Compliance report

There were no significant environmental, social and/or governance-related incidents during 2024. These include incidents of legal non-compliance (whether under investigation, pending finalisation or finalised), directives, compliance notices, warnings, investigations and any public controversies.

No fines, settlements, penalties, or other monetary losses were suffered in relation to ESG incidents.

REGULATORY COMPLIANCE REPORT

The Internal Risk and Compliance Committee (IRCC) oversees regulatory compliance responsibilities. The Committee monitors, assesses, researches and reports on the regulatory environment in which Blue Label operates. The IRCC reports to the Audit, Risk and Compliance Committee (ARCC).

The process of compliance management encompasses:

  • identifying and prioritising all Acts and regulations at a national level applicable to Blue Label;
  • incorporating regulatory requirements into control measures such as standard operating procedures, processes, manuals and policies;
  • recommending corrective measures or steps to ensure compliance; and
  • monitoring compliance through the adequacy and effectiveness of control measures.

The risk of non-compliance is being managed through:

  • the quarterly review and update of the Blue Label regulatory universe;
  • the compilation of compliance risk management plans for high-risk legislation utilising external service providers; and
  • the continuous monitoring of the regulatory environment.

The regulatory environment changes constantly. We proactively contribute to and manage our regulatory environment by considering the interests of all our stakeholders and clients.

The Board is satisfied that Blue Label has complied with all relevant provisions of the Companies Act of South Africa and the JSE Listings Requirements and has operated in conformity with Blue Label's MOI during the year.

No substantial complaints have been received concerning breaches of customer privacy, as, categorised by complaints received from data subjects and complaints or requests for information from the Information Regulator.

APPROACH TO TAX

Taxation compliance

Taxation is managed as part of the regulatory compliance process managed under the IRCC and overseen by the ARCC. There were no instances of significant penalties or disputes with the South African Revenue Service during the year under review. Expert advice is obtained in managing compliance with any complex areas of tax legislation. Blue Label does not have any significant foreign subsidiaries.

The total tax incurred by Blue Label in the current year amounted to R346.1 million. The total amount consists of the following categories of taxes:

Category 2024
R'000
2023
R'000
Income taxes 136 033 235 506
Property taxes 2 918 2 497
Net (creditable)/non-creditable VAT (18 919) 74 588
Employer-paid payroll tax 224 676 177 839
Other taxes 1 343

The information below summarises how Blue Label has managed the requirements of two pieces of significant South African legislation:

Protection of Personal Information Act, 2013 (POPIA)

POPIA gives effect to section 14 of the Constitution, which provides that everyone has the right to privacy. The Act promotes the protection of personal information processed by public and private bodies and seeks to balance the right to privacy against other rights such as access to information.

The following POPIA initiatives have been embedded to ensure compliance at 31 May 2024:

  • The Blue Label Compliance Framework has been reviewed and approved by the Audit and Risk Committee.
  • POPIA information sessions have been presented to the various subsidiaries, associates and stakeholders.
  • POPIA-related policy documents have been updated.
  • POPIA Control Risk Management Plan has been completed to assist risk management.
  • Promotion of Access to Information Act, No 2 of 2000 (PAIA) manuals have been updated.
  • POPIA impact assessments have been updated to perform gap analyses. These impact assessments are ongoing based on new products or initiatives being introduced throughout Blue Label.

Cybercrimes Act, 19 of 2020

Blue Label operations rely heavily on technology platforms to facilitate service delivery, which increases the risk of cybercrime. Therefore, it is critical to maintain the integrity and stability of key IT systems to protect stakeholder interests against increasingly sophisticated targeted attempts at digitally assisted fraud, which is one of the main objectives of the Cybercrimes Act, 19 of 2020.

Cybersecurity threats remain a critical ongoing risk and cause a significant part of our technology investments. Stringent standards for information and infrastructure security controls are constantly being reviewed and reinforced to ensure our efforts continue strengthening our cybersecurity posture. We proactively assess our vulnerabilities and risk of exposure on an ongoing basis while driving cyber risk prevention, assessment and education programmes to maintain vigilance. Blue Label is embedding security as a core component within the platform delivery via governed development mechanisms and implemented detection capabilities and response processes in our environment.

The initial focus of our cybersecurity maturity journey was on the suite of NIST cybersecurity framework controls, in line with our approved strategy. The following has been accomplished:

Initiative   Description
Implementation of Security Operations Centre (SOC) services.   Our SOC has been fully implemented and is currently operational, which provides 24/7 cybersecurity monitoring for our environment.
Security awareness training campaigns through the KnowBe4 platform.   Monthly security awareness training campaigns are rolled out to staff, covering various security domains.
Designed and implemented cybercrimes and incident management processes.   Cybercrimes and incident management processes are still in effect.
An annual review of the processes was conducted.   Internal audit performed reviews around processes supporting compliance with the Cyber Crimes Act.
Developed incident response and incident response testing as well as scenario planning.   Incident response processes are still in place and scenario testing will be performed during 2024/25.
Developed and implemented an Information Security Management Systems (ISMS) aligned to ISO 27001.   We have achieved certification against ISO 27001:2022 for our ISMS. Our core trading platform and environment operate stringent security controls to safeguard our customer and employee data. Maintenance of ISMS is ongoing. Surveillance audits will be conducted to ensure the maintenance of the certification.