Whereas our four strategic choices respond directly to our operating context and direct our resource allocation and trade-offs, the group’s material matters ensure that we keep those aspects that enable us to create sustainable value, top of mind. As with the strategy, the board plays a key role in identifying and testing assumptions and approving the material matters.
Our 2019 material matters in summary
Our material matters explained
In this section, we provide more detail on the material matters, including the stakeholder groups most affected, positively or negatively, by each. The
risk report contains specific detail on some of these matters. For example, in the risk report, we set out the material matters in relation to the principal risks and identify the board committees mandated to consider each.
Ethical leadership, management and business
Ethical leadership means setting the tone from the top. We believe in doing ethical business not just for the good of the group, but for the common good.
This matter is material as corruption in government and business is increasingly being exposed, with the realisation that some practices have potentially become entrenched in and accepted by some in our society. We want to contribute to eradicating corruption and fraud in government, civil society and business.
Capricorn Group’s response and approach
We have created an ethical organisation where our stakeholders are motivated to support our values of being inspired, open and dedicated. Our ethical culture is directed by the ethics strategy, our risk culture which is grounded in The Capricorn Way, the Group Code of Conduct and Ethics Policy and the qualitative risk appetite statement on ethical conduct, which are all aimed at the proactive and holistic management of ethics risk.
The Group board sustainability and ethics committee (BSEC) is an independent and objective body to assist the board in ensuring that the Capricorn Group remains a good corporate citizen. We implement our ethics strategy and reporting framework according to four focus areas:
- Leadership commitment to ethical behaviour
- Setting ethical standards
- Employee ethics awareness
- Managing ethics risks
The Group Code of Ethics and Conduct Policy serves as the moral foundation for all other rules and policies. The Code describes the desired ethical behaviour of non-executives, including their fiduciary duties, conflicts of interest and duties to display reasonable skill and care.
The group conducts an ethics risk assessment as part of its ethics programme. The assessment is based on an anonymous survey conducted throughout the group. The survey informs an understanding of the ethical conduct of employees and assesses whether the climate is conducive to ethical behaviour.
Gaps identified in the assessment are addressed through management actions overseen by the subsidiary executive management teams and ultimately, the BSEC. Internal and external mechanisms are available to report concerns about unethical or unlawful behaviour.
The Group board, through the approved qualitative risk appetite statement, is explicit in its zero tolerance of unethical conduct. Boards of group legal entities and employees are made aware of their obligations to manage all types of risk, including ethics risk through our practical and case study-oriented Risk Culture Building programme. Our risk culture is grounded in The Capricorn Way, which espouses our values and the behaviours that we display in the best interest of the group and our stakeholders.
Credit risk management and mitigating losses due to bad debt
The economic recession in Namibia, regional economic stagnation, the drought, low business confidence and rising unemployment are all factors leading to a substantial increase in credit risk and consequently a potential rise in non-performing loans and losses due to bad debt. According to the Bank of Namibia, the asset quality of the banking industry deteriorated since 2017. The deterioration in non-performing loans (NPLs) and overdue loans persisted, despite a dampened appetite for credit by consumers. In Namibia, the industry NPLs increased by 39% to N$3.7 billion in March 2019, up from the N$2.7 billion recorded in March 2018. NPLs and overdue loans increased, with all loan product categories represented in the increase in NPLs.
We expect further deterioration in key economic indicators, which could potentially result in a downgrade in credit ratings for the countries in the region. This could lead to a further decline in foreign direct investment, weakening currencies and increased cost of funding.
Capricorn Group’s response and approach
The group has always been prudent in its lending practices, and we pride ourselves on the quality of the advances book and strong underlying collateral value. This remains a key focus and receives increasing attention during these challenging economic times.
We are taking a more proactive and forward-looking approach to credit risk management. This entails the early identification of accounts exposed to or representing increased credit risk for timely remedial action. Credit teams are pre-emptively engaging customers that are showing signs of distress.
Restructuring and consolidation efforts in Bank Windhoek for non-performing clients are yielding positive results.
The agricultural sector is expected to be hit hardest by the current drought, following five years of below-average rainfall. An extensive exposure assessment was performed to determine potential financial impacts under different scenarios. A task force was established to discuss potential next steps for the group. This includes restructuring facilities or changing the frequency of instalments.
NPLs started to flatten towards the end of the financial year, supported by an improvement in early arrears roll rates.
The graph below illustrates Bank Windhoek’s NPL and advances.
NPL and advances
Financial and cybercrime/
Cybercrime is a growing threat internationally. Continuous assessment, monitoring and security improvements are required to protect data and assets. The scale and complexity of financial and cybercrime are increasing and can lead to reputational damage and a loss of income. On an industry level, it jeopardises the stability and security of the entire financial services system.
Effective controls against money laundering and the financing of terrorism require cooperation between stakeholders, appropriate tools to investigate these crimes and quality data. On a global scale, the Financial Action Task Force (FATF) tests anti-money laundering (AML) capabilities per country against a set of standards.
Last year Botswana was reported by the FATF due to AML deficiencies. Since then, the European Union has blacklisted Botswana among 22 other countries for money-laundering-related deficiencies. As a result of this, Bank Gaborone’s correspondent bank relationships are at risk, with international transactions increasingly being scrutinised.
Namibia is scheduled to undergo an evaluation by the FATF and the Eastern and Southern African Anti Money Laundering Group (ESAAMLG) in June 2020. A national committee has been established to ensure that Namibia receives a positive rating on technical and effectiveness compliance.
According to the Namibian Financial Intelligence Centre (FIC), banks report the highest number of suspicious transactions (other bodies include unit trust schemes, lending institutions and stockbrokers). Among the offences reported up to April 2019, tax evasion ranked highest in number, followed by fraud, which ranked highest in monetary value. ATM fraud ranked as one of the lowest offences in Namibia.
Capricorn Group’s response and approach
Cybercrime is the number one priority for Capricorn Group’s IT function. Systems and infrastructure are designed and implemented with the required controls and technology to ensure that these are protected against potential cybercrime threats. We use in-house and external experts and service providers to ensure we are up to date with the latest cybercrime threats. Defences are continuously updated to address any potential weaknesses or changes in the technology landscape. In addition, we do regular internal and external scans and simulate attacks on our systems and infrastructure to ensure that they are optimal in protecting the group.
The impact of financial crime is mitigated by a collective and collaborative approach by the industry and relevant stakeholders. We believe that sharing data and centralising resources are the most effective ways to identify risk and develop interventions that proactively prevent either systemic or unilateral threats. The group actively supports government law enforcement entities during investigations of financial crime. Employees continuously received training on AML measures.
We continuously initiate campaigns aimed at employees and customers that help to improve fraud awareness and empower people with the knowledge to recognise risk and prevent losses. Internally, systems, device and data protection measures are continually updated, and incident response and support mechanisms are used to reduce the impact of the risk and to increase awareness of information security. Risk practitioners collaborate across subsidiaries to share knowledge and practices.
Bank Windhoek also implemented a comprehensive management action plan to ensure that clients are compliant with the Financial Intelligence Act 13, of 2012, especially in respect of enhanced due diligence for high-risk clients. The bank is continually engaging the FIC on this matter. Risk is mitigated through a combination of system enhancements and manual interventions.
Meeting customer needs and expectations
Customer centricity has become a key competency for banks. This entails understanding and meeting the needs of existing, emerging and new-generation customers, and being able to offer appropriate value propositions.
The availability and use of data management, statistics and analytical modelling are essential to be able to respond to these changing customer trends.
Capricorn Group’s response and approach
Bank Windhoek won the Centre for Economic and Leadership Development’s Global Female Impact Excellence Award for the Best Bank in the Gender-Sensitive Product category. The award recognises our Women in Business financial solution, which demonstrates our commitment to investing in women-owned and women-led businesses. Features are being enhanced to drive further success in this offering.
The launch of the Bank Windhoek credit cards in 2018 helped the bank to close a gap in its product offering. With certain unique features such as interest-free periods on all transactions and a responsible approach, the bank has enriched its offerings in key target segments.
Leveraging the capability delivered at Bank Windhoek, Bank Gaborone can offer credit cards to acquire and retain their key segments with this offering.
An outbound contact centre capability at Bank Windhoek was introduced to complement the inbound call facility, which has greatly added to supporting the business to drive sales and activations of channels like e-statements and cellphone banking.
The HeyJude App was successfully launched in Namibia to Bank Windhoek customers in May 2019. This was a first-of-its-kind offering in the Namibian banking environment where a unique, value-added digital service is being coupled with our banking offering to cement our brand promise of Connectors of Positive Change. The app serves as a digital personal assistant or concierge service that sources products and services, negotiates discounts and arranges payment and delivery on a customer’s behalf.
Bank Gaborone continues to develop new offerings in response to customer needs. After identifying and testing the opportunity to offer transactional church accounts, this has now been formalised into a bundled account that makes the accounting, reconciliation and auditing of accounts easier for churches. Churches will qualify for preferential rates and will have the opportunity to collaborate with Bank Gaborone on CSR initiatives.
Bank Gaborone’s Lebandla account offers a group savings option aimed at clubs, stokvels, burial societies or groups of people wanting to save towards a common goal. The account is further designed to provide security in that no single individual is in control of the funds. Funeral cover is offered as part of the Lebandla account benefits.
Bank Gaborone also ventured into a point-of-sale (POS) device offering. The POS payment solution offers convenience and flexibility in that customers can use cards as an alternative to cash, especially in areas where the bank does not have ATMs.
“Relying solely on algorithms and computer capability will not assist us to fully understand evolving customer habits and lifestyle expectations regarding banking. We need to ensure both qualitative and quantitative approaches.” – Capricorn Group board member
Data for three customer satisfaction indicators per bank were measured over a 12-month period:
Customer satisfaction ratings
The sharp improvement in both customer satisfaction and net promoter score for Bank Windhoek and Bank Gaborone was mainly driven by the introduction of the Capricorn Group Contact Centre as an additional touchpoint with very high call volumes driving up the response rate. These scores improved slightly in branches as well, but are significantly lower in comparison to the contact centre. The Bank Windhoek Net Promoter Score improvement was further driven by the media consumption survey that was done with a very large market sample of over 12,000 responses, which is much more representative of the customer base in comparison with the samples used back in 2018 when the first customer satisfaction, net promoter score and customer effort score were determined through the annual DSQ survey with samples less than 1,000 respondents for each business entity. At the same time, interactive customer measurement was introduced across all three entities, which provided closer insights enabling the business entities to respond faster on customer pain points.
All customer experience scores for Cavmont Bank decreased due to the current challenging business operating environment having a negative impact for both customers and staff morale.
Customer effort improvement is much lower than customer satisfaction. Net promoter score as customers still experience some difficulties in dealing with all entities, mainly driven by some cumbersome processes and procedures, especially the onboarding time of new customers in branches. This is a specific focus of the Nawa process improvement project being undertaken at all banks currently – which should see improvements in these scores.
Demand for specialist skills driving focused development, training and diversity
According to a discussion paper by McKinsey & Company in 2018, a skills shift followed the adoption of automation and artificial intelligence. The need for technological, social and emotional skills is rising as the demand for physical and manual skills decline. An inadequately or inappropriately skilled workforce is a major constraint to businesses.
The need for future-oriented skills development, including the fundamental reform of education systems and labour policies, remains critical. The Harambee Prosperity Plan recognises that the provision of quality skills is one of the major constraints to competitiveness in Namibia. The plan commits to addressing the gap between the demand for and supply of skilled labour by supporting practical training programmes and the streamlining of the system for the import of skilled labour.
Specific human capital challenges for the Capricorn Group include:
- the ability to attract and retain key talent
- the need to develop a pipeline of leaders for succession at board and executive and senior management level
- a focus on the development of the “critical layer” to address the significant gap between middle and executive management
- a lack of diversity (whether real or perceived) in terms of gender, ethnicity and age at executive management and board level
Capricorn Group’s response and approach
Internal and external bursary holders study at the University of Namibia and the Namibia University of Science and Technology (NUST) with highly specialist programmes provided by South African universities. Our internship programme focuses on business requirements and serves as another skills deficit resource pool for employment.
We partnered with Stellenbosch University for tailor-made senior management development and management development programmes. Sixty middle managers and 30 senior leaders are currently undergoing training.
We partnered with the internationally accredited Retail Banking Academy in London for the certified banker qualification, with 26 employees enrolled. The programme consists of three phases:
- Retail banking I is designed to introduce the theoretical and practical core competencies that are required for success in a retail banking organisation.
- Retail banking II focuses on the issues that are encountered when leading people and departments.
- Retail banking III focuses on the issues that are encountered when you are leading people and departments. The aim is to develop and enhance the capabilities required to run retail banking strategic business units for best results.
Bank Windhoek also partnered with NUST and B360 Education Partnerships, a Swiss-based non-governmental organisation. NUST graduates are hosted for one-week career development workshops. Aimed at coaching graduates on how to prepare themselves for possible employment in a highly competitive job environment, the workshops expose the students to skills required to prepare for interviews, to write a curriculum vitae and other business skills.
Bank Windhoek keeps abreast of industry challenges in terms of scarce skills. Through the recent scarce skills survey conducted within the financial sector in Namibia, we identified various challenges. In response to the findings, we have introduced a two-year graduate training programme that exposes graduates to practical working environments. Once we are confident that our process is effective, the graduates will be employed to close the skills gap. Plans to extend the programme beyond our own bursars are underway. We also have a pipeline of external candidates for possible employment.
At Bank Gaborone, we introduced an 18-month graduate training programme to reduce the skills gap faced by the bank while helping to reduce the level of unemployment in Botswana, especially among local graduates from institutions of tertiary education. Bank Gaborone is committed to identifying graduate talent and connecting them to opportunities to gain practical experience in the financial industry. By doing so, they should become more employable by our bank and other corporate players in the country’s financial sector.
The composition of the NeXtGen board was a significant step towards creating a pipeline for succession, with a high level of diversity achieved.
The group’s diversity was also acknowledged in the Capricorn Group’s rating by the Namibian Preferential Procurement Corporation in January 2019. The group achieved 98.34% (exceptional equitable economic empowerment level contributor status) on its scorecard.
Capricorn Group employees are employed by the entities as set out in
this diagram. The most substantial portion of employees is permanently employed. The following table summarises the group’s employee profile as at 30 June 2019.
Responding to a changing regulatory and operating landscape
Financial services globally are exposed to an ever-increasing regulatory compliance burden. A significant portion of new regulation introduced in the Capricorn Group jurisdictions is influenced by extraterritorial pressures. Examples are Basel iii, the Foreign Account Tax Compliance Act (FATCA), IFRS and Anti-Money Laundering regulation. Regulatory changes in the region are also influenced by local socio-political circumstances and government priorities. The expansion of operations into adjacent or different industries further increases the amount of regulation that the group must comply with.
Regulatory compliance can divert management attention and increase capacity needed to make changes to comply, thereby reducing the aptitude to pursue strategic objectives. It often tends to increase the size of risk, compliance and assurance functions which monitor, maintain and report on compliance. Regulatory compliance can introduce complexity and inefficiencies into ordinary business processes, which drive up cost and impact customers who do not always appreciate the value of regulations.
In addition to regulatory compliance matters, the regional economies are confronted with sustainability challenges, such as climate change, poverty, health issues and resource shortages (water, food and energy). In addressing these concerns, governments use regulation as an instrument to enable and encourage the necessary change. While sustainability issues may trigger regulatory responses, they also bring about new opportunities. The banking sector can play a vital role in accelerating the local markets’ transition to a sustainable future.
There are early signs that government is addressing sustainability challenges which have been deepened by inconclusive legal and regulatory reforms. We welcome government’s response to concerns raised by the private sector on the National Equitable Economic Empowerment Framework (NEEEF), in particular on the ownership pillar. The National Equitable Economic Empowerment Bill (NEEEB) will go a long way towards providing policy certainty. Government is also in the process of revising new investment legislation and has put the Namibia Investment Promotion Act on hold to accommodate broader inputs by the private sector. Unemployment, especially among the youth, and widespread retrenchments in the wholesale, retail and construction sectors remain of great concern.
In Namibia there have been several new government interventions, including the following:
- New tax proposals which, if implemented, will affect trusts and income from commercial activities of charitable, religious and educational institutions as well as the introduction of a dividends tax on dividends paid to residents.
- The Microlending Act, 7 of 2018 was introduced to promote responsible borrowing while protecting the rights of borrowers.
- Regulation 15 of the Long-Term Insurance Act and Regulation 28 of the Pension Funds Act Regulations were amended, requiring long-term insurance companies and pension funds operating in Namibia to invest 45% of their assets in Namibia compared to 35% previously.
- Implementation of the industry’s regulatory and compliance projects such as PSD7 (Determination on the Efficiency of the National Payment System) will bring efficiency, safety and effective control of the domestic Electronic Fund Transfer components of the Namibian Payment system.
In Botswana, a high unemployment rate remains one of the key social issues. This is partly due to a skills mismatch in the market, as new graduates are unable to meet business requirements. Proposed amendments to the National Employment Act, 29 of 1982 is expected to assist in addressing the mismatch and achieving a greater level of employment.
Three national priority areas were identified in terms of the environment:
- Pollution prevention and control
- Sustainable use of natural and cultural resources
- Climate change and global warming
Botswana has partnered with the World Bank to develop a renewable energy strategy that will allow the country to be more independent in its energy consumption. The government has established the Energy Regulatory Authority to set out the rules for independent power production and to ensure that proper procedures are adhered to in financing renewable energy projects.
New regulatory changes include the requirement to register all trusts with the high court and the implementation of the Company Re-registration Act, 24 of 2018. Financial Intelligence Agency amendments were made, which increased the penalties and broadened the scope of AML issues covered.
In Zambia, the Bank of Zambia issued a prohibition against bank charges and fees that are deemed unwarranted. The new Employment Code Act, 3 of 2019 relates to contracts, entitlements and employment benefits, which affects Cavmont Bank.
Failure to comply with applicable rules and regulations can expose the group to penalties and reputational damage. The group remains optimistic that with regulatory change and within sustainability challenges there are opportunities to be exploited to our advantage. This requires a positive and proactive stance.
Capricorn Group’s response and approach
In terms of regulatory changes, our Group Risk Internal Control and Assurance Framework follows a systematic approach to ensure that new regulations are identified in advance and that changes are proactively introduced. The purpose of our legislative review process is to identify emerging regulation in advance to ensure that the group can use every opportunity to influence and prepare for regulation.
Dedicated capacity was created to implement changes to systems and processes that are required by regulation and industry standards. In doing so we have simplified our change environment to better focus on strategic change.
An established risk and compliance framework ensures that our regulatory risk profile is reviewed and updated at least annually, or as and when new regulatory requirements are introduced.
We maintain good relations with all regulators as part of a deliberate stakeholder engagement strategy. This status has been maintained throughout the reporting period in all jurisdictions.
In relation to the operating environment Capricorn Group, as a corporate citizen, acts as a Connector of Positive Change in our operating context. Our operating context is reflected in the needs and concerns of our stakeholders. To be successful as a Connector of Positive Change it is necessary for the group to maintain good stakeholder relations which allow the group to sense and respond to stakeholder needs. These efforts illustrate how we respond to our operating context. Examples include:
In response to the Namibian government’s state of emergency declaration, Bank Windhoek is exploring innovative ways to determine the exposure of commercial and communal farmers and mitigate the impact of loss of income on their financial obligations. The Bank Windhoek vehicle and asset finance team is offering bush equipment to enable the production of animal fodder, using encroached bush. Bush thinning helps to restore degraded farmland and increase agricultural productivity. There are currently 30 million hectares of Namibian farmland that are bush encroached according to the de-bushing advisory services of the Ministry of Agriculture, Water and Forestry.
Bank Windhoek also contributed N$500,000 to the Dare to Care initiative. This is aimed at assisting farmers in preparing their animals for market and saving their core breeding herds for when the rain returns.
“All regulated businesses have to contend with regulatory changes: realistic and unrealistic. We need to respond, but much more, we should anticipate and predict so that we can be proactive. We should also leverage changing regulatory landscapes as these are opportunities if we look for them.” – Capricorn Group board member
Fintech, insurtech and evolving digital assets
The banking sector is characterised by disruptive innovation from non-traditional competitors who use automation and digitisation to render some conventional offerings obsolete and to compete on price. These new players design flexible and dynamic solutions based on new financing platforms, open banking and cloud-based products and services.
Regulators around the world, including southern Africa, are keenly observing the managed roll-out of open banking in the UK, which started in January 2018. Open banking is a reform which obliges all UK-regulated banks to share customers’ financial data (such as bank, credit card and savings statements) with authorised providers if customers give their banks permission to do so. The goal is to give consumers more choices by increasing competition between banks and fintech start-ups while ensuring secure and stable markets.
Capricorn Group’s response and approach
Bank cheques have been phased out in Namibia, effective end June 2019. As such, Bank Windhoek is offering its customers other payment methods such as mobile banking, internet banking and cellphone banking in addition to point-of-sale (POS) devices, ATMs across the country and various card products. Biometrics that assist in validating know your customer (KYC) information and reduce the risk of identity theft is being investigated for implementation.
In terms of process automation, the group completed the first wave of business improvements that are enhancing client onboarding, simplifying application processes and introduced cloud-enabled control on debit and credit cards. Customers can now adjust limits themselves.
EasyWallet continues on a steep growth curve owing to the convenience of doing secure and simple money transfers.
On 1 July 2019, the group concluded a 30% acquisition in Paratus Group Holdings Limited. Paratus Group Holdings and its subsidiaries and associates operate in 24 African countries, the most significant of which are Angola, Namibia, Zambia and Botswana.
Our investment in Nimbus, and indirectly in Paratus, was a deliberate move to explore new technology and digital infrastructure options. We anticipate new opportunities from the convergence between telecommunications and financial services combined with strong growth in demand for data services.
Nimbus is focusing its investment strategy on ICT companies in sub-Saharan Africa. Paratus provides communication, connectivity, carrier and cloud services to the public, private and corporate sectors in Namibia. Its telecommunications and network services include VSAT solutions, IP products, multiprotocol label-switching technology, fourth-generation wireless broadband network solutions, wireless data communications and E-Pad solutions. Paratus Namibia also owns the Trans-Kalahari Fibre line.
In Zambia, we are staging a partnership with a fintech start-up bringing a minimum viable proposition first to that market in pursuit of the opportunity presented by digitising the cash economy so prevalent throughout Africa.
Our aim is to continue making diverse investments in customer-centric technology and digital assets.
Enhancing and optimising management and operational systems
Operational excellence is a key competitive choice for the group. It can enhance internal effectiveness, security and process optimisation – doing things faster and more cost-effectively, reducing errors and ultimately improving the quality of customer experiences.
Capricorn Group’s response and approach
We created eight delivery platforms and adopted the Agile and Six Sigma methodologies to achieve operational excellence. We are more adaptive in planning and responding to change quickly. We have also seen the benefits of more collaboration throughout the group.
At Bank Windhoek, we enhanced the customer experience by introducing and updating digital functionality and solutions to provide a fully integrated service offering. For example, we are improving the onboarding time for new clients to under 30 minutes, issuing cards in-branch and significantly reducing the need for paperwork. We are also in the process of introducing biometrics to enhance security. Bank Windhoek remains the only bank with a token linked to the internet banking application, significantly reducing the risk of fraud. Smartphone-based tokens will be introduced in the new financial year.
At Bank Gaborone, operational excellence initiated the centralisation of the back office, emphasising the sales role in branches and reducing administrative functions. Data quality, consistency and compliance have also improved as all the related functions are happening in one space and not in a fragmented fashion. The approach is scalable and has been replicated in the centralisation of collateral. This has decreased the turnaround time between receiving credit applications and disbursing loans. In future other roles will be centralised, including account opening and customer service, among other things.
Network downtime is severely impacting Cavmont Bank’s ability to achieve operational excellence. To address its IT infrastructure challenges, a new service provider and primary data centre were established. This has increased the reliability of banking services and improved incident-handling time.
In summary, from a strategy perspective, and specifically in terms of operational excellence, we measure our customer productivity on a range of metrics with performance targets calibrated by entity. We measure our customer performance, from an operational excellence perspective, on a monthly basis with feedback to entity EMTs on a monthly basis and feedback to the group board on a quarterly basis. We use the methodologies mentioned above (Agile and Six Sigma), with ongoing actions developed by the entities, to adapt, refine, develop and implement customer propositions that drive our customer productivity in the right direction as per the set of strategy and customer metrics we have in place.