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Combating Financial Crime

A Zero-Tolerance Approach

Financial crime poses a threat to the integrity of the global financial system and thus to Sanlam’s own strategic objectives within this system. We recognise our role in protecting the financial system as a whole, and our own integrity and brand. Sanlam supports all efforts by the international community, South Africa and all jurisdictions in which we do business to combat financial crime. This includes holding those involved in financial crime accountable in accordance with all applicable criminal, civil and labour laws.

Sanlam has a zero-tolerance approach to unlawful conduct and financial crime. Financial crime is any activity, conduct, suspected activity or suspected conduct related to financial services or the financial services industry. It typically takes the form of:

  • money laundering;
  • the financing of terrorism;
  • fraud, including insurance fraud;
  • bribery;
  • corruption;
  • theft;
  • cybercrime or computer-related crimes;
  • extortion;
  • any statutory or common law offence that is regarded to be a criminal offence; and
  • any form of unlawful conduct.

Unlawful conduct usually has dishonesty as a material element and includes general corrupt practices, the operation or promotion of illegal investments schemes, including pyramid schemes and the misuse of information.

Sanlam shall institute criminal prosecution where prima facie evidence of criminal conduct is found, irrespective of whether Sanlam has suffered losses. Sanlam’ approach is that any extenuating circumstances that may apply should be taken into account by a judge or magistrate hearing a matter and should not influence Sanlam’s decision to institute action.

High ethical standards are non-negotiable. We expect all directors, managers, employees, independent contractors, agents, service providers and business partners to act with integrity and honesty conducting Sanlam’s business. Read more about our commitment to ethics. Read more about this commitment in the 2019 Sanlam Governance Report.

To ensure anonymity of anyone reporting financial crime, the Sanlam Confidential Reporting Hotline is offered in accordance with the provisions of the Protected Disclosures Act, 26 of 2000.

Governance in Support of Combating Financial Crime

The Group financial crime combating policy and the Group anti-money laundering and the countering of the financing of terrorism (AML/CFT) policy provide frameworks for the combating of financial crime.

The chief executives of the business clusters are responsible for the implementation of the financial crime combating policy. However, the latter does not prescribe the establishment of a dedicated forensics or financial crime combating function for each cluster.

The Sanlam Personal Finance and Santam clusters opted to establish dedicated forensic functions as these clusters represent the areas where the highest volumes of incidents are likely to occur. Sanlam Personal Finance and Santam further maintain statistics on financial crime experienced and actions taken. The remaining clusters deal with financial crim as part of broader risk management and information on financial crime experiences is provided on a case-by-case basis.

Sanlam Life Insurance is a licensed financial service provider.
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