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SANLAM LIFE INSURANCE LIMITED

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

          oversight of policy compliance
        

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

All investments should adhere to the principles as set out by the United Nations (UN) Principles of Responsible Investment and the Code for Responsible Investing by Institutional Investors in South Africa 2011 (CRISA). 

Sanlam Investment Management has a formal Responsible Investment Policy and Procedure document in place which governs the principles around responsible investment management and it is based on the UN and CRISA principles around responsible investment.

Sanlam Limited has realised the need to have a specific guidelines for Environmental, Social and Governance factors. These are currently not explicit in the Investment Policy.

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

01.6. Additional information [Optional].

          The Group Investment Policy covers shareholder portfolio investments. As those investments are effected through the investment manager,their responsible investment policy applies. we do not have a specific responsible investment policy as per PRI requirements. This is being worked on. within our current Investment Policy we specify that	Sanlam, specifically Sanlam Investment Management, subscribes to the United Nations Principles of Responsible Investment and the Code for Responsible Investing by Institutional Investors in South Africa 2011 (CRISA).

Investments in subsidiaries and associates are dealt with in the Group Governance Policy, and currently there is no overt reference to responsible investing.
        

SG 01 CC. Climate risk (Private)


SG 02. Publicly available RI policy or guidance documents

 

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Additional information [Optional].


SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

The Sanlam Group has well-established risk and compliance management functions, both on a Group level and on a subsidiary level. The Group Conflict of Interest Policy covers all potential conflict of interest risk across the Sanlam Group (including the investment process), and also includes all subisdiary businesses. It is supported by the overarching Group Code fo Ethical Conduct, as well as other policies that address combating financial crime, and gratifications etc. We annually publically disclose a Capital and Risk Management Report as part of our Integrated Annual Report, where the risk management mechanism are shared.

The Group Governance framework also deals with compliance to investment principles.  The compliance principles set out in this policy is supplementing those in the Group Governance framework.  Compliance to the Group principles is the responsibility of the individual Business Units and there is a second line of assurance through Group Risk Management and third line of assurance through Internal Audit.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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