Corporate governance aligned to King IV principles

Giving effect to Corporate Governance Codes

The tables that follow are structured around the five core categories of King IV. These are:
Leadership, ethics, and corporate citizenship
Strategy, performance, and reporting
Governing structures and delegation of authority
Governance of functional areas
Stakeholder relationships

In the tables, we show how the Fund has embraced and aligned to King IV Principles and the UK Corporate Governance Code in their efforts to achieve the spirit of what is intended by the five core categories above.

Principles 1–3:
Leadership, Ethics and Corporate Citizenship

King IV principles and our activities
  • Principle 1 – The governing body should lead ethically and effectively
  • Principle 2 – The governing body should govern the ethics of the organisation in a way that supports the establishment of an ethical culture
  • Principle 3 – The governing body should ensure that the organisation is and is seen to be a responsible corporate citizen
Effective and ethical leadership
  • The Board sets the tone for accountability, ethics, and integrity, acting in the best interests of all stakeholders
  • The Board implements procedures and guidance to deal with actual or potential conflicts of interest and at the beginning of each Board meeting. Directors have an opportunity to declare any interest that could result in a conflict of interest
  • Through the Fund’s values, we commit to being ethical and honest, and thereby inspire trust in all our business dealings. The Fund has a formal ethics policy and code of conduct, as well as dedicated resources to embed requirements and investigate ethics and integrity concerns reported as endorsed by the Fund’s “Whistleblowing Policy”
Corporate citizenship
  • Sustainability is deeply rooted in our DNA, and our purpose-driven leadership model continues to place value creation for our stakeholders and wider society
  • Our objectives are focused on giving back to the community and promoting education, health, financial wellness/literacy, and the environment through our Corporate Social Investment Initiatives (CSI) in support of the Sustainable Development Goals (SDGs)
Desired outcome:

Effective and ethical leadership, to be an organisation with an ethical culture, as well as being a good corporate citizen

Effective and ethical leadership
  • Continuous monitoring and reporting on the ethics performance of the organisation
  • Ethical leadership and transparency throughout the organisation
  • The values embodied by NSSF drive a sound culture and inform how we expect our employees and stakeholders to behave during their interaction with us
  • Ethics cases are investigated by Internal Audit in a confidential and timely manner and investigation reports are submitted to Management and the Audit and Risk Assurance Committee (ARC) for oversight
  • An external law firm (SIGNUM Advocates) was onboarded to manage the whistleblowing process
Corporate citizenship
  • The Fund is committed to acting in a manner that is responsible and transparent through the promotion of sustainable business practices, environment, employee, and community development, supporting the achievement of prioritised SDGs as follows:
  • For NSSF, this means we are leveraging our business and policy expertise, data, and capital to help drive an inclusive recovery, expand access to economic opportunity and accelerate sustainability and climate solutions
  • Oversight of sustainability takes place through the Board Staff Administration and Corporate Affairs Committee
Summary of the arrangements for leading ethically, effectively, and responsibly
  • Disclosure of conflicts of interest
  • Performance evaluations of the Board, Board Committees, and members
  • Whistleblowing policy
  • Code of business conduct and ethics
  • A governance structure with clear delegation of authority to ensure an ethical culture
  • Procurement policies and practices
  • Anonymous reporting of unethical behaviour
  • Our sustainability drivers are embedded in our strategy and focused on ensuring sustainability for our business, our customers, communities, society, the economy, and the environment
  • Commitment to prioritised UN SDGs
  • Water and Energy Management Policy
Key areas of focus during the reporting period
Measures taken to monitor ethical, effective, and responsible leadership and how the outcomes were addressed
  • Revisiting/reaffirming Committee terms of reference
  • Formalising action plans to address the areas of improvement identified and recommended by the external auditors and other investigative agencies
  • The Board and Executive Management set the tone for an ethical culture in the Fund
  • Staff are encouraged to report unethical behaviour without reprisal
  • Monitoring and investigation of ethics cases by Internal Audit
  • Ethics to promote an ethical culture is embedded in the NSSF HR Manual which is given to each staff member
  • The ARC monitors oversight of the implementation of the ethics and whistleblowing policy and code of conduct
  • Annual environmental risk assessments on all Fund projects in partnership with the National Environmental Authority (NEMA)
  • Specific targets to reduce energy, paper, and water consumption
  • Compliance with City Council Solid Waste Management ordinance of 2000

Principles 4–5: Strategy, Performance and Reporting

King IV principles and our activities
  • Principle 4 – The governing body should appreciate that the organisation’s core purpose, its risks and opportunities, strategy, business model, performance and sustainable development are all inseparable elements of the value creation process
  • Principle 5 – The governing body should ensure that reports issued by the organisation enable stakeholders to make informed assessments of the organisation’s performance and its short-, medium- and long-term prospects
  • The Board is responsible for the strategic direction of the Fund and has provided an enabling governance framework to support management to achieve its strategic plan by 2025
  • Key performance measures are aligned to the strategic objectives which translate into an organisational scorecard, cascading into individual scorecards
  • The Board ensures that it provides transparency to key stakeholders, both in good and tough times, by providing timely and balanced information, and in so doing, promotes stakeholders’ confidence in the business. The NSSF reports the material results of its performance internally and to stakeholders. The Board is responsible for providing reporting guidelines regarding quality and depth of reports, meaningfulness, and relevancy to meet internal and external needs
  • We strive to give effect to the reporting requirements of the various leading practice codes/guidance/frameworks and good practice in our industry, etc. See Our Report Overview, Reporting Frameworks
Desired outcome:
  • Optimised performance, value creation and sustainability
  • The Fund has a clearly defined strategy incorporating Key Performance Indicators (KPIs) geared towards long-term value creation
  • Our sustainability drivers are embedded in our strategy to demonstrate our commitment to delivering on our prioritised SDGs and the environmental and social (ESG) impact we would like to make as a Fund
  • The Fund continues to deliver excellent results in all metrics we measure ourselves against to ensure achievement of milestones and execution of strategy
Internal reports
  • The Board and its Committees are supplied with complete and timely information from Management to enable the Directors to discharge their responsibilities
External reports
  • The NSSF publishes an annual integrated report and audited financial statements to ensure all stakeholders remain informed. The integrity of the information included in the reports is overseen by the Board, with specific areas of reporting reviewed and challenged for appropriateness by the relevant Board Committees, as well as our internal audit and combined assurance functions
  • Board training includes integrated reporting to deepen Directors’ understanding of the requirements of the Integrated Reporting Framework
  • The Board ensures reporting of accurate, complete, and balanced information in the Integrated Report
  • Information related to the required disclosures appears in our Integrated Report. This includes matters relating to our strategy and detailed sections about our long-term goals, medium- to long-term targets, stakeholder engagement, governance approach and outlook. Additionally, our governance principles, including the King IV application are included in this chapter
  • IR training is available to new Board members
Summary of the arrangements for governing and managing strategy, performance, and reporting
  • A ten-year strategy, supported by detailed Board strategic planning sessions
  • A fully integrated strategy, risk and opportunity and performance management process
  • Adequate budget and resources to deliver strategy

Board assessment of the Fund’s performance against the strategic targets and overall strategy.

Measures taken to monitor strategy, performance, and reporting and how the outcomes were addressed

The integrity of the information in the reports is overseen by the Board, with specific areas of reporting reviewed and challenged for appropriateness by the relevant Board Committees, as well as our internal audit and combined assurance functions. The annual financial statements are audited by PricewaterhouseCoopers (PwC).

Planned areas of future focus


Business Perspective Key Issue(s) Assessed Broad Strategic Intervention(s) Definition of Success Position in 2021/2022 Position in 2022/2023
  • Customer experience (pain points due to data quality and manual processes)
  • Inadequate engagement with customers across the life cycle
  • Develop a new business model for the Fund to include market segmentation, innovation of products and customer growth
  • Ubiquity in customer services channels
  • Increased self-service
  • Product Innovation
  • 95% customer satisfaction
  • 82%
  • 88%
  • Service quality has been maintained across all channels
  • Deliver a real rate of return on customer’s savings
  • Improve options for financial protection
  • Continuous review and adjustment of the Fund’s strategic asset allocation
  • Product innovations that deliver enhanced financial protection
  • Return of at least 10-year moving average of inflation +2%
  • UGX 20Tn AUM
  • UGX 17.25Tn
  • UGX 18.56Tn
  • Progress towards UGX 20Tn by 2025 is on track
  • Manual interventions in key customer processes
  • Inadequate data quality for agile business decisions and deeper customer insights
  • Automation of all core business processes
  • Leveraging on partnerships using cross-reference to NIRA database
  • Full development of Octopas to enable straight through processing of claims
  • Pay customer benefits within 1 day
  • Update member statements in 24hrs
  • 12.3 days
  • 11.9 days
  • Benefits payment turnaround reduced due to the implementation of the Pension Administration System
  • Close monitoring of the Turn Around Turn and measuring the average time taken to process claims
Learning, Culture, Growth
  • Progress maturity as a high-performing organisation
  • Become a talent magnet, and nurture talent
  • Improve staff work experience
  • Address key “hygiene factors” to improve work environment
  • Re-organise structure in line with process re-engineering to add more value to jobs (70:30)
  • Improve reward
  • 95% staff satisfaction rate
  • 92%
  • 86%
  • Employee satisfaction levels significantly reduced due to the changes with the Fund’s structure, and this caused anxiety amongst staff