CODE OF ETHICS

The company is loyal to the application, implementation and enforcement of our Code of Ethics. We willingly submit to the authorities, a code designed to uphold the integrity with which we conduct our business. We trust in the honesty of our people and our stakeholders, and in the standards and principles applied to those who interact with all our people.

The company will act in a way that will earn it and its subsidiaries the reputation of being:

• Open and honest in all dealings.
  
• Consistent in fulfilling its moral and legal obligations.
  
• Socially responsible.
  
• Environmentally responsible.
  
• Non-sectarian.
  
• Non-political.
  
• Supportive of loyalty and long-standing relationships.
  
• Protective of the quality of its services and products.
  

As regards our people, we are committed to enlightened employment policies and practices whereby:

• Discrimination is eliminated.
• Training and skills development is emphasised
  
• Employees have an uncontested right to organise and negotiate their conditions of employment.
  Our code of ethics deals with the following issues:
  
• Obligations of divisional managers and directors to behave ethically and to communicate this code to all employees and ensure enforcement of this code.
  
• Obligation of all employees to behave ethically
  
• Policy with regards to declaration of outside interest and instruction to avoid a conflict of interest as well as instruction how to deal with a conflict of interest.
  
• Required ethical conduct in our dealings with all our stakeholders
  
• Prohibited acceptance and giving bribes
  
• Procedure for dealing in company shares
  
• Prohibition of insider trading

Each divisional manager and director has a responsibility to ensure that this code is communicated to all employees within the company and is adhered to at all times.

Our internal audit department distributes quarterly newsletters dealing with industry fraud scams as well as contact details for employees to anonymously report suspected fraud.

Corporate Governance
We comply with the listing requirements of the JSE Securities Exchange South Africa in relation to the Code of Corporate Practices and Conduct as contained in the third King Report on Corporate Governance. It is the responsibility of the audit committee to ensure compliance with good-corporate governance.

As a group we comply with the following requirements:

• A separate CEO and Chairperson
  
• An audit committee and remuneration committee
  
• The audit committee reviews the performance of external auditors annually and addresses their findings
  
• An internal audit function.