Santiago Principles Self-Assessment®
FSDEA 2025
Pillar 1: Legal
Principle 1
1. The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s).
1.1. The legal framework for the SWF should ensure legal soundness of the SWF and its transactions.
1.2. The key features of the SWF’s legal basis and structure, as well as the legal relationship between the SWF and other state bodies, should be publicly disclosed.
Legal framework
Presidential Decree No. 48/11(3rd September 2011), created the Sovereign Wealth Fund of Angola (previously called Oil Fund). As per Article 2 of such Decree, FSDEA “is a legal person, endowed with legal personality, with administrative, financial and asset autonomy.”
Presidential Decree No. 212/19 of 15th of July (Organic Statutes) and Presidential Decree No. 218/24 of 21 of October( Changes to the Organic Statutes)
Article 2 affirms that FSDEA “The Sovereign Fund of Angola is a legal entity with legal personality, under the form of Public Fund, with administrative, financial and patrimonial autonomy.” Article 4 affirms that FSDEA must follow all applicable laws for Public Institutes, as well as other relevant laws.
Governance
The Presidential Decree No. 212/19, of 15th July establishes the structure and governance of FSDEA (including the Board of Directors, investment committee and other bodies). It also outlines the rules of engagement and the scope of the supervisory role by the Ministry of Finance, among other aspects. In 2024, the changes to the Organic Statutes added a new Body (Advisory Council) which is composed of internal and external members acting as advisors to the BoD.
Presidential Decree No. 214/19 lays out the rules and principles that must be observed in the management of the assets under FSDEA control.
Relationship with other public bodies
Presidential Decree No. 212/19, FSDEA is under the direct supervision of the Ministry of Finance. It submits periodic reports to the Ministry and its annual budget is approved by the Ministry of Finance. However, investment decisions are approved independently by the Board of Directors, without any interference, in accordance with what is established in article 4 of the investment policy approved by Investment Policy, Presidential Decree No. 216/24 of October 21st.
Principle 2
2. The policy purpose of the SWF should be clearly defined and publicly disclosed.
FSDEA´s purpose is set out in its Investment Policy which assigns the following mandates:
- Savings and wealth transfer to future generations;
- Maximization of results;
Besides these objectives, FSDEA can also be given other specific mandates, such as fiscal stabilization or implementing national flagship projects, based on assets specifically endowed for these purposes.
Principle 3
3. Where the SWF’s activities have significant direct domestic macroeconomic implications, those activities should be closely coordinated with the domestic fiscal and monetary authorities, so as to ensure consistency with the overall macroeconomic policies.
The Organic Statues of FSDEA set on article 7 that, among other mechanisms, the Ministry of Finance expresses its supervision power over FSDEA by defining the guidelines to ensure that Fund’s activities are aligned with macroeconomic policies set by the Government.
Principle 4
4. There should be clear and publicly disclosed policies, rules, procedures, or arrangements in relation to the SWF’s general approach to funding, withdrawal, and spending operations.
4.1. The source of SWF funding should be publicly disclosed.
4.2. The general approach to withdrawals from the SWF and spending on behalf of the government should be publicly disclosed.
General approach to funding
Presidential Decrees No. 213/19 and 214/19 lay out the governance and regulations of the Fund
Initial funding (Presidential Decree n.º 107/13, Article 2) - Revoked
“1. After the initial endowment with a value of (five) US$5 billion, the excess of the Strategic Oil Reserve for Basic Infrastructure relating to the General State Budget (OGE) of the past year shall be attributed to the Sovereign Fund of Angola.”
Source of ongoing funding (PD - 216/24, Article 2) - “The Sovereign Wealth Fund is endowed with additional capital in accordance with the rules defined in the Law approving the General State Budget for each financial year.”
General approach to withdrawals [Management Regulations Article 5 (appended to 214/19))
“5. The Minister of Finance may, exceptionally, upon a formal mandate from the President of the Republic, request a withdrawal of resources from the Fund which shall be exclusively intended to meet the emergency needs of the country during a natural disaster, and shall be a last resort to protect the country during a severe economic crisis, however, the withdrawals cannot cumulatively exceed 40% of the Fund's net assets.
FSDEA complies with provisions of the
Presidential Decree No. 214/14 Article 7 which states:
1. The Board of Directors shall compile and submit a quarterly report to the Minister of Finance, which, after an opinion within 15 days, shall be forwarded to the President of the Republic.
2. The report is prepared in accordance with national accountability legislation and in line with best practices of sovereign wealth accountability models and should include the overall performance and return of the Fund, a summary of the state of internal organization and investments by asset class, with specific notes for any investment representing 5% or more of the total portfolio assets.
3. The Fund undertakes to ensure the inclusion and implementation of the Santiago Principles on reporting and dissemination of information
4. The Fund should be integrated into the State General Account and be managed prudently, responsibly and transparently under the legal framework to which it is subject.
Principle 5
5. The relevant statistical data pertaining to the SWF should be reported on a timely basis to the owner, or as otherwise required, for inclusion where appropriate in macroeconomic data sets.
FSDEA complies with provisions of the
Presidential Decree No. 214/14 Article 7 which states:
1. The Board of Directors shall compile and submit a quarterly report to the Minister of Finance, which, after an opinion within 15 days, shall be forwarded to the President of the Republic.
2. The report is prepared in accordance with national accountability legislation and in line with best practices of sovereign wealth accountability models and should include the overall performance and return of the Fund, a summary of the state of internal organization and investments by asset class, with specific notes for any investment representing 5% or more of the total portfolio assets.
3. The Fund undertakes to ensure the inclusion and implementation of the Santiago Principles on reporting and dissemination of information
4. The Fund should be integrated into the State General Account and be managed prudently, responsibly and transparently under the legal framework to which it is subject.
Pillar 2: Institutional
Principle 6
6. The governance framework for the SWF should be sound and establish a clear and effective division of roles and responsibilities in order to facilitate accountability and operational independence in the management of the SWF to pursue its objectives.
In addition to the governance measures mentioned in relation to the Organic Statute, the following describes the organizational structure of FSDEA:
The Sovereign Wealth Fund of Angola has the following structure:
Governing Bodies:
- Board of Directors;
- Fiscal Council (named by Ministry of Finance);
- Advisory Council (external members named by Ministry of Finance, Economy and the Central Bank).
- The others governing bodies are as per organic structure above.
objectives
Presidential Decree No. 216/24 of 21st of October , the Investment Policy of the Fund. Article 2 establishes FSDEA’s mandates which comprises:
Saving and wealth transfer, Maximization of returns and Fiscal Stabilization or National Flagship Project for resources specifically allocated for these purposes.
Appointing the governing body
As Per number 3 of Article 10 of the Organic Statute, “The Board of Directors shall be appointed by the President of the Republic for a term of five (5) years, renewable once.”
The Fiscal Council is appointed by the Minister of Finance, to whom they submit semi-annual reports on the management of the Fund.
The external auditors shall be appointed annually by the President of the Republic.
The external auditors shall be obliged to submit Auditor reports to the Minister of Finance and to the Board of Directors.
Principle 7
7. The owner should set the objectives of the SWF, appoint the members of its governing body(ies) in accordance with clearly defined procedures, and exercise oversight over the SWF’s operations.
Duties of the Board
Article 10 of the Organic Statute lays out the extensive duties of the Board of Directors. The current BoD is composed by members with extensive managerial experience in public, multilateral and private sector.
Authority of the Board
Per Article 10 of that document, the Board of Directors is “responsible for all actions required for managing the Fund and carrying out its duties”.
Furthermore, the Article 2 of the Organic Statute states that FSDEA has administrative, financial and asset autonomy which gives adequate authority to the BoD to carry out its functions.
As for acting in best interest of FSDEA, the BoD as well as other governing bodies must adhere to Public Probity Law which sets the standard of conduct expected from them which includes loyalty and no conflict of interest provisions.
Principle 8
8. The governing body(ies) should act in the best interests of the SWF, and have a clear mandate and adequate authority and competency to carry out its functions.
Duties of the Board
Article 10 of the Organic Statute lays out the extensive duties of the Board of Directors. The current BoD is composed by members with extensive managerial experience in public, multilateral and private sector.
Authority of the Board
Per Article 10 of that document, the Board of Directors is “responsible for all actions required for managing the Fund and carrying out its duties”.
Furthermore, the Article 2 of the Organic Statute states that FSDEA has administrative, financial and asset autonomy which gives adequate authority to the BoD to carry out its functions.
As for acting in best interest of FSDEA, the BoD as well as other governing bodies must adhere to Public Probity Law which sets the standard of conduct expected from them which includes loyalty and no conflict of interest provisions.
Principle 9
9. The operational management of the SWF should implement the SWF’s strategies in an independent manner and in accordance with clearly defined responsibilities.
Article 4 of the Regulations (Presidential Decree No. 214/19) establishes that the Board of Directors is responsible for managing the Fund and implementing the Investment Policy. In line with Chapter III of the Organic Statute, the Board approves the organigram, which clearly defines reporting lines, delegates authority, and segregates responsibilities across divisions.
For internally managed portfolios, investment activities are carried out within the respective divisions according to their mandates. For externally managed portfolios, the Board ensures oversight through supervision and monitoring of external asset managers. This structure ensures that the Fund’s strategies are executed independently, with operational management acting in accordance with clearly defined roles and responsibilities.
Principle 10
10. The accountability framework for the SWF’s operations should be clearly defined in the relevant legislation, charter, other constitutive documents, or management agreement.
The accountability framework for FSDEA is clearly set out in its Organic Statutes, Investment Policy, Management Regulations, and other applicable legislation governing public entities. These instruments define the principles and rules that FSDEA must adhere to in its operations.
The Board of Directors and other governing bodies have roles and responsibilities expressly enshrined in these documents, ensuring clarity in decision-making and management oversight.
FSDEA is subject to independent external audit, and its financial statements are made publicly available, reinforcing transparency. In addition, the Fiscal Council—appointed by the Ministry of Finance and operating independently from FSDEA—monitors the Fund’s activities to ensure compliance with its directives and applicable law.
The Organic Statutes also establish the supervisory role of the Ministry of Finance, including FSDEA’s obligations to submit reports, obtain certain approvals, and comply with oversight requirements.
Furthermore, in accordance with national legislation, FSDEA is subject to inspection and audit by the Tribunal de Contas (Court of Auditors), which provides an additional layer of accountability to safeguard public resources.
Principle 11
11. An annual report and accompanying financial statements on the SWF’s operations and performance should be prepared in a timely fashion and in accordance with recognized international or national accounting standards in a consistent manner.
FSDEA governing documents establish requirements for regular annual audits and sets the IFRS as the accounting standard adopted.
The annual report and the financial statements as soon as the audit is completed are published in the widely circulated newspapers and made available on the FSDEA website. The annual report will, in nutshell, include information regarding investment performance, risk profile, macroeconomic, and financial statements.
Principle 12
12. The SWF’s operations and financial statements should be audited annually in accordance with recognized international or national auditing standards in a consistent manner.
FSDEA is regularly audited by highly reputed firms in the (big four), currently EY, in line with International Financial Reporting Standards (IFRS).
Principle 13
13. Professional and ethical standards should be clearly defined and made known to the members of the SWF’s governing body(ies), management, and staff.
All internal policies are accessible by all employees on the FSDEA the intranet.
The Fund has a Code of Conduct with four stated objectives:
Guarantee compliance with the provisions of the law on the respect of professional duties incumbent upon FSDEA, its employees and third parties
Ensure compliance with legislation and policies on the prevention of corruption and on anti-money laundering and terrorist financing;
Ensure that, in addition to complying with the rules and duties arising from the applicable legal and regulatory provisions, the activities of FSDEA shall be performed in accordance with strict ethical and deontological principles;
Contribute to the promotion an institutional image of rigour, efficiency and competence.
In addition to the compliance rules and policies to which all employees of the Fund are subject, under the terms of current legislation, members of the board of directors are required to present the declaration of assets at the commencement of their duties to the Public Prosecutor's Office.
Principle 14
14. Dealing with third parties for the purpose of the SWF’s operational management should be based on economic and financial grounds, and follow clear rules and procedures.
FSDEA mandates that its partners and asset managers prioritise return maximization, savings and wealth transfer are grounded on economic and financial rationale. The selection of Investments are made on a risk/return basis. As set out in the Public Procurement Law and internal policy, only those goods and services that are more economically advantageous to FSDEA are chosen. External managers are chosen based on a competitive process, custodian and other service providers are selected on the economic merit of their proposals. To prevent conflicts of interest or deviations to these operational principles/rules, there is the Code of Conduct and other relevant laws(i.e. Public Probity Law, etc)
Principle 15
15. SWF operations and activities in host countries should be conducted in compliance with all applicable regulatory and disclosure requirements of the countries in which they operate.
The Management Regulations (Approved by Presidential Decree 214/19) sets out in article 4 that FSDEA actions must be in compliance with all applicable laws and regulations of the jurisdictions FSDEA is operating on.
Principle 16
16. The governance framework and objectives, as well as the manner in which the SWF’s management is operationally independent from the owner, should be publicly disclosed.
Article 4 of the Regulations (Presidential Decree 214/19) publicly available on the Fund's website, charges the Board of Directors “with executing and implementing the Investment Policy.” The Board of Directors has full discretion with regard to investment decisions and managerial decisions as long as they are within the boundary defined by the applicable regulations (i.e. Investment Policy, etc). So, in choosing the options to implement its mandate FSDEA does so independently.
Principle 17
17. Relevant financial information regarding the SWF should be publicly disclosed to demonstrate its economic and financial orientation, so as to contribute to stability in international financial markets and enhance trust in recipient countries.
Besides publishing its financial statements and annual reports, FSDEA is also transparent about new investments it makes both in Angola and overseas. FSDEA recent actions can be consulted on the website.
Pillar 3: Investment
Investment and Risk Management Framework.
Principle 18
18. The SWF’s investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles.
18.1. The investment policy should guide the SWF’s financial risk exposures and the possible use of leverage.
18.2. The investment policy should address the extent to which internal and/or external investment managers are used, the range of their activities and authority, and the process by which they are selected and their performance monitored.
18.3. A description of the investment policy of the SWF should be publicly disclosed.
FSDEA’s has an Investment Policy (Presidential Decree 216/24 of 21of October) that addresses all the aspects on principle 18. The investment policy is a public document that is published in the Official Gazette and available on FSDEA´s website.
Principle 19
19. The SWF’s investment decisions should aim to maximize risk-adjusted financial returns in a manner consistent with its investment policy, and based on economic and financial grounds.
19.1. If investment decisions are subject to other than economic and financial considerations, these should be clearly set out in the investment policy and be publicly disclosed.
19.2. The management of an SWF’s assets should be consistent with what is generally accepted as sound asset management principles.
FSDEA investment policy sets that investment decisions are made on the risk/return basis given the mandates of return maximization and savings.
FSDEA hires well reputed External Managers appointed on competitive basis, has a diversified portfolio and adheres to international best practices in management of assets
Principle 20
20. The SWF should not seek or take advantage of privileged information or inappropriate influence by the broader government in competing with private entities.
FSDEA does not take advantage of privileged information when competing with private entities. When engaging with private entities, it does so in good faith and according to the law.
Principle 21
21. SWFs view shareholder ownership rights as a fundamental element of their equity investments’ value. If an SWF chooses to exercise its ownership rights, it should do so in a manner that is consistent with its investment policy and protects the financial value of its investments. The SWF should publicly disclose its general approach to voting securities of listed entities, including the key factors guiding its exercise of ownership rights.
Per Article 6 of Presidential Decree 214/19, “[t]he Fund intends to exercise of Rights in Subsidiaries. The representative / legal representative of the Fund shall, whenever the Fund holds a qualifying holding in an entity, attend meetings of that entity in order to safeguard the rights and interests of the Fund.” Underlying voting decisions is the return maximization objective which restricts FSDEA to only take voting action that protect and maximize value of its investments.
Principle 22
22. The SWF should have a framework that identifies, assesses, and manages the risks of its operations.
22.1. The risk management framework should include reliable information and timely reporting systems, which should enable the adequate monitoring and management of relevant risks within acceptable parameters and levels, control and incentive mechanisms, codes of conduct, business continuity planning, and an independent audit function.
22.2. The general approach to the SWF’s risk management framework should be publicly disclosed.
FSDEA has a risk management framework that feeds on the portfolio information on custodian platform which are readily accessible. The exposures to different portfolios are monitored against limits and reported periodically to the relevant Committees and BoD. External and internal managers are provided with guidelines and the risk management framework monitors adherence to them and also. FSDEA has internal audit function that independently checks on the control systems and environment.
Principle 23
23. The assets and investment performance (absolute and relative to benchmarks, if any) of the SWF should be measured and reported to the owner according to clearly defined principles or standards.
FSDEA investments, especially the listed ones, are made with reference to benchmarks. So, the performance is measured and reported also on relative basis. The alternative investments(assets) are subject to annual valuation by independent entity which also considered in external audit process.
Principle 24
24. A process of regular review of the implementation of the GAPP should be engaged in by or on behalf of the SWF.
As per Article 7 of Presidential Decree 214/19:
“3. The Fund undertakes to ensure the inclusion and implementation of the Santiago Principles on reporting and dissemination of information.”