Integrated Report

Ethics statement

Aspen has a zero tolerance approach to unethical behaviour and is committed to ensuring that the Group and its employees uphold Aspen’s laudable reputation. The Group Code of Conduct governs the conduct of all Aspen’s employees throughout the Group. Furthermore, Aspen’s service providers and suppliers are required to adhere to the Group’s Code of Conduct in accordance with relevant clauses included in the legal agreement templates.

The areas covered by the Group Code of Conduct include:
  • acting in accordance with Aspen’s values;
  • equitable treatment for all;
  • acting as ambassadors of Aspen;
  • business integrity;
  • gifts, entertainment and bribery;
  • integrity of qualitative and quantitative information;
  • protection and use of property;
  • business controls;
  • confidential information;
  • insider trading;
  • safety, health, quality and the environment;
  • competition law;
  • political activities;
  • compliance;
  • accountability; and
  • corporate governance.

An independently monitored whistle-blowing hotline, Deloitte’s Tip-Offs Anonymous®, has been rolled out to employees across the Group’s businesses, whereby employees can report suspected fraud and/or activities which are considered to be transgressions to the Group’s Code of Conduct. Tip-offs training and awareness sessions are conducted periodically to promote utilisation of the facility where necessary. The Tip-offs service has also been extended to key customers and suppliers in the South African business. Roll-out of the service to selected suppliers and customers at Aspen’s International businesses is at various stages of progress in accordance with an implementation plan.

  Tip-offs statistics   2011   2010  
  Number of tip-off logs received by Deloitte   27   65  
  Number of clutter calls   21   57  
  Number of valid tip-off logs   6   1  
  Number of tip-off logs investigated   6   1  

All logged calls were received from the South African region and were reported to relevant managers timeously. Corrective action has been implemented in all instances to improve controls, to prevent recurrence of the incident and, in one instance, resulted in the termination of the employee’s contract.

Fraud prevention

Management is required to complete a fraud checklist twice a year and to sign a declaration on an annual basis stating that all management information is completed truthfully and accurately and that no incidents of fraudulent activity were identified by management for the reported period. This promotes fraud awareness and the review of fraud prevention controls among management teams across the businesses. Aspen has developed a formalised fraud prevention strategy which is planned for formal implementation during 2012.