Business Policies Compliance Policy

Compliance Policy

At Old Mutual Wealth we subscribe to the compliance philosophy and policy of Old Mutual South Africa (OMSA).

We believe that compliance with regulatory requirements:
  • Protects the clients and stakeholders of a business.
  • Fosters good relationships with regulators.
  • Enhances the reputation of a business.
  • Represents good business practice.
  • Contributes to good corporate governance.


The Old Mutual (SA) Compliance Philosophy and Policy

The philosophy establishes the approach to regulatory compliance that has been adopted by the OMSA Group.

The policy, which is consistent with the OMSA Group's requirements in relation to corporate governance, and also with the Old Mutual plc Group Compliance Policy, establishes the framework within which the identification, monitoring and reporting will take place in order for the OMSA Group to discharge its statutory and regulatory obligations.

Philosophy

OMSA recognises its accountability to all its stakeholders under the legal and regulatory requirements applicable to its businesses.

OMSA is committed to high standards of integrity and fair dealing in the conduct of its business.

OMSA is committed to comply with both the spirit and the letter of applicable requirements and to always act with due skill, care and diligence.

Policy

In order to realise this philosophy, OMSA has adopted the following compliance policy:

Where a business is subject to regulatory requirements, it will comply with those requirements. The business will furthermore establish and maintain systems of internal control to monitor and report the extent of compliance with those requirements.

In the absence of regulatory requirements for all or part of a business, certain minimum standards of conduct shall be established and maintained by that business to the extent required as determined by the management of that business.

Accountability for ensuring compliance with regulatory requirements and minimum standards rests with the Chief Executive Officer and Board of each company within the OMSA Group, whilst the enforcement thereof is the responsibility of the respective line management.

To assist in the discharge of this obligation, OMSA will establish and maintain an independent compliance function under a Group Compliance Officer.

The Group Compliance Officer will be responsible for the adequacy of the monitoring and reporting arrangements within the OMSA Group and will also be responsible for the implementation of a Group Compliance Strategy within the OMSA Group. In addition each business unit within the OMSA Group will establish and maintain an independent internal compliance function as is appropriate to its business requirements.

The internal compliance function for each business unit will be responsible for establishing and maintaining systems of internal control to identify, assess, monitor and report the extent of its compliance with regulations, rules and other standards to which it must comply.

Generally, and subject to issues of legal privilege, each business unit shall be open and specific in its reporting of issues and concerns to the Group Compliance Officer and the OMSA Compliance and Risk Management Committee.

Standards
The compliance function, both at a Group and at a business unit level must at all times display
  • independence and objectivity
  • integrity
  • accountability
  • transparency
  • understanding of and insight into business and regulatory requirements

Systems of control are required to ensure that there is timely reporting of rule breaches and other regulatory non-compliances to the Board and senior management of the business unit.

Subject to the escalation and reporting procedures as defined by the OM plc Group, significant compliance issues must be reported by the Group Compliance Officer to the OMSA Board via the OMSA Board Audit Committee and to the OM plc Board via its Compliance and Risk Management Committee.