Page 101 - Profile's Unit Trusts & Collective Investments - September 2025

Legislation and guidelines Chapter 5

CRISA embraces five key principles, which should be encapsulated in formal policies adopted by
institutions:
R The institutional investor should incorporate sustainability considerations, including a
systemic approach to integrating material environmental, social and governance (ESG), into
its investment analysis and investment activities.
R The institutional investor should demonstrate the acceptance of the rights and responsibilities
of asset ownership diligently to enable effective stewardship. In practice, this means that
institutions are encouraged to engage with companies in which they invest, to attend and vote
at shareholder meetings in accordance with CRISA policies, and to promote transparency in
communication. Under CRISA, these responsibilities still attach to the institution even if some
functions are outsourced to third-party service providers.
R Where appropriate, institutional investors should consider a collaborative approach to
promote acceptance and implementation of the principles of CRISA and other codes and
standards applicable to institutional investors and targeted capacity building throughout the
investment industry.
R The institutional investor should have sound governance structures and processes in place
so that investment structures and activities reflect and promote responsible investment and
diligent stewardship and proactively manage conflicts of interest.
R Investment organisations should ensure disclosures are meaningful, timeous and
accessible to ensure stakeholders can make informed assessments of progress towards
positive outcomes.
The code requires that institutional investors fully and publicly disclose at least once a year to
what extent the code has been applied. Reasons must be given if any of the principles of the code
have not been followed.
Although CRISA is a voluntary code it has become the standard for investment activities in SA.
The full code is available on the CRISA website: www.crisa2.co.za

Treating customers fairly (TCF)
One of the responsibilities of the FSCA is to protect consumers of financial products offered by
regulated entities. As part of this objective, the FSCA released a treating customers fairly discussion
paper in May 2010 based on the TCF initiative of the UK Financial Services Authority (FSA) started
in 2001. In November 2011 ASISA published a TCF Best Practices Guideline for its members, which
has since been updated, most recently in 2022, to reflect evolving regulatory expectations and
industry best practices.
Objective Outcome
Right culture and governance TCF is entrenched in the organisation so that the fair
treatment of customers is central to corporate culture
Right targeting and product suitability Products are correctly designed for specifically identified
consumer groups and sold only to the targeted groups
Right information and disclosure Straightforward information is provided and customers
are kept informed prior to, during and after the sale
Right advice The provision of suitable advice that takes into account
customers’ circumstances
Right delivery Products are supplied that meet customer expectations
and live up to promises made in terms of performance
and service levels
Right post-sale treatment Product switches, customer queries and service
complaints are facilitated without the imposition of
undue administrative barriers

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