Santam short term insurer

SOS 08605059111

Financial director's report

The Santam group achieved excellent underwriting results in 2011, while also achieving double-digit growth in gross written premium of 12%. Underwriting results were almost on par with the outstanding results achieved in 2010. However, compared to 2010, investment results were negatively impacted by the low fair value movements on listed equities. This resulted in headline earnings decreasing by 11% compared to 2010. Cash flow from operations was significantly higher than 2010 while the solvency margin increased to 48% (2010: 45%). A solid 25% return on average shareholders' funds was achieved.

BASIS OF PRESENTATION AND ACCOUNTING POLICIES
The group consolidated financial statements for the year ended 31 December 2011 are prepared in accordance with International Financial Reporting Standards (IFRS) and the interpretations issued by the International Accounting Standards Board (IASB) in compliance with the JSE Listings Requirements.

The accounting policies that have been applied during the reporting period are consistent with those applied in 2010. The financial statements provide comprehensive information regarding the assets, liabilities, income and expenditure of the group and the company. Detailed background is also provided regarding the recognition and measurement of insurance contracts and insurance and financial risks.

The following amendments to published standards are mandatory for the accounting periods beginning on or after 1 January 2011:

IAS 24 (amended) - Related party disclosures
This amendment provides partial relief from the requirement for government related entities to disclose details of all transactions with the government and other government-related entities. It also clarifies and simplifies the definition of a related party.

Improvements to IFRSs
This is a collection of amendments to various IFRSs and is the result of conclusions reached by the IASB on proposals made in its annual improvements projects. These amendments were considered but did not have a significant impact on the preparation of the financial statements.

An abridged set of financial statements have been printed with the Integrated Report for 2011 in accordance with IAS 34. The full annual financial results are available on our website, www.santam.co.za, or in printed format on request from the company secretary. Cross references to notes in this report are made with reference to the full set of financial accounts.

FINANCIAL RESULTS
The salient financial statistics are set out on page 2.

The local economy showed signs of a slow recovery in 2011 but was impacted by the economic uncertainty in the developed economies of Europe and the United States of America. Santam's net underwriting result was marginally below the 2010 result. However, income from investment activities was 26% down on 2011 performance as a result of fair value movements in listed equities, bond and money market instruments. As a result, headline earnings for the group of R1 372 million declined by 11% and headline earnings per share of 1 216 cents (2010: 1 376) showed a similar reduction when compared to 2010.

Underwriting performance
The South African insurance industry's underwriting results are inherently cyclical. The "typical" short-term insurers in South Africa traditionally generated an average underwriting margin of between 4% and 6% through the cycles. With direct insurers and bank insurers becoming more prominent over the last decade, margins have progressively shown an increase.

Santam's underwriting result compared to the "typical" insurers is shown in the following graph. Santam's results have been closely correlated with the industry and in general the group has outperformed or matched the underwriting margin of its peer group.

In light of industry developments, and our own concerted efforts to improve our underwriting performance, we have revised our targeted underwriting margin upwards from the current 4% to 6% to between 5% and 7% over our current strategic planning cycle up to 2014. We are confident that this target is achievable over the next few years given our expectations of market conditions. Furthermore, we have initiated several strategic initiatives with the aim to make the higher target sustainable through the cycles over the long term.

The 2011 net underwriting result of R1 131 million was 1% less than the excellent result achieved in 2010. The overall net underwriting margin of 7.7% compared to 8.5% in 2010 and outperformed our newly defined 5% to 7% target.

Margins in most of the significant business classes were satisfactory.

  • The crop business was turned around from a loss-making situation in 2010 to generate a positive underwriting result in 2011.
  • The motor book performed exceptionally well and made the largest contribution to the net underwriting profit. The improvement was due to several factors, most notably the focused reduction in the cost of claims through improved processes and sourcing practices, the continued use of our client segmentation model, and external factors such as the improvement of roads during 2010 in anticipation of the FIFA World Cup.
  • The property book performed well due to a limited impact from large industrial and fire-related claims for our net underwriting account.
  • The alternative risk transfer class suffered a loss due to a single large claim estimate increase on medical cover insurance business that was subsequently cancelled.
  • Underwriting profit of the liability class was on lower levels in 2011 than in 2010 due to a few large claim estimate increases during the year, but performance was still well above the required risk-adjusted return target for the class.
  • The portfolio management business continued to perform well under the improved management practices introduced in 2010.

In general, lower average claims cost and our continuous focus on risk management improved the quality and diversity of the risk pool. This impacted underwriting margins positively. On a segmented basis, commercial business continued to generate the bulk of the underwriting profits with a contribution of over 80%. When considering the business class perspective, property follows the 41% contribution from motor with a contribution of 22%, while 12% of underwriting profits arise from the liability class of the company.

A concerted effort to drive profitable growth and the successful implementation of strategic growth initiatives such as the diversification of distribution channels and continued improvements to support existing channels, resulted in the achievement of excellent growth of 12% in gross written premium. Gross written premium in the South African insurance industry is historically linked to GDP growth plus inflation with a margin of up to 2%. We are pleased with the growth that we achieved given that it outperformed this historical benchmark of GDP growth plus CPI by close to 3%.

Given our strategic objective of retaining our leadership position, one of the components that we measure is our market share of gross written premium. We aim to increase our market share by growing in excess of the market. The formal measurement of our performance against this target is only available in the second half of the year, once the Financial Services Board (FSB) publishes the relevant industry data for the previous financial year. The interim measures available only provide for net written premium comparisons which are distorted by reinsurance arrangements. Based on the 2010 FSB data the gross written premium of the industry grew by 5% (vs. net written premium growth of 9%) compared to Santam's growth in gross written premium of 6% in 2010. The Santam group's market share was 22.8%, based on the 2010 data. Santam's net written premium growth of 8.5% for 2011 compared to an industry growth of 8.2%.

Positive growth was achieved across all significant insurance classes. The top performing insurance class from a growth percentage perspective was the crop business that benefited from the increase in commodity prices. The engineering book of business grew by over 24% following the acquisition of 55% of the voting equity in Mirabilis Engineering Underwriting Managers on 1 March 2011. The growth in the motor book of business of 14% was supported by the growth in our direct insurance business, MiWay.

The net acquisition cost ratio of 28.1% increased from 27.4% in 2010. The increase can be ascribed to the increase in spend on strategic initiatives, including the continued investment in MiWay and re-engineering activities as described in more detail in the operational review. The aim is to manage the acquisition cost ratio down to around 27% in 2012 while continuing to spend on key strategic initiatives required for long-term sustainability. In the medium to long term our aim is to further reduce our acquisition cost to 26%. However, we continue to consider the appropriate level for acquisition cost taking cognisance of our business composition and structural changes in the industry.

Our aim is to maintain optimum retention levels within acceptable risk profiles. The level of reinsurance earned premium as a percentage of gross earned premium increased from 14.9% in 2010 to 16.1% in 2011. The bulk of this increase, 0.8%, is attributable to the effect of cell business which is inherently bulky and volatile in respect of premium volumes.

Santam's diversified business lines position it well to face the challenges of the insurance market. We will also continue our efforts to optimise profitability across the business with a strong focus on risk management and operating efficiencies.

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Net insurance result
Investment returns on insurance funds of R388 million decreased from the R395 million earned in 2010. These lower returns resulted mainly from lower interest rates.

The combined effect of insurance activities resulted in a net insurance income of R1 519 million or a 10.4% margin, compared to R1 542 million and a margin of 11.4% in 2010.

Investment income
Investment income comprises interest, dividends, realised and unrealised investment gains and foreign exchange differences. The reduction in interest rates affected interest income received adversely. Dividend income was 27% higher than 2010 levels.

Equity markets were very volatile during 2011 resulting in significantly lower income from fair value movements in 2011 of R77 million compared to the R510 million generated in 2010. The fair value movements in bonds and money market instruments of R53 million in 2011 compared unfavourably to the R96 million reported in 2010. The derivative fence structures entered into during September and October 2010 were unwound during July and August at no cost to the company. Reported investment results benefited from the fence structures which generated a credit of R80 million for the year. The fair value movement on debt securities was R40 million compared to the R85 million of 2010. Santam's investment portfolio performance compared favourably to the benchmarks set in the investment mandates.

The weakening of the rand during 2011 had a positive impact on the valuations of our foreign currency assets held by our local operations of R90 million.

Net earnings from associated companies of R85 million increased from R69 million in 2009. This was as a direct result of improved earnings by key associates. The main contributors were Credit Guarantee Insurance Corporation of Africa Ltd and NICO Holdings Ltd in Malawi.

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Cash flow
The group's operations generated R2.5 billion in cash for the year compared to R2.1 billion in 2010 due to improvements in working capital.

Dividends
The company paid an interim dividend of 200 cents per share which was 8% higher than the 185 cents per share in 2010. Santam declared a final dividend of 355 cents per share for 2011 (2010: 325 cents per share), resulting in a total dividend of 555 cents per share for the year (2010: 510 cents per share). This represents an increase of 8.8%.

Dividend payments are made in context of the company's capital management policy. The approach followed with payment of interim and final dividends is conservative and supports the company's aim not to skip or reduce ordinary dividend payments. When special dividends are being considered, we take into account capital levels (as informed by the solvency margin targets of 35% to 45%) and potential investment opportunities.

Given our strong solvency margin of 48% at the end of December 2011 and the stabilisation of the investment markets, the board decided to declare a special dividend of R8.50 per share. This will be the fifth special dividend paid by Santam since 2004 and will bring the total special dividend per share declared over this period to R52.

INVESTMENTS
Santam follows a policy of managing its investment portfolios in a diversified manner. We invest in all the major classes of financial instruments ranging from listed equities to cash-related investments. Our aim is to optimise investment income within the approved risk appetite profile. Detail on risk management practices can be found in note 3 to the full annual financial results published on our website at www.santam.co.za or available on request from the company secretary.

The asset allocation is also managed and monitored from an asset/liability perspective. This ensures that there are sufficient liquid funds available to meet Santam's insurance liabilities, to ensure that the subordinated debt obligations are adequately covered by matching interest-bearing instruments and that the shareholders' funds are not unduly exposed to investment risk.

The investment strategy, including return objectives, asset allocation, portfolio construction and asset manager selection, has been formulated and approved by the board of directors and any variations have to be approved by the board. The board has delegated some of its responsibility to the investment committee which operates as a subcommittee of the board as described in more detail in the corporate governance report.

For years Santam has followed a consistent approach where the management of the bulk of its investments is outsourced to independent external fund managers under predetermined mandates. The overall performance of the fund managers against their mandates, derived from Santam's investment strategy, is monitored and tracked by an independent multimanager, who reports back to the Santam investment committee on a quarterly basis. The mandate guidelines include performance objectives, market risk limitations such as tracking error and duration, asset allocation, credit and exposure limitations, the use of derivative structures and compliance with relevant FSB regulations. At the end of 2011 approximately R11.7 billion of the total group investments were managed by external investment managers. Their mandates consist of a combination of various benchmarks; inter alia, different JSE indices, SWIX and SteFi.

Refer to page 110 for a detailed analysis of the investments. In short, the composition of Santam's total investments was as follows as at 31 December 2011:

Asset class

CAPITAL MANAGEMENT
Santam's capital management philosophy is to maximise the return on shareholders' capital within an appropriate risk framework. The aim is to increase shareholder wealth by assisting management to make informed, strategic business decisions around the following:

  • The amount and sources of capital in the business
    This is also linked to the current and future regulatory capital requirements in terms of the existing and the newly formulated solvency assessment and management (SAM) requirements.
  • The allocation of capital between business units
  • The appetite, level and type of risk within the company

Issue of shares
The company did not issue any new shares during the year. The total number of shares in issue was 119 346 at a capital of R107 million. The total authorised number of ordinary shares is 150 million shares of no par value and 12 million non-redeemable, non-participating, non-cumulative, no par value preference shares. All issued shares are fully paid. Subject to the restrictions imposed by the Companies Act, the authorised and unissued shares are under the control of the directors until the forthcoming annual general meeting. Until the next annual general meeting the directors are authorised to issue 10 million of the unissued shares for any purpose and in accordance with such rules and conditions as they see fit.

Treasury shares
Following on the large voluntary share buyback in 2007, the group held a total of 7 087 168 of Santam shares, classified as treasury shares. During 2011, the group bought back 288 892 shares in the open market at a cost of R37 million. A total of 528 663 shares were reissued in terms of the employee share incentive programme. The total number of treasury shares held at the end of 2011 was 6 086 185. The company has the right to reissue these shares at a later date subject to approval by the JSE and the Regulator.

Credit rating
Fitch Ratings affirmed Santam's Insurer Financial Strength rating of AA+ (double A plus) and rating on Santam's subordinated debt of R1 billion issued in 2007 at A+ (A plus). The outlook remains stable. The affirmation reflects Santam core status within the Sanlam group, its strong position as the largest non-life insurer in South Africa, its good and robust capital position and its improved and resilient financial performance, despite the prevailing tough economic conditions.

Global Credit Ratings Company ("GCR") affirmed Santam's domestic rand currency claims paying ability rating of AAA (triple A) and domestic rand currency long-term subordinated debt rating of AA- (double A minus) during July 2011. This is the highest rating that can be attained by an insurance company. This is indicative of very high credit quality and strong protection factors.

Discretionary capital and solvency level
Santam's board of directors has targeted a solvency level in the range of 35% to 45% of net written premium for the group. From a pure economic risk capital perspective, the current solvency requirement is between 20% and 25%. The excess is maintained for the following reasons:

  • As a buffer over regulatory capital requirements which was at 25% up to the end of 2011 and approximately 33% under the interim SAM arrangements if our internal model is not used or approved as calculated as input into the QIS1 process. This is discussed in more detail under regulatory capital and solvency requirements later in the report.
  • To fund new business growth
  • To maintain Santam's insurer financial strength credit rating
  • To allow for any potential investment opportunities

The group solvency ratio of 48% at 31 December 2011 was higher than the maximum of 45% of the targeted solvency range. Net asset value per share increased from 4 535 cents at the end of 2010 to 5 336 cents at the end of 2011. Given the high solvency level it was decided to declare a special dividend as reported. We will continue to monitor our solvency levels and required solvency range in light of industry changes and regulatory requirements. We remain committed to efficient capital management and consider it to be ingrained in our DNA.

BROAD-BASED BLACK ECONOMIC EMPOWERMENT (BBBEE)
The Santam BBBEE scheme is hosted in a special-purpose company (BEE SPV) and consists of three components:

  • The Emthunzini BEE Staff Trust
  • The Emthunzini BEE Business Partners Trust
  • The Emthunzini BBBEE Community Trust

The value in the scheme is proportionally allocated to these three trusts. Within the trusts, allocations are made to beneficiaries according to the specific rules in the respective trust deeds. The total value in the scheme at 31 December 2011 was approximately R555 million. During 2011 the dividend income received by the structure housing the scheme was sufficient to fully service the senior debt facility and make a proportional payment towards servicing of the mezzanine debt.

The scheme also made another unit allocation to new black employees that joined the Santam group during 2011 and to black employees that were promoted since the previous allocation. A second round of allocations was also made to qualifying non-executive directors.

In total, 25% of the value in the scheme will be allocated to specific projects within previously disadvantaged communities. Cash distributions of approximately R5.5 million were allocated to the scheme for distribution to identified beneficiaries during 2011. More information on the scheme can be found in our Sustainability Report on our website at www.santam.co.za.

Of the current value of R555 million in the scheme, 49% (R274 million) is attributable to the Business Partners Trust, 26% (R145 million) to the Staff Trust and 25% (R136 million) to the Community Trust. To date, more than 80% of the value in the scheme has been allocated to participants and we intend to continue with allocations to participants in all three trusts during 2012.

CORPORATE ACTIONS
The following significant corporate transaction was completed during the year ended 31 December 2011:

  • On 1 March 2011 Santam acquired 55% of the voting equity in Mirabilis Engineering Underwriting Managers (Pty) Ltd (Mirabilis) by merging its construction and engineering business into Mirabilis. The new merged entity is the leading engineering underwriter in the South African market

The corporate actions reported on in 2010 are starting to bear fruit. The acquisition of Emerald Risk Transfer (Pty) Ltd enhanced our specialist underwriting skill in the corporate property environment as demonstrated by the turnaround from a loss-making situation in 2009 to double-digit underwriting margins in 2010 and 2011. The acquisition of MiWay Group Holdings (Pty) Ltd contributed significantly to the growth target set for diversifying our distribution channels while the acquisition of Indwe Broker Holding (Pty) Ltd served its purpose of protecting Santam's premium income from this source.

Full details of the company's holdings in subsidiaries and associated companies are contained in note 44 to the full annual financial results published on our website at www.santam.co.za or available on request from the company secretary.

REGULATORY SOLVENCY AND CAPITAL REQUIREMENTS
The FSB is in the process of developing a new solvency regime for the South African long-term and short-term insurance industries to be in line with international standards. This will be done under the Solvency Assessment Management (SAM) banner.

The basis of the SAM regime will be the principles of the Solvency II Directive as adopted by the European Parliament. But this will be adapted to South African specific circumstances where necessary.

The implementation date of interim measures relating mainly to changes to the calculation of incurred but not reported claims (IBNR) and the calculation of capital adequacy was 1 January 2012. The overall financial impact on Santam will not be material. Amendments to legislation to provide the regulator with a mechanism to manage insurance groups and also to introduce new requirements for risk management, governance and outsourcing are expected to come into effect during 2012. We have assessed our readiness to comply with these requirements and are confident that they will have a minimal impact on the group. The target date for implementation of the final requirements under the new regime, including the internal model approach for short-term insurers, is January 2015.

As previously reported, Santam developed an internal dynamic financial analysis model of the business in line with best practice to assist management with risk quantification and decision-making. More detail on the model can be found in the Operational Review: Risk Services. Santam intends to use this internal model for determining its capital requirements once SAM has been enacted by the FSB. We expect that capital requirements for Santam under this approach will not be higher than the current 25% solvency requirement.

More information about our participation in the FSB's quantitative impact study (QIS1) and a readiness assessment carried out during 2011 can be found in the Operational Review: Risk Services.

NEW LEGISLATION
A hive of activity in the regulatory environment is and will continue to impact the company. Impact assessments and the implementation of requirements are impacting resources and results in additional cost of running the company. However, Santam is determined to ensure that, where possible, we derive benefits from the implementation of requirements as opposed to an approach of merely performing cosmetic exercises without business or governance value. Our approach to legal compliance and the philosophy that we adopted in this regard are discussed in detail in the Corporate Governance report. There were several regulatory developments in 2011 which are summarised below:

Companies Act 71 of 2008
The new Companies Act came into effect during the 2011 financial reporting year. Santam's response to the Act is set out in the Corporate Governance report.

Insurance regulation and legislation changes
FSB directive 156.A.i (ST)
Pursuant to the FSB's attempt to ensure consistency in the application of the STIA, and in particular, section 45 which deals with the handling and receipt of policy premiums by intermediaries, it released directive 156.A.i (ST) on 16 August 2011. This directive provides guidelines on how insurers and independent intermediaries are to apply section 45. Santam's response to the directive is set out in detail in the Corporate Governance Report.

Financial Advisory and Intermediary Services Act, Act No 37 of 2002 ("the FAIS Act")
In terms of the General Code of Conduct for authorised financial services providers and representatives, authorised financial services providers, such as Santam, were required to put in place a conflict of interest management policy which was aimed at avoid conflict of interests and, where this is not possible, to mitigate conflict of interest between itself and policyholders when rendering financial services to policyholders. The Santam board approved Santam's conflict of interest management policy in April 2011 and the policy has been implemented. Further relevant actions taken are described in the Corporate Governance report.

Upcoming regulatory changes
A number of regulatory changes will impact Santam in future, most notably:

Amendments to section 48, introduction of 48A of the Short-term Insurance Act, Act No 53 of 1998 ("the STIA") and the introduction of regulation 6 issued in terms of the STIA from 1 January 2012
Section 48 regulates remuneration paid by insurers to intermediaries, section 48A lays down requirements under which insurers may conclude binder agreements with third parties and regulation 6 introduces new definitions and prescribes requirements, limitations and prohibitions relating to binder agreements, consideration that may be offered or provided to binder holders, and any participation by binder holders in profits attributable to the policies referred to in binder agreements and for certain exemptions. Insurance Laws Amendment Bill 2011 ("the Bill").

In August 2011, the FSB released the Bill as part of the SAM II Project. The Bill is aimed at introducing interim measures relating to the governance of insurers, risk management, internal controls, group supervision, and outsourcing of functions. A further aim is to address the existing regulatory gaps and introduce technical amendments to insurance legislation.

Micro-insurance legislation
The Micro-insurance White Paper provides that insurers will, in future, have an option of either selling micro-insurance products using their current licences, albeit with limitations, or ringfencing their micro-insurance business under a micro-insurance licence. The capital and some governance requirements for micro-insurers will be relaxed.

Treating clients fairly ("TCF")
TCF is aimed at introducing a framework to ensure that clients in the financial services industry receive fair treatment when engaging with regulated entities.

Developments in taxation
The new dividends taxation will come into effect on 1 April 2012 and will replace the current secondary tax on companies. It is an indirect tax in terms of which taxation on dividends of 10% will be withheld from specified shareholders as determined by the Income Tax Act.

The South African Revenue Service (SARS) is currently reviewing value-added tax (VAT) for insurance contracts. SAIA has formed a tax task group to engage with SARS and communication from SARS on any changes to the VAT treatment for insurance contracts is expected by March 2012. Santam is represented on this task group and has provided input into the process.

The Minister of Finance in his budget speech of 22 February 2012 announced that the capital gains tax (CGT) inclusion rate for companies will be increased from 50% to 66.6% (effective CGT rate from 14% to 18.6%). The change in the CGT rate will apply in respect of capital gains during years of assessment commencing on or after 1 March 2012. The increase will have an impact on the taxation of Santam's gains and losses on financial assets, effectively increasing the tax rate.

RISK MANAGEMENT
Santam is exposed to several financial and other risks namely market risk, credit risk, insurance risk, liquidity risk, operational risk, legal risks and risks associated with the management of capital. The potential impact and management of these risks are discussed in detail in note 3 of the full annual financial results published on our website at www.santam.co.za or available on request from the company secretary.

LOOKING AHEAD
It is expected that the South African economy would grow by somewhat less than the forecasted 3% worldwide growth in gross domestic product in 2012. Headline inflation will be impacted by the changes in food prices while core inflation is expected to continue to rise in the first half of the year following the increases in commodity prices and the weakening of the rand in the second half of 2011. It is expected that headline inflation will average around 6% for 2011 and some increase in insurance inflation is likely. This should improve average premium levels somewhat. However, competition in the market will continue to put pressure on premium rates and prevent across-the-board premium increases. Santam is positioned to manage increases selectively through our market and risk segmentation approach.

The weakening of the rand during the course of 2011 is expected to put some upwards pressure on claims cost, most notably on the cost of motor vehicle repairs due to the increased cost of imported vehicle parts. However, we are optimistic that our continued efforts to reduce claims cost as described in more detail in our operational review: claims would offset some of the impact of the upwards cost pressure. It is expected though that the underwriting margin in 2012 will be lower than the levels achieved in 2011.

Nominal interest rates are expected to remain on current levels during 2012 if the rand remains around its current level. Therefore, interest received is not expected to be higher in 2012 implying a flat return on insurance funds for 2012 compared to 2011. Uncertainty remains in the investment markets due to the impact of the instability in Europe. On the back of the assumption that the European economy will not disintegrate but faces a very slow and long-term recovery, it is expected that investment markets should be more stable in 2012 compared to 2011. This should support an improvement in fair value gains in 2012.

FORWARD-LOOKING STATEMENTS
In this report we make certain statements that are not historical facts and relate to analyses and other information based on forecasts of future results not yet determinable, relating, among others, to gross premium growth levels, underwriting margins and investment returns. These are forward-looking statements as defined in the United States Private Securities Litigation Reform Act of 1995. Words such as "believe", "anticipate", "intend", "seek", "will", "plan", "could", "may", "endeavour" and "project" and similar expressions are intended to identify such forward-looking statements, but are not the exclusive means of identifying such statements.

Forward-looking statements involve inherent risks and uncertainties and, if one or more of these risks materialise, or should the underlying assumptions prove incorrect, actual results may be very different from those anticipated. Forward-looking statements apply only as of the date on which they are made, and Santam does not undertake any obligation to update or revise any of them, whether as a result of new information, future events or otherwise.

MJ Reyneke
Financial Director

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