Code of Ethics

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[well color="primary-dark" class="text-well"]The Public Investment Corporation Limited (PIC) recognises the importance of protecting the organisation, its employees, its revenue, expenditure and assets, and the public funds with which it has been entrusted, from any attempt by any person to gain financial or other benefits in an unlawful, dishonest or unethical manner.

That is why at the PIC, we strive to be an asset manager of choice by conducting our business ethically in order to meet the legitimate expectations of all our stakeholders.

The PIC Code of Ethics serves as the foundation for a culture that fosters actions consistent with our ethical standards. It reminds us that ethics requires action.

Together we can ensure we create a PIC that is known for its ethical conduct. I commit to act with integrity in all my actions and decisions. I commit to do my part and I urge you to commit to doing yours, as we can only win by doing this as a collective.
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Why do we have a Code of Ethics?

The purpose of this Code is to provide a behavioural standard that promotes ethical business practices and upholds our values. It makes clear that we not only follow the law but strive to operate with the highest levels of ethics and integrity. It describes the ethical norms and behaviours that the PIC expects from each of us as employees and Directors. Our Code promotes a shared understanding of what achieving the right results the right way means.

Who must comply with this policy?

This Code applies to members of the PIC Board of Directors and all PIC employees as well as contract employees, consultants, agents, investee companies, service providers, contractors, outside agencies conducting business with the PIC. Although many investee companies, consultancies, agents, and service providers may have their own codes or principles, the PIC expects that anyone who is involved in our activities act in ways that are consistent with principles as set out in the PIC Code of Ethics.

Who must be consulted if you have questions?

You should contact the Ethics Office or Askethics@pic.gov.za if you have any questions about the Code. [/well] 

[well color="primary-dark" class="text-well"] Anonymously (External)

• Contacting our PIC External Whistleblower Hotline anonymously: 0800205098
• Via email at information@whistleblowing.co.za
• Via the link on the PIC website (Whistle Blowers)

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The PIC Clients

The PIC expects all employees to treat its clients fairly, according to our formulated key principles which you can find in the Treating Clients Fairly Policy.

At the PIC, we have dedicated skills and resources to deliver on our clients’ investment goals and objectives. All investment decisions are directed by detailed investment mandates, which are negotiated individually with each client in line with their investment profile and risk appetite.

Furthermore, the PIC must report accurately and timely to our clients as required by the agreements and applicable legislation.

Investee Companies

The PIC believes that a strong commitment to the highest standards of business ethics and sound corporate governance is essential to creating long-term value for clients. To that end, the PIC seeks investee companies that it enters into a business relationship with, to adopt similar ethical business practices and sound corporate governance.

Our investee companies are expected to share our commitment to integrity by doing business fairly, ethically and in compliance with all applicable laws and regulations. It is therefore important for the PIC to conduct due diligence in line with the PIC governance processes from time to time, which includes embedment of environmental, social and governance (ESG) principles.

The PIC reserves the right not to invest in any company that has been convicted or proven to practice unethical behaviour or does not adhere to principles of responsible investment.

External Fund Managers

In line with our ethical investment principles, the PIC requires all external fund managers to incorporate responsible ESG practices in their investment process which are governed by ESG policies and that is aligned to the PIC policies as well as best practice principles.

Shareholder

The PIC is an asset management firm wholly owned by the Government of the Republic of South Africa, represented by the Minister of Finance. The PIC through its shareholder compact must ensure that there is efficient use of resources and accountability for the stewardship of those resources. Furthermore, the PIC must report accurately and timely to our Shareholder as required by the PFMA and applicable legislation.

Our Suppliers

The PIC suppliers must be selected through a fair and competitive procurement process, based on merit and not through personal connections, bias, or improper influence.

Employees and directors of the PIC should have no relationship, financial or otherwise, with any supplier that might conflict, or appear to conflict, with the employee’s and director’s obligation to act in the best interest of the PIC and our clients. We avoid conflicts of interest or any situation that could give rise to an appearance of a conflict of interest.

Government, Rule of Law and Regulators

The PIC respects the authority of governments, the rule of law and regulators wherever it conducts business.

We commit to ensuring that our processes, dealings and activities are compliant with all prevailing laws, common law rules and all relevant regulatory, directive and supervisory requirements of the countries we operate in.

Health and Safety

The PIC is committed to taking reasonable precautions to ensure safety, healthy and security in the work environment for all employees and directors.

Business Continuity

At the PIC, in addition to our role as an asset manager, the uninterrupted continuity of processes and services is of the essence to our work. The PIC has implemented business continuity plans, which are regularly reviewed to ensure that any unforeseen event is managed timeously and effectively.

Environment

PIC as a responsible investor, is committed to the protection of the environment, through encouraging environmentally conscious Investee Companies.
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Avoiding Conflicts of Interest

All directors and employees of the PIC must avoid situations that might lead them to place their own interests (or those of another) above their obligation to the PIC.

Gifts and Entertainment

Employees and directors must maintain the highest standards of integrity and professionalism in relation to the provision or acceptance of Gifts, gratification, or hospitality in order to avoid unnecessary risk. There are declaration and pre-approval requirements for the giving or receiving of gifts. There are also restrictions, including pre-approval limits that are set out in the PIC Gifts and Entertainment Policy.

Cooling Off Period in Respect of Ex-Employees and Ex-Directors

To avoid a conflict of interest or any situation which could give rise to the appearance of favouritism, undue influence and/or unfair advantage, the PIC has deemed it appropriate to introduce the following prohibitions which shall apply for a period of 18 months from cessation of a relationship with the PIC and shall be extended to any persons affiliated to the PIC ex-employee or ex-director (“related party”).

Prohibition from contracting with PIC as Service Providers

All ex-employees and ex-directors of the PIC are prohibited from contracting with the PIC as a service provider and/or supplier and/or consultant.

Prohibition from transacting during cooling off period

All ex-employees and ex-directors of the PIC are prohibited from contracting with the PIC, in respect of assets under management by the PIC, either as borrower or investee and in respect of the purchase of any investments and/or sale of securities.

Financial Crime, Fraud and Corruption

The PIC adopts a zero-tolerance approach to any acts of fraud, bribery and corruption perpetrated by PIC employees, directors, suppliers and or investee companies with whom we do business or who act on our behalf.

The PIC will also not be associated with or facilitate money laundering or terrorist financing and has introduced a Risk Management and Compliance Programme, which comprise policies, processes, practices, procedures and plans to ensure statutory duties and regulatory obligations and agreed risk management standards are met.

Political Contributions

The PIC does not make direct or indirect contributions in cash or in-kind to any political party.

Data Privacy

The PIC regards the fair and lawful treatment of personal information as being of utmost importance. We abide by privacy laws and regulations that set out requirements for handling personal information.

Ethical Guidelines for Associated Parties

At the Public Investment Corporation (PIC), we value partnerships based on trust, transparency and shared values. These Ethical Guidelines for Associated Parties set out the standards expected from our business partners to maintain integrity, legal compliance and ethical conduct. Following these guidelines supports an ethical culture that benefits our clients, communities and the economy. Guidelines for Associated Parties.pdf[/well]