ESG INSIGHT SA - Governance Research

ESG and Executive Pay in South Africa

Strategic Alignment of Executive Remuneration and ESG Performance in the JSE Ecosystem - from King IV's "pay for purpose" philosophy to sector-specific mechanisms, active ownership and the ongoing battle against greenwashing in pay.

Published Oct 2025
Coverage JSE Listed Companies
Sources 45 Primary References
Classification Public Research
00 - Executive Summary

Pay for purpose - the transformation of executive incentives

The convergence of executive compensation and ESG performance marks a transformative era for corporate governance in South African capital markets. The traditional "pay for performance" paradigm - once strictly limited to financial outcomes - is being replaced by a "pay for purpose" philosophy. This shift is driven by King IV, the JSE's evolving sustainability disclosure guidance, and an increasingly assertive institutional investor community demanding measurable ESG outcomes at the executive level.

91.6%
Avg Shareholder Support
For remuneration policies across JSE Top 40 - but dissent is rising materially
5.4%
Sub-50% Implementation Votes
Companies receiving less than 50% approval doubled from 2.6% to 5.4% in one year
20%
ESG LTI Weighting
Anglo American and Woolworths both formally weight ESG at 20% of long-term incentives

For South African listed companies, integrating ESG metrics into remuneration structures is no longer an optional disclosure but a critical component of institutional legitimacy. The evidence from JSE companies demonstrates that when pay is aligned to purpose, it creates a powerful incentive for executives to address the systemic challenges of the South African economy - from decarbonisation and water security to financial inclusion and socio-economic transformation.

"The path to prosperity is now inextricably linked to the preservation of the planet and the progress of its people."

SOUTH AFRICAN EXECUTIVE REMUNERATION STRUCTURE - ESG INTEGRATION MAP FIXED PAY 💼 Base salary Benefits & pension Market benchmarked No direct ESG link SHORT-TERM (STI) 🎯 Annual bonus pool Safety deductors ESG conduct gates 5–15% ESG weighting Growing ESG influence LONG-TERM (LTI) 📈 Share / PSP vesting 20% formal ESG weight GHG · Water · B-BBEE 3–5 year horizon Strongest ESG mechanism REMCO OVERRIDE ⚖️ Ethical downwards Governance failure veto King IV judgement FirstRand 2024 example Legitimacy safeguard Source: PwC 2025 Directors Remuneration Report; King IV; Anglo American ESG Remuneration Factsheet 2025

01 - King IV

The governance bedrock - apply and explain

The King IV Report, effective from April 2017, serves as the primary philosophical and structural guide for corporate governance in South Africa. Unlike King III's "apply or explain" regime, King IV introduced "apply and explain" - requiring governing bodies to provide a qualitative narrative on how their pay practices achieve specific governance outcomes: ethical culture, good performance, effective control and legitimacy.

King IV's Principle 14 explicitly addresses remuneration, stating that the governing body should ensure the organisation remunerates fairly, responsibly and transparently. This is underpinned by the "ICRAFT" values: Integrity, Competence, Responsibility, Accountability, Fairness and Transparency. When applied to executive pay, these values mandate that incentives reward not only financial success but also the ethical and effective leadership required to prevent negative consequences on society and the environment.

KING IV - FOUR GOVERNANCE OUTCOMES APPLIED TO REMUNERATION ETHICAL CULTURE 🧭 "Conduct" and "integrity" gates in bonus pools Ethics over profit GOOD PERFORMANCE 📊 Balance short-term financial targets with long-term ESG milestones No short-termism EFFECTIVE CONTROL 🔒 Rigorous oversight of ESG data quality and audit trails for pay Anti-greenwashing LEGITIMACY 🤝 Transparent wage gap and transformation progress disclosure Social licence to operate Source: King IV Report on Corporate Governance; MDPI Analysis of King IV and SDG Transparency Practices 2026
King IV OutcomeApplication to RemunerationImpact on Executive Behaviour
Ethical CultureConduct and integrity gates in bonus pools - below-threshold behaviour forfeits awardPrioritises ethical decision-making over aggressive profit-seeking
Good PerformanceBalancing short-term financial targets with long-term ESG milestones via LTI structureEncourages sustainable growth - discourages short-termism
Effective ControlRigorous oversight of ESG data quality and audit trails for all pay outcomesReduces risk of greenwashing or metric manipulation
LegitimacyTransparent disclosure of wage gaps and B-BBEE transformation progressEnhances social licence to operate and investor trust

02 - JSE Disclosure and ISSB

Standardising the data that links pay to purpose

The JSE's Sustainability Disclosure Guidance, released in 2022 and updated in January 2025, serves as a bridge between South African companies and global reporting standards, specifically aligning local reporting with IFRS S1 and IFRS S2. This alignment is significant because it provides a consistent, comparable and verifiable set of metrics that can be used to judge executive performance - treating ESG data with the same level of importance as financial data.

The JSE now highlights "Core Metrics" that are universal and industry-agnostic: greenhouse gas emissions (Scope 1 and 2), water usage and gender diversity in management. The guidance explicitly requires organisations to describe how their approach to remuneration relates to their economic, environmental and social objectives - creating a direct reporting link where the board must disclose how material sustainability considerations are integrated into remuneration policies at the executive level.

Double Materiality as a Strategic Driver

A sophisticated development within South Africa is the adoption of "double materiality" - used by leading firms including Sanlam and Sappi. This requires companies to analyse both how ESG factors impact enterprise value (financial materiality) and how the company's activities impact society and the environment (impact materiality). From a remuneration standpoint, it ensures executives are not just rewarded for mitigating risks to the bottom line, but are also held accountable for the company's total footprint - carbon, water, labour - on the world.



04 - Mining Sector

Anglo American and Sasol - the tension between production and purpose

The South African mining sector represents the most complex intersection of high executive rewards and extreme ESG risk. As a sector that is both a massive employer and a significant environmental polluter, mining companies have been early adopters of sophisticated ESG-linked pay structures - driven by investor pressure, regulatory obligations and reputational necessity.

Anglo American - The Benchmark

Anglo American provides the JSE benchmark for integrating safety and environmental metrics into variable pay. A "safety deductor" is applied to the overall annual bonus - the three fatalities recorded in 2024 resulted in a 15% deduction from the total bonus outcome. In their LTI structure, ESG measures represent a formal 20% weighting across strategic pillars.

ANGLO AMERICAN LTI STRUCTURE - ESG COMPONENTS (2024–2025) 80% Financial Financial KPIs - 80% ESG Measures - 20% ESG 20% - COMPONENT BREAKDOWN GHG Emissions Reduction 10% Target: 1.34 MtCO₂ reduction vs 2023 baseline for 100% vesting Tailings Management (GISTM) 5% Target: 95% conformance with Global Industry Standard on Tailings Management Social Responsibility / Gender 5% (incl. 37% gender rep. target at band 5+) Source: Anglo American ESG-Linked Variable Remuneration Factsheet 2025; Integrated Annual Report 2025

Sasol - The Production-Decarbonisation Tension

Sasol's journey highlights the challenges of aligning pay to purpose in a fossil-fuel-dependent business. In May 2025, Sasol presented an Emissions Reduction Roadmap claiming to meet 2030 targets at lower cost - primarily by increasing production volumes while maintaining cost discipline. Critics, including Just Share, argue this roadmap fails to integrate the true climate and air-quality costs of operations.

The LTI Emissions Metric Risk: Sasol's FY25 LTI metric was modified to "maintain our roadmap to reducing our carbon footprint whilst increasing our production." If production volumes are the top priority, the "E" metric becomes secondary - a greenwashing risk that institutional investors have flagged repeatedly.

Investor Pushback: Institutional investors and climate advocacy groups continue to challenge Sasol's ERR at AGMs, arguing that an "optimised" transition that maintains coal dependency does not constitute genuine decarbonisation progress worthy of executive reward.


05 - Financial Services

Sanlam's inclusion agenda and FirstRand's ethical override

Case Study - Sanlam
🌍

Financial Inclusion as Core KPI

Sanlam's remuneration philosophy is anchored in empowering generations to be "financially confident, secure and prosperous." For FY2024, Exco members were measured against ESG measures accounting for 5–10% of their total performance scorecard, integrated into the annual bonus to ensure the business is "managed in a sustainable way." Specific outcomes include progress in financial inclusion at scale and successful ESG integration across all business units.

Case Study - FirstRand
⚖️

The Ethical Override - Governance Over Formulae

Despite delivering a normalised ROE of 20.1% and 4% earnings growth in 2024, FirstRand's Remco reduced vesting for executive directors involved in the UK motor commission matter - reducing outcomes to 123.2% vs 144.6% for other participants. This decision, "technically outside policy," was deemed necessary to align management's experience with shareholders. It demonstrates sophisticated Remcos moving away from robotic formulaic pay toward judgmental oversight.

"Sophisticated Remuneration Committees are moving away from robotic formulaic pay toward judgmental oversight that protects institutional reputation."

FirstRand Remuneration Report 2024

06 - Retail

Woolworths' Good Business Journey - ESG embedded in the LTI

Woolworths Holdings Limited has one of the most transparent links between pay and sustainability in the JSE retail sector through its "Good Business Journey." ESG measures are a formal pillar of the LTI Performance Share Plan structure, representing a 20% weighting - with specific, quantified targets required for 100% vesting.

Performance Condition (WHL LTI)WeightingKey Metric / Target
adHEPS Growth40%Adjusted Headline Earnings Per Share growth
ROCE40%Return on Capital Employed
Supplier DevelopmentESG 20%Scaling supplier development in line with sales growth
Sustainable Products-99% of Food products with two or more sustainability attributes
Local Sourcing-35% of FBH products sourced locally
Energy Intensity-280 KWh per m² across stores
B-BBEE Status-Achievement of Level 4 or better
Why LTI Embedding Matters

By embedding ESG metrics in the LTI rather than just the annual bonus, Woolworths ensures executives are focused on multi-year systemic changes in the supply chain rather than one-off "green" initiatives. This multi-year horizon is critical - it aligns the executive's wealth creation timeline with the long-term nature of ESG outcomes, preventing "metric gaming" at the end of any single financial year.


07 - Investor Demands

The PIC and Old Mutual - setting the standard

Institutional investors are the ultimate arbiters of the link between pay and purpose. The Public Investment Corporation and Old Mutual Investment Group have been the most active in setting clear expectations at JSE AGMs - using their combined voting weight to drive accountability on executive pay structures.

PIC PROXY VOTING TRIGGERS - VOTE AGAINST REMUNERATION RESOLUTIONS PIC VOTES AGAINST IF: ⚠ Information not transparent / lacks integrity ⚠ No strategic KPIs disclosed for STIs ⚠ LTI weighting distributions not provided ⚠ Targets not deemed "stretching" ⚠ Company rated "ESG laggard" - concerns unaddressed ⚠ Unlinked bonuses / ex-gratia payments Voted against AVI & RCL Foods in Dec 2024 OLD MUTUAL DEMANDS: ✓ Pay parity ratio closer to 100:1 ✓ Binding "say on pay" votes ✓ Executive pay = direct ESG strategy result ✓ Fair pay as primary board ethics indicator ✓ Escalate to Remco member votes after 25% dissent ✓ Wage gap disclosure - Companies Amendment Act Source: OMIG Robert Lewenson Article; King IV Principle 14

08 - Active Ownership in Practice

ESG INSIGHT SA - challenging corporate pay since 2014

Long before ESG INSIGHT SA became a technology platform, the firm - operating as Inkunzi Fiduciary Solutions under the leadership of Mehluli Mncube - established itself as one of South Africa's most active and vocal proxy representatives at JSE AGMs. Acting as stewardship agent for a group of institutional pension funds, Mncube systematically challenged the executive pay practices of major JSE-listed companies - at a time when such direct engagement was rare from the South African market's own investor base.

This active ownership track record is not historical footnote - it is the lived institutional knowledge that underpins ESG INSIGHT SA's platform design, its understanding of what "good" remuneration governance looks like, and its deep familiarity with the tactics companies use to obscure poor pay alignment behind compliant-looking disclosure.

INKUNZI FIDUCIARY SOLUTIONS → ESG INSIGHT SA - AGM INTERVENTION RECORD 14 Standard Bank AGM Challenged dual-CEO pay equity 19 Old Mutual AGM Led 69% vote against Moyo R50.5M pay / golden handshake 20 Pick n Pay AGM 8 questions on pay transparency ESG Platform Transformation Inkunzi → ESG INSIGHT SA Advisory expertise encoded in AI Sources: Moneyweb; Daily Maverick; CHRO South Africa; eNCA - 2014 to 2020
Old Mutual AGM - May 2019

Leading the 69% Vote Against Moyo's Pay - Old Mutual

Representing five institutional pension funds invested in Old Mutual, Mehluli Mncube was a leading voice in the vote where approximately 69% of shareholders voted against the implementation of Old Mutual's remuneration report at the May 2019 AGM. The intervention centred on CEO Peter Moyo's total compensation of R50.5 million - a 32% increase in 2018 - and the risk of a substantial "golden handshake" following the board's handling of a conflict of interest.

"We don't want shareholder funds to be used for a golden handshake because the company knew about this conflict of interest and thought it could manage it. We are closely watching the pay-out. Old Mutual is a big company and should have strong corporate governance controls. You don't fire a CEO abruptly - this causes volatility in the share price which affects the value of pension funds."

- Mehluli Mncube, Inkunzi Fiduciary Solutions, quoted in Moneyweb & Daily Maverick, June–September 2019
Pick n Pay AGM - December 2020

Eight Questions on Pay Transparency - Pick n Pay

At Pick n Pay's virtual AGM in December 2020, Mncube spoke as proxy for five undisclosed pension funds and posed eight structured questions related to the link between executive pay, bonuses and performance targets - at a time when the retailer had recorded a 50% drop in half-year earnings. His central challenge: "there was not enough transparency around executive pay and performance targets." The non-binding vote saw approximately 25% of shareholders vote against the remuneration policy - narrowly avoiding the JSE threshold that would have required formal engagement with dissenting shareholders.

- Mehluli Mncube, Inkunzi Fiduciary Solutions, quoted in CHRO South Africa & Business Live, December 2020
Standard Bank AGM - 2014

Challenging Dual-CEO Pay Equity - Standard Bank

At Standard Bank's 2014 AGM, Mncube questioned the payment of near-equal salaries to two joint CEOs - saying Standard Bank was "worse off" when it came to levels of pay relative to performance. The challenge drew public attention to the governance questions surrounding the bank's dual-CEO structure and the compensation rationale for maintaining it, at a time when the bank's total executive remuneration exceeded R42.7 million across its prescribed officers.

- Mehluli Mncube, Inkunzi Fiduciary Solutions, quoted in eNCA, September 2014
From Advocacy to Intelligence

Why This History Powers the Platform

The active ownership record of Inkunzi Fiduciary Solutions - the firm that became ESG INSIGHT SA - is not separate from the platform's analytical capabilities. It is the source of them. Every remuneration committee technique, every obfuscation tactic, every metric manipulation pattern documented in this report was first encountered in the boardrooms and AGM halls of JSE-listed companies. That institutional memory is now encoded in ESG INSIGHT SA's Governance scoring models, controversy detection algorithms and stewardship reporting frameworks.

Read Our Full Transformation Story →

09 - Greenwashing and Challenges

The risk of symbolic governance

While the integration of ESG into pay is accelerating, it is not without significant challenges. Without rigorous standardisation, ESG-linked pay can become a "symbolic" governance tool that masks poor performance or facilitates greenwashing - the practice of disclosing misleading or overly optimistic ESG information to improve reputation without making substantive operational changes.

THREE GREENWASHING TACTICS IN JSE EXECUTIVE REMUNERATION VAGUE METRICS 🌫 Using qualitative goals like "improve stakeholder relations" that are subjective - yielding higher payouts than hard targets Tick-box "sustainability" LOWERING THE BAR 📉 Setting "on-target" payouts for performance that is essentially "business as usual" with no genuine stretch target WTW: ESG payout spread narrower than financial METRIC SUBSTITUTION 🔄 Focus on E or S pillars where performance is already strong while ignoring the most material ESG risks to the business Sasol production/emissions example
The Data Volatility Problem

ESG as a Pay "Buffer" - Decoupling Management from Market Reality

Analysis by WTW suggests that the spread of LTI payouts for environmental metrics is narrower than for financial metrics - indicating more consistent, and potentially less rigorous, achievement levels. If ESG payouts are consistently high while share price (TSR) or earnings (HEPS) are plummeting, it creates a "buffer" that protects executive pay from market reality. This decouples the interests of management from those of shareholders - precisely the outcome King IV's pay framework was designed to prevent.


10 - The "S" in South Africa

B-BBEE, wage gaps and the living wage imperative

In the South African context, the "Social" pillar of ESG is uniquely weighted toward Broad-Based Black Economic Empowerment and the reduction of vertical income inequality. For almost every JSE-listed company, B-BBEE status is a critical component of executive scorecards - not just a regulatory requirement but a business necessity for securing government contracts and maintaining a social licence in sectors like mining and telecommunications.

CompanySocial Metric in PaySpecific Target / Outcome
WoolworthsB-BBEE StatusAchievement of Level 4 or better - embedded in LTI
Anglo AmericanGender Representation37% gender representation at band 5 and above by 2027
SanlamFinancial InclusionProgress in emerging markets and inclusive product growth at scale

South Africa faces some of the highest levels of income inequality in the world. The "S" pillar in remuneration is increasingly focused on the living wage - advocacy groups like Just Share consistently demand that retailers and miners increase transparency on pay and rewards for their lowest-paid workers. The JSE Top 40 companies have a "patchy" record on wage transparency, but the 2024 Companies Amendment Act will soon mandate disclosure of the gap between the highest and lowest earners.

B-BBEE Integration in Executive Scorecards - Large JSE Companies~85%
Wage Gap Disclosure - JSE Top 40~45%
Living Wage Targets Linked to Executive Bonuses~20%
Female Board Representation (Leading Asset Managers)49%

11 - The "E" in South Africa

Energy, water and the crisis-driven ESG agenda

The "Environmental" pillar for JSE companies is dominated by South Africa's national energy crisis and water scarcity - both of which are systemic risks to the South African economy and represent the most material environmental performance metrics for executive incentives.

Energy Transition

Energy Intensity and Renewable Procurement

Given South Africa's reliance on coal and the instability of the national grid, energy efficiency has become a critical executive performance metric. Executives at manufacturing and mining firms are incentivised to reduce energy intensity (KWh per unit/m²) and contract renewable power via PPAs with IPPs. Sappi's milestone PPA with EnPower and Anglo American's renewable energy supply targets in Southern Africa are leading examples.

Water Stewardship
💧

Water - A Systemic Risk Hiding in Plain Sight

While only 30% of JSE-listed firms currently disclose water usage data, those in water-intensive sectors - paper (Sappi), chemicals (AECI) - are linking pay to water recycling and abstraction reduction. Sappi has committed to reducing fresh water withdrawals by 50% by 2030, a goal informing its "Thrive" strategy and executive performance reviews. Woolworths targets full supply chain circularity on waste.

Environmental MetricSector RelevanceLead Company Example
GHG ReductionHigh - Mining / IndustryAnglo American: 1.34 MtCO₂ reduction target vs 2023 baseline
Energy IntensityHigh - Retail / PropertyWoolworths: 280 KWh per m² across stores
Water RecyclingHigh - Agri / IndustrySappi: 50% reduction in fresh water withdrawal by 2030
Waste ReductionHigh - Retail / FMCGWoolworths: Supply chain circularity target
Renewable Power (PPAs)High - Mining / IndustrialAnglo American + Sappi/EnPower renewable energy agreements

12 - Conclusion and Roadmap

Three factors that determine whether ESG pay actually works

The integration of ESG into executive remuneration in South Africa is no longer a peripheral governance issue - it is a central pillar of corporate strategy. The evidence from the JSE's most prominent companies suggests that when pay is genuinely aligned to purpose, it creates a powerful incentive for executives to address the systemic challenges of the South African economy: decarbonisation, water security, financial inclusion and socio-economic transformation.

Rigorous Measurability: Moving away from qualitative "soft" goals toward audited, quantitative metrics that are material to the business model. The Anglo American LTI with its 1.34 MtCO₂ reduction target and Woolworths' 280 KWh/m² energy intensity target are the benchmark for what "rigorous" looks like.

Active Shareholder Oversight: Investors must use their "say on pay" votes to demand that ESG targets represent a genuine "stretch" and are not merely a mechanism to ensure high payouts during periods of financial underperformance. The PIC's explicit ESG-linked voting triggers and Old Mutual's pay parity demands are the institutional standard.

Governance Integrity - The Override Principle: The board, through its Remuneration and Social and Ethics committees, must be willing to exercise judgment and overrides when ethical or reputational failures occur - even if financial targets are technically met. The FirstRand 2024 Remco intervention is the South African benchmark for this principle in practice.

+8%
CEO Pay Increase (2025)
Against a backdrop of rising investor scrutiny and mandatory ESG disclosure alignment
20%
ESG LTI Weighting
The JSE best-practice benchmark for formal ESG weighting in long-term incentives
69%
Against - Old Mutual 2019
Shareholder vote led in part by ESG INSIGHT SA (then Inkunzi) against Moyo's remuneration
The ESG INSIGHT SA Perspective

From Activism to Intelligence - The Same Principles, Greater Scale

The questions Mehluli Mncube asked at Old Mutual's 2019 AGM, at Pick n Pay's 2020 virtual meeting, and at Standard Bank's boardroom in 2014 - about transparency, about the link between pay and genuine performance, about protecting pension fund members from governance failures - are the same questions our platform's governance intelligence module asks at scale, across every JSE-listed company, every quarter. Active ownership did not end when Inkunzi became ESG INSIGHT SA. It was encoded into the algorithm.

ESG INSIGHT SA Platform

ESG INSIGHT SA's platform governance module monitors remuneration policy and implementation disclosures across the JSE universe - flagging pay-for-performance misalignments, detecting ESG metric obfuscation, and supporting your stewardship team's AGM engagement strategy with AI-powered governance intelligence.