Given the increased scope and complexity of the Sanlam Emerging Markets cluster, governance, risk and compliance are vital to ensure sound management of the business.
Our multinational governance framework aligns all business units and geographies to:
To support and develop mature governance and ethics structures and processes in the emerging markets where we operate, all companies are expected to confirm compliance with our governance principles in their annual board representation letters. We also conduct rolling risk management maturity assessments. There is a strong focus on increasing awareness and knowledge of the non-negotiable role ethical conduct plays in the success of Sanlam among SEM employees and management, as well as subsidiary companies.
In 2019 we compiled a Sanlam Pan Africa specialist business underwriting and reinsurance governance framework to address mandates and governance criteria for businesses.
SEM’s strategy is underpinned by a focus on strong governance, compliance and risk management. In 2018 PwC concluded a compliance maturity assessment for SEM and subsequently assisted to address gaps. The rollout to most of the major subsidiaries in SEM countries was completed at the end of 2019. A compliance maturity assessment for Saham Finances was completed in May 2019 and key activities for implementation prioritised.
We established SEM asset management committees (SEM asset and liability committee and SEM Estate), to oversee consistent governance, inform strategic investment across the continent and optimise returns for the SEM portfolio and shareholders.
The structure of compliance functions in the SEM cluster follows a hybrid model. The compliance model is regionally organised and not according to the split by business lines followed elsewhere in the cluster:
Large entities (for example in Morocco, Cote d’Ivoire, Angola, Saham Re and Continental Re) use their own functions, but smaller entities outside of these countries are subject to guidance and oversight from the SEM central compliance functions above.
During 2019 significant time and effort went into the rollout of training and compliance methodology implementation, with additional training and communication through regular newsletters and in-country visits.
To strengthen governance, we ensure that Sanlam is represented on boards in partner companies. At the moment we are represented on 69 company boards in Sanlam Pan Africa.
A fine of N$16 million was imposed on Sanlam (Namibia) on non-compliance with Anti Money Laundering (AML) grounds. Sanlam is appealing this fine.
We also developed and introduced the SEM Toolkit, which is a list of key information security policies that have been simplified for use in the African businesses. This toolkit makes reference to Control Objectives for Information and Related Technology 5 and ISO 27001 controls. It was created as a minimum standard that all the businesses need to comply with and have implemented