Environmental, Social, and Governance (ESG)

We are committed to trading in an environmentally-friendly, socially-supportive, and ethical way. Robust governance structures, an ethical culture, diversity, and equality are already part of the Group’s ethos. To better manage our ESG risk and impact, we have established an ESG Committee that has an integrated view of ESG in the Group and is responsible for:

  • Developing, managing, and overseeing the implementation of our ESG strategy
  • Implementing our ESG reporting framework
  • Advising on best practice when discussing policies and regulations that impact ESG
  • Improving our understanding and raising awareness of ESG within the Group
  • Integrating ESG considerations into the Group’s respective value propositions
  • Reporting on ESG compliance to the Board of Directors
  • Staying abreast of the latest ESG developments and industry trends


The ESG Committee investigated several standards, frameworks, and guidance manuals. Taking into consideration where the Group is on its journey to a comprehensive and integrated ESG strategy, the ESG Committee decided to adopt the Sustainability Accounting Standards Board’s (“SASB’s”) standards, read in conjunction with the International Financial Corporation’s Performance Standards and other related documents for guidance and insight. The SASB’s standards focus on financially material areas of impact, link sustainability to business performance, and can be monitored, measured, and reported on.

The standards are based on five dimensions of sustainability:

  • Environmental
  • Social capital
  • Human capital
  • Business model and innovation
  • Leadership and governance

The “Asset Management and Custody Activities Industry” category in the SASB standards best aligns with the Group’s business activities. The Group’s ESG reporting is restricted to this category for this reporting period.

The Group believes that the SASB standards will provide sufficient and appropriate standards on ESG reporting, given the:

  • SASB standards are underpinned by evidence-based research
  • SASB standards were developed through broad and balanced participation from companies, investors, and subject-matter experts
  •  The International Financial Reporting Standards (“IFRS”) foundation assumed responsibility for the SASB standards during August 2022 and will, ultimately, be replaced by IFRS Sustainability Disclosure Standards. The Group reports make use of the IFRS accounting standards and it, therefore, makes sense to align its financial and ESG reporting in the near future.

As per the SASB’s guidance, the Group’s ESG reporting is stratified into five main topics:

  1. Sustainability disclosure topics and accounting metrics
  2. Employee diversification and inclusion
  3. Incorporation of ESG factors in Investment Management and Advisory Services
  4. Business ethics
  5. Systemic risk management


  • Under the Group’s POPI Act Programme, we conduct yearly personal information impact assessments, and review and implement various data protection policies and procedures, disclaimers, consent, and guidelines to work together to achieve POPI Act compliance.
  • The Compliance function monitors selling practices on an ongoing basis.
  • To address gender equality in top and middle management, the Group’s Employment Equity and Recruitment Policies are reviewed annually.
  • Our social goals include to have 30% black women representation at Board level and to have 33% women representation at senior management level by 2024 and 2028, respectively.
  • From a transformation perspective, the Group’s Board approved its strategy for 2022 to 2024. This includes targets to improve our B-BBEE score from non-compliant to a Level 6 Contributor by 2024, and thereafter, to continuously improve our score to a Level 4 Contributor.

Other projects include:
  • CSI: Footprints 4 Sam Trust
  • The Ulwazi Educational Trust
  • The Efficient Group’s Internship Programme
  • Employee Relief Fund


We are proud to have a small environmental footprint, but we are, nevertheless, committed to lowering our environmental impact wherever possible. We do so by educating our employees and by continuously implementing actions to further reduce our negligible carbon footprint. Through recycling and responsible water usage, we aim to reduce our environmental footprint even further. We actively recycle paper where we can, and we favour technology solutions over printing. We also encourage the use of video-conferencing facilities for employee attendance at remote locations, thereby reducing the environmental impact of our meetings.

ESG Fund

Globally, there is a growing demand for investments that incorporate sustainability factors into their portfolios to encourage companies to act responsibly. Many studies illustrate that ESG investing does not detract from longterm returns. On the contrary, it can enhance returns while reducing risk. In South Africa, Regulation 28 of the PFA encourages trustees to integrate ESG into their investment decisions. Despite this, South Africa has not seen the same growth in ESG thematic investing as other countries, especially when looking at developed markets. Although many asset managers incorporate ESG factors into their investment processes, asset managers will not necessarily exclude stocks with a low ESG score.


  • ESG is a standing agenda point on the Product and Development Committee meetings and included in the Committee’s terms of reference.
  • The Group’s has a Anti-Bribery and Corruption Policy which includes mandatory due diligence on suppliers and purchasers, to ascertain standards of conduct, and to identify any potential risks before entering into an agreement. The Policy also requires that senior management must ensure the prompt investigation of suspicions of fraud or corruption, and to then report the investigation results to the Group CEO.
  • Our Compliance function is responsible for monitoring and reporting on the effectiveness and the application of this policy to senior management, as well as for escalating risks relating to bribery or corruption to the Audit and Risk Committee.
  • Whistleblowing training forms part of employee induction training and general awareness is created among all employees by means of newsletters and intranet published guidelines.
  • To enhance our operational resilience, we have detailed succession plans for key senior individuals with Individual Development Plans (“IDPs”) for their successors.