Corporate Citizenship

AN HONEST COMMITMENT TO SUSTAINABLE BUSINESS

Reputation management

In addition to delivering on its mandate to ensure sound business and investment growth for its shareholders and clients, Peregrine is deeply committed to taking care of its employees, the communities in which it operates and the environment. The Group’s vision, strategic objectives and values are all aligned with the Group’s sustainability initiatives. Ultimately sustainability is written into Peregrine’s policies, procedures and decision-making strategies.

To this end, Peregrine has a Code of Conduct that lays out the overall principles and guidelines to be adopted by all employees across the Group. As a responsible corporate citizen, the Group is committed to maintaining the highest ethical standards when carrying out its business activities. Sustainability is inextricably linked to Peregrine’s corporate culture, and adherence to the provisions of the Code of Conduct is a condition of employment within Peregrine. The Code of Conduct aims to encourage the following behaviour:

employees who act with honesty and integrity in all dealings with stakeholders;

employees who interact with fairness, dignity and respect within and outside of the Group in all business dealings;

employees who create and protect a working environment free from harassment and discrimination;

employees who obey the law and understand that it is the foundation on which the Group’s ethical standards are built;

employees who avoid or properly mitigate all conflict situations, where personal interest could conflict with duties to the Group and/or to clients;

employees who have access to confidential information about the Group or any other entity do not use or share that information for trading purposes, either within the Group or the other entity’s securities or for any other purpose, except in the conduct of the Group’s business;

a diverse work environment. The Group is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegally discrimination or harassment based on race, colour, religion, sex, national origin or any other protected class; and

employees who follow all applicable environmental laws and regulations.

To give practical effect to the Code, an anonymous whistleblowing process has been implemented, which is designed to enhance the culture of responsible information disclosure, relating to criminal and other irregular conduct in the workplace and/or any other contraventions of the Code.

Any reported instances of non-adherence will be immediately investigated. Where necessary, Human Resources is mandated to escalate serious contraventions to the Chief Executive Officer. To date no such incidences have been reported.

Annual declarations are completed by employees indicating their awareness, as well as adherence to the Code. Peregrine’s long-standing position, as a reputable market-leader in the wealth and asset management arena supports its sustainability strategy.

Responsible investing

Peregrine acknowledges that its stewardship of its clients’ investments places an onus on the Group’s shoulders of responsibility and accountability. Its key role is to protect, manage and grow client assets and to deliver sustainable value. In addition to assessing economic return, Peregrine takes into account environmental, social and governance concerns when assessing potential investments.

To this end, as part of its Corporate Responsibility, Citadel formally subscribes to the Code for Responsible Investing in South Africa (CRISA), which encourages domestic institutional investors to integrate into their investment decisions sustainability considerations in line with King IV.

Market conduct

Treating Customers Fairly (TCF) is an outcome-based regulatory and supervisory approach designed to ensure that specific, clearly articulated fairness outcomes for financial services consumers are delivered by regulated financial firms. It provides for six policy outcomes, which aim to ensure that all financial services customers are treated fairly. TCF is core to market conduct regulation.

The Peregrine Group has always been committed to treating its customers fairly. We actively strive to attain the six TCF outcomes at all times. These six outcomes are:

Right Culture: Consumers can be confident that they are dealing with a Group where the fair treatment of customers is central to the corporate culture.

Right Targeting: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.

Right Information: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

Right Advice: Where consumers receive advice, the advice is suitable and takes into account their circumstances.

Right Delivery: Consumers are provided with products that perform as the Group has led them to expect and the associated service is both of an acceptable standard and as they have been led to expect.

Right Post-Sale Treatment: Consumers do not face unreasonable post-sale barriers when wanting to change product, switch provider, submit a claim or submit a complaint.

In line with TCF principles, the relevant subsidiaries, inter alia –

have processes in place to ensure that all affected individuals meet fit and proper requirements and, where applicable, write and pass regulatory exams and undergo all required training;

have complaints procedures in place which ensures that complaints are swiftly and appropriately dealt with;

have processes to ensure clear and appropriate disclosures are made to clients;

continuously monitor compliance with client mandates;

have a range of compliance and other policies in place, including, conflict of interest management policies and personal account trading policies; and

have adopted TCF Policies.