The Supervisory Board recognises that it is ultimately accountable for legal compliance and for establishing an effective legal compliance framework for TFG. Management, with the assistance of TFG’s legal compliance team, implements this legal compliance framework, monitors legal compliance and implements processes to ensure that legal compliance risk management is part of an integrated risk management framework within TFG.
The legal compliance team monitors compliance with regulatory requirements and, where required, assist and guide management. They are considered an integral part of the combined assurance process. The team meets with management to refine or rethink processes to ensure compliance. This includes encouraging a proactive culture and attitude to legal compliance among staff, reviewing or amending training material for staff, assisting quality assurance team members in addressing legal compliance matters, training staff members at head office and assisting internal audit by analysing data from the store self-assessments. The above, and the roles and responsibilities set out below, provide a means to ensure that legal compliance is effective.
TFG is impacted by, adheres to, or uses as guidance in its operations, numerous non-binding rules, codes, standards, initiatives and frameworks.
Key areas of focus during the reporting period
Over the past financial year, legal compliance (for TFG Africa, TFG London and TFG Australia) focused on the following regulatory key matters:
- Proposed amendments to credit and competition legislation.
- Proposed localisation legislation with regards to TFG Africa.
- Financial sector changes affecting optional customer insurance products.
- Protection of personal information or data.
- Monitor the progress on Brexit and related implications.
- Anti-corruption, money-laundering and criminal finances legislation.
ROLES AND RESPONSIBILITIES
- Reporting to the Audit, Risk, and Social and Ethics Committees.
- Providing assurance to the Audit and Risk Committees as the second line of defence under combined assurance.
- Creating a culture of compliance with regulatory requirements.
- Identifying, reviewing and advising TFG on existing, new or draft legislation, including giving recommendations on applicable rules.
- Facilitating legal compliance and assigning responsibility for legal compliance.
- Drafting legal compliance risk management plans for key pieces of legislation, including compiling legal compliance risk registers which form part of the wider risk management process within TFG.
- Monitoring legal compliance by the business and reporting on findings to management.
- Advising on regulatory developments that could affect or present opportunities for TFG by attending parliamentary meetings.
Key future focus areas
TFG will continue to focus on the areas listed above over the next financial year as well as any other relevant legislative developments that may arise.
Based on key laws that were effective as at 31 March 2018, there were no material areas of non-compliance. During the past financial year, there were no monitoring or legal compliance inspections by environmental regulators, no findings of non-compliance with environmental laws and no criminal sanctions or prosecutions for non-compliance with environmental legislation.