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Maintaining our legitimacy

Maintaining our legitimacy

The board, assisted by the social and ethics committee, ensures the MultiChoice Group is, and is seen to be, a responsible corporate citizen by considering not only its financial performance but also the business's impact on the environment and the societies where it operates. The group's purpose, values and strategy are aligned with the principles of responsible corporate citizenship.

Responsible corporate citizenship

The group's businesses manage numerous corporate citizenship initiatives affecting the workplace, economy, society and environment.

These include:

  • BBBEE and employment equity performance for South African subsidiaries
  • Local employment
  • Health and safety laws
  • Employee development opportunities
  • Responsible tax policy
  • Fraud and anti-bribery and anti-corruption initiatives
  • Initiatives to minimise our environmental impact
  • CSI initiatives
  • Privacy and data protection

Ensuring compliance with laws and regulations

The group has a primary listing on the JSE and is subject to the JSE Listings Requirements, the guidelines in King IV and legislation applicable to publicly listed companies in South Africa. The board is responsible for ensuring the group complies with all of its statutory requirements and has taken sufficient steps to ensure the group's compliance with all relevant requirements.

The board and senior management empower and properly resource the group head of compliance, who handles the day-to-day responsibilities, including mitigating risks and building trust amongst its stakeholders, with support from segment legal compliance teams and, where necessary, external consultants. The risk committee oversees compliance, including reviewing and approving the legal compliance policy, and other related policies. The board governs compliance with applicable laws and adopted, rules, codes, and standards.

The legal compliance framework (the framework) incorporates the group governance structures and controls in line with legislative requirements and international best practices. The framework recognises ethical behaviour and compliant culture as the core elements of its compliance programme. The culture supports principled performance, ensuring that all preventative, detective and response measures put in place are effective.

The framework is aligned with the legal compliance policy which is approved by the board and reviewed on a three-year rotational basis. The framework is also aligned to the 'Generally Accepted Compliance Practice Framework' principles and standards issued by the Compliance Institute of Southern Africa.

Compliance risk assessments are conducted annually to understand the group's compliance risk appetite and tolerance levels and identify risks or events which have the highest impact and measure their probability or likelihood.

The group's compliance communication programme facilitates awareness of applicable laws, regulations, policies, and procedures, and educates directors, management, employees, and other stakeholders on how to comply with them. Major compliance related training activities concluded include the following:

Compliance training

Online training activities – broken down by audience Total Governing
body
Employees Third
parties
Competition Compliance * 267 267
Cyber Security Essentials 4 053 4 4 040 9
Data Governance and Privacy * 108 64 44
Diversity, Equity and Inclusion 2 162 1 2 153 8
Occupational Health and Safety 2 551 2 2 538 11
Sanctions * 289 17 272
Anti-Money Laundering * 365 365
Treating customers fairly * 365 365
Total 10 160 24 10 064 72
Online training activities – broken down by segment Total Governing
body
Employees Third
parties
MultiChoice South Africa 8 003 6 7 925 72
MultiChoice Rest of Africa 1 861 1 1 860
Irdeto 296 17 279
Total 10 160 24 10 064 72

* Online training modules rolled out to selected target audiences.

Assurance on the effectiveness of compliance management is received through a combined assurance model.

These arrangements enable the risk committee and the board to oversee the group's legal compliance holistically in a way that supports good corporate citizenship. Internal audit conducts regular governance reviews of the group legal compliance function to assess its adequacy and effectiveness.

Incidents, fines and penalties

The group operates in a highly regulated environment, making compliance a critical consideration. We participate in the regulatory processes affecting our industry through various public forums and debates, providing inputs on formulating standards and strategies for the industry. There has been no significant non-compliance, environmental, social and/or governance related incidents during the reporting period and directors are satisfied that the group has complied and operated in conformity with:

  • The provisions of the Companies Act and any other applicable laws relating to its incorporation.
  • Its MOI and other relevant constitutional documents.

Further, there has been no significant fines, settlements, penalties, and other monetary loss suffered in relation to environmental, social or governance incidents or breaches.

Performance and future focus

Our key areas of focus during the reporting period were:

  • Revising the compliance-related policies, management processes and compliance culture
  • Developing focused awareness campaigns and training interventions
  • Revising group social media policy
  • Revising various group policies
  • Supporting ongoing maturation of the third-party risk management framework
  • Revising the group whistle blower process, policies and training interventions
  • Executing planned training and awareness activities

Going forward, we will focus on:

  • Continuing to manage reputational risk
  • Conducting risk-based compliance assessments to identify highest risk areas
  • Implementing enhanced controls to address identified areas of improvement
  • Updating applicable compliance statutes, rules and regulations
  • Coordinating training and awareness campaigns
  • Updating compliance risk management plans
  • Monitoring implementation of compliance programmes