Rendani Nematswerani

Ethics Governance Policy Management
• Develop, implement, and maintain the organisations Code of Ethics and related policies.
• Ensure policies are regularly reviewed and updated to align with legislation, industry standards, and best
practices.
• Provide input to governance structures (Board, Ethics Committees) on ethics matters.
Training, Awareness Culture Building
• Design and roll out ethics training programmes for employees, executives, and Board members.
• Facilitate onboarding ethics orientation for new hires.
• Lead ethics awareness campaigns to promote a culture of integrity and accountability.
Ethics Advisory Conflict of Interest Management
• Provide confidential and impartial advice to employees, management, and directors on ethical dilemmas,
professional conduct, and conflict of interest matters.
• Maintain a conflict-of-interest register and ensure annual declarations are completed and reviewed.
Reporting, Investigation & Case Management
• Manage the organisations ethics helpline and other reporting channels.
• Oversee the intake, triage, investigation, and resolution of ethics-related complaints or allegations.
• Track and report ethics cases and trends to the Ethics Committee or Board.
Monitoring, Audit & Continuous Improvement
• Regularly review ethics programme effectiveness and recommend enhancements.
• Collaborate with internal audit, compliance, and risk teams to ensure integrated governance.
• Keep abreast of changes in legislation, governance codes, and ethics best practices.
• Conduct ethics and compliance risk assessments for potential and existing third parties.
• Ensure third-party contracts include ethics, anti-bribery, and conflict-of-interest provisions.
• Monitor supplier and partner adherence to NECSAs ethical standards through audits, questionnaires,
and performance reviews.
• Address and manage ethics breaches involving third parties, with escalation to legal and compliance
teams where necessary.
Stakeholder Engagement & Reporting
• Present ethics programme updates, reports, and trends to executive management and the Board.
• Act as the key liaison with regulators, professional bodies, and industry ethics networks.

• Implement codes and policies to ensure that structures, systems, and processes are in place to
familiarise the board, management, and all employees with the organisations ethical standards.
• Lead and drive the coordination of all activities that contribute to providing content to codes and policies,
and facilitate the implementation thereof.
• Provide advisory and safe reporting facilities that allow employees to have various courses of action on
ethical issues to avoid compromising their official responsibilities.
• Conduct ethics-related investigations to ensure legal and regulatory compliance.
• Manage conflicts of interest, with particular attention to the recordkeeping, analysis and evaluation of
issues relating to: Financial disclosures related to employees; Applications for external remunerative
work, and o Departmental gift registers.
• Oversee consequence management through reward and discipline to ensure personal accountability to
ethical practices is promoted.
• Develop, implement, and oversee ethics awareness and other ethics training programmes for current
and new employees that translate organisational values into visible and measurable behaviours.
Compliance:
• Oversight and management of the companys risk and compliance framework
• Consider risk and compliance management strategically and based on expertise, bringing innovative
concepts to streamline and improve the functional capabilities.
• Provide advise to management or interpretation and application of legislative requirements and ensuring
that such requirements are duly implemented and documented.
• Effective stakeholder engagement at stakeholder meetings and forums (e.g., combined assurance
forums, risk & compliance forums, etc.) by sharing knowledge, changes, and new developments.
• Compliance Monitoring: Monitoring the organizations compliance with relevant regulatory requirements
and assessing the impact of the training and guidance efforts on compliance metrics.
• Manage, mentor and coach team members on risk and compliance management.
• Provided Compliance reports as and when required by management, the Board and Auditors.
• Managing end to end Legal Compliance process.

Ethics:
• Oversee the Ethics management committee (EMC) as a multidisciplinary committee capacitated by
ethics ambassadors.
• Integrate ethics risks in the organizational risk register and assign risks owners.
• Conduct ethics due diligence assessments of suppliers (vetting).
• Establish an ethics helpdesk where stakeholders can inquire on ethics related issues.
• Ethics awareness campaign linked to THREAD values (e.g. newsletters, posters).
• Ethics training for all levels of Management.
• Design and implement THREAD and ethics training for new employees (induction).
• Utilise existing management forums to ensure that ethics are discussed with employees and employees
have an opportunity to ask ethics-related questions and raise concerns.
• Design and implement initiatives where employees showcase exemplary ethical behaviour.
• Oversee the investigation of incidents of unethical behavior. Ensure that corrective actions are fair,
consistent and transparent.
Compliance:
• To provide SANBS with a fully functional and risk-based Compliance Function.
• To ensure that SANBS complies with relevant laws, standards, policies and codes.
• To ensure adherence to King IV Report on Corporate Governance for South Africa, 2016 (King IV) in
particular Principle 13 thereof.
• Ensure development and implementation of SANBS Ethics Strategy and Management Plan.
• Develop and manage and update a regulatory universe, framework as well as the Compliance policy for
SANBS.
• Provide for formal and structured monitoring of the Compliance Requirements.
• Provide strategic, transactional and day-to-day compliance advice and direction.
• Assist management and the organisation in discharging its responsibility to comply with company
regulations.
• Adhere to any other reasonable instructions or requests by the Company Secretary, the CEO, or Board
and its committees.

• Communications, Training and Education: Support the MDs in setting the tone at the top, by planning
and implementing targeted compliance training, delivering or assisting management in delivery of training
related to the PMI Code of Conduct and Conflicts of Interest, identifying potential training gaps, ensuring
all employees have copy of the PMI Code of Conduct.
• Develop and deliver communications concerning to speaking up and policy for retaliation, and reporting to
MDs and Regional Compliance Director or Manager status updates.
• Investigations: Conduct compliance investigations as directed by the Regional Compliance Director or
Manager, ensuring that such investigations are conducted according to PMIs investigations Principles,
and monitor post-investigation actions to ensure disciplinary and remedial measures are enacted, and
seek out and address any potential retaliatory actions, in coordination with the Regional Compliance
Director or Manager and local Human Resources.
• Speaking Up and Reporting Up: Act as a trusted point of contact for employees who wish to discuss or
report potential misconduct, and ensuring that all reports of suspected misconduct are reported up to the
Regional Compliance Director or Manager and that the relevant MD is kept informed of such reports and
the outcome of any related investigations.
• Risk Assessment: Lead the Management Teams in the annual compliance regulatory risk self
assessment exercise, providing input in strategy preparation and planning and keeping Management
Teams up-to-date on current and emerging risks, and on behalf of the MDs, oversee the development and
timely implementation of effective risk mitigation plans resulting from the compliance risk self
assessments.
• Planning: In conjunction with the Regional Compliance Director or Manager, develop and implement an
annual action plan to meet the compliance objectives of each market, including drawing from recent
compliance risk assessments, global, regional or market-level compliance initiatives, compliance
investigations, and external or regulatory developments.

• Ensure that Ethics and Compliance risks are identified, assessed and mitigated as part of risk
management processes adopted by the BP Southern Africa FVC.
• Promote ethical leadership by supporting, encouraging and advising the Business or Function senior
management to manage the ethics and compliance risks through appropriate resource allocation and
credible support;
• Develop with the support of E&C, an annual compliance programme which is endorsed by management
and in particular:
◦ identifies training needs in key risk areas;
◦ promotes an ethics and compliance communications plan;
◦ identifies key processes for addressing key risk areas.
• Maintain the quarterly compliance scorecard and ensure that the annual ethics and compliance
certification process is completed on a timely basis;
• Support the delivery of training, including Code of Conduct induction training, as required to meet
business needs;
• Provide guidance on the proper and timely use of E&C tools (i.e. Gift & Entertainment register, Breach
database, etc);
• Encourage employees and leaders and third parties who work for BP to speak up about ethics and
compliance issues using any means available, including through line management, E&C, BP Legal,
• Responsible for the overall compliance with the Fraud and Misconduct Reporting Standard (FMRS).
• Ensure that rules and regulations affecting the company are complied with.

• Ensure that Legislative Landscapes for the area of responsibility are in place and updated regularly;
• Arrange and facilitate legal compliance risk identification and assessment workshops in the area of
responsibility in accordance with the Annual Group Legal compliance coverage plan;
• Compile detailed legal compliance risk registers in area of responsibility and update it regularly;
• Ensure that the need for training in the area of responsibility is identified and that the required training
material is developed and presented to the target group;
• Conduct legal compliance monitoring in the areas of responsibility in accordance with the legal compliance
risk registers;
• Ensure that the adequacy of Legal Compliance processes and outcomes of such processes are
systematically reported to the management of the Business Unit and Senior Legal Compliance Managers.
• Create awareness of legislative requirements and legal risks;
• Advise management on controls to be implemented to address risks identified;
• Assist with the preparation of quarterly reports to the business in the area of responsibility;
• Drafted reports to various Executive Board in area of responsibility
• Conduct Legal Audits in the area of responsibility;
• Implement Legal Compliance in accordance with the Group Legal Compliance Roadmap;
• Keep record of all Legal Compliance actions in a concise and auditable fashion;
• Assist internal audit with annual audits of the Legal Compliance process implementation.

• Developing and implementing the Banks compliance program, managing compliance reviews on different
sections and departments of the bank.
• Reviewing new regulations affecting the bank and analyze regulatory impacts (SAMA and CMA
regulations).
• Review all the new Capital Markets Authority (CMA) Laws and regulations and arrange for implementation
of regulations and compliance thereto.
• Assist in the Anti-money Laundering unit including investigations and reports etc. Managed all the AML
and KYC functions including monitoring, investigations and reporting.
• Compilation of The Financial Action Task Force (FATF) 40+9 recommendations on behalf of the Bank and
overseeing compliance with such recommendations.
• Checking other banks AML/CTF compliance. This is by checking the FID (Financial Institute Department)
KYC documents when other banks wanted to do business with Riyadh Bank
• Drafting enhanced due diligence KYC/AML verification documents especially with regard to countries that
are considered High risk in terms of FATF guidelines.
• Drafting compliance questionnaires based on regulations to examine the level of compliance.
• Developing and drafting procedures to comply with relevant regulations.
• Communicating procedures, policies across the bank and giving presentations on compliance issues.

• Establishment and maintenance of compliance framework within the organization;
• Developing, maintaining and revising policies and procedures for the general operation of the compliance
plan and its related activities;
• Reporting on compliance with legislation, regulations, policies and procedures;
• Updating legislative and regulatory compliance requirements;
• Identifying and prioritising key requirements of legislative compliance risks;
• Undertaking departmental compliance audits;
• Conduct investigations of alleged violation of rules, regulations and procedures;
• Providing compliance training and guidance, and reinforcing a culture of compliance;
• Regularly reporting to EXCO ( Monthly), Audit and Risk Committee (Quarterly) on the progress of the
implementation of compliance plan

• Implementation of Compliance Strategy in Business Units and also Compliance Methodology;
• Compilation of Compliance Risk Profiles (annual and quarterly) and also Drafting Compliance Risk
Management Plans(RMPs) for all Core and High risk Legislative requirements;
• Conduct Compliance Monitoring in the following forms as per the Compliance methodology:
◦ Effectiveness reviews (all core and high risk regulations)
◦ Sign-offs / checklists
◦ Spot checks
◦ Compliance Controllers
◦ Quantity and quality of monitoring
◦ Utilization of Internal Audit (IA)
◦ Issues - log, follow-up and resolving compliance issues
• Compliance awareness and training to new staff at Contact center and Self Service Channels;
• Provide Compliance advice relating new products development and due diligence reviews;
• Management of relationships with all stake-holders with specific reference to BROs, Business Unit
Management, Assurance, Group Legal (this includes ensuring the effective and timeous mutual sharing of
information by Compliance and the stakeholders;

• Continual monitoring of compliance with the FAIS Act, FICA, Short Term Insurance Act, Financial Score
Card etc.
• Assisting Line Management in discharging its Responsibility to comply with applicable statutory, regulatory
and supervisory requirements.
• Provide advice on all Compliance related Matters;
• Making sure that the Company Complies with all legislations affecting the Company; Correspondence
with the Financial Advisory Body;
• Preparation of the Compliance Reports.
• Liaising with attorneys; Vetting of Contracts and also Drafting of Contracts.

• Continual monitoring of equals subsidiary if they are Complying with Fais Act- i.e. Financial Advisory and
Intermediary Services Act;
• Auditing processes of ongoing procedures;
• Continual evaluation of processes and procedures;
• Liaising with attorneys;
• Drafting of Contracts and Minutes of the Company;