We are committed to acting with the highest standards of ethical behaviour and effective governance, in the interests of all stakeholders, which is imperative to our reputation and ensuring a sustainable business. Personal and organisational integrity are embedded in our culture and translate into our values.
A business integrity policy is in place which is reviewed regularly. This is further supported by policies on gifts, conflicts of interest and whistleblowing. Adherence to these policies extends beyond our employees to include our suppliers, who are required to agree to be guided by the policies. We have implemented an awareness programme relating to these policies.
The Social, Ethics and Transformation Committee continues to regularly monitor the group’s ethical compliance including regular feedback from the whistleblower hotline and the internal audit department. Our anonymous whistleblowing facility is available to employees, customers, suppliers and shareholders to report dishonesty, fraud and other inappropriate or unethical behaviour in the workplace in a safe, confidential and secure way. It is operated and managed by Tip-offs Anonymous. The whistleblower facility operates 24/7 through varied channels including a toll-free telephone line, email, FreePost and free fax. Trained telephone operators answer in English, isiZulu, Afrikaans, isiXhosa and seSotho. Reports are “sanitised” and provided to internal audit who prioritises (with the approval of the Chairman) and investigates said reports.
A Fraud Prevention Committee is responsible for strategies to prevent, detect and respond to fraud and corruption and occurrences of corporate crime. The committee further provides a forum for consideration of all ethics-related issues within the group as well as raising group awareness of ethical issues.
Directors are required to declare their personal interests at each Board and sub-committee meeting. In addition, they are required to complete an annual declaration of interest form. They are also required to recuse themselves from any discussion and decision on matters in which they have a personal interest. The Board has delegated the function of evaluating the Directors’ declarations of interest to the Social, Ethics and Transformation Committee. A Directors’ declaration of interest policy has been developed, endorsed by the Social, Ethics and Transformation Committee and finally approved by the Board. This matter is a standing agenda item for the committee.
There were no ethics-related penalties, fines or criminal prosecutions during the year.