The group social and ethics committee is responsible for ensuring that we act ethically in relation to internal and external stakeholders, and society more broadly.
The committee meets quarterly and includes executive and non-executive directors. Key issues discussed by the committee during 2018 included progress on embedding an ethical culture in Standard Bank; group-wide principles for stakeholder engagement; measures to accelerate gender and racial transformation within South Africa, and gender equity across the group; effectiveness of group policies and processes to minimise instances and support the victims of discrimination and sexual harassment; issues raised by environmental and social rights groups; and employee wellbeing.
operate in each of the business units to address client risk management matters. These committees include specific consideration of ethical considerations. The bank may choose to exit a client relationship based on consideration of commercial factors, contractual obligations to the client, compliance, reputational and other risk considerations.
Our supplier risk committee
oversees supplier relationships, including risks arising from the ethical behaviour of suppliers, as well as financial crime and reputational risks including conflicts of interest, anti-competitive practices and human rights violations. A new third-party risk management framework has been approved by the group risk oversight committee.
is based on the matrix operating model of the organisation. All procurement transactions must be objective, transparent and fair, in line with sound corporate governance principles, and the highest procurement and ethical standards must be applied to all such transactions. We require all our suppliers to respect basic human rights and establish a clean and safe working environment. This includes not allowing forced labour, child labour or discrimination, and paying appropriate wages, regulating working hours and respecting everyone’s freedom of association. Suppliers, consultants and contractors to the bank must comply with all the environmental and social legislation applicable, and they must follow good environmental and social practice that applies to their sector and to the goods or services supplied. The bank strives to procure goods and services that have a lesser or reduced impact on the environment and on the health and safety of workers and communities.
Employees and other stakeholders can seek advice or report concerns about unethical or unlawful behaviour anonymously. Information on our policy and processes for whistle-blowing is readily available to all employees. Employees have access to an independent, confidential whistle-blowing hotline. They are actively encouraged to make use of this should they feel that the group’s values or code of ethics is being compromised. Standard Bank commits to protecting employees who whistle blow in accordance with the procedures set out in our whistleblowing policy.
serve as beacons for the behaviour and qualities that define us as we execute our strategy.
Our culture is ‘the way we do things’. Our work to shift our culture for the better recognises that how we do things is as important as the things we do. Our culture is determined by our purpose, vision, values and our approach to ethics. Our code of ethics guides us to be responsible and respectful in our dealings with all our stakeholders as we work to become Africa’s leading financial services organisation. It outlines acceptable business conduct and is an important reference point for employees acting on behalf of Standard Bank. These clearly defined parameters empower us to make faster, more confident decisions that have the interests of our clients, and the people of Africa, at heart.
We are focusing on three critical behaviours that will shift our culture and make the biggest difference in supporting our strategic journey:
The chairman and the board set the ethical tone for the group. The board, through the relevant board committees, provides oversight of the group’s activities, assesses adherence to our values and ethics, and monitors compliance with regulatory and legislative requirements, based on reporting by executive management, internal auditors and external auditors on measures implemented to ensure compliance with regulatory and legislative requirements. The group chief executive, together with the chief ethics officer, are responsible for embedding the group’s values and code of ethics across the group. They are supported by business unit ethics officers at an operational level.
Standard Bank’s code of ethics is informed by relevant anti-corruption and corporate governance legislation in our countries of operation, globally recognised standards, including the King IV Code of Governance, industry best practice, and Standard Bank’s eight corporate values. It is certified by the Ethics Institute of South Africa as conforming to the highest standards of international best practice. Our code of ethics is integrated into our governance standards and policies, our group-wide conduct programme, and our compliance training programmes. It applies to all our banking operations and is aligned to group standards, policies and procedures. It is currently published in English, French and Portuguese.
Our code of ethics and our group values serve as the primary reference for employees when resolving any ethical issue. Our employee handbook, which is available online to all employees, sets out our policies, principles and ways of working, and has a section devoted to our code of ethics and culture. Our values and ethics also form part of our employee performance management system.
All new employees are inducted into our ethics culture as part of our employee orientation programme. Internal employee engagement mechanisms are used to deliver ongoing communication on our ethics stance and culture. All employees are required to complete an online training course on our code of ethics, on an annual basis. Course content is regularly updated and incorporates learning from real incidents.
Standard Bank Group’s conduct risk framework uses a culture-led strategy to achieve the culture, ethics and conduct we expect to see from our employees. We’ve put in place effective governance structures with clear responsibility and oversight to promote fair and effective customer outcomes. The board and senior management play a prominent role in supporting awareness and embedding conduct standards.
Since launching our treating customers fairly (TCF) programme in July 2014, we’ve undertaken a significant amount of work to embed the TCF principles. This work is based on sound tenets of business ethics and is aligned to our values. As part of the evolution of the TCF journey, we have strengthened our governance environment with the institutionalisation of our conduct risk management framework. The framework defines the group’s conduct risk appetite and informs our approach to identify, assess and manage conduct risk through enhanced reporting and monitoring that considers fair customer outcomes in material business decisions.
Different areas across the group are required to complete monthly conduct dashboards, which are submitted to the relevant group management committee. Conduct dashboards monitor indicators related to conduct culture and governance. The dashboards include metrics related to employee turnover, absenteeism, registration of gifts and entertainment, personal account trading, declaration of outside business interests, data privacy and protection, and client complaints. They provide a barometer of a significant dimension of the prevailing ethical climate. All business units and corporate functions submit their conduct dashboards to group executive committee on a quarterly basis.
Our conflicts of interest policy forms part of our conflicts of interest management framework. The policy is aimed at ensuring that Standard Bank and all our employees comply with the applicable statutory and regulatory obligations by ensuring that all reasonable steps have been taken to prevent or fairly manage potential conflicts of interest, and thereby mitigate the effect that such conflicts could have on our clients, as well as the bank. The policy reflects the minimum requirements that need to be adhered to, to ensure that all reasonable steps are taken to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of our clients. It also serves to ensure that there are processes, procedures and mechanisms in place to identify, prevent or manage conflicts of interest to:
Our money laundering and terrorist financing control framework and structures for managing our money laundering and terrorist financing risk are designed and maintained to ensure compliance with Financial Action Task Force recommendations and in-country legislative requirements in all jurisdictions.
The South African Financial Intelligence Centre Act has been amended to incorporate a risk-based approach to compliance in relation to the anti money laundering/combating the financing of terrorism (AML/CFT) regulatory framework. This includes the requirement to develop, document, maintain and implement a risk management and compliance programme that must demonstrate the group’s ability to effectively apply a risk-based approach.
Our money laundering control policy and our financial sanctions and terrorist financing policy comply with applicable statutory and regulatory obligations and ensure that:
Standard Bank manages our anti-bribery and corruption (ABC) risk in accordance with the Organisation for Economic Co‑operation and Development’s Guidance for Multinational Enterprises. Oversight of ABC is provided through the bribery and corruption review committee. An ABC risk assessment for the group was completed in 2018 and presented to the group social and ethics committee. Specialised training has been developed for areas that are perceived as being more susceptible to risk of bribery and corruption.
Our ABC policy ensures compliance with applicable statutory and regulatory obligations. It commits us to:
We’ve introduced several automated solutions across our countries of operation to improve efficiency in money laundering control and declaring outside business interests.
All Standard Bank employees must complete compulsory compliance training, which is available online and can be accessed via a computer or mobile device. Training uses case studies and course assessments and provides immediate feedback. We also hold regular ‘compliance conversations’ with a wider audience across the bank, including topics such as anti-bribery and corruption, anti-money laundering and combating the financing of terrorism, conflicts of interest and riskbased approaches to compliance documented in compliance policies.
We track fines and penalties issued against the group to assist us to identify problems areas that need attention and to implement appropriate remedial action.
Regulatory and compliance risk
Our executives, senior management and compliance teams work together to reinforce a compliance culture across the group. This encompasses our approach to business risk conduct, dealing with client risk and personal conduct risk. Group compliance assists in ensuring that we continuously manage our regulatory, supervisory and conduct risk. Group internal audit provides independent, objective assurance and advice to improve risk management, control and governance processes. Group governance and group compliance ensure that we meet our regulatory requirements in terms of Banks Act requirements, company law, financial sector regulation and corporate governance. We have expanded our compliance capability over the past year and have worked closely with middle management to emphasise its role in driving a culture of compliance at all levels across the group.
Our combined assurance model includes group internal audit, group compliance monitoring and integrated operational risk, which together ensure a coordinated approach to providing assurance on whether top risks are effectively managed in the group.
The Standard Bank Group audit committee is responsible for:
Environmental and social risk
The board’s responsibility for environmental and social (E&S) risk management oversight is delegated to the group risk and capital management committee, which has delegated functional E&S risk responsibility to the group risk oversight committee. This committee is responsible for ensuring effective E&S risk management in line with the bank’s risk appetite, and overseeing the processes implemented by business unit risk committees and mandated forums. The group environmental and social risk and finance (GESRF) team is responsible for ensuring that environmental and social risks are identified, evaluated and managed and that green, social and carbon financing opportunities are identified and pursued.
Standard Bank’s new E&S risk governance standard, adopted in March 2018, provides the principles under which we identify, measure, manage and report on environmental and social risk. The E&S risk governance standard aims to ensure that Standard Bank upholds its commitment to manage and mitigate negative environmental and social impacts arising from our activities, support conscious risk-taking, and enable the development and implementation of solutions with positive social and environmental impacts. It covers all forms of environmental and social risk, and applies across Standard Bank globally, while acknowledging differences in economic and social priorities and regulatory, compliance and legal frameworks in different geographies. The E&S risk governance standard will be reviewed and updated every two years to reflect changes in the bank’s strategy or to address new and emerging environmental and social perspectives.
The E&S risk governance standard is supported by the group’s revised E&S policy, also adopted in March 2018. The policy applies to the group globally and covers all legal entities across our countries of operation, with the objective of ensuring that all our operations effectively assess and manage E&S risk associated with all business transactions, irrespective of size, nature of business or location. The policy is primarily applicable to business, commercial and corporate clients, and includes our main financing products such as project finance, commercial debt and equity, short-term banking facilities and trade finance. The E&S policy is supported by the exceptions list.
Strengthening democracy through political party funding, South Africa