired by the Head of HR with the managing director as a member, which meets quarterly. A temporary Integration Council, set up for the Topdanmark integration, closed in autumn 2025.
For inclusion, the goal is that at least 85% of employees agree they feel included, with results examined by gender, age and two If Specifically Underrepresented Groups. A DEI maturity model has four stages: Global compliance, Developing, Proficient and Strategic.
Surveys also measure well-being and trust, and managers discuss results with their teams.
Remediation and channels to raise concerns
Reference: pages 52-53.
Employees can raise concerns with their leader, in employee surveys, with HR, work environment councils, employee representatives, health and safety representatives, or through the whistleblowing system. Main reporting channels are confidential but not anonymous; the whistleblowing system is anonymous, confidential and run by an external party (pages 52-53).
The business incident reporting system holds reported incidents that could harm operations, customers or employee safety. Incidents on ethics, including harassment and discrimination, go to the Ethics Committee (page 53).
Bi-annual surveys test willingness to speak up and whether the channels are fit for purpose. If says it "does not have a formal process to assess its own workforce's awareness" of the procedures, but notes the channels have been used, which indicates they are accessible and visible (page 53).
The Whistleblowing Instruction explains the right to anonymous reporting and states that a case will be investigated if reported in good faith.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Actions on material impacts on own workforce
Reference: pages 53-54.
Working conditions: the main task in 2025 was integrating Topdanmark A/S. If supported employees through frequent communication and leader training. Growth talks and the One Responsible If training will not be mandatory for former Topdanmark staff until 2026. The health strategy from 2024 continued, with seminars on resilience and stress; approximately 500 leaders attended global leadership seminars on the psychosocial work environment. An AI ambassador program had 94% of participants satisfied or very satisfied (page 53).
Equal treatment: actions follow the DEI maturity model. A new neurodiversity maturity model was introduced. Cases of discrimination and harassment go to the Ethics Committee. If runs an annual equal pay analysis with an action plan to fix unwarranted individual gaps (page 54). The "final candidate principle" for senior roles showed some improvement, though the integration complicated follow-up.
Privacy: employee data was integrated into one system in steps, with testing and a dedicated HR expert (page 54).
If monitors workforce data quarterly and does a deeper analysis yearly (page 54).
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: page 54.
If has set time-bound, outcome-oriented targets through its employee engagement surveys. The eNPS target is above 50 for H1 and above 45 for H2. Results were 36 in the spring survey and 23 in the autumn survey, the autumn figure including former Topdanmark employees. Two minor subsidiaries run separate surveys and are excluded.
If says 2025 results fell compared with earlier years. It had expected a decrease because of the integration, organizational changes and the relaunch of workplace guidelines for hybrid work. It expects team leaders to analyze results and act, and the stated aim is to reverse the negative trend in spring 2026.
Survey targets are agreed with management and union representatives and results are shared with all employees. Participation was 85% in both surveys.
A separate inclusion goal of at least 85% of employees feeling included appears in S1-2 (page 52).
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of employees
Reference: pages 55-56.
At 31 December 2025 If had 11,178 employees by headcount (11,172 in 2024) and 10,460 FTE (10,570) (page 55). By gender: 5,838 women and 5,340 men; If only collects binary gender data because of legal restrictions (page 55).
By country, headcount: Denmark 2,863, Sweden 2,781, Finland 2,090, Norway 1,785, Latvia 577, Estonia 542, Spain 323, Lithuania 189, and 351 elsewhere (pages 55-56).
Contract types: 11,090 permanent and 88 temporary employees; 158 with non-guaranteed hours; 10,516 full-time and 662 part-time (pages 55-56).
Turnover: 1,090 terminations, a 10% rate (10% in 2024), counting voluntary and involuntary departures of full-time permanent monthly-paid staff. Rates ran from 6% in Estonia to 36% in "Other" countries (page 56). Hourly paid staff, summer workers and trainees are excluded (page 55).
If notes headcount was stable except for the Topdanmark integration (page 55).
S1-6(was S1-7)Characteristics of non-employee workersReported
Characteristics of non-employee workers
Reference: page 56.
On 31 December 2025 the number of non-employees registered in the HR systems was 1,565 (1,825 in 2024). Non-employees are primarily consultants hired by the company or independent contractors, for example consultants working in IT (page 56).
The report gives no further breakdown of this group by type, country or gender.
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Collective bargaining coverage and social dialogue
Reference: pages 56-57.
85% (79% in 2024) of employees are represented by an independent trade union or covered by collective bargaining agreements. The figure counts only employees fully covered by agreements in places where unions are formally recognized. The agreements still set the terms of employment for most employees, excluding top management, even where they are not covered (pages 56-57).
There are several agreements across the EEA, depending on country and practice. If follows local rules and respects freedom of association. Information on trade unions is on the intranet and part of new-employee induction.
If has no Global Framework Agreement but does have an information and consultation agreement with workers' representatives, modeled on European Works Council rules. The Communication Council, chaired by the Head of HR, meets quarterly (pages 56-57).
Coverage is shown by country for those with more than 50 employees, representing over 10% of total employees (page 57). The report says there were no major changes in 2025.
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: page 57.
If says 2025 and 2024 are not comparable because of management structure changes tied to the Topdanmark integration.
Top management is defined as the managing director and those reporting to the managing director. At 31 December 2025:
- Level 1 (managing director): 1 man, 0 women
- Level 2: 2 women (33%) and 4 men (67%)
- Level 3: 11 women (30%) and 25 men (70%)
Age distribution by headcount at year end 2025: under 30, 1,668 (14.9%); 30-50, 6,175 (55.2%); over 50, 3,335 (29.8%). The over-50 share was 27.2% in 2024.
Board gender balance is reported under GOV-1: women held 0% of seats on the Board of the holding company (page 11).
S1-9(was S1-10)Adequate wagesReported
Adequate wages
Reference: page 58.
If states that remuneration depends on objective criteria, such as work experience, competence, position and responsibilities, and that all employees are paid an adequate wage in line with applicable benchmarks (page 58).
Pay and benefits are not based on or affected by gender or other non-professional factors. Job title and job position structures keep employees in the same position on the same conditions, and internal and external benchmarks are used to set salary ranges.
The report gives no figures on the number of employees below an adequate wage benchmark or the benchmark used.
S1-10(was S1-11)Social protectionReported
Social protection
Reference: page 58.
If states that all employees are covered by social protection against loss of income from major life events: sickness, unemployment, employment injury and acquired disability, parental leave and retirement (page 58).
The report gives no country-by-country breakdown. Related benefits are described under S1-1, where employees are offered health insurance covering illness and accidents, partial income compensation during sickness, rehabilitation, and conversion support in case of dismissal due to shortage of work (page 51).
S1-11(was S1-12)Persons with disabilitiesReported
Persons with disabilities
Reference: page 58.
If states: "If does not collect data on disabilities due to legal restrictions" (page 58). No headcount or share of employees with disabilities is therefore reported.
The disclosure is a single statement with no table or further breakdown. Related qualitative material sits under S1-1 and S1-4 (pages 51, 54).
S1-12(was S1-13)Training and skills development metricsReported
Training and skills development metrics
Reference: page 58.
Metrics are calculated on headcount. If says it developed its reporting processes for skills development in 2025 and that further development is needed in coming years (page 58).
Growth talks are the main process: forward-looking conversations on feedback, ambitions and skills. The recommendation is two talks a year, documented. All employees are eligible for regular career development reviews. Growth talks were not implemented in former Topdanmark A/S in 2025 and will launch in 2026.
Average training hours by gender include mandatory internal training and leadership training, and are calculated by dividing total hours by average headcount. A table gives the figures by gender.
The share of employees who took part in career development reviews was 51% in 2025, excluding former Topdanmark. For Topdanmark in 2024 the share was 70% overall (80% of women, 63% of men) (page 58).
Learning offers include job shadowing, job rotation, mentorships and Teams communities.
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: page 58.
100% (100%) of employees are covered by an occupational health and safety management system, which refers to the occupational healthcare services provided by the employer (page 58).
2025 figures, employees only:
- Fatalities from work-related injuries: 0 (0)
- Recordable work-related accidents: 38 (20 in 2024, restated)
- Rate of recordable work-related accidents: 2.19 per million hours worked (1.34 restated)
The 2024 figures were corrected for a clerical error; originally reported as 54 accidents and a rate of 3.62. In 2025 the hours-worked estimate moved from headcount to FTE average, so the comparison is not like for like (page 58).
If does not collect data on work-related ill health, deaths from ill health or days lost to ill health, citing legal restrictions. Non-employees are excluded.
S1-14(was S1-15)Work-life balance metricsReported
Work-life balance metrics
Reference: page 59.
All employees in the headcount are entitled to family-related leave through social policy or collective bargaining agreements. Family-related leave includes maternity, paternity, parental, carers and adoption leave (page 59).
Share of employees who took family-related leave, calculated against year-end headcount:
- Women: 12.0% (11.5% in 2024)
- Men: 8.7% (7.0%)
- Total: 10.4% (9.5%)
If notes that the 2024 numbers had been presented in the wrong order. For former Topdanmark in November-December 2024 the shares were 4.2% for women, 1.4% for men and 2.6% in total (page 59).
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total remuneration)
Reference: page 59.
Gender pay gap, 2025 (2024 restated): fixed remuneration 19.9% (16.8%); fixed and variable remuneration 23.3% (19.9%). The 2024 figures were corrected for a calculation error and were first reported as 16.9% (fixed) and 20.1 (fixed and variable) (page 59).
If says the gap "developed negatively" in 2025 partly because of a change in data delimitation and partly because of one-off payments to employees leaving in connection with the Topdanmark integration. Targeted actions include a wider candidate pool and a better recruitment toolbox, and revised job architecture ahead of the Pay Transparency Act in 2026.
Pay ratio of the highest paid individual to median annual remuneration: 32.1 (40.0). The method changed in 2025 because of the integration and payroll changes, so the years are not fully comparable (page 59).
The calculation covers monthly paid employees plus the executive management group and managing director, based on FTE average.
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: page 59.
In 2025 If reported 0 (0) severe human rights incidents concerning its own workforce (page 59).
Complaints through channels for the own workforce, including the whistleblower scheme, rose to 18 (3). Of these, 8 (0) were confirmed cases of discrimination or harassment. Corrective measures were taken under the internal process. None of the incidents or complaints led to fines, penalties or compensation for damages (page 59).
If says it refined its data collection for human rights incidents and complaints in 2025, which raised case numbers, and that former Topdanmark A/S was included for the full year against two months in 2024. The count of discrimination and harassment incidents uses the definitions in the Sampo Group Code of Conduct.
S2 – Workers in the Value Chain
S2-1Policies related to value chain workersReported
Policies related to value chain workers
Reference: page 61.
If works to make UN Global Compact principles part of strategy and daily operations, and its policies address value chain workers through customers (Underwriting Policy), investees (Responsible Investment Policy) and suppliers (Supplier Code of Conduct and Procurement Policy) (page 61).
- Underwriting Policy: corporate clients are expected to respect Global Compact principles; a client in breach is asked to remedy it or may be asked to find another insurer.
- Procurement Policy: suppliers must follow the Supplier Code of Conduct, backed by due diligence, audits, site visits and the right to end contracts.
- Supplier Code of Conduct: covers human rights, labor rights, environment and anti-corruption, and bars child and forced labor. It applies to suppliers' staff and contingent workers.
- Whistleblowing Instruction: lets value chain workers raise concerns in confidence.
If "was not made aware of any severe confirmed cases" of non-adherence to global standards for value chain workers during the reporting period (page 61).
S2-2(was S2-2 + S2-3)Engagement with workers in the value chain, existence of channels for workers in the value chain to raise concerns or needs and approaches to remedyReported
Engaging with value chain workers
Reference: page 62.
If says it "does not engage directly with its value chain workers or their legitimate representatives or credible proxies". Engagement is indirect, through suppliers, corporate customers and investee companies (page 62).
With claims suppliers, topics such as working conditions come up in meetings and site visits. A supplier in a high-risk sector or region fills out a self-assessment questionnaire with questions on workers' conditions and rights. Social questions are part of the screening of investees and larger commercial customers. Frequency depends on assessed risk (page 62).
Business support specialists, business developers or procurement specialists handle claims partner dialogues; the investment management team handles investees.
If has not identified vulnerable groups in its immediate value chain, but accepts it lacks full insight beyond tier 1 and that groups such as migrant workers in construction may exist (page 62).
Remediation and channels for value chain workers
Reference: pages 62-63.
If says it will cooperate in providing remedy under applicable law should it cause harm to value chain workers. Where non-compliance with the Supplier Code of Conduct, Responsible Investment Policy or Underwriting Policy is found, If engages with the supplier, client or investee to correct it, with reviews and follow-up. For a significant breach, or an unwilling party, it may terminate the contract or divest (page 62).
The whistleblowing platform is open to employees and external stakeholders, including value chain workers, and can take anonymous reports on legal breaches, criminal offenses and serious violations of human and labor rights. An external party runs it, separate from If's IT systems (pages 62-63).
Suppliers must tell their employees about the channel and report breaches of the Code to If.
If "currently has no formal processes for evaluating" whether the channel is used and trusted by value chain workers, though external stakeholders have used it (page 63).
S2-3(was S2-4)Taking action on material impacts on value chain workersReported
Actions on material impacts on value chain workers
Reference: pages 62-64.
If has identified no actual negative impact on value chain workers and rates the risk of a potential one as generally low. In 2025 0 (0) severe human rights incidents were reported in the value chain (page 63).
Suppliers: high-risk suppliers get a self-assessment questionnaire, possible corrective action plans, site visits or audits. A digital platform and consultancy support help purchasers, and former Topdanmark operations were brought into the process in 2025 (pages 62-63).
Investments: one portfolio company with a confirmed breach of competitive practices was found. Norm-based research shows confirmed incidents under 0.1%, credible allegations 1.5% and none or unconfirmed 98.4% (page 63). If reviewed 6 (7) potential engagements and joined 5 (4) pooled engagements.
Underwriting: If assessed 569 (533) corporate clients, 14 (15) were referred to the ESG team, and 1,074 have been assessed since 2021. Customers terminated: 0 (1) (page 63).
S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets for value chain workers
Reference: page 64.
If states that it "has not set group-wide and time-bound targets" for metrics on workers in the value chain, because challenges differ between business areas and a common measure is hard to find. Each business unit sets internal targets yearly, and many concern including the Supplier Code of Conduct in contracts or implementing due diligence. If is looking into a common target in coming years (page 64).
Tracked metric: share of existing supplier agreements that include the Supplier Code of Conduct, 94.0% in 2025 against 91.1% in 2024 (the Topdanmark figure at end 2024 was 57.0%). If says the share rose in 2025, that contract data was reviewed to align with the Code, and that templates now carry the Code's wording as standard (page 64).
The metric covers suppliers of office equipment, claims handling (repair shops, construction partners, health service providers) and IT hardware and software. Some suppliers, such as large IT companies and consultancies, are excluded.
S4 – Consumers and End-users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: pages 65-67.
If lists the Distribution Policy, Complaints Handling Policy, Whistleblowing Instruction and Personal Data Policy as examples that target consumers and end-users (page 65). Others cited: the Sampo Group Code of Conduct, Ethics Policy, Conflicts of Interest Policy, Sustainability Policy and Underwriting Policy (pages 65-66).
Content points: premiums are based on relevant data and never on discriminating factors such as sexual orientation, religious belief or ethnic background; information on costs, risks and conditions must be clear; marketing must not mislead; distribution must not reward sales that conflict with customers' interests (pages 65-66).
The Personal Data Policy requires lawful, fair processing, consent for sensitive data and rights to deletion, access and objection (pages 66-67).
If "was not made aware of any severe legal cases of non-adherence to global standards" for direct consumers and end-users during the year (page 65).
S4-2(was S4-2 + S4-3)Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedyReported
Engaging with consumers and end-users
Reference: page 67.
If engages through customer meetings, customer satisfaction surveys and the Customer Ombudsman, on a daily, weekly or monthly basis depending on the case. The most senior roles responsible are the heads of the business areas and the Claims unit, and the managing director (page 67).
The Customer Experience program makes sure feedback is collected, followed up and used in training and quality assurance, including follow-up with dissatisfied customers. Net Promoter Score is tracked against yearly targets, reported to top management and forms part of an employee reward program.
If says insurers are bound by law to design and sell products customers need. No minors are included in the provision of customer feedback. The Customer Ombudsman can suggest changes to customer handling or claims handling.
Central principles: premiums use only relevant data, and all customers are treated equally in claims handling, except in fraud handling.
Remediation and channels for consumers and end-users
Reference: page 67.
A customer who feels misinformed or does not understand policy terms can contact the Customer Ombudsman. The aim is a solution agreed by discussion; failing that, the customer can appeal to an external complaints board (page 67).
For personal data, If has an incident investigation and corrective action process and a Data Protection Officer with overall responsibility for compliance monitoring and contact with supervisory authorities. If a breach is likely to pose a high risk to individuals, affected people are told without undue delay (page 67).
Channels for concerns: customer service, the Customer Ombudsman, the whistleblowing channel (anonymous, run by an external party) and external complaints boards.
If "currently has no formal processes for evaluating" whether the whistleblowing channel and other channels are used and trusted by consumers, though external stakeholders have used the whistleblowing channel (page 67).
S4-3(was 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 actionsReported
Actions on material impacts on consumers and end-users
Reference: pages 67-68.
Data privacy: 2025 actions included staff training on data protection law, Data Protection Impact Assessments and Records of Processing Activities before new processing starts, privacy review of all new systems, and an updated process for data subject access requests. Staff may use public AI tools only for public data (page 68). The Topdanmark integration required aligning breach processes and merging privacy notices. Planned for 2026: better procurement and monitoring of data processors (page 68).
Loss prevention: house assessments for private customers with top-level cover, offered every four years; the If Building Check for small and medium-sized clients in Norway and Finland, offered every five years. Usage-based insurance uses car and phone data to encourage safer driving (page 68).
Preventive health: If published its Nordic Health Report for the third year in 2025 (page 68).
Resources are allocated across product development, sales and marketing, IT and risk management. No severe human rights issues are connected to these actions (page 68).
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets for consumers and end-users
Reference: pages 69-70.
Customer satisfaction: If uses transactional NPS (tNPS). The target for the Private business area is 57, and the result was 57 in 2025 (57 in 2024). Former Topdanmark set no separate target for 2025; its score was 55 (57 in 2024) (page 69). Targets and results are publicly disclosed. If says the NPS method has limits, including oversimplifying sentiment, and that external stakeholders were not directly involved in target setting. There was no change to the target definition.
Data privacy: the goal is to protect personal data. No numeric target is stated; effectiveness is tracked by metrics: complaints from data subjects and from data protection authorities, data breaches reported to authorities, and information security incidents (page 69).
In 2025 If reported 27 data breaches to the Swedish Data Protection Authority, and Topdanmark A/S reported 65 to the Danish authority until it merged into If P&C Insurance Ltd on 1 July 2025 (page 69). One information security incident was reported to the Financial Supervisory Authority (2024: 0) (page 70).
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 72-73.
If is committed to the UN Global Compact principles and applies them through the Sampo Group Code of Conduct, HR Policy, Ethics Policy, Underwriting Policy, Complaints Handling Policy, Whistleblowing Instruction, Responsible Investment Policy and Supplier Code of Conduct (page 72).
Culture work includes the Leadership Compass Programme, which began with 1,000 leaders in 2023, and the One Responsible If program, mandatory at onboarding and every year for all staff including the managing director and Board (page 72).
Anti-corruption: training covers ethics, AML/CTF and conflicts of interest, and checks screen customers for politically exposed person status and sanctions (pages 72-73).
Whistleblowing: the channel takes anonymous reports from employees and outsiders. The Chief Compliance Officer is responsible for it. Cases go quarterly to the Risk Committee and Sustainability Committee and yearly to the Board. A good-faith reporter will not lose their job or suffer sanctions (pages 72-73). Topdanmark's process merged with If's on 1 July 2025 (page 72).
G1-2(was G1-2 + G1-3)Actions related to business conductReported
Management of relationships with suppliers
Reference: page 73.
If is a major buyer of goods and services, especially in claims handling, and so affects the economy, environment and people. It encourages suppliers and partners to use more sustainable methods (page 73).
The Supplier Code of Conduct sets minimum sustainability requirements for all suppliers and business partners and doubles as a risk filter for choosing serious partners.
Due diligence processes follow the OECD Guidelines for Multinational Enterprises, to identify, avoid and address possible harm to human rights, labor, the environment and anti-corruption commitments in the supply chain. More detail sits in S2-2.
On payment practices, payments follow local law, and digital invoicing and regular use of the same suppliers support an automated flow that helps prevent late payments (page 73). Payment performance is reported under G1-6 (page 74).
Prevention and detection of corruption and bribery
Reference: page 73.
Incidents are detected through reporting channels such as the whistleblowing channel, screening of customers and investments, and supplier selection and risk assessment (page 73).
Corruption risk is a compliance risk inside the Operational and Compliance Risk Assessment process. Controls include steering documents, employee training, access rights, segregation of duties and the four eyes principle. Anti-corruption work is tied to anti-money laundering work, with checks on politically exposed persons and sanction lists. In 2025 If continued a project against organized crime.
The Board ensures resources through the Ethics Committee and Ethics Officers. Incidents reported through the whistleblowing channel go to the Sustainability Committee, the quarterly Risk Committee report and the Annual Compliance report to the Board.
One Responsible If is mandatory each year for all employees, including the Board and functions at risk. Former Topdanmark employees join from 2026.
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Back-filled from the business conduct chapter. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS, so the 2023 ESRS this report was prepared against had no separate targets requirement for G1.
Reference: pages 72-73.
The G1 chapter states no business conduct target. It describes how effectiveness is followed instead:
- The effectiveness of risk mitigation techniques "is monitored through various kinds of quality follow-ups in the business" (page 73).
- Corruption risk sits in the Operational and Compliance Risk Assessment process (page 73).
- Whistleblowing cases are reported quarterly to the Risk Committee and Sustainability Committee and in the Annual Compliance report to the Board (pages 72-73).
- Confirmed incidents of corruption or bribery are counted and reported under G1-4: 0 in 2025 (page 73).
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: page 73.
In 2025 If was not convicted of any corruption or bribery incident and paid no related fines. For that reason it did not need specific actions on breaches of procedures and standards on anti-corruption and anti-bribery. No public legal cases on corruption or bribery were brought against If in 2025 (page 73).
Confirmed incidents of corruption or bribery: 0 in 2025 (0 in 2024, including Topdanmark for November-December 2024).
If says confirmed incidents are reported as part of regular sustainability, compliance and risk reporting, using information from established channels such as the whistleblowing channel (page 73).
The Appendix 2 datapoint on standards of anti-corruption and anti-bribery (paragraph 24(b)) is marked "Not material", while the datapoint on fines (paragraph 24(a)) points to this page (page 81).
G1-6Payment practicesReported
Payment practices
Reference: page 74.
In 2025 the average time to pay an invoice was 22 days. The report gives standard payment terms and the share of payments that met them (page 74):
- Terms of up to 14 days: 24% of payments, 67% paid within terms
- Terms of 15 to 30 days: 57% of payments, 90% within terms
- Terms of 31 days or more: 19% of payments, 93% within terms
- Total: 100% of payments, 85% within terms
If cannot give standard payment terms by main supplier category because of the diversity of its suppliers and confidentiality. Main reasons for late payment were delays in invoice review and approval, late arrival of invoices, and issues with new suppliers. 62% of late payments were made within seven days of the due date. If is not party to any legal proceedings over late payments.
Baltic data is only partly included because of a process change, and one minor subsidiary is excluded.