King IV Commenting Platform

Filled Sunday, May 15, 2016

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Welcome to the official King IV Commenting Platform. After you have

downloaded and reviewed the draft King IV Report here [if this link does not

open, please copy and paste the following into your browser:

https://c.ymcdn.com/sites/iodsa.site-

ym.com/resource/resmgr/King_IV/King_IV_Report_draft.pdf], you will be able

to enter your comments using this platform. The public comment process takes

place in 2 phases, the first of which invites comment on the whole of the King IV

Report, bar the Sector Supplements. The Sector Supplements are to be

subjected to public comment during phase 2. This platform will remain open in

respect of phase 1 for two months from 15 March 2016 to 15 May 2016. Phase

two of the commentary process, being commentary on the sector supplements,

will be opened on notice. Commenting terms and conditionsPlease note that

this process is open and transparent. All comments submitted will be available

for public view at http://www.iodsa.co.za/page/KingIVCommentLibrary and NO

anonymous comments are permitted. Comments received are added to the

library for public viewing weekly together with the identity of the individual or

organisation on behalf of whom the submission is made. Only comments

submitted through this platform will be considered for the finalisation of the

King IV Report.

Do you agree to the King IV commenting terms and conditions? Yes

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Personal Details Section:

*Title: Mr

*First Name: MARIUS

*Last Name: MEYER

*I am commenting on behalf of: An organisation

*Name of organisation: SA BOARD FOR PEOPLE PRACTICES (SABPP)

*Capacity within organisation: CEO

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PART 1: Introduction and Foundational Concepts

PART 1: Introduction and Foundational Concepts Add your comments for this part here:

Variable Response

PART 1: Introduction and Foundational Concepts | 1. Introduction

In general the introduction and foundational concepts provide an adequate summary of the important background issues and factors to be considered. Once again, the role of governance as a key enabler for growth and prosperity has been clearly highlighted in part 1. However, while King III was at pains of explaining to the market why the word "governance" was dropped and back then only referred to "governance" in denoting all entities, the shift back to the King I and II term "corporate governance" is not explained.

PART 1: Introduction and Foundational Concepts | 2. Objectives of King IV

The objectives of King IV are clearly articulated on page 2.

PART 1: Introduction and Foundational Concepts | 3. King IV definition of corporate governance

A relevant and useful definition of corporate governance has been provided on page 2. However, a stronger link and role of management as daily custodians of governance should have been added to the definition.

PART 1: Introduction and Foundational Concepts | 4. The underpinning philosophies of King IV

The underpinning philosophies have been well articulated. Consistent and building on King III, we are glad to see the reaffirmation of the importance of the role of leadership in corporate governance. The importance of ethics is highlighted in King IV, and yet again, it all starts with ethical leadership. The overarching responsibilities of the board as governing body are outlined (i.e. providing strategic direction, approving policy, providing oversight and disclose during reporting). This ensures a more systematic approach to the corporate governance value chain. Furthermore, King IV builds on the philosophy of good governance as discussed in King III, but now some of the key concepts such as ethical leadership and corporate citizenship are not only refined, but also better defined. In particular, the role of the governing

body in developing and overseeing the core purpose of the organisation, including the driving of value, and stakeholder engagement is better articulated. SABPP is also glad to see that the same values underpinning corporate governance, i.e. responsibility, accountability, fairness and transparency as identified in King III, have been retained in King IV. The role of the governing body in taking responsibility for the governance of ethics as well as the ethics of governance is sufficiently covered in the introductory section. Specifically, the creation of an ethical culture is highlighted, in addition to the need for values as expressed in a code of conduct, trust, character and building the reputation of the organisation. Moreover, the inclusion of integrated thinking is a useful improvement from King III and will steer boards in realising the need to consider all interdependencies before making decisions. We are also glad to see that sustainable development has been retained. Sustainable development should be embedded in strategy and not be treated as a separate priority (thus, the practice of separate sustainable development reports should be discouraged). While King III highlighted the triple context, King IV goes further to suggest that these three components should not be seen as separate issues, but rather be combined to leverage its impact as an integrated whole or intertwined concept (this also reinforces the notion of integrated thinking). It is also good to see that King IV has made the shift to a more balanced approach to business risk by also considering opportunity as part of the risk mindset. Also, King IV acknowledges an elevated focus on compliance by adopting a more balanced approach to compliance. We believe it is key to strike the optimum balance between performance and compliance. Moreover, SABPP is satisfied to see that King IV aims to foster enhanced accountability on remuneration. The better focus on remuneration and repositioning it as a corporate citizenship matter is a welcome development indeed. the disclosure pertaining to the remuneration policy, as well as the actual remuneration of directors and prescribed officers are commendable. Although King IV has for the first time admitted to the wage gap between executives and employees and thus moved into the direction of addressing the wide gap between executive remuneration and employee pay, the shift is too subtle, and doers not go far enough in addressing the problem of excessive remuneration. While the need for comparative analysis is acknowledged, the result of such efforts "with the same peer group" will in all likelihood merely perpetuate the wage gap if the outcome of such analysis is used for

benchmarking purposes. If excessive remuneration is the norm as is currently the case, such a benchmarking exercise will serve no purpose if he underlying problem of inequality is not addressed. Although it is also a positive development to see that the role of remuneration consultants is mentioned for the first time, we believe that a stronger statement is needed in this regard, in fact it may be necessary to follow the best practice of rotating auditors to also rotate remuneration consultants to prevent the inflation of remuneration if the same consultants are rewarded for their work over an extended period of time.SABPP is satisfied that the six capitals as identified by the International Integrated Reporting Council are mentioned by King IV, however, given the fact that at least three of these capitals relate t o people, it is disappointing to see that human capital is neglected in King IV (it was more prominent in King II). Stating that it is the discretion of each organisation to identify the important physical and intangible resources that it uses or affects" is too vague and non-directive, and may result in many organisations to continue neglecting its human and social capital for another eight year period when King V will come into play.In addition, King IV now accepts that organisations should now appoint an executive of stakeholder relationships. While this is indeed a best practice in leading firms, it is surprising that King IV does not propose that organisations should first appoint an executive of human resources as has become the best practice in many leading organisations. It does not make sense to appoint an executive for external relations, if an executive for human resources internally is not in place in the first instance. This omission is in contradiction to the "stakeholder-inclusive model" mentioned in King IV. Furthermore, King IV admits that integrated reporting has "brought challenges regarding independent assurance." This problem is exacerbated in areas where the provision of assurance in matters for which there are very limited assurance standards in place. However, the development of environmental standards by several agencies, as well as the South African human resource standards and audit framework may fill these gaps. Having said that, the development of the combined assurance model is a positive development indeed. We are also glad to see that dispute resolution has been embedded in King IV. During the implementation period of King III (2009-2016), South Africa has seen some of the worst periods of labour conflict, unrest and violence. The Marikana massacre, right in the middle of the King III cycle in 2012, is a stark reminder of the worst case scenario pertaining to the consequences of unresolved disputes. It is therefore not surprising

that King IV urges organisations to resolve disputes "expeditiously, efficiently and effectively" especially in the light of the labour strike action becoming protracted and hostile. Once again, this should be a wake-up call about the importance of human capital in corporate governance regimes.

PART 1: Introduction and Foundational Concepts | 5. Local and international developments since King III

Some of the most relevant local and international developments since King III have been included in the report, although the importance of preventing daily governance errors and scandals could have been emphasised more.

PART 2: Content Elements and Development

PART 2: Content Elements and Development Add your comments for this part here:

Variable Response

PART 2: Content Elements and Development | 1. Overview of the nine parts of the King IV Report

(No response)

PART 2: Content Elements and Development | 2. King IV Code elements (No response)

PART 2: Content Elements and Development | 3. Sector Supplements (No response)

PART 2: Content Elements and Development | 4. Content development process (No response)

PART 2: Content Elements and Development | 5. Drafting convention (No response)

PART 2: Content Elements and Development | 6. Presentation features of King IV (No response)

PART 3: Application of King IV

PART 3: Application of King IV Add your comments for this part here:

Variable Response

PART 3: Application of King IV | 1. Legal status of King IV (No response)

PART 3: Application of King IV | 2. Scope of application of King IV (No response)

PART 3: Application of King IV | 3. Proportionality – appropriate application and adaption of practices

(No response)

PART 3: Application of King IV | 4. Disclosure on application of King IV (No response)

PART 3: Application of King IV | 5. Transition from King III to King IV (No response)

PART 4: King IV on a page

PART 4: King IV on a page Add your comments for this part here:

(No response)

PART 5, CHAPTER 1: Leadership, Ethics and Corporate Citizenship

PART 5CHAPTER 1: Leadership, Ethics and Corporate Citizenship Add your comments for this part here:

Variable Response

PART 5CHAPTER 1: Leadership, Ethics and Corporate Citizenship | 1.1 Ethical leadership

The importance of ethical leadership is clearly highlighted in this section. Chapter 1 of King IV contains some relevant recommended practices for ensuring that the governing body sets the example with ethical leadership. The six ethical characteristics are important, but it is recommended that in order to achieve competence, all board members must be trained in in corporate governance and ethics.

PART 5CHAPTER 1: Leadership, Ethics and Corporate Citizenship | 1.2 Organisation values, ethics

To give further expression to setting an ethical tone, a recommendation could be added that all board members undertake an oath to lead the organisation in an ethical way. This will further enable them to set the tone for an ethical culture in an organisation. The

and culture other recommended practices pertaining to ethics management are appropriate, in particular regarding the ethics codes becoming more prominent, and that ethics is infused into recruitment, promotion and performance evaluation practices.

PART 5CHAPTER 1: Leadership, Ethics and Corporate Citizenship | 1.3 Responsible corporate citizenship

Several appropriate recommended practices have been documented to ensure that the organisation is a responsible corporate citizen.

PART 5, CHAPTER 2: Performance and Reporting

PART 5CHAPTER 2: Performance and Reporting Add your comments for this part here:

Variable Response

PART 5CHAPTER 2: Performance and Reporting | 2.1 Strategy, implementation, performance

Chapter 2 takes corporate governance to a new level of significance by establishing principles and practices for the governing body to lead the value creation process by appreciating that strategy, risk and opportunity, performance and sustainable development are inseparable elements. This moves away from the traditional approach to organisations in which the core business process and the financial goals attached to it dominate the organisation, and all other functions being expected to support this goal. Once again, in driving strategy, performance is expected in the economic, social and environmental context and the achievement over the short, medium and long-term. Furthermore, policies, plans and performance criteria and the reporting thereof should be in place for all these areas. Consistent with the SABPP standard on HR Risk Management, risks are not seen from a negative perspective only, thus, identifying opportunities go hand in hand with sound risk management practices. The interconnectivity and inter-dependence of all these factors, including the six capitals are outlined as key factors for governing bodies to consider.

PART 5CHAPTER 2: Performance and Reporting | 2.2 Reports and disclosure

Reporting on these areas by including industry standards enable stakeholders to make an informed assessment of the performance of the organisation and its ability to create value in a sustainable manner. While different reports may be generated, an integrated annual report

is of utmost importance in disclosing organisational performance.

PART 5, CHAPTER 3: Governing Structures and Delegation

PART 5CHAPTER 3: Governing Structures and Delegation Add your comments for this part here:

Variable Response

PART 5CHAPTER 3: Governing Structures and Delegation | 3.1 Role of the governing body

SABPP is satisfied with the principles and recommended practices regarding the role of the governing body as focal point and custodian of corporate governance in the organisation. Building on chapter 2 and providing further evidence of integration, chapter 3 also emphasises the role of the governing body in directing ethics, performance and value creation, including the reporting thereof. Specific reference is made to the governing body structure and delegation. For instance, ensuring that in its composition there is a balance of the skills, experience, diversity, independence and knowledge needed to discharge its role and responsibilities. Also, the governing body is empowered to consider additional governing structures to assist with the balancing of power and to discharge responsibilities. The SABPP team is also satisfied that the Code recommends the appointment of competent executive management to ensure effective exercise of authority and responsibility. Additionally, the performance evaluation of the governing body, its structures, its chair and members, the CEO and governance professional is another recommended practice.The focus on a stakeholder relationship approach to governance is commendable.

PART 5CHAPTER 3: Governing Structures and Delegation | 3.2 Composition of the governing body

In an effort to prevent the current practice of the same board members sitting on too many governing bodies, while simultaneously tapping into multiple boards experience, King IV requires a statement of other commitments and a statement of time available to fulfil governance responsibilities.SABPP supports all the recommended practices pertaining to the formalising of governing body appointments, induction, training and professional development and mentorship to ensure that board members are sufficiently appointed and developed.Given the current increase in corporate and governance scandals relating to conflicts of interest, the King IV drafters have done a good job at listing relevant factors on a substance-over-form basis, when making an assessment of independence for the purpose of classification as “independent.” SABPP is also satisfied with all recommended actions

pertaining to the chair of the governing body as these actions promote independence and prevent undue influence and/or manipulation by a Chair or ex-CEO.To promote the notion of independence in board appointments, SABPP recommends that all board appointees sign a declaration of independence to mitigate any conflict of interest risks. Where governing bodies are willing to accept a lack of independence as a result of the exceptional quality and potential contribution of the appointee, such factors should be documented and approved with a clear statement on how such risks will be managed.The SABPP research indicates that current approaches to board and staff induction is too informal, unstructured and haphazard with the result that very little proper induction and on-boarding of board members takes place. A more structured approach to induction should be used (e.g. the SABPP Professional Practice Standard on On-boarding may be a useful guideline in this regard).

PART 5CHAPTER 3: Governing Structures and Delegation | 3.3 Committees of the governing body

This section is appropriate. The compulsory training of committee members in the relevant areas of expertise is of utmost importance. For example, a person can not sit on a remuneration committee if he or she has not been trained in remuneration.While several functional governance areas are addressed such as risk and opportunity, technology and information, compliance and internal audit, SABPP is disappointed that the area consisting of the biggest part of an organisation’s budget, i.e. human capital is not covered under functional governance. Although remuneration is covered, it is only one small aspect of the overall human capital value chain.SABPP supports the recommended practice of investigating governance body candidates’ backgrounds, but we propose a stronger commitment to formalise this approach by adding that the backgrounds (experience and qualifications) must be verified by a recognised independent verification agency. Over the last few years there were too many examples of scandals relating to inappropriate board and senior management appointments resulting in crippling financial and reputational damage to leading organisations such as Prasa, SABC, SAA and several others. Independent verification prior to appointment may reduce or eliminate this risk.While social and ethics committees could take responsibility for transformation in ensuring that organisations reflect the broader population, SABPP is disappointed that this matter has not be addressed more explicitly. We are concerned that some organisations with transformation committees may dissolve these committees since it is not mentioned in King IV. We recommend that all organisations with boards, management teams and staff profiles that do not reflect the broader diversity profile of the population should have

transformation committees in place.

PART 5CHAPTER 3: Governing Structures and Delegation | 3.4 Delegation to management

SABPP is glad to see that King IV recommends that various functional heads such as finance, human resources, technology and information, assurance and stakeholders relationships are appropriately appointed with clear role clarity and subsequently managed and resourced. In particular, the competence and ability of functional managers is emphasised. Moreover, SABPP is impressed with the additional recommendation that they be assessed regularly by an independent assessment of skills and competence. The disclosure of the executive and senior managers’ structure, including the role and relevant qualifications and experience could make a major contribution to improving the appointment of organisational leaders who are well qualified and experienced. The could play a positive role in building the reputation of governing bodies and managers, and thereby the reputation of the organisation, and may lead to greater trust of the media and the public in management appointees.Although SABPP is satisfied with the recommended practice of executives and managers be independently assessed on their competence, the assessment results on its own is not sufficient. The loop must be closed with clear development plans as a results of the assessments, in particular in areas of weakness that could pose a risk to the organisation. Moreover, another recommended practice that could be added is that only managers with management qualifications should be appointed, or at the very least, functionally qualified managers who have completed a management development programme. The current practice of appointing people in management positions without management qualifications has resulted in significant damage to their departments, organisations, sectors, customers and society at large. Similarly, directors should be encouraged to obtain director qualifications. These qualifications must be developed for South Africa, and during its absence, high level workshops conducted to build director competence.

PART 5CHAPTER 3: Governing Structures and Delegation | 3.5 Performance evaluations

It should be added that no lucrative bonuses may be issued if the organisation is underperforming in the triple context.

PART 5, CHAPTER 4: Governance Functional Areas

PART 5CHAPTER 4: Governance Functional Areas Add your comments for this part here:

Variable Response

PART 5CHAPTER 4: Governance Functional Areas | 4.1 Risk and opportunity governance

We are glad to see a more balanced approach by adding opportunity to risk governance.

PART 5CHAPTER 4: Governance Functional Areas | 4.2 Technology and information governance

Regarding technology and information governance, the ethical and responsible use of technology and information is addressed. This section also acknowledges the integration of people, technologies, information and processes in the digital business value chain of the organisation. It also mentions the integration of cyber-security risk into risk and opportunity management. In essence, a culture needs to be created where employees are alert to cyber-security risk and being proactive in raising concerns.

PART 5CHAPTER 4: Governance Functional Areas | 4.3 Compliance governance

Another important area to address is compliance governance. This section addresses compliance to laws (including labour laws), and non-binding rules, codes and standards and how these relate to one another in an integrated manner. Management should decide on strategic relationships with regulators and professional bodies in order to understand the environment and trends.

PART 5CHAPTER 4: Governance Functional Areas | 4.4 Remuneration governance

A whole sub-section on remuneration governance has been included in chapter 4. In essence, the governing body should provide strategic direction for fair, responsible and transparent remuneration on an organisation-wide basis, including approving policy and attracting, rewarding and retaining high-quality talent. This section should also recommend that lucrative bonuses and increases should not be awarded if the organisation underperforms on the triple context.

PART 5CHAPTER 4: Governance Functional Areas | 4.5 Assurance

Chapter 4 also addresses the importance of ensuring that assurance results are adequate in an effective control environment, as well as the integrity of reports for better decision-making. The five lines of assurance constitutes a comprehensive and integrated approach to combined assurance.

PART 5, CHAPTER 5: Stakeholder Relationships

PART 5CHAPTER 5: Stakeholder Relationships Add your comments for this part here:

Variable Response

PART 5CHAPTER 5: Stakeholder Relationships | 5.1 Stakeholders

Chapter 5 of King IV covers the notion of stakeholder relationships. A stakeholder-inclusive approach is adopted, which takes into account and balances their legitimate and reasonable needs, interests and expectations. The recommended practice of an integrated stakeholder communication plan is particularly useful. Additionally, King IV proposes standards and processes for development of content and sharing of information on digital and other communication platforms. This includes assigning of decision-making authority on approval of content and manner of dissemination. Furthermore, a systematic analysis of information emanating from communication platforms to assess reputational risks and to develop appropriate responses are needed. A dispute resolution mechanism is also needed to address the organisation’s contractual arrangements with employees and other stakeholders. Chapter 5 also includes reference to the impact of digitisation and automation on future workforce requirements, and the possible impact on employees and society. Skills development of employees will be key to drive innovation, growth and the leverage of technology for business and societal impact.

PART 5CHAPTER 5: Stakeholder Relationships | 5.2 Responsibilities of shareholders

Section 13 is not only relevant to shareholders, it could also be useful for non-profit organisations.

PART 6: Sector Supplements

PART 6: Sector Supplements Content on Part 6: Sector Supplements will be published and opened for commentary during May

2016.

PART 7: Application Register

PART 7: Application Register Commentary on Part 7: Application register will be addressed in the Comment Questions section,

Question 10.

PART 8: Glossary of Terms

PART 8: Glossary of Terms Add your comments for this part here:

While the glossary contains some relevant terms, some key terms covered in the report requiring

explanation have been omitted. These are corporate governance, proportionality, controls, control

environment, oversight, principles, practices, integrated reporting, relational capital, human capital,

social capital, intellectual capital, natural capital. Also, some of the terms are not adequately

explained, e.g. Code, effective leadership, external stakeholders and internal stakeholders and just

stakeholders later on. The definition of stakeholders in King III was more appropriate. External

stakeholders are not necessarily affiliated to the organisation. In addition, the definition provided

of effective leadership in the glossary contradicts the definition inside the document. Add in the

definition of governing body after appointed: and/or elected (to incorporate non-profit

organisations) . The definition of plan is weak. A better definition of a plan is a list of actions and/or

steps taken, including responsibilities, resources, timelines and measures to accomplish a set goal

or strategy.

The definition of policy can also be strengthened. Add the word consistency somewhere, and add

mechanisms for monitoring, evaluation and control as the last bullet.

A better definition of strategy: strategy deals with the core purpose of the organisation and the

setting of its short, medium and long-term direction in its endeavour to create, improve and

leverage value in sustaining the organisation.

Enrich the definition of values by adding: the behaviour of the members of the governing body,

management and employees and other stakeholders.

Comment Questions (1-5)

Comment QuestionsQuestion 1 - Question 5

Question 1 The set objectives of the King IV Report are to: -promote good corporate governance as integral to

running an enterprise and delivering benefits to it;broaden the acceptance of good corporate

governance by making it accessible and fit for application by organisations of a variety of sizes,

resources and complexity of strategic objectives and operations;reinforce good corporate

governance as a holistic and inter-related set of arrangements to be understood and implemented

in an integrated manner; andpresent good corporate governance as concerned with not only

structure, policy and process but also an ethical consciousness and behaviour.To what extent would

the draft King IV Report as it stands achieve each of these objectives?Please comment on how this

could be optimised.

It addresses all four objectives in an integrated manner.

Question 2 Part 2 of the draft King IV Report: Content Elements and Development, deals with outcomes,

principles and practices. Clear differentiation of these content elements is key to reinforcing

qualitative governance which is outcomes driven rather than about mindless compliance. Is the

rationale and the difference between these content elements clearly explained? Please provide

suggestions on how this could be further enhanced.

While it makes sense, it will be confusing to most directors and managers who are not corporate

governance specialists. Although King IV specifies that they don't want to provide examples,

clearer definitions, descriptions and examples may have been useful in this section.

Question 3 King IV uses the broader form of address namely: ‘organisations’; ‘governing body’; and ‘those

charged with governance duties’. Does this make the King IV Report more broadly relevant to all

organisations and sectors?

Yes it does. But an earlier release of the sector codes could have provided more clarity on how this

will be conceptualised.

Question 4 The King IV Code recommends that as a minimum, the chief executive officer (CEO) and one other

executive should be appointed to the governing body. Other than in King III, it does not specifically

recommend the inclusion of the chief financial officer (CFO) as a member of the governing body.

This allows flexibility for another executive to be appointed as a member of the board, depending

on the nature and needs of the business.Would a recommendation specifically providing for

inclusion of the CFO be more appropriate or is flexibility preferable in light thereof that

organisations differ?

Our recommendation is two other executives, preferably the CFO and CHRO, given the fact that the

CFO controls the finances, while the CHRO is custodian for the largest proportion of the budget of

the organisation.

Question 5 Do the independence criteria in Chapter 3 of the Code provide clear and useful guidance for

assessment of independence on a substance over form basis?

Yes.

Comment Questions (6-10)

Comment QuestionsQuestion 6 - Question 10

Question 6 Will the new disclosure and voting requirements on remuneration in Chapter 4 of the Code lead to

increased transparency and more meaningful engagement on remuneration between organisations

and their stakeholders? Please provide suggestions for further enhancement.

Yes, to a certain extent.

Question 7 King IV introduces in Chapter 4 of the Code, the 5 lines on assurance in the place of the traditional 3

lines of defence. It also expands on the implementation of the combined assurance model. Will this

assist with more effective co-ordination and alignment of assurance? Please provide suggestions for

further enhancement.

Clear explanation and examples of the 5 lines would be useful.

Question 8 The governing body as the focal point of corporate governance and is therefore the primary

audience of the King IV Report. King IV requires the governing body of an institutional investor to

ensure that the organisation exercises its rights as holders of beneficial interest in companies,

responsibly.Does this principle establish the necessary linkage between King IV and the Code for

Responsible Investing in South Africa (CRISA) so that governance is reinforced by all role players?

How can King IV further reinforce responsible investing practices? (For access to CRISA go to

www.iodsa.co.za.)

Yes.

Question 9 King IV introduces ‘risk and opportunity’ governance to emphasise risk as being about uncertainty

and the effect of it occurring or not occurring having a possible negative or positive effect on the

organisation achieving its objectives.Is it useful to refer to risk and opportunity governance and will

it reinforce it as a value-add rather than conformance exercise?

Yes, very positive development, but we are concerned about the tone of this question in positioning

the word "conformance" in a negative light (see King III for a more positive approach).

(No response)

(No response)

Question 10 The application regime of King IV is ‘apply and explain’ as opposed to ‘apply or explain’ in King III.

The main difference between the application regime of King III and King IV is that application of the

principles is assumed in King IV as they are basic to good corporate governance. Furthermore, the

75 principles in King III have been replaced with 17 principles in King IV. For the ‘apply and

explain’ regime, explanation is required in the form of a high level narrative of the practices that

have been implemented and the progress made in the journey towards giving effect to each

principle. Will ‘apply and explain’ encourage greater transparency and qualitative? Should

disclosure on King IV application be required to be signed off by the governing body? (For further

information on the application regime refer to Part 3: Application of King IV and to Part 7 for a

template of the application register.)

The implications could be clearer. Should be assured and signed off.

(No response)

Question 11 should have been provided for additional comments or inputs. Also check that the

reference to corporate governance framework refers correctly to the registered trade mark of the

CGF Research Institute.

(No response)

Survey Questions

Survey Questions

How much do you agree or disagree with the following statements, please give

a reason for your answer. You may need to scroll to the right to see all the options, depending on the size of the screen you are

using.

Why do you say that?

The King IV document is easy to understand

Disagree King IV jumps around. King III was easier read.

The document meets the King IV objectives Agree Addresses the 4 objectives directly

King IV is an improvement on King III Agree Latest developments added.

END

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