Newsletter
Dear reader
In this newsletter we continue our support to trustees with a Privacy Policy. We investigate whether a member can nominate a church as a prospective beneficiary to his death benefit and whether a member is in receipt of a disability income benefit can choose to resign or retire. We provide feedback on the latest Pensions Industry Meeting conducted by NAMFISA, we report on an interesting case relating to a permanent life partner’s claim to death benefits, and more. Find it below.
As usual we also have links to topical articles from various media that readers should not overlook – they are carefully selected for the value they add to the financial well-being of pension funds and individuals.
As always, your comment is welcome, so open a new mail and drop us a note!
Regards
Tilman Friedrich
Tilman Friedrich's Industry Forum
Benchtest Monthly 08.2016
In August the average prudential balanced portfolio returned 1.86% (July: 0.61%). Top performer is Allan Gray (3.13%) while EMH Prescient (0.52%) takes the bottom spot. For the 3 month period Metropolitan, takes top spot, outperforming the ‘average’ by roughly 1.0%. On the other end of the scale Stanlib underperformed the ‘average’ by 1.0%.
How should I secure my retirement nest-egg in the face of volatility and turmoil?
Global financial markets are in a sorry state and it is very hard to see a silver lining. The US economy is showing mixed signs, no clear trend to be seen, the European economy is flat, Japan is struggling, so is China, not to speak of Russia and many of the developing countries including South Africa and us. The one thing these countries all have in common is a huge debt burden often substantially higher than the countries’ GDP, at historically low interest rates. China, for example has accumulated total debt of US$ 28 trillion, representing a whopping 255% of its GDP by the end of 2015 (worse even than Greece) - an increase of 107% over the past 7 years. That is 38% of global GDP and as much as the commercial banking loan books of the US and Japan combined! The Bank of International Settlements is warning that China is facing an escalating risk of a major debt and banking crisis. The BIS is also concerned about a possible spill-over from China to the global economy.
These are prevailing economic threats to the global economy. Of course with the wars going on around the Mediterranean and on the border between Russia and the Ukraine the economic concerns are reinforced by concerns about a possible major military confrontation between Russia and the US with its European allies.
Read part 6 of the Benchtest 08.2016 newsletter to find out what our investment views are. Download it here...
Pension fund governance - a privacy policy
In this newsletter we present a privacy policy that sets out how the fund (and its administrator) will deal with sensitive personal information of fund members.
The following documents can be further adapted with the assistance of RFS.
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Download the privacy policy here...
AND
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Download a draft rule dealing with the appointment of the board of trustees here...
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Download the code of ethics policy here...
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Download the generic communication policy here...
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Download the generic risk management policy here...
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Download the generic service provider self-assessment here...
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Download the generic conflict-of-interest policy here...
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Download the generic trustee performance appraisal form here…
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Download the generic investment policy here...
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Download the generic trustee code of conduct here...
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Download the unclaimed benefits policy here...
In future newsletters we will consider the following matters also identified by NAMFISA as frequently missing:
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Service provider agreements are not in place.
Can a church be nominated as beneficiary?
One of our pension fund clients recently raised the question whether or not a member can nominate a church as beneficiary to his/her death benefit.
An article in Personal Finance, 1st quarter 2016, sets out two diverging views on this topic. The Pension Funds Act clearly does not consider the estate as a nominee, the estate only being referred to as the default recipient in the event of there being neither dependants nor nominees. In our opinion a nominee cannot be a non-natural person based on the definition of ‘nominee’ per Oxford English dictionary that reads “person who is nominated for an office, a position”. We believe that only a natural person can be nominated to an office or a position. In the other definitions of derivatives of ‘nominee’ the dictionary never refers to a non-natural person. Similarly, the definition of ‘person’ also specifically refers to a ‘human being’ in one instance but nowhere to a legal or non-natural person. We agree with the assertion in the attached article that the intention of section 37C is not to provide for inheritance but rather to provide for social objectives of providing for dependants and nominees that survive a deceased member. Only if neither dependants nor nominees exist would the benefit fall into the realm of inheritance through having to be paid into the deceased’s estate.
The answer is thus not clear-cut. In the first instance the trustees must ascertain that the needs of all dependants have been established and will be addressed by the proposed death benefit distribution. Only if this is the case, the trustees can consider any nominated beneficiary who is not a dependant, particularly if it is a non-natural person. If this has been achieved to the satisfaction of the trustees, we would suggest that the trustees obtain a written acceptance of the proposed distribution from the natural beneficiaries designated by the deceased before finalising the distribution that includes an allocation to the church, to mitigate the risk of a dependant or a nominated natural person challenging the payment to the church.
But what about the IT Act prescribing that an annuity must be paid if needs be to the estate?
As we commented in a previous newsletters with reference to Inland Revenue Practice Notes 5 of 2003 and Practice Note 1 of 1998, the former directs that a minimum of 34% of the total capital available upon death in a defined contribution pension fund must be paid in the form of an annuity (and note this proportion is applied at benefit level and not at beneficiary level) while the latter prescribes that no further commutation is allowed of an annuity upon death of the annuitant.
The definition of ‘pension fund’ in the IT Act that Practice Note 5 of 2003 relies upon, states that ‘… the fund is…established for the purpose of providing annuities for employees on retirement from employment or for widows, children, dependants or nominees of deceased employees, or mainly (interpreted to mean 51%) for the said purpose and also for the purpose of providing benefits other than annuities for the persons aforesaid (i.e. the remaining 49%).
So here the IT Act prescribes that annuities must be paid to inter alia to nominees who according to our interpretation of Section 37C of the Pension Funds Act cannot be a non-natural person, i.e. a trust or an estate for that matter. Does this now mean that where the deceased has left neither a dependant nor nominated a beneficiary, the fund cannot rid itself of its obligation to pay a benefit in the event of death of the member or pensioner?
The crucial difference between the Pension Funds Act and the IT Act is that the Pension Funds Act does not define ‘person’ and one has to resort to the dictionary to establish its meaning. The IT Act in contrast does define a person as ‘…includes any trust and the estate of a deceased person…’. So the concern that a fund cannot pay an annuity to an estate is evidently unwarranted.
Can a member in receipt of a disability income choose to resign or retire?
We were recently approached with a question with regard to the following scenario:
The fund member who is 48 years old now, was declared disabled in 2008 and is still receiving a disability income from the Fund’s insurance company. The member decided that he does not want to be on disability anymore and that he wants to terminate his membership and receive his fund credit to go and start a business. Per the rules, early retirement age is 50, normal retirement age is age 60 and late retirement is age 70.
The two questions arising from this scenario are:
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Can the Trustees prevent and or enforce the rule and force him to remain in the fund until such time that he can exit and what are the consequences?
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Can they allow the member to terminate his membership to the fund as he wishes and what will be the consequences thereof?
In finding an answer to these questions, one has to study the rules of the fund and these will be different from fund to fund although some of the principles will mostly still be relevant.
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Firstly, the definition of ‘employee’ and of ‘membership’ in fund rules typically require that for every new employee fund membership shall be a condition of employment of all persons in the permanent and full-time service of the employer who have not yet attained normal retirement age.
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Secondly rules would typically direct that membership terminates only when the member ceases to be an employee, unless he/she is in receipt of a disability benefit, or when he or she becomes entitled to any benefit in terms of the rules.
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Thirdly, the rules typically then provide for withdrawal benefits, retirement benefits, death benefits and disability benefits. For this scenario the rules on retirement benefits, resignation benefits and disability benefits must now be considered to establish whether they specifically allow or prohibit a member in receipt of a disability income to withdraw from the fund voluntarily.
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The withdrawal benefit would typically apply if a member terminates service before normal retirement age and is not entitled to any other benefits under the fund. Unless elsewhere specifically allowed, a member in receipt of a disability benefit would thus not meet this precondition.
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Retirement benefit would typically be available when a member reaches normal retirement age, in the event of voluntary early retirement as from an earlier age and only with the employer’s consent, in the event of ill-health early retirement as from any age, again only with the employer’s consent due to ill-health, or in the event of late retirement after normal retirement age, mostly also only with the employer’s consent. Only one of these alternative retirement avenues are thus not subject to employer consent, being normal retirement, where it is the member’s right to retire.
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Finally, rules typically provide for a disability benefit to a member who becomes disabled before normal retirement age provided that the claim has been accepted by the insurer. The rules mostly further provide that contributions towards the fund will continue for as long as the member is in receipt of a disability benefit and he/she will consequently remain a member of the fund for as long as the disability benefit is paid by the insurer and until the member becomes entitled to any other benefit in terms of the rules.
In terms of paragraph 2, membership of a member in receipt of a disability benefit can typically only terminate when he/she becomes entitled to a retirement benefit or death benefit, but not upon withdrawal (resignation). Since the member is only 48 years old and still below normal retirement age, he is not entitled to retire early in terms of the relevant rule due to him being ‘under age’. This leaves as only potential early exit option, retirement due to ill-health. This rule typically requires employer consent due to ill-health. In our opinion, this rule cannot be used as the member is not employed by the employer anymore, although this would have to be confirmed by reference to the conditions or contract of employment. If the definition of employee in the fund rules reads similar to that in 1 above, it would clearly preclude a person on a disability benefit to remain an employee, stating that the person must be either in the permanent full-time employment or must be employed on a predetermined contract period. If the person is no longer employed by the employer there is no employer to consent to the person’s ill-health, and early or late retirement for that matter. We would further argue that even if by some remote deduction the person could still be regarded an employee of the employer, the intention of the early ill-health retirement rule cannot be to allow a member to employ this clause where the rules still provide a benefit for the very reason of ill-health. This member in most cases then also cannot proceed on early retirement nor retire late, as this would also require employer’s consent, where the disabled member does not have an employer anymore who could consent.
Based on the above scenario the member in most likelihood cannot exit the fund prior to reaching normal retirement age. The situation would be different once the insurer ceases payment of the disability benefit.
Tilman Friedrich is a qualified chartered accountant and a Namibian Certified Financial Planner ® practitioner, specialising in the pensions field. Tilman is co-founder, shareholder and managing director of RFS, retired chairperson, now trustee, of the Benchmark Retirement Fund. |
Compliment from senior official of NAMFISA
“Good Afternoon K,
Your prompt response to the request is highly appreciated. Kindly note that this effort forms part of consultations from our part and further consultations will take place once we have established a foundation, before implementation that is. Your participation in the exercise is highly noted.”
Read more comments from our clients, here... |
Gunter Pfeifer's Benchmark Notes
Preservation should become compulsory
‘Leakages’ in the pensions system are an issue that policy makers, employers and fund trustees alike should be seriously concerned about, and lump sum benefits represent one of the most serious leakages in the system. After all, the purpose of a pension fund is primarily to provide for the needs of members upon retirement and for dependents of members in the event of death of a member.
Barring a few exceptions, the vast majority of pension fund members will not be able to purposefully apply a lump sum benefit to meet their and their dependents’ needs for as long as they may live. We therefore urge the regulator to do what is in the best interest of pension fund members – enforce preservation upon termination of fund membership until retirement. It is noted with interest that NAMFISA considers draft statement RF.S.5.8 on compulsory preservation as being ‘sensitive’ and requiring more consultation. If it is left to the unions, it is unlikely that compulsory preservation will ever be introduced.
Do not access your retirement funds when changing jobs, no matter how tempting it may be.
Gunter Pfeifer is former Principal Officer and now a trustee of the Benchmark Retirement Fund. He holds a Bachelor of Commerce (Cum Laude). He completed his articles with Deloitte & Touche. He completed the De Beers Program For Management Development at Gordon Institute for Business Science, and the Advanced Development Program at the London Business School. He was formerly Financial Manager of De Beers Marine. |
Kai Friedrich's Administration Forum
The risk of terminating membership upon dismissal
Whilst the dismissal of an employee may appear to be purely a matter of following the correct procedures as envisaged in the Labour Act, the implications for the employer may be a lot more profound than just a possible reinstatement.
Consider the scenario of dismissing an employee. HR will now complete a withdrawal form that will be forwarded to the pension fund administrator. As far as the Fund is concerned its rules would typically determine that membership of the Fund terminates upon termination of employment by the employer. The implication for the administrator is that a termination benefit must be paid. Whether or not the employer was within its rights to initiate the termination of this person’s membership of the Fund is not within the administrator’s knowledge. The fund administrator will therefor terminate the employee’s membership of the fund and will pay out the benefit due to the employee in terms of the fund’s rules.
The employee then challenges his dismissal. In the meantime and before the matter is concluded, the employee passes away or becomes disabled. The court then finds the dismissal to have been unfair and orders the reinstatement of the employee. Where does this now leave the employer as far as the fund’s death or disability benefit is concerned, to which the employee should now be entitled in the light of his reinstatement?
The dismissal of an employee can clearly create a dilemma for the employer given that the employee can challenge such dismissal, while the fund is obliged to terminate fund membership once a notification of termination of service has been issued by the employer.
To avoid the risk of being held liable to make good the loss of the benefit that would have been due to the employee from his fund upon death or disability, the employer should rather consider suspending contributions to the fund in case of a dismissal where there is any possibility of such dismissal being challenged by the employee. The employer would thus not contribute to the fund in respect of the employee but the fund would maintain death and disability benefits. The cost of keeping cover in force will be a fraction of the cost of making good the loss of the benefit to the employee.
Kai Friedrich Director: Fund Administration, is a qualified chartered accountant and a Namibian Certified Financial Planner ® practitioner, specialising in the pensions field. He holds the Post Graduate Diploma and the Advanced Post Graduate Diploma in financial planning from the University of the Free State. |
News from NAMFISA
Transfer of retirement capital from approved fund to unapproved policy
The latest feedback on this topic is that NAMFISA engaged an advocate to provide an opinion. NAMFISA has not had a response yet. It did receive a number of queries from the advocate on the matter and responded accordingly. NAMFISA thus awaits his feedback but will continue making regular follow-ups. Again caution is warranted with the transfer of retirement capital from an approved fund to a member owned insurance policy until NAMFISA has pronounced itself on this matter.
Feedback from industry meeting held on 19 September
Rauha Shivute and Justine Shipanga represented Retirement Fund Solutions at the latest pension funds industry meeting of 19 September 2016. Here are the key messages:
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Ms Grace Mohammed still acting as GM Provident Institutions;
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231 complaints received over 2nd quarter, 54 relate to pension funds;
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FIM Bill now expected to be tabled in parliament only in November;
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NAMFISA identified statements RF.R.1, RF.R.4, RF.R.5, RF.R.6 and RF.S.5.1 – RF.S.5.10 as being critical. Download our summary here…
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RF.S.5.8 on resignation benefits/ compulsory preservation is sensitive, requires more consultation;
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RF.S.3.5.6, unclaimed benefits being discussed with Ministries of Finance and of Justice;
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June SIH returns, 84 funds submitted in time, 7 submitted late, 6 had to resubmit;
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Total industry assets N$ 122.3 billion, N$ 14.9 billion in insurance policies, N$ 3.8 billion in unlisteds;
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Quarterly reporting being adapted to reflect risk based approach of NAMFISA, chart of accounts being standardised across industry, report to be rolled out quarter 1 2017;
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A number of prescribed standard forms must now be submitted on ERS;
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Ministry of Finance considering proposed amendments to regulation 28;
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81 funds submitted levy returns in time, 13 did not submit and will be penalised;
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Non-payment of contributions must be reported to NAMFISA.
Download the notes of the meeting here...
Reader's letter
Bank of Namibia in talks with local asset managers
In this letter a reader expresses her concern about the offshore component of her pension fund capital prospectively being repatriated to Namibia where this is her only consolation in the face of our volatile currency. She specifically enquires whether:
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this would apply to her living annuity;
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whether asset managers have expressed their willingness to cooperate and if so, which ones;
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whether it would at all be possible to circumvent this if all asset managers were to cooperate; and
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whether this would be legal if instituted via the asset managers?
In our response we point out that asset manager are generally vested with full discretion as to the allocation of capital to foreign markets and could use this discretion to meet Bank of Namibia’s request. We do believe that managers would not do so out of their own volition due to the likelihood of losing investors’ funds and would only move if the industry in unison would go this route. However even in such event pension fund trustees in all likelihood would not easily agree with such a move.
Another route government could follow is to enforce repatriation through an amendment of regulation 28. If this were to happen, all pension funds and their members would be in the same boat and there would be no way to avoid one’s offshore exposure being repatriated.
The letters are in German and for the sake of our German speaking readers they can be downloaded here...
Media snippets
(for stakeholders of the retirement funds industry)
Permanent life partners – can you claim fund death benefits when your partner dies?
“Permanent life partners do qualify as dependants in terms of section 1(b)(ii) of the Act. This of course does not mean you will automatically receive any part of the death benefit - the fact that someone falls within the definition of “dependant” only entitles him/her to be considered by the Board when making the benefit allocation decision. Once the Board has identified all the dependants, the next stage of the enquiry will be to examine the needs of each dependant so that it can make an equitable distribution amongst them. In doing so, it will consider all the relevant facts (to the exclusion of irrelevant facts) and factors such as:
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The age of the parties;
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The relationship with the deceased;
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The extent of dependency;
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The wishes of the deceased placed either in the nomination forms completed during his lifetime and/or his/her last will; and
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The financial affairs of the dependants including their future earning potential.
Once the trustees have established the needs of each identified dependant they will distribute the death benefit according to the level of dependency of each dependant.
An interesting observation of the adjudicator in the case Whitcombe vs Momentum Provident Preservation Fund and another reported in this article is as follows:
“However, a death benefit payable to Ms Pollock [the permanent life partner] was limited to the extent of her provable dependency. Therefore, where the board conducted an investigation and determined her extent of dependency, any gratuitous payment made to her on top of what had been determined to be the extent of her dependency on the deceased, which had the effect of reducing the initial allocations made to the deceased’s children who were mentioned in the will, is unreasonable and an improper exercise of a discretion vested in the board.”
In Namibia of course, children of a deceased have no automatic right to the benefit unless they were dependent or nominated as beneficiary by the deceased.
Read the full article by Liz de la Harpe in Insurancegateway of 30 August 2016, here...
The two options at retirement
In this article Patrick Cairns addresses the option between a living annuity (investment linked annuity) from which a pension can be drawn as long as the account has funds and a guaranteed annuity that will be payable for life.
The reader’s question is relevant to every prospective retiree even though it refers to retirement from SA equivalent of our GIPF, the GEEF. It reads as follows:
“I will retire at the end of October 2016 from government service. I have the option of a retirement gratuity of R1.2 million plus a monthly pension of R 27 414 for life, or a resignation benefit of R5 047 648.
The downsides of taking the annuity option are that when I die the monthly pension that will go to my wife will halve; and that when she dies, the pension stops altogether and nothing will go to our children. I'm also worried by the current political landscape in South Africa whether I can have peace of mind with regard to how the GEPF will be managed in future.
My question is this: If I rather take the resignation benefit of R5 047 648, can I obtain a monthly income comparable to the monthly pension of R27 000 plus the yield on the investment of the R1.2 million gratuity through investing this amount?”
Read the full article by Patrick Cairns in Moneyweb of 1 September 2016, here...
Media snippets
(for investors and business)
An unexpected way to stop people from quitting
“At my company, year after year we score high in our employee satisfaction surveys. Yet, despite these results, we still see a sizeable chunk of annual staff turnover. This has always bothered me. If people love the company, why are they leaving? In part, it’s simply a sign of the times. Millennials change jobs more frequently: an average of once every 2.5 years during the first decade out of college. That’s double the rate of their Gen X predecessors.
But I wanted to better understand the actual reasons why this happens. So over the past year, we spoke to a range of employees in an effort to find out. In doing so, I realized it wasn’t about compensation (or, at least, just about compensation). Nor was it problems with bosses or co-workers. Many people were leaving because they wanted to try something new. They wanted to be challenged with a different role and different set of responsibilities.
We were losing A players, in other words, because they were bored. Personal development is far more than just a buzzword to Millennials. In fact, 65% of Millennials say that personal development is the most important factor on the job, according to a UNC Kenan-Flagler Business School study. And this doesn’t mean just levelling up an existing skill set. It means being able to explore and internalize different skills entirely: to learn something new.”
If you experience this phenomenon in your company and are looking for clues to address it, read the full article by Ryan Holmes in Linkedin of 13 September 2016 here...
Want to be an Authentic Leader? Try this Smartphone Hack
“Earlier this year, I received some tough feedback via our bi-annual workplace survey: My thousand or so employees said I wasn’t accessible enough on a day-to-day basis. As CEO of a social media company—which prides itself on open communication—this was a pretty big concern for me. I wanted to remedy it quickly.
My priorities were pretty straightforward. I needed a way to frequently share breaking company news, solicit and respond to feedback and provide transparency into the business. I needed to do this for every member of my staff, around the world. But my time commitment also needed to be minimal: I couldn’t afford to spend hours prepping updates. Finally, this had to be something I could do from anywhere, since my schedule often requires travel.Fast forward to the present, and I’ve been doing weekly video selfies on Facebook at Work for four months now. Here’s what I’ve learned and some ideas on how this approach could be adapted to companies of any size:
Don’t make it a work of art: Minimal prep and zero production value are key.
So, I just did away with all that. I shoot my videos—selfie-style—on my iPhone. I give myself one take to get them right, no cuts or edits. If I fumble, I generally just regroup and keep going. In the end, I think the low-production value actually adds an element of transparency and authenticity—I’m not hiding behind edits.
Having said that, I’m not just rambling on, stream-of-consciousness style. After some trial and error, I’ve settled on a pretty standard format for each video:
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a brief hello and intro;
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a quick rundown of major company wins across different departments;
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a short section sharing what’s top-of-mind for me this week;
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and then a final segment where I respond to a few user-submitted questions.”
Read this interesting article by Ryan Holmes in Linkedin of 7 August 2016 here...
Emotional Intelligence: How Competent Are You?
“When I talk about emotional intelligence, I’m not referring to a fixed trait. Emotional intelligence is a set of skills that can be developed. In my model of emotional intelligence those skills fall into four domains: self-awareness, self-management, social awareness, and relationship management. Richard Boyatzis and I worked with KF Hay Group to produce a tool for assessing twelve emotional intelligence competencies nested within each of these four domains that make people stars in the workplace. Competence is another way of saying skill. It’s learned and learnable...In our research, we’ve specified emotional intelligence competencies used by outstanding leaders that can be assessed objectively, behaviourally—everyone can see it, you know you’re doing it…
Self-awareness
Emotional Self-Awareness: Leaders who are attuned to their feelings and how they affect their job performance. They use their values to make decisions. Emotionally self-aware leaders are authentic and able to speak openly about their emotions.
Emotional Self-Control: People skilled at managing their emotions. Leaders with this skill remain calm and clear-thinking in stressful situations and hold on to their emotional balance.
Achievement Orientation: Leaders who hold themselves and others to high standards. They work toward challenging and measurable goals. They continually seek ways to improve their performance and that of their team.
Positive Outlook: These leaders see every situation as an opportunity, even those that may look like a setback to others. They see other people positively and expect them to do their best. They expect the changes in the future to be for the better.
Adaptability: Leaders with this skill handle many demands while staying focused on their goals. Uncertainty is both expected and comfortable for these leaders. They flex in response to new challenges and are quick to adjust to sudden changes.
Social Awareness
Empathy: Leaders who can comprehend an individual or group’s unspoken emotions. They listen well and easily grasp other’s perspectives. Empathetic leaders explain their ideas in ways other people understand and work well with people from diverse cultures and backgrounds.
Organizational Awareness: Leaders who understands all aspects of an organization: where formal and informal power is held, relationships that provide opportunities for networking, conflicts, unspoken norms, and guiding values.
Relationship Management
Influence: Leaders who are skilled at appealing to others and developing buy-in from key players in a situation. They are engaging and persuasive with individuals and groups.
Coach and Mentor: Leaders who take interest in assisting others. They know the individuals with whom they work, including their strengths and goals. They give constructive feedback to co-workers and help others focus on growth opportunities.
Conflict Management: These leaders make an effort to recognize different perspectives. They focus on helping everyone find the common ground upon which they can agree. They allow everyone’s opinion and direct efforts toward finding an agreeable resolution.
Inspirational Leadership (Inspiration): A leader who inspires can move people. Their articulation of a shared mission causes others to join them. They show others the purpose behind their day-to-day work.
Teamwork: These leaders build an atmosphere of cooperation, helpfulness, and respect. They help others commit to the group’s effort. They help a team develop an identity, positive relationships, and spirit.”
Read the article by Daniel Goleman in Linkedin of 7 September 2016 here...
And finally...
“The Budget should be balanced, the Treasury should be refilled, public debt should be reduced, the arrogance of officialdom should be tempered and controlled, and the assistance to foreign lands should be curtailed, lest Rome will become bankrupt. People must again learn to work instead of living on public assistance.”
~ Cicero, Roman Emperor, 55 BC
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