The Responsible Investment and Ownership – A Guide for Pension Funds in South Africa (the RIO Guide) was first published in September 2013 in response to the added requirement under Regulation 28 of the Pension Fund Act which requires pension funds to actively consider ESG factors in their investments. The RIO Guide was at the time produced under the project “Sustainable Returns for Pensions and Society” which was convened in 2011 by Batseta (formerly the Principal Officers Association of South Africa), IFC (International Finance Corporation), the Government Employees Pension Fund (GEPF), and the Association for Savings and Investment South Africa (ASISA), alongside a project working group comprised of an additional 15 stakeholder organisations from the South African pension fund investment industry . More about the history of the RIO Guide can be found here.
In June 2019, South Africa’s new Financial Sector Conduct Authority (FSCA) issued further regulatory guidelines to drive implementation of Responsible Investment by pension funds, namely Guidance Notice 1 of 2019: Sustainability of investments and assets in the context of a retirement fund’s investment policy statement.
With this updated version of the RIO Guide we have aimed to further empower South African retirement funds to comply with the Regulation, Guidance Notice and the voluntary Code for Responsible Investing in South Africa (CRISA) that calls for integration of environmental, social, and corporate governance (ESG) factors in pension fund investment decisions.
As a leading industry association, Batseta recognises that more than any other investor, retirement funds depend by their nature on a long-term investment horizon. There can be no doubt that we face real challenges in South Africa and globally and institutional investors also need to take account of these. The effect on the environment of a particular company needs to be considered when deciding whether or not to invest in that company. In addition, there is the company’s governance record and how the company affects society, whether in its employment practices or the effects of its operations on the communities that are close to it.
Without an ongoing sustainable base from which we operate, retirement funds will not be able to continue to deliver returns for their members, spouses and dependants.
A fund also needs to be able to do intelligent risk assessments – assessments that will take into account the monetary return on an investment as well as the feasibility of an ongoing success if a fund continues to invest in a certain way. For this reason, the RIO Guide continues to be a critical tool for the South African retirement investment industry; it empowers boards of Trustees to take responsibility for their investment choices by giving them means to be directly involved in shaping investment strategies that will support sustained economic growth and long-term returns for pensions and society.
The task team from IFC and Batseta gratefully acknowledge their debt to all concerned and extend their thanks and appreciation for the time, information and advice that has been contributed.
Batseta would like to extend a special thank you to IFC whom through funding from the Swiss Government’s State Secretariat for Economic Affairs (SECO) was able to provide financial and technical expertise for this updated guide to materialise.
Additional special thanks and acknowledgement goes to the invaluable contributions from the individuals from the institutions that supported the update of the RIO Guide through their participation in an Expert Review Panel (in alphabetical order):
- ASISA Academy: Adrian Bertrand
- Batsets Asset Owners Forum South Africa: Isaac Ramputa
- Batseta Secretariat: Anne-Marie D’Alton
- The Congress of South African Trade Unions (COSATU): Jan Mahlangu, Dusty Ngwane
- CRISA working group: Corli le Roux
- Eskom Pension and Provident Fund: Ndabezinhle Mkhize
- Financial Services Conduct Authority, Olano Makhubela
- Government Employees Pension Fund (GEPF): Nilesh Moodley
- IFC: Cecilia Bjerborn Murai, Ben Gaffney, Louise Gardiner
- Impact Investing South Africa National Task Force: Susan De Witt
- Old Mutual Investment Group: Jon Duncan
- Principles for Responsible Investing (PRI): Nicole Martens
- Trustee Representation: Jolly Mokorosi, Independent Trustee and Principal Executive Officer
It is important to remember that ESG factors are not about owning a few or certain assets in an effort to tick boxes in a sustainability checklist. Instead, the correct approach is to test every asset against these ESG factors as part of prudent risk management to identify and manage risk.
This places an enormous responsibility on trustees, who are tasked with overseeing our retirement savings and are under statutory duty to ensure that these savings are managed prudently, properly and for the benefit of members and pensioners. Our trustees, as representatives of the ultimate owners of the assets, need to take an active approach in ensuring that companies and projects they invest in uphold the highest standards of care in how they are managed, how they treat employees and the environment they operate in, including how companies approach social and critical issues like gender and racial inequality, as well as animal poaching.
To assist the industry, Regulation 28 of the Pension Funds Act and the FSCA Guidance Notice 1 of 2019 confirms and provides guidance on the regulatory requirement to consider the impact of ESG factors on the performance of all investments, especially over the long-term, across all asset classes. This is in line with global best practice and reflects the global and regional evidence of the impacts of climate change, social inequality and poor governance in organisations. As this guide shows, there is compelling evidence that ESG factors influence the financial performance of investments. These linkages are now becoming critical and will remain so in the future.
FSCA welcomes and supports this updated version of the RIO Guide as it provides guidance to all trustees on how to best consider and give effect to the regulatory requirements.
We should not (always) wait for compulsion or legislation to do the right things.