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Keeping Ethics Top of Mind

The Sanlam Group Business Philosophy

Sanlam was built on a commitment to always doing things right and doing what is right for our stakeholders. This promise underpins our core values and our professional and ethical behaviour. We are responsible for ensuring that we uphold this commitment at all times.

The Board’s approach to ethical and effective leadership is directed by the Sanlam Group Business Philosophy. It explains in detail how the Group acts and conducts its business as a single entity and positions the Group as “One Brand”. It includes a summary of Sanlam’s culture, its values and responsibilities, thereby encapsulating the way we conduct business and allocate resources.

The Sanlam Group Business Philosophy is underpinned by the Group’s Code of Ethical Conduct which, in turn, underpins Sanlam’s core values. Find a summary of the Sanlam Group Business Philosophy and download the Sanlam Code of Ethical Conduct.

The Sanlam Core Values

Our Code of Ethical Conduct

The Sanlam Group has evolved into a diversified financial services group operating in an ever-changing environment. However, one thing remains constant: our commitment to our values. Sanlam’s Code of Ethical Conduct applies to all Sanlam businesses and employees and serves as a guide to ensure that all businesses and employees uphold the highest level of integrity and ethical conduct. The Code remains relevant to all environments in which we operate, which allows us to consistently deliver on the promise of the Sanlam core values.

The Code was revised at the end of 2018 with no substantial change in the principles. Amendments were implemented to ensure alignment with the growing Sanlam footprint.

Salient features of our Code of Ethical Conduct are:

  • Our conduct shall at all times conform to the Sanlam core values.
  • We are committed to complying with all applicable legislation and regulations.
  • We are committed to fostering and maintaining an equitable and sustainable employer-employee relationship, including the provision of a safe, healthy and productive working environment.
  • We shall protect and maintain the property and information of Sanlam, its employees and its clients.
  • We shall manage and mitigate all conflicts or perceived conflicts of interest.
  • We shall provide protection for any person who reports violations of the Code.
  • We shall monitor and enforce the implementation of the Code.

All companies across the Group are expected to adhere to and confirm their compliance with Sanlam’s governance principles in their respective annual board representation letters. There remains a strong focus on increasing awareness, capacity and knowledge of the non-negotiable role ethical conduct plays in the success of Sanlam among employees and management, as well as subsidiary companies.

Sanlam continuously engages with its various business clusters to ensure that there is a common understanding of how we report on ethical mattes and the types of ethics breaches to be included in reporting.

The Governance of Ethics

The Sanlam Board charter recognises and outlines the Board’s role regarding its ethical responsibilities. These include:

  • The Board determines, reviews and oversees that Sanlam’s vision and values are congruent with Sanlam being a responsible corporate citizen.
  • The Board assumes responsibility for Sanlam’s performance by steering and setting the direction for the realisation of Sanlam’s core purpose and values through its strategy.
  • The Board provides effective leadership on an ethical foundation and ensures that it acts ethically, beyond mere compliance.
  • The Board must ensure that Sanlam is and is seen to be a responsible corporate citizen by having regard to the financial aspects of the business, and the impact that business operations have on the Group’s stakeholders, natural resources and the society within which it operates.

The Social, Ethics and Sustainability committee monitors whether Sanlam complies with the relevant social, ethical and legal requirements and best practice codes. This includes reviewing Sanlam’s social, ethics and sustainability strategy and structures annually. It monitors performance against specific targets and objectives. The committee reports any ethical breaches or matters to the Board quarterly.

The Group Ethics committee is chaired by the Group Chief Risk Officer. It includes representatives of the business clusters and divisions. The Group Ethics committee’s objective is to monitor compliance with the principles underlying the Code and investigate all matters brought to its attention, if and when necessary.

Reporting Ethical Breaches

The table below summarises the reporting channels (with specific focus areas) that are available to stakeholders in cases of an ethical breach.

An independent external service provider manages Sanlam’s Confidential Reporting Hotline to guarantee the anonymity of anyone who wishes to report fraud or unethical or unlawful conduct without disclosing their identity. Anonymity is guaranteed by the Protected Disclosures Act, 26 of 2000.

Since the inception of the Sanlam Confidential Reporting Hotline on 1 July 2019, we received 53 hotline reports. All reports were referred for investigation and no material irregularities were identified.

We encourage anyone who suspects that fraud, unethical conduct, suspected unlawful conduct or non-compliance is being perpetrated within the company or against a Sanlam company or client, to report it to:

International numbers are also available for callers from outside of South Africa. The service extends to all Sanlam businesses in and outside of South Africa and in all the primary languages of the jurisdictions within which Sanlam operates. Several Sanlam Emerging Markets businesses also operate their own whistleblowing lines in addition to the Sanlam facility.

Trained operators respond to calls in English 24 hours a day, seven days per week. Depending on the jurisdiction where the report is made, operators will also respond in the official languages of the caller’s country during business hours from 08:00 to 17:00. Operators interview callers, probing for specific facts to record as much information and understand things as clearly as possible.

The information is analysed and forwarded to designated senior officials at Sanlam, who investigate any alleged breach of the Code and decide on corrective action to be taken. If anonymity is requested, Tip-Offs Anonymous cannot be compelled by Sanlam or anyone else to disclose any information that could assist in the identification of the reporter.

Sanlam Group Policies Support Ethical Behaviour

Extracts from or summaries of several key policies that support ethical behaviour and form the ethical foundation of the Group are listed below:

Sanlam is committed to conducting its business ethically, responsibly and in compliance with all applicable legislation, regulation, adopted industry codes and standards, as well as internal policies and sound corporate governance principles. Sanlam has no appetite for deliberate or purposeful violations of these. Sanlam seeks to conduct its business with due skill, care and diligence in order to minimise violations arising from negligence. All identified breaches of requirements will be addressed as soon as practicable.

The Board sets and oversees the implementation of Sanlam’s corporate culture, business objectives and strategies for achieving those objectives, including its compliance strategy and compliance risk appetite. Ultimate accountability and responsibility for ensuring and overseeing the management of compliance in Sanlam resides with the Board. The Board of every Sanlam entity is in turn accountable and responsible for ensuring and overseeing the management of compliance in that entity.

All these boards have delegated the effective execution of compliance management to the senior management of Sanlam and each entity respectively and will be accountable to their respective boards for the effective discharge of their delegated responsibilities.

The boards will ensure that a robust independent compliance function is established for Sanlam and each Sanlam entity. The compliance functions of Sanlam and each Sanlam entity shall act as independent assurance providers and monitor and report to their respective boards and senior management on the status of compliance management. In addition, the compliance functions will advise, guide and assist the boards and senior management in the discharge of their compliance responsibilities.

All compliance functions in Sanlam shall be appropriately authorised, positioned, resourced and provided with reasonable, ongoing access to all relevant staff, information and documentation to discharge their responsibilities.

Sanlam regards high ethical standards as non-negotiable. We expect all our directors, managers, employees, independent contractors, agents, service providers and business partners to act with integrity and honesty when conducting the business of Sanlam.

Financial crime poses a threat to the integrity of the global financial system and, as such, to Sanlam’s own strategic objectives within this system. In addition to the need to protect the financial system as a whole, Sanlam recognises the need to protect its own integrity and brand. In doing so Sanlam supports all efforts by the international community, South Africa and all jurisdictions in which we do business to combat financial crime.

Read more in the section on combating financial crime.

Sanlam is firmly committed to participating in international efforts to combat money laundering and the funding of terrorism and will not allow its operations to be used or abused for purposes of these or other financial crimes. Sanlam will observe all relevant and applicable sanctions regimes that apply or may apply to its operations and shall not establish or maintain any business relationship or conclude any transaction with an individual or entity on a specified sanctions list where this would constitute a breach of a sanctions regime.

The Sanlam Group AML/CFT policy applies to all Group subsidiaries wherever they operate and advocates a risk-based approach to managing AML/CFT risk. Group associates are required to provide assurances to Sanlam that they comply with all applicable and relevant AML/CFT laws and regulations and that Sanlam would not be exposed to any non-compliance on their part. In special circumstances Sanlam may require Group associates to formally commit to compliance with this policy and to do so in writing.

The disclosure and effective management of conflicts of interest is an essential component of ethical behaviour and good governance. The Sanlam Group Code of Ethical Conduct specifically includes a principle which deals with managing and mitigating all conflicts and perceived conflicts of interest. This principle, together with enhanced regulatory scrutiny and intervention, also necessitated a Group-wide approach to managing conflicts of interest.

The purpose of the policy, which was approved in 2019, is not to prevent employees from pursuing personal interests, but rather to govern and mitigate any potential risk associated with such interest.

All employees are required to declare all actual or potential conflicts of interest as and when they arise. In addition, and in the absence of any actual or potential conflicts of interest, employees will be required to at least annually declare that they do not have any conflicts of interest warranting a declaration.

The policy provides practical guidance regarding the identification of potential conflicts of interest and the governance relating to Sanlam’s relationships with third-party service providers.

Ethics Priorities Going Forward

The Group Chief Executive delivered a personal message on ethical conduct to Sanlam employees via a video recording broadcast in July 2019. The message conveyed a personal commitment to ensure ethical conduct and included an instruction to the Group Compliance Office to monitor and report on progress with the institutionalisation of an ethical culture in Sanlam within the next 12 months.

The Group Chief Executive’s message marked the start of a series of initiatives that would ensure the structured management of ethics in the Group. At the centre of these initiatives will be a refresher message on the Group Code of Ethical Conduct to be delivered to the entire Sanlam Group early in 2020. A Group-wide ethical climate survey and risk assessment is planned for the first half of 2020, and incidences of unethical conduct will be monitored on an ongoing basis.

Case Study:

Glacier Invest Offers an Ethical and Principle-based Investing Option to Special Interest Groups

Sanlam’s commitment to ethics extends to solutions offered to clients who have specific ethics relating to how they invest and manage their assets.

Shari’ah investing is a form of ethical investing within discretionary fund management that complies with Islamic law. This kind of investing is not exclusively for investors who follow Islam.

Shari’ah investing helps investors who have an ethical or moral interest in where their money is being invested. Shari’ah-compliant funds avoid stocks and shares in any company or industry whose core business and revenue are derived from non-halaal (forbidden or haram) sources. They pursue companies focused on sustainable, planet-conscious processes.

Of the 164 stocks on the All Share Index, only 74 are Shari’ah-compliant. The Shari’ah investable universe is therefore quite limited, focusing mainly on the resources and property sectors.

Glacier Invest offers three Shari’ah-compliant wrap funds covering three risk profiles. The Glacier Shari’ah Stable Wrap Fund launched this year is a first-of-its-kind Shari’ah-compliant wrap fund catering to investors in the post-retirement phase who need some measure of growth with capital protection and to draw an income.