Compliance and governance

The STANLIB Compliance Function serves all business units, divisions and companies in the STANLIB Group and is independent of line management. The Compliance Function ensures the following:

• Compliance with legislative and regulatory requirements
• Compliance with investment mandates of third-party clients on behalf of whom STANLIB manages investment portfolios
• Compliance with investment mandates of collective investment portfolios managed by STANLIB
• Compliance with STANLIB’s policy in respect of Personal Account Trading

The Compliance Function is staffed by a team of professional compliance officers registered with the Financial Services Board. The Compliance Function uses a risk-based approach in managing compliance risks within STANLIB. A state-of-the-art mandate compliance monitoring system was implemented by the Compliance Function at the end of 2008. This system, acquired from Charles River, facilitates both pre- and post-trade compliance monitoring of investment portfolios. The Compliance Function reports to the STANLIB Internal Review Committee and the Liberty Holdings Audit and Risk Committees on a quarterly basis.

The Risk Management Function serves all business units, divisions and companies in the STANLIB Group and is independent of line management.

The Risk Function is responsible for implementing a risk management process across all business units within STANLIB. The risk management process focuses on identifying and assessing all risks and controls within STANLIB. Where controls are believed to be inadequate, remedial action is agreed upon with the relevant risk owner, and progress in implementing the remedial action is tracked.

Quarterly control self assessments are conducted within STANLIB to identify new risks, control weaknesses and breakdowns. The results of these control self assessments are verified against key risk indicators, loss events and internal and external audit findings.

STANLIB has documented and tested Disaster Recovery solutions and Business Continuity solutions in place that are regularly maintained to ensure the IT continuity and business operations in the event of IT failures and or other business disruptions.

The Risk Management Function reports to the STANLIB Internal Review Committee and the Liberty Holdings Audit and Risk Committees on a quarterly basis.

The companies within the STANLIB Group hold the following Regulatory Approvals:

STANLIB Asset Management Limited

• Registered with the Financial Services Board as a Category II Discretionary Financial Services Provider
(Investment Manager) in terms of the Financial Advisory and Intermediary Services Act (License Number: 26/10/719)
• Registered with the Financial Services Board as a Pension Fund Investment Manager in terms of the Pension Funds Act (Registration Number: 24/122)

STANLIB Collective Investments Limited

• Registered with the Financial Services Board as a Collective Investment Scheme in Securities Manager in terms of the Collective Investment Schemes Control Act (Management Company Number: 36)

STANLIB Wealth Management Limited

• Registered with the Financial Services Board as a Category II Discretionary Financial Services Provider (Investment Manager) and a Category III Administrative Financial Services Provider (LISP) in terms of the Financial Advisory and Intermediary Services Act (License Number: 26/10/590)
• Registered with the Financial Services Board as a Pension Fund Benefit Administrator and Investment Manager in terms of the Pension Funds Act (Registration Number: 24/178)

STANLIB Multi-Manager Limited

• Registered with the Financial Services Board as a Category II Discretionary Financial Services Provider (Investment Manager) in terms of the Financial Advisory and Intermediary Services Act (License Number: 26/10/763)
• Registered with the Financial Services Board as a Long-term Insurer in terms of the Long-term Insurance Act.

As a Financial Service Provider, STANLIB has been issued with a license by the Registrar of Financial Services Providers in terms of section 8 of the Financial Advisory and Intermediary Services Act to carry on the business of a Discretionary Financial Services Provider and to render Financial Services to individuals and institutions in respect of Financial Products. Click here to view the license certificates.

STANLIB encourages internal compliance through its Code of Ethics and Conduct policy. The policy is largely based on CFA standards and is a set of company values rather than a specific asset management Code. There are specific Asset Management policies dealing with Personal Account (PA) Trading, Prevention of Insider Trading, Allocation of Trades and Valuations. Compliance with the Code is checked against downloads obtained from the JSE.

As a subsidiary of the Liberty Group, STANLIB falls under the indemnity and fidelity policy of Liberty Holdings Limited. The cover is renewed every calendar year. Cover is in place in respect of Commercial Crime, Computer Crime and Professional Indemnity via Stanbic International Insurance Limited while the cover in respect of Directors and Officers Liability is via Lloyds and others.

What is Global Investment Performance Standards (GIPS®)?

The GIPS® standards are a set of ethical standards for investment performance presentation to ensure worldwide acceptance of fair representation and full disclosure for investment performance. GIPS® promote accurate and consistent performance reporting to ensure equal competition amongst investment management companies.

The GIPS® standards require companies to include all actual, discretionary, fee-paying portfolios in at least one composite (consisting of a single or a combination of funds) defined by investment mandate, objective or strategy in order to prevent firms from ‘cherry-picking’ their best performance.

How does GIPS® benefit other asset managers, clients and prospective clients?

GIPS® serves to aid by

• eliminating the use of representative accounts,
• eliminating the use of selective time periods,
• eliminating the survivorship bias and
• fostering the notion of ‘self-regulation’.

Disclaimer:

STANLIB Asset Management

STANLIB Asset Management is a 100% owned operating entity within STANLIB Ltd. The company comprises all portfolios managed by STANLIB Asset Management.

STANLIB Asset Management claims compliance with the Global Investment Performance Standards (GIPS®). To receive a list of composite descriptions of STANLIB Asset Management and/or a presentation that complies with the GIPS® standards, contact STANLIB Performance at 0860 123 003, write to STANLIB Asset Management, PO Box 202, Melrose Arch, 2076 or email stanlib.performance@stanlib.com.

STANLIB Limited (Reg No. 1997/014748/06).
Directors: S J Macozoma (Chairman), A P Cunningham*, T Dloti, J B Hemphill, J H Sutcliffe*, C G Troskie, B S Tshabalala.

* British

STANLIB Limited has the following subsidiary companies:
STANLIB Wealth Management Limited (Reg. No. 1996/005412/06). Authorised FSP in terms of the FAIS Act, 2002 (Licence No. 26/10/590) Directors: S J Macozoma (Chairman), A P Cunningham*, T Dloti, J B Hemphill, J H Sutcliffe*, C G Troskie, B S Tshabalala.

* British

STANLIB Asset Management Limited (Reg No: 1969/002753/06). Authorised FSP in terms of the FAIS Act, 2002 (Licence No. 26/10/719). Section 13B of the Pension Funds Act Investment Manager Reg No: (24/122)
Directors: S J Macozoma (Chairman), A P Cunningham*, T Dloti, J B Hemphill, J H Sutcliffe*, C G Troskie, B S Tshabalala.

* British

STANLIB Collective Investments Limited (Reg. No. 1969/003468/06). Liberty is a member of the Association for Savings and Investment of South Africa. The Manager is a member of the Liberty group of companies.
Directors: T Dloti (Chief Executive Officer), I C Bennie, B T G Mageba, A Katakuzinos, N P Mamathuba, M Rabe, S C Rider, C M Sanqela.

STANLIB Multi-Manager Limited (Reg. No. 1999/012566/06). Lodestone Holding (Pty) Limited (Reg. No: 2000/014947/07).
Authorised FSP in terms of the FAIS Act, 2002 (Licence No. 26/10/763)
Directors: T Dloti (Chairman), C S Benfield (Managing Director), S Braudo, E S Ntsimane, M Rabe.

Group Company Secretary: J M Parratt.