


The Board acknowledges the necessity for systems and procedures that are required to entrench the values and ethics of the organisation as formulated in its Code of Conduct (the Code), which requires directors and employees to maintain the highest ethical standards when conducting the business affairs of the Group, and dealings with each other and the Group’s various stakeholders.
A function of Human Resources is to monitor compliance with the Code, to follow up complaints, to review disciplinary measures and the outcomes thereof, and to ensure the consistent application of disciplinary measures.
The Group has an insider trading policy that requires directors, employees or their associates who could be expected to have access to price-sensitive information, to be precluded from dealing in the Company’s shares during closed periods in line with the JSE Listings Requirements.
To ensure that share dealings are not undertaken during “closed periods”, directors and employees are required to obtain permission from the Chairman or CEO before dealing in Company shares. All approved share dealings by directors are disclosed to the JSE and published on SENS (Stock Exchange News Services).