Tabs Demo
Just Share’s advocacy work includes submissions on proposals for and amendments to policies, regulations and legislation relevant to responsible investment and shareholder activism.
Sustainable Finance and Responsible Investing
- Submission to National Treasury on the draft Green Finance Taxonomy (July 2021)
- Just Share comments to the University of Cape Town’s Panel for Responsible Investment (UPRI): UCT Endowment Fund’s fossil fuel investments (May 2021)
- Just Share comments on CRISA 2020 Revision Consultation Draft (January 2021)
- Submission to National Treasury on the Draft Technical Paper on Financing a Sustainable Economy (20 July 2020)
- Just Share comments on IFRS Consultation Paper on Sustainability Reporting (15 December 2020)
Inequality, diversity & transformation
- Comments by Just Share and six other civil society organisations – Comments on the Companies Amendment Bill (2 November 2021)
- Just Share’s comments on the annual review of the National Minimum Wage for 2022 (4 October 2021)
- Just Share response to National Minimum Wage Commission Proposal for 2021 Annual Adjustment (19 December 2020)
- Submissions on the Companies Amendment Bill 2018: fair and responsible remuneration (26 November 2018)
- Response to the JSE’s “Consultation Paper on possible regulatory responses to recent events surrounding listed issuers and trading in their shares” (19 October 2018)
Climate change
- Just Share’s comments on South Africa’s draft Nationally Determined Contributions (NDCs) (30 April 2021)
- Submissions on the FSCA’s Draft Directive (Pension Funds Act, 1956) on Sustainability Reporting and Disclosure Requirements (18 May 2018)
Governance

In September 2021, Just Share invited 33 of South Africa’s largest and most prominent asset managers to participate in our 2021 South African Asset Manager Climate Risk Survey. The asset managers included the top 20 managers by size as per the Alexander Forbes Manager Watch Survey of 2020 and the top 12 managers by size as reported in the 27Four BEE Survey of 2021.
For the first time in South Africa, this report provides retail investors, pension fund trustees, philanthropic foundations, university endowments, and civil society organisations with assessment of the extent to which the local asset management community is meeting best practice standards in integrating climate risk into investment decision-making.
The survey findings reveal that while there are encouraging signs of local asset managers adopting the necessary approaches to successful, effective climate risk integration, relatively few of them demonstrate excellence when assessed against international best practice standards. Those that do align with international best practice do so in some areas, but not in all.
We hope that this report will contribute to a better understanding of the status of climate risk integration in the local asset management industry, and also assist in identifying areas for improvement and enhancement of climate change-related decision-making, in order to accelerate South Africa’s transition to a low-carbon economy.
While overall there is much work to be done by local managers to meet international best practice, we have attempted to shine a light on those that are leading the way, in the hope that this will spur faster and more coordinated action to align investment decision-making with the goals of the Paris Agreement, and the country’s just transition to a more sustainable and inclusive economy.
Just Share, together with international environmental legal NGO ClientEarth, commissioned a legal opinion from Fasken on the question of whether the boards of pension or provident funds are required under South African law to take into account climate-related risks and opportunities when making investment-related decisions on behalf of their funds. The legal opinion is unequivocal in finding that they are required to do so.
Pension and provident funds are important social actors with a key role to play in creating a more inclusive and sustainable economy. Factoring climate risk into investment decisions is essential to driving a just transition to a low-carbon economy, and is fully consistent with trustees’ fiduciary duties.
Just Share and ClientEarth have written to most of SA’s major pension fund boards, to share the opinion, highlight the latest developments relating to investment risks and opportunities stemming from climate change, and provide guidance as to what steps trustees must take to comply with their legal duties.