As Link Group connects millions of people with their assets, we are committed to a high standard of information and data security, privacy and corporate governance practices. At the same time, we maintain a focus on the creation of new, innovative solutions and continuous operational improvements to support the achievement of our strategic goals.
As part of this, we understand and manage the impacts of regulatory change, changing technological and demographic trends and evolving community and market expectations. We monitor and manage these impacts to mitigate identified risks, structure our business and build our capabilities to capture the opportunities that these create.
Our sustainability performance across all jurisdictions is available in Link Group’s FY2019 Sustainability Report, which is available on the Link Group website at www.linkgroup.com.
Our Governance
We recognise that a strong corporate governance culture plays an important role in sustainable value creation for our shareholders.
While the Board has overall accountability for an effective corporate governance framework, all of our people are equally responsible for upholding the corporate governance standards.
These standards are clearly articulated in our Code of Conduct and Ethics and reflected in our core values of Professionalism, Integrity, Respect, Commitment and Teamwork.
GOVERNANCE STRUCTURE: The Board is appointed by, and represents Link Group’s shareholders. It is accountable to shareholders for creating and delivering sustainable value. The Board’s role includes providing leadership and guiding Link Group’s strategic direction, driving performance and overseeing the activities of Management and the operation of Link Group.
Separate Board Committees for Risk and Audit, Technology and Operations, Human Resources and Remuneration, and Nomination all support the Board in carrying out its role by providing detailed oversight in these specialist areas.
The ELT, through the Managing Director, is accountable to the Board for the day-to-day management of the business. The ELT is supported by our senior leaders and also by a number of governance, risk and operationally-focussed management committees with specific responsibilities designed to provide the necessary information upon which sound business decisions can be made.
This is underpinned by a two-way flow of open, constructive discussion between the Board and Management.
We comply with the ASX Corporate Governance Council’s Principles and Recommendations (Third Edition).
For more on our corporate governance practices, our 2019 Corporate Governance Statement and related key governance documents are available on Link Group’s website at www.linkgroup.com.
Fines/sanctions for non-compliance during FY2019
- Link Pension Trustees Limited in the UK, and Sharex Dynamic (India) Pvt Limited in India were both sanctioned by regulators for conduct which originated before they were acquired by Link Group. Our Sustainability Report includes further details on this matter. No other entity controlled by Link Group was subject to any sanction during the period.
- There were no confirmed incidents of corruption during the year.
FCA Investigation
As disclosed on 18 June 2019, the Financial Conduct Authority (FCA) has notified Link Fund Solutions (LFS) that it is commencing an investigation into LFS as authorised corporate director (ACD) to the LF Woodford Equity Income Fund (Fund).
The key responsibility of LFS in its role as ACD of the Fund, is to always act in the best interests of all investors in the Fund. LFS considers that it has at all times acted in accordance with applicable rules and in the best interests of all investors in the Fund and it continues to do so.
FCA investigations may run for a considerable period of time before any outcomes are announced. While this may present a potential financial and reputational risk, as stated in Link Group’s audited FY19 financial statements, there has been no enquiry, complaint or claim received by LFS regarding its role in relation to any fund, including the Woodford Fund, which should be recognised as a contingent liability.
Our Environment
As a service-based financial services organisation, we have no manufacturing operations and have limited use of natural resources. We operate from leased office premises and therefore have a reasonably small energy‑and‑resources footprint compared to companies producing physical goods. However, we still take our environmental responsibilities seriously.
This year, we are reporting 12 months of data for the expanded Link Group for the first time (including CPCS which was divested on 27 June 2019). We continue to strive to improve our environmental performance.
OFFICE ENERGY USE: Almost all the energy consumed in our offices comes from grid electricity. During FY2019, we consolidated our premises as part of our integration and transition strategy. This included:
- closing offices in the UK, the Netherlands, Switzerland, Luxembourg and South Africa;
- significantly reducing our office space in Ireland; and
- occupying two new offices in the Netherlands and one in Switzerland.
We will continue to take more space in energy-efficient buildings, consolidate offices where possible especially as leases end, and continue to reduce our power costs and emissions.
AIR AND RAIL TRAVEL: Our major impact from travel is emissions from commercial airline flights and a small amount from rail travel. We do not currently purchase carbon offsets on flights.
OFFICE PAPER: We consume paper as part of our own operations and on behalf of our clients for their shareholder and fund member communications. While encouraging clients to embrace electronic communications, we also seek to reduce paper use in our offices, to use more environment-friendly paper and to recycle more.
OTHER MATERIALS: We report the amount of IT hardware we have disposed of through recycling, reuse or resource recovery at end of life, and our non-paper general waste.
Our Supply Chain
We prefer to work with suppliers that share our commitment to continuously improving their sustainability performance.
We have engaged with a number of our larger suppliers in Australia and asked them about their own sustainability performance and plans including policies, business continuity planning (BCP), labour standards, the environment, community involvement and their own suppliers. In FY2019 we extended oversight of our supply chain to a number of smaller suppliers. Of our total Australian non-labour operating costs of $251.0 million, the suppliers we have engaged with represent $201.1 million, or 80% (2018: 69%).
Our aim is to gradually broaden our supplier engagement to understand the key issues suppliers face and determine where we need to focus our efforts.
We will continue to focus on issues most likely to present a potential risk to Link Group. We are required by both the Australian and UK Modern Slavery Acts to issue a Modern Slavery Statement and our first combined report will cover the FY2020 financial year. A component of this reporting is to gauge the risk of any slavery or other form of forced labour in our supply chain.
We have a strong desire to work with suppliers whose standards are similar to ours, and who seek continuous improvement in their sustainability performance, as we do. In order to manage sustainability risks and impacts in our supply chain, we are preparing to write our broad sustainability expectations into our larger contracts.
We plan to look further into our supply chain, to increase our understanding of Link Group’s sustainability risks and, where appropriate, encourage our suppliers to match our commitment to sustainable work practices.
Our Clients
Our relationships with clients are critical to the future of Link Group and our stakeholders, and we work to build and maintain strong relationships with them.
Innovative technology
Growing our capability to create, develop and roll out innovative new solutions and service enhancements is a key contributor to our relevancy and sustainability as an organisation.
For that reason, we are continually re-investing in technology, systems and platforms as well as infrastructure and information and data security.
Security and privacy
The security of client and investor data is critical to Link Group and we employ rigorous controls and allocate considerable time, resources and systems to protect it, with ISO27001 certification in key markets, policies and procedures, significant system protections, limited access and mandatory compliance training for employees. Privacy is equally important, with our people receiving regular training on our privacy obligations and principles.
IT security controls
Owing to the nature of our business, IT security controls are critical. We have processes, systems and procedures in place so that access to systems and data is restricted to those authorised and that our systems are maintained and upgraded regularly.
Business continuity and disaster recovery
Our Business Continuity and Disaster Recovery plans are reviewed and tested regularly. We expect that under most scenarios, we can resume operations from alternative locations within agreed timeframes.
Ethical standards
We strive to act ethically, protect privacy and manage data securely in all markets. Our Code of Conduct and Ethics is complemented by a series of policies. We apply our risk management frameworks to help prevent and mitigate risks and all employees are required to undertake annual Code of Conduct and Ethics training.