Guideline 23. Policy on disclosure

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The social security institution’s policy on disclosure of information (as outlined in the ISSA Guidelines on Good Governance adequately covers the disclosure of relevant investment information. The board and management abide by the policy, including the parameters as to when to exercise discretion in providing information to stakeholders. The policy covers the disclosure of any potential conflicts of interest.

Guideline code

INVEST_02600

Mechanism

When the board (or management) chooses to exercise discretion in the disclosure of information, the external authority (or board) may impose a time limit on the information embargo, beyond which the board (or management) may be compelled to disclose the information.
High-level information regarding the investing institution’s investments should be regularly disclosed to stakeholders, e.g. investment mission, investment beliefs, investment goals, high-level investment strategy (possibly including the strategic asset allocation), and portfolio and benchmark performance. It may not be appropriate to disclose certain information (e.g. relating to internal investment managers and external fund managers, or dynamic investment decisions).
Where the board or management is aware of any conflict of interest that may arise as a result of the investing institution’s investments, they should ensure the conflict is disclosed in full as per the social security institution’s policy on disclosure of information. Examples of conflicts of interest may include, but are not limited to:

Direct investment by any member of the board, management or investment committee, or any other member of staff of the social security institution or their close family in a company or asset in which the investing institution has a significant holding;
Association (shareholder, employee or otherwise) of any member of the board, management or investment committee or any other member of staff of the institution or their close family, with any third party organization appointed by the social security institution, including an external fund manager, custodian, performance measurer or adviser.

Parent

C. Common Processes

Structure

The board should establish a policy on disclosure of information that clearly defines the grounds on which the board may choose to exercise discretion in providing information to stakeholders. For example, this may be relevant in cases where disclosure of information may lead to adverse effects on the institution or the assets in which the social security institution is invested.
The management should implement a board-approved policy on disclosure of information. The policy should identify the limited instances when the management may choose to exercise discretion in the disclosure of information to stakeholders.
The public should be informed of the policy on disclosure of investment information (as part of the social security institution’s policy on disclosure of information).
An external authority should validate instances when the board chooses to exercise discretion in providing information to the institution’s stakeholders. Likewise, the board should validate instances when the management chooses to exercise discretion in providing information.
There should be complete transparency between the board, management and investment committee.
High-level information regarding the investing institution’s investments and performance should be disclosed to stakeholders.
The policy should detail requirements for the disclosure of any potential conflict of interest that may arise as a result of the investing institution’s investments.

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