Santiago Principles Self-Assessment®
GIC 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.
GIC’s legal framework is detailed in the Singapore Companies Act, under which GIC was incorporated in 1981. GIC is wholly owned by the Government of Singapore..
The Singapore Companies Act is available at
https://sso.agc.gov.sg/Act/CoA1967
GIC’s legal relationship with the Government of Singapore is disclosed on our website and in our Annual Reports.
GIC is a fund manager for the Government of Singapore. We do not own the assets that we manage. As a rule, GIC invests outside Singapore.
The Government, represented by the Ministry of Finance (MOF), mandates GIC to manage all assets in a single pool, on an unencumbered basis and without regard to their source, with the objective of achieving good long-term real returns. The Government gives GIC an investment mandate that stipulates the terms of appointment, investment objectives, risk parameters, investment horizon, and guidelines for managing the portfolio.
https://www.gic.com.sg/who-we-are/our-governance/
Principle 2
2. The policy purpose of the SWF should be clearly defined and publicly disclosed.
GIC is one of the three investment entities in Singapore that manage the Government’s reserves.
GIC’s purpose is clearly defined; we aim to achieve good long-term returns for the Government - a reasonable risk-adjusted rate above global inflation over a 20-year investment horizon. By achieving these returns, we meet our objective to preserve and enhance the international purchasing power of Singapore's foreign reserves. The reserves provide a stream of income that can be spent or invested for the benefit of present and future generations.
GIC’s policy purpose is publicly available at:
https://www.gic.com.sg/who-we-are/
https://www.mof.gov.sg/policies/reserves/who-manages-the-reserves
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.
As a rule, GIC invests outside Singapore, in line with our mission to preserve and enhance the international purchasing power of these reserves.
By investing globally (outside Singapore), GIC diversifies its portfolio to mitigate risks and reduce the impact of adverse economic conditions in any single country (especially in Singapore) on the portfolio. The diversified portfolio of global investments helps to stabilise Singapore’s financial reserves against domestic economic volatility.
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.
GIC’s source of funds is disclosed on our website and in our Annual Report. The sources of the Government’s assets, as stated by the MOF, include proceeds from the issuance of Government debt, Government surpluses and proceeds from the Government’s land sales.
https://report.gic.com.sg/governance.html
The Constitution of the Republic of Singapore stipulates a spending rule that determines how much of the investment returns on its reserves the Government can spend. The spending rule allows up to 50% of the long-term expected real return on the net assets invested by Singapore’s reserve management entities (GIC is one of them) to be taken into the Government’s annual budget.
\https://www.mof.gov.sg/policies/reserves/what-are-the-reserves-used-for
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.
GIC provides monthly and quarterly reports to the Accountant-General Department within the Ministry of Finance. These reports contain the financial statements, holdings, and bank account balances of GIC. The reports also provide detailed performance and risk analytics, as well as the distribution of the portfolio by asset class, country, and currency.
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.
The Investment Mandate from the Government of Singapore to GIC sets out the terms of appointment, investment objectives, investment horizon, risk parameters and investment guidelines for managing the portfolio. The Government, which is represented by the Ministry of Finance in its dealings with GIC, neither directs nor influence GIC's decisions on individual investments. It holds the GIC Board accountable for the overall portfolio performance.
The Board is ultimately responsible for the long-term asset allocation strategy and for the overall performance of the portfolio. It is accountable to the Government for the effective management of the portfolio in accordance with the Investment Mandate.
Board committees oversee critical areas: on investment policy and processes, risk, audit, and human resources. External advisers with global experience serve on the investment and risk committees to provide external perspectives and ideas from their areas of expertise.
The Auditor-General, who is appointed by the President of Singapore, submits an annual report to the President and Parliament on the audit of the Government and other bodies managing public funds. This audit includes the Government’s portfolio managed by GIC and the main companies in the GIC Group.
https://www.gic.com.sg/who-we-are/our-governance/
https://report.gic.com.sg/governance.html
https://www.istana.gov.sg/The-President/Presidents-Duties/Constitutional
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.
GIC’s objectives are set out by the Government and are detailed in GAPP 2 above. Representing the Government (who is also the fund owner), the Ministry of Finance ensures that a competent Board is in place. No one may be appointed to, or removed from, the GIC Board without the concurrence of the President of Singapore who is independent of the Government and must not be a member of any political party. This provides an additional layer of oversight.
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.
The Board is accountable to the Government for the effective management of the portfolio in accordance with the Investment Mandate.
GIC is a private limited company wholly owned by the Government. The Ministry of Finance, representing the Government, ensures that a competent Board of Directors is in place; GIC helps by suggesting qualified candidates.
As a Fifth Schedule Company, as defined in the Constitution of the Republic of Singapore, the appointment, removal or renewal of members of the GIC Board requires the approval of the President of Singapore. This ensures that GIC appoints only people of integrity who are competent and can be trusted to safeguard these assets.
In addition, external advisers with global experience also serve on the Board’s investment strategies committee and risk committee to provide external perspectives and ideas from their areas of expertise.
https://www.gic.com.sg/who-we-are/our-governance/
https://report.gic.com.sg/governance.html
https://www.gic.com.sg/who-we-are/international-advisory-board/
https://www.mof.gov.sg/policies/reserves/how-are-past-reserves-protected
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.
The Government, which is represented by the Ministry of Finance in its dealings with GIC, neither directs nor influences GIC’s investment decisions. It holds the GIC Board accountable for the overall portfolio performance. The management formulates and executes investment strategies, is responsible for all investment transactions, and reports regularly to the Board and the Government.
https://www.gic.com.sg/who-we-are/our-governance/
https://report.gic.com.sg/governance.html
Terms of Reference
GIC Board
- Responsible for GIC’s long-term asset allocation strategy, and for the overall performance of the GIC Portfolio.
- Does not approve individual investments which are the responsibilities of the GIC Management.
International Advisory Board
- Provides views on market developments generally and, in particular, on the medium- to long-term outlook for investment opportunities around the world.
Board Committees
Investment Strategies Committee
- Assists the GIC Board in evaluating the GIC Management’s recommendations on asset allocation and in its oversight of overall portfolio performance.
- Recommends the key drivers for GIC’s return and risk outcomes.
- Does not approve individual investments.
Investment Board
- Assists the GIC Board in its oversight of GIC’s investment process, with particular attention to large individual investments.
Risk Committee
- Oversees the effectiveness of risk management policies and practices of the GIC Group.
Audit Committee
- Looks into the effectiveness of the internal control systems for safeguarding company assets and the Client’s investment portfolio.
- Reviews the integrity of the financial reporting process, significant ethics violations, compliance with regulatory and legal requirements, and issues of fraud and financial loss.
- Human Resource & Organization Committee
- Oversees organisational matters in GIC, including compensation policies, talent development, succession planning, and organisational development.
GIC Management
- Formulates and executes investment strategies.
- Constructs the Active Portfolio, with an overlay of active, skill-based strategies.
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.
GIC’s accountability framework is defined in our Investment Mandate, the Constitution of the Republic of Singapore, and the Singapore Companies Act.
The Investment Mandate from the Government to GIC sets out the terms of appointment, investment objectives, investment horizon, risk parameters and investment guidelines for managing the portfolio.
As a Fifth Schedule company (a category that comprises key statutory boards and Government companies that are listed in the Fifth Schedule under the Constitution of the Republic of Singapore), GIC is accountable in various key areas to the President of Singapore. The President is empowered to access any information needed to safeguard the country’s reserves.
GIC was incorporated in 1981 under the Singapore Companies Act. The Companies Act and GIC's Memorandum and Articles of Association state how the Board of GIC is to be set up, and other matters pertaining to the governance of GIC and the Board members. The Memorandum and Articles of Association are legal documents which all companies incorporated under the Companies Act must have.
https://www.gic.com.sg/who-we-are/our-governance/
https://report.gic.com.sg/governance.html
https://sso.agc.gov.sg/Act/CONS1963
https://sso.agc.gov.sg/Act/CoA1967
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.
GIC provides monthly and quarterly reports to the Accountant-General within the Ministry of Finance. These reports contain the financial statements, holdings, and bank account balances of GIC. The reports also provide detailed performance and risk analytics, as well as the distribution of the portfolio by asset class, country, and currency. Once a year, the management meets the Minister for Finance and his officials formally to report on the risk and performance of the portfolio in the preceding financial year.
Since 2008, GIC has been publishing an annual report on the management of the Government’s portfolio, typically in the third quarter of calendar year.
https://report.gic.com.sg/governance.html
https://www.gic.com.sg/newsroom/reports/
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.
The main companies in the GIC group and the Government’s portfolio managed by GIC are independently audited by the Auditor-General, in addition to being audited by GIC’s internal audit department. Public accounting firms audit other companies in the group and the investment holding companies.
The Auditor-General submits an annual report to the President and Parliament on his audit of the Government and other bodies managing public funds.
The President, rather than the Government, appoints the Auditor-General to safeguard his independence, as the Government’s accounts are subject to his audit. There are also provisions in the Constitution of the Republic of Singapore to ensure that his remuneration cannot be reduced and to protect him from being removed except based on adjudication by an independent panel. This is to ensure that he can audit without fear or favour.
https://report.gic.com.sg/governance.html
https://sso.agc.gov.sg/Act/CONS1963?ProvIds=pr148F-&ViewType=Advance&Phrase=procedure&WiAl=1
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.
We require our staff to observe GIC’s code of ethics, maintain exemplary conduct, and comply with laws and regulations, including prohibitions against insider trading and other unlawful market conduct. These are among the guidelines set out in our compliance manual maintained by the legal and compliance department. Staff must protect confidential information and handle material non-public information with due care. The manual also states policies relating to the management of conflicts of interest, gifts and entertainment, copyright rules, personal investments and whistle-blowing.
Regular and targeted in-person and online training is conducted, and an annual Compliance and Risk Refresher Training and Quiz is administered to reinforce awareness and understanding of key compliance and corporate policies and strengthen GIC’s risk and compliance culture.
https://report.gic.com.sg/managing-the-portfolio.html#managing-risks
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.
External managers are chosen for their ability to access investment opportunities beyond GIC’s current skill sets and to complement our internal management capability.
Requests for proposals and assessment of the proposals are done in a fair manner and follow internal operating policies and procedures.
https://report.gic.com.sg/managing-the-portfolio.html#investment-process
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.
GIC’s compliance programme comprises robust policies, procedures, effective controls, monitoring, surveillance, and the enforcement of disciplinary actions against violations or misconduct. The implementation of a rigorous compliance programme is underpinned by a strong culture of ethics, risk management, and compliance.
The investment and operations teams collaborate with the legal and compliance function to manage legal, regulatory, compliance, and reputational risks arising from the group’s investment and operational activities. The legal and compliance function monitors compliance with applicable laws and regulations, including but not limited to laws on securities trading and investment, competition law requirements, financial crimes and sanctions compliance, licensing, and regulatory approvals and reporting. Emerging legal and regulatory issues and proposed regulatory changes are also closely monitored. Additionally, the in-house legal team works with external lawyers to address legal risks.
https://report.gic.com.sg/managing-the-portfolio.html#managing-risks
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.
The GIC annual report and GIC’s website disclose the governance framework of GIC and the investment objectives of the fund and how GIC is operationally independent of the owner.
Please refer to the overview of the governance framework outlined in Principle 9.
https://www.gic.com.sg/who-we-are/our-governance/
https://report.gic.com.sg/governance.html
https://www.gic.com.sg/who-we-are/
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.
The GIC annual report is published via the website, to give the international community a better appreciation of the context and circumstances in which GIC operates, and to assure that GIC invests only to achieve financial returns sustainably.
GIC discloses relevant information to demonstrate its economic and financial orientation. The GIC annual report describes GIC’s investment objectives, legal and corporate governance framework, investment approach, as well as risk management framework.
GIC has taken further steps in the direction of increased transparency over the years. Beginning in 2011, GIC publishes the nominal returns and annualised volatility of these returns over 5-year, 10-year and 20- year horizons, in addition to the 20-year real return disclosed since 2008.
https://report.gic.com.sg/investment-report.html
https://www.gic.com.sg/newsroom/reports/
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.
GIC’s investment policy and activities are anchored by our long-term asset allocation. It defines the asset classes that GIC invests in, and how it allocates funds to these asset classes. The purpose is to meet the investment return objective within the risk tolerance determined by the Government as the owner of the funds.
Investment decisions comply with prescribed guidelines and limits to ensure that they keep within the Investment Mandate from the Government. At all levels of investment decision making, the risks taken by our portfolio managers and their investment results are constantly monitored. Such risks include portfolio volatility, leverage, amongst other risk metrics. Clear mandates are provided to internal and external managers, stating the range of their activities and authority. In addition, the independent risk and performance management department regularly monitor the portfolio’s performance, risk and asset exposures against the approved thresholds and limits.
The allocation between internal and external managers is based on the principle of best sourcing. These managers are selected for their ability to access investment opportunities beyond GIC’s current skill set and to complement GIC’s internal management capability.
https://report.gic.com.sg/managing-the-portfolio.html#managing-risks
https://www.gic.com.sg/our-policy-portfolio/
https://www.gic.com.sg/how-we-build-our-portfolio/
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.
We do not invest other than for economic and financial considerations.
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.
GIC does not have, nor does it seek, access to privileged information or inappropriate influence through the Government. The Government neither directs nor influences in GIC’s investment decisions. GIC’s compliance manual for staff further provides a framework to prevent access to and use of privileged information.
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.
Consistent with our portfolio management approach, GIC will exercise ownership rights in our investments, where appropriate, to protect the financial interests of the assets under our management. Financial considerations guide our general approach to the exercise of our ownership rights.
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.
Identifying and managing risk is a clear and integral part of management responsibility at all levels in GIC. The risk management framework sets the accountability and responsibility for risk-taking. In addition to the Board and its risk committee, different bodies and groups are specifically charged with the task of identifying, analysing, monitoring, reporting and on-the-ground managing of risks.
Our approach to risk management is multi-dimensional and guided by a strong culture of ethics and accountability. Starting with portfolio investment risk, we identify, evaluate, monitor and report such risks through a mix of quantitative measures, stress testing, and scenario analyses. Reputational risk management is integral to maintaining GIC’s trust and competitive advantage, and legal, regulatory, and compliance risks are mitigated through robust governance, policies, training, and monitoring programmes. Counterparty credit risk is managed through stringent selection processes, exposure limits, and collateral arrangements. Operational risks are addressed via cross-functional reviews, control assessments, and timely reporting of key events. Cybersecurity, technology, and information risks are managed through a “defence in depth” approach, incorporating multiple protective layers, employee training, and proactive threat mitigation. Business disruption risks are handled through coordinated continuity and crisis management programmes, while people risk is mitigated by aligning conduct with GIC’s PRIME values, prudent remuneration, and strong talent development practices—all ensuring that GIC upholds a prudent, ethical, and resilient approach to risk management.
https://report.gic.com.sg/managing-the-portfolio.html#managing-risks
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.
GIC’s mandate is to preserve and enhance the international purchasing power of the reserves under our management over the long term. The primary metric used for evaluating GIC’s investment performance is the rolling 20-year real rate of return.
GIC provides monthly and quarterly reports to the Government through the Accountant-General of Singapore. These reports contain the financial statements, holdings and bank account balances of GIC. They also provide detailed performance and risk analytics, as well as the distribution of the portfolio by asset class, country, and currency.
Once a year, the GIC Management formally meets the Minister for Finance and his officials to report on the risk and performance of the portfolio in the preceding financial year.
https://report.gic.com.sg/governance.html
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.
GIC self-assesses and reviews our implementation of the GAPP annually. We have published our assessment in this report.