Our compliance with the GRI G3 reporting requirements

Based on the GRI G3 reporting requirements, we are self-declared level B+ compliant. This is based on information contained in this webbased Sustainability Report and its supporting documents, together with other relevant information presented in our 2011 Integrated Annual Report and on the broader Sanlam Group website (www.sanlam.co.za). In other words, we have reported on all the company profile disclosures listed under Column B below and have disclosed our broad approach to managing each of our material sustainability pillars. We have reported on at least 20 specific performance indicators relating to stated material pillars, with at least one from each of the economic, environment, human rights, labour, society and product responsibility categories.

GRI Table

SANLAM SUSTAINABILITY REPORT GRI PERFORMANCE INDICATORS
	GRI G3 ELEMENT	GRI COVERAGE	REFERENCE / COMMENTARY
STRATEGY AND PROFILE
1. Strategy and analysis
1.1	Senior decision makers' statement about the relevance of sustainability to the organisation and its strategy.	Full	See Message from the Chairman of the Social, Ethics and Sustainability Committee and Message from Group Chief Executive.
1.2	Impacts, risks and opportunities (on stakeholders and financial performance)	Full	See Addressing our material sustainability pillars: the report at a glance.
2. Organisational profile
2.1	Name of reporting organisation.	Full	See Sanlam Group at a glance.
2.2	Primary products and services.	Full	See Sanlam Group at a glance.
2.3	Organisational operating structure.	Full	See Sanlam Group at a glance.
2.4	Location of the organisation's Headquarters.	Full	2 Strand Road, Bellville, Cape Town, South Africa.
2.5	Countries where the organisation operates.	Full	See This is Sanlam.
2.6	Nature of ownership and legal form.	Full	See Sanlam Group at a glance.
2.7	Markets served.	Full	See Sanlam Group at a glance.
2.8	Scale of the reporting organisation.	Full	See Sanlam Group at a glance.
2.9	Significant changes during the reporting period.	Full	See About this report.
2.10	Awards received.	Full	Refer to our 2011 Integrated Report: Some awards and market recognition in 2011.
3. Report parameters
3.1	Reporting period.	Full	See About this report.
3.2	Date of most recent previous report.	Full	See About this report.
3.3	Reporting cycle.	Full	See About this report.
3.4	Contact point.	Full	See About this report.
3.5	Process for defining report content.	Full	See About this report and Addressing our material sustainability pillars: the report at a glance.
3.6	Boundaries of report.	Full	See About this report.
3.7	Limitations.	Full	See About this report.
3.8	Basis for reporting on joint ventures and subsidiaries.	Full	See About this report.
3.9	Data measurement techniques.	Full	Included in the various sections on our material sustainability pillars.
3.10	Explanation of effect of re-statements.	Full	None to report.
3.11	Significant changes.	Full	See About this report.
3.12	GRI index.	Full	GRI Index.
3.13	Assurance.	Full	See Assurance statement and About this report.
4.Governance, commitments and stakeholder engagement
4.1	Governance structure.	Full	See Sustainability governance and management structure. Also refer to our 2011 Integrated Report: Corporate Governance report.
4.2	Indicate whether the Chair of the highest governance body is also an executive officer.	Full	See Sustainability governance and management structure. Also refer to our 2011 Integrated Report: Corporate Governance report.
4.3	Board profile (number, gender, Executive vs. Non-executive)	Full	Refer to our 2011 Integrated Report: Sanlam Board of directors and committee memberships.
4.4	Mechanisms for stakeholders and employees to provide recommendations to Sanlam Board.	Partial	See Engaging our stakeholders. Our stakeholder engagement strategy is currently being developed. This indicator will be fully reported on in 2012.
4.5	Linkage between compensation and performance.	Full	Group remuneration structures are aligned to business strategy through some direct link of the vesting of bonuses and long-term incentives to the sustainable management and growth of the business over the long term. Refer to our 2011 Integrated Report: Corporate Governance report.
4.6	Processes for managing conflicts of interest.	Full	Refer to our 2011 Integrated Report: Corporate Governance report.
4.7	Process for determining qualifications and expertise.	Full	As part of our annual BBBEE verification process random EXCO/Board members are interviewed to verify their qualifications and expertise. Refer to our 2011 Integrated Report: Corporate Governance Report.
4.8	Internally developed statements of mission or values,codes of conduct, and principles relevant to economic, environmental and social performance.	Full	See Promoting ethical behaviour through good governance, providing for ESG issues within Sanlam Investment Management (SIM), and materials and waste management.
4.9	Board oversight of CSR policies and risk management.	Full	See Sustainability governance and management.
4.10	Processes for evaluating the board's sustainability performance	Partial	See Integrated Report: Corporate Governance report.
4.11	Explanation of how the precautionary approach or principle is addressed by the organisation.	Full	This indicator is not specifically addressed in this report, however a precautionary approach is taken through risk management which forms part of the Group's centralised function.
4.12	Externally developed, voluntary economic,environmental and social charters, sets of principles, or other initiatives.	Full	See Message from the Chairman of the Social, Ethics and Sustainability Committee, responsible products and services, responsibility towards the natural environment and responsibility for developing our people.
4.13	Memberships in associations (such as industry associations) and/or national/international advocacy organizations	Full	See Promoting ethical behaviour through good governance, and providing for ESG issues within Sanlam Investment Management (SIM).
4.14	List of stakeholder groups.	Full	See Engaging our stakeholders.
4.15	Basis for identification and selection of stakeholders.	Full	See Engaging our stakeholders.
4.16	Approaches to stakeholder engagement.	Partial	See Engaging our stakeholders. A process is currently underway to develop a more coordinated stakeholder management strategy and action plan. We will report fully on this indicator in 2012.
4.17	Key topics and concerns raised during stakeholder engagement.	Partial	The concerns raised by our stakeholders have informed the development of our Sustainability Management Framework and are therefore reflected in our material pillars. An outcome of the more coordinated stakeholder engagement strategy and action plan will be a clear presentation of topics and concerns raised.
ECONOMIC
Economic performance
EC1	Direct economic value - revenues, operating costs, employee compensation, donations and other community investments, retained earnings, and payments to capital providers and governments.	Full	See Our economic value added.
EC2	Financial implications and other risks and opportunities for the organisation's activities due to climate change.	Partial	See climate change and energy and promoting responsible investment. Please also refer to our 2011 Carbon Disclosure Project (CDP) response available at www.cdproject.net
EC3	Coverage of Sanlam's defined benefit plan obligations.	Full	Refer to our 2011 Integrated Report: Annual Financial Statement note 32.
EC4	Significant financial assistance received from Government.	Full	None.
Market presence
EC5	Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation.	Not reported	This is not deemed material.
EC6	Policy, practices, and proportion of spending on locally-based suppliers at significant locations of operation.	Partial	See our economic value added and responsible procurement. Each office or department within our South African operations follows procurement guidelines. As a financial services company procurement is generally limited to office stationery and goods or services required on a needs basis. Efforts are made to procure locally wherever possible. Due to the ad hoc nature of much of our procurement this also makes practical sense.
EC7	Procedures for local hiring and proportion of senior management hired from the local community at significant locations of operation.	Partial	See Workplace transformation and diversity.
Indirect economic impacts
EC8	Development and impact of infrastructure investments and services provided primarily for public benefit through commercial, in-kind, or pro bono engagement.	Not reported
EC9	Understanding and describing significant indirect economic impacts, including the extent of impacts.	Partial	Sanlam provides appropriate risk, savings, investment and retirement products that encourage good financial management, mitigate financial risk and stimulate growth and economic development. We have not quantified this impact for each operation; however further detail is available at promoting access to financial services, and our economic value added.
ENVIRONMENTAL
Materials
EN1	Materials used by weight or volume.	N/A	Not deemed material due to the nature of the business with its lack of materials used.
EN2	Percentage of materials used that are recycled input materials.	N/A	Not deemed material due to the nature of the business, with its lack of materials used.
Energy
EN3	Direct energy use segmented by primary source.	Partial	See managing our direct environmental impacts.
EN4	Indirect energy consumption by primary source.	Partial	See managing our direct environmental impacts.
EN5	Energy saved due to conservation and efficiency improvements.	Partial	This is not currently measured. Systems are being implemented to enable measurement in the future. Energy savings due to individual energy reduction initiatives is available on request. Associated savings in greenhouse gas emissions as a result of these energy savings is reported in our 2011 Carbon Disclosure Project (CDP) report available at: www.cdproject.net
EN6	Initiatives to provide energy-efficient or renewable energy based products and services, and reductions in energy requirements as a result.	Partial	See climate change and energy. Please also refer to our 2011 CDP response available at www.cdproject.net. There were no onsite renewable energy initiatives underway this year. Sanlam does not provide any products and services that directly assist clients reduce energy use.
EN7	Initiatives to reduce indirect energy consumption and reductions achieved.	Partial	See managing our direct environmental impacts and climate change and energy. Reductions are not currently reported.
Water
EN8	Total water withdrawal by source.	Partial	See sustainable water usage.
EN9	Water sources significantly affected by withdrawal of water.	N/A	We do not consume a significant amount of water at our operations and therefore do not deem our impacts on water sources to be material.
EN10	Percentage and total water volume of water recycled and reused.	N/A	We do not consume a significant amount of water at our operations and therefore do not deem our impacts on water sources to be material.
Biodiversity
EN11	Location and size of land owned, leased or managed in biodiversity-rich habitats.	N/A	None of Sanlam's operations are in biodiversity-rich habitats.
EN12	Description of significant impacts of activities,products, and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas.	N/A	None of Sanlam's operations and activities impact on protected areas.
EN13	Habitats protected or restored.	N/A	This is not material to Sanlam's operations.
EN14	Strategies, current actions and future plans for managing impacts on biodiversity	N/A	Sanlam does not operate in areas where there is risk to biodiversity.
EN15	Number of conservation list species affected by operations	N/A	This is not material due to nature of the business.
Emissions, effluent and waste
EN16	Total direct and indirect greenhouse gas emissions by weight.	Full	See our carbon footprint performance. Also refer to our 2011 CDP response available at www.cdproject.net
EN17	Other relevant indirect greenhouse emissions by weight.	Full	See our carbon footprint performance. Also refer to our 2011 CDP response available at www.cdproject.net
EN18	Initiatives to reduce greenhouse gas emissions and reductions achieved.	Partial	See climate change and energy. Also refer to our 2011 CDP response available at www.cdproject.net
EN19	Emissions of ozone-depleting substances by weight.	N/A	This is not material due to nature of the business.
EN20	NOx, SOx, and other significant air emissions by weight and type.	N/A	This is not material due to nature of the business.
EN21	Total water discharge by quality and destination.	N/A	This is not material due to nature of the business.
EN22	Total amount of waste by type and disposal method.	Not reported	We do not report quantitatively against this indicator because we do not generate a significant amount of waste. See materials and waste management.
EN23	Total number and volume of significant spills.	N/A	This is not material due to nature of the business.
EN24	Weight of transported, imported, exported or treated waste deemed hazardous under the terms of the Basel Convention AnnexI, II, III, and VIII, and percentage of transported waste shipped internationally.	N/A	This is not material due to nature of the business.
EN25	Identity, size, protected status and biodiversity value of water bodies and related habitats significantly affected by the reporting organisation's discharges of water and runoff.	Full	None to report: we do not "significantly affect" water bodies through discharges of water and runoff.
Products and services
EN26	Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation.	Partial	See responsibility towards the natural environment.
EN27	Percentage of products sold and their packaging materials that are reclaimed by category.	N/A	This is not measured due to the nature of the products and services involved in the business.
Compliance
EN28	Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations.	Full	None to report. No significant fines or non-monetary sanctions for non-compliance with environmental laws and regulations.
Transport
EN29	Significant environmental impacts of transporting products and other goods and materials used for Sanlam's operations, and transporting members of the workforce.	Partial	See carbon footprint performance. In transporting products and members of the workforce, we strive to reduce our carbon footprint.
Overall
EN30	Total environmental protection expenditures and investments by type.	N/A	This is not material due to nature of the business.
LABOURPRACTICES AND DECENT WORK
Employment
LA1	Total workforce by employment type, employment contract and region.	Partial	See workplace transformation and diversity - Sanlam Group staff complement at 31 December 2011. We do not collect data per region but at group level.
LA2	Total number and rate of employee turnover by age group, gender and region.	Partial	See attracting and retaining talent.
LA3	Benefits provided to full-time employees that are not provided to temporary or part-time employees, by major operation.	N/A	We do not believe that it is sufficiently material to provide information on this issue at the recommended level of detail.
Labour/Management relations
LA4	Percentage of employees covered by collective bargaining arrangements.	Full	3.6% of our employees are covered by collective bargaining agreements.
LA5	Minimum notice period(s) regarding significant operational changes, including whether it is specified in collective agreements.	N/A	The issue is not considered material for reporting. Throughout our operations, systems are in place aimed at ensuring effective dialogue and relations with all employee representative groups.
Occupational health and safety
LA6	Employee representation in health and safety committees	N/A	Employee representation in health and safety practices is ensured where applicable throughout the organisation. Measurement of representation is not deemed material.
LA7	Rates of injury, occupational diseases, lost days, absenteeism and total number of work-related fatalities, by region.	N/A	This information is not deemed material to include in this report; information is available on request.
LA8	Employee wellness programmes regarding serious diseases	Full	See promoting employee wellness and Sanlam culture.
LA9	Health and safety topics covered in formal agreements with trade unions.	N/A	Sanlam has no formal agreements with trade unions.
Training and education
LA10	Average hours of training per year per employee by category.	Not reported	Not measured. Sanlam relies on alternative measures as a means of assessing the impact of training. skills development and career progression.
LA11	Programmes for skills management and lifelong learning that support the continued employability of employees and assist them in managing their careers.	Full	See skills development and career progression.
LA12	Percentage of employees receiving regular performance and career development reviews.	Partial	See skills development and career progression.
Diversity and equal opportunity
LA13	Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership, and other indicators of diversity.	Partial	See workplace transformation and diversity. Also refer to our 2011 Integrated Report: Corporate Governance report.
LA14	Ratio of basic salary of men to women by employee category.	N/A	We do not report against this indicator. There is no differentiation between male and female employee salaries.
HUMAN RIGHTS
Investment and procurement activities
HR1	Percentage and total number of significant investment agreements that include human rights clauses or that have undergone human rights screening.	N/A	This is not specifically measured, as it is not deemed material. We are committed to the UN Principles of Responsible Investment (PRI) and, while no formal policy exists, will take human rights into consideration when making significant investments consistent with the Group's values.
HR2	Percentage of significant suppliers and contractors that have undergone screening on human rights and actions taken.	N/A	This is not measured as it is not deemed material. Where applicable, we are legislatively compliant.
HR3	Total hours of employee training on policies and procedures concerning aspects of human rights that are relevant to operations, and percentage of employees that are trained.	N/A	This is not measured as it is not deemed material. All employees receive training on the company's Code of Ethical Conduct. Where applicable, we are legislatively compliant.
Non-discrimination
HR4	Total number of incidents of discrimination and actions taken.	Full	See managing cases of grievance.
Freedom of association and collective bargaining
HR5	Operations identified in which the right to exercise freedom of association or collective bargaining may be at significant risk, and actions taken to support these rights.	Full	None of our operations have been identified as being at significant risk.
Child labour
HR6	Operations identified as having significant risk for incidents of child labour, and measures taken to contribute to the elimination of child labour.	Full	No operations have been identified for this risk.
Forced and compulsory labour
HR7	Operations identified as having significant risk for incidents of forced or compulsory labour, and measures taken to contribute to the elimination of forced or compulsory labour.	Full	No operations have been identified for this risk.
Security practices
HR8	Percentage of security personnel trained in the organisation's policies or procedures concerning aspects of human rights that are relevant to operations.	N/A	This is not measured as it is not deemed material due to nature of the business.
Indigenous rights
HR9	Total number of incidents of violations involving rights of indigenous people and actions taken.	Full	None reported. Where applicable, we are legislatively compliant.
SOCIETY
FS15	Policies for the fair design and sale of financial products and services	Partial	Refer to Responsible products and services.
Community
SO1	Nature, scope, and effectiveness of any programs and practices that assess and manage the impacts of operations on communities, including entering, operating, and exiting.	N/A	This is not reported as it is not deemed material. As a financial services company our physical operations do not have any significant impacts on communities. We believe that our products contribute positively to the financial security of people in the communities which we service.
FS13	Access points in low-populated or economically disadvantaged areas by type.	Not reported	This is not specifically measured. This is qualitatively addressed in Responsible products and services.
FS14	Initiatives to improve access to financial services for disadvantaged people.	Full	See Responsible products and services. Through our sponsorships (Takalane Sesame) and CSI initiatives we deliver financial education. Sanlam Sky is specifically targeting the low-income, disadvantaged people, to provide services that they demand and to encourage the uptake of services that promote good financial management.
Corruption
SO2	Percentage and total number of business units analysed for risks related to corruption.	Not reported	This is governed by our mandatory Code of Ethical Conduct. We do not report quantitatively on this indicator. Refer to our material sustainability pillars: reviewing our 2011 performance.
SO3	Percentage of employees trained in organisation's anti-corruption policies and procedures.	Not reported	This is governed by our mandatory Code of Ethical Conduct. We do not report quantitatively on this indicator. Refer to our material sustainability pillars: reviewing our 2011 performance.
SO4	Actions taken in response to incidents of corruption.	Full	See promoting ethical behaviour through good governance.
Public policy
SO5	Public policy positions and participation in public policy development and lobbying.	Full	See promoting ethical behaviour through good governance.
SO6	Total value of financial and in-kind contributions to political parties, politicians and related institutions by country.	Full	No money was donated in this regard. Our business integrity policy prohibits us from making donations to any political party or politicians.
Anti-competitive behaviour
SO7	Total number of legal actions for anti-competitive behaviour, anti-trust, and monopoly practices and their outcomes.	Full	None.
Compliance
SO8	Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with laws and regulations.	Full	None.
PRODUCT RESPONSIBILITY
FS1	Policies with specific environmental and social components applied to business lines.	Partial	See responsible products and services. We aim to report more comprehensively on the requirements of the Financial Services Sector Supplement in the future.
FS2	Procedures for assessing and screening environmental and social risks in business lines.	Partial	See responsible products and services. We aim to report more comprehensively on the requirements of the Financial Services Sector Supplement in the future.
FS3	Processes for monitoring clients' implementation of and compliance and social requirements included in agreements or transactions.	Partial	See responsible products and services. We aim to report more comprehensively on the requirements of the Financial Services Sector Supplement in the future.
FS4	Process(es) for improving staff competency to implement the environmental and social policies and procedures as applied to business lines.	Partial	See responsible products and services. We aim to report more comprehensively on the requirements of the Financial Services Sector Supplement in the future.
FS5	Interaction swith clients/investees/business partners regarding environmental and social risks and opportunities	Not reported	None. We will look to formally include interactions in this regard aspart of our stakeholder engagement process, which is currently being developed.
Product Portfolio
FS6	Percentage of the portfolio for business lines by specific region, size (e.g. micro/SME/large) and by sector.	N/A	It is not deemed material to report on this indicator to the level of detail required.
FS7	Monetary value of products and services designed to deliver a specific social benefit for each business line broken down by purpose.	Partial	See our socially responsible investment funds. It is not deemed material to report on this indicator to the level of detail required.
FS8	Monetary value of products and services designed to deliver a specific environmental benefit for each business line broken down by Purpose.	N/A	We do not have products designed to deliver a specific environmental benefit.
Customer health and safety
PR1	Life cycle stages in which health and safety impacts of products and services are assessed for improvement, and percentage of significant products and services categories subject to such procedures.	N/A	This is not measured as it is not deemed material due to nature of the business.
PR2	Total number of incidents of non-compliance with regulations and voluntary codes concerning health and safety impacts of products and service during their life cycle, by type of outcomes.	N/A	This is not measured as it is not deemed material due to nature of the business.
Product and service labelling
PR3	Type of product and service information required by procedures, and percentage of significant products and service subject to such information requirements.	Not reported	Sanlam's products are legislatively compliant. Refer to our material sustainability pillars: reviewing our 2011 performance.
PR4	Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labelling, by type of outcomes.	Partial	No significant incidents.
PR5	Practices related to customer satisfaction,including results of surveys measuring customer satisfaction.	Full	See treating our clients fairly.
FS16	Initiatives to enhance financial literacy by type of beneficiary	Partial	See corporate social investment (CSI) and client education initiatives.
Marketing communications
PR6	Programmes for adherence to laws, standards and voluntary codes concerning marketing communications, including advertising,promotion and sponsorship.	Not reported	See treating our clients fairly for a qualitative comment in relation to this indicator.
PR7	Total number of incidents of non-compliance with regulations and voluntary codes of concerning marketing communications,including advertising, promotion, and sponsorship by type of outcomes.	Partial	No significant incidents.
Customer privacy
PR8	Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data.	Full	None.
Compliance
PR9	Monetary value of significant fines for non-compliance with laws and regulations concerning the provision and use of products and services.	Full	None.
Audit
FS9	Coverage and frequency of audits to assess implementation of environmental and social policies and risk assessment procedures	Not reported	We do not fully report on FS1 and FS2. When formal environmental and social policies and risk assessment procedures are in place, we will conduct audits to ensure effective implementation.
Active ownership
FS10	Percentage and number of companies held in the institution's portfolio with which the reporting organization has interacted on environmental or social issues.	Partial	We do not report quantitatively on this indicator. SIM is increasingly engaging with companies on environmental and social issues. See Increasingly using proxy votes to influence remuneration.
FS11	Percentage of assets subject to positive and negative environmental or social screening.	Partial	We do not report quantitatively on this indicator. SIM is increasingly engaging with companies on environmental and social issues. See providing for ESG issues within Sanlam Investment Management (SIM).
FS12	Voting polic(ies) applied to environmental or social issues for shares over which the reporting organization holds the right to vote shares or advises on voting	Full	We have enhanced our engagement with investee companies through our proxy voting policy. See Increasingly using proxy votes to influence remuneration.

1. Sustainability Governance

2. Responsibility for Developing our people

3. Responsible products and services

4. Responsibility towards a prosperous society

5. Responsibility towards the natural environment

Our compliance with the GRI G3 reporting requirements

GRI Table