The Company has developed a Code of Conduct for Directors and a separate Professional Code of Conduct and Ethics Policy for employees which sets out the guiding principles for ethical business conduct. These codes assist in identifying and avoiding areas which may lead to legal, regulatory or reputational risks for the Directors and employees personally and for the Company.
Directors must set the ethical tone within the Company and must encourage all management and employees to act ethically and in accordance with applicable laws and regulations and the policies of the Company. The Code of Conduct for Employees applies to all permanent and temporary employees of the Company.
The Company values the principles of transparency, accountability, respect, honesty and integrity in all aspects of its business operations and is committed to follow best practice in all employment related matters. The purpose of the Code of Conduct for Employees is to :
The Company is committed to promote shareholder’s confidence by implementing internal controls which ensure that dealings in the Company’s securities take place in an ethical, transparent and informed manner. In this regard, the Company has put in place a Share Dealing Policy regarding the dealings in its securities by Directors, Executive Management, employees and third parties.
The purpose of the policy shall be to provide guidance on dealing with the Company’s securities and the prohibitions thereto, however it is not designed to be an exhaustive guide to applicable laws on trading of the Company’s securities or trading in general.
The policy mainly outlines the following areas:
The Company has established a Whistleblowing Policy which establishes and defines procedures that allow employees of the Company to disclose their concerns. Any form of retaliation against an employee who reports a real or perceived problem or concern with honest intentions is strictly prohibited, and any employee who commits or condones any form or retaliation shall be subject to the Company’s disciplinary procedures.
All employees of the Company, in keeping with the values and business principles of the Company, are encouraged to act in good faith and report suspected and actual wrongdoing.
The Company shall be committed to investigate reports of wrongdoing in a fair, independent, and professional manner, consistent with all local laws and requirements, and in a way that will gather the facts necessary to allow for a credible assessment of the allegations or suspected violations under investigation.
The Company has developed a policy for the nomination and election of directors, which applies to all candidates, and covers the following areas with respect to Directors nomination:
The Corporate Social Responsibility (CSR) Policy demonstrates the Company’s commitment towards providing a working environment that is safe and fit for its intended purpose and ensures that health and safety issues are the priority for all business operations.
The Company is guided by its aim to become an employer of choice and it shall ensures that its business is conducted in all respects according to rigorous ethical, professional and legal standards.
The Company regards suppliers as its partners and works with them to help it achieve its aspirations in the delivery of its products and services.
The Company strives to be a good corporate citizen, recognizing its responsibility to work in partnership with the community in which it operates and follows the environment laws, rules and regulations, wherever applicable to its operations and activities.
The Company strives to provide employment and economic opportunities for the local community. The Company also engages with the local community service providers such as charitable organisations in order to identify how the Company can provide assistance.
The Anti-Fraud Policy defines the approach and sets-up a framework to prevent, detect, report, investigate and respond to any instances of fraud. This Policy is applicable to the Company and all of its subsidiaries.
The process required to be followed in detecting and reporting suspected cases of fraud has been defined as well as investigating and responding to such cases.
The scope of this policy applies to any instances of fraud or suspected instances of fraud, involving not only employees, but also vendors, directors, outside agencies, and other persons/parties having a business relationship with the Company.
The policy establishes the principles of conduct that the Company is required to adopt in order to guarantee transactions with related parties are managed appropriately. It further lays down the procedural rules to be followed for the approval of related party transactions entered into by the Company, to provide greater safeguards for minority shareholders and other stakeholders by preventing any abuse that might arise from related party transactions, including potential conflict of interests resulting in an improper or illegal benefit to a related party.
