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.