The Code of Conduct and Ethics Policy establishes the ethical standards, values, and behavioural expectations that govern the conduct of employees, management, directors, and stakeholders. It provides a comprehensive framework for promoting integrity, accountability, professionalism, and responsible business practices while outlining expectations for workplace behaviour, conflicts of interest, confidentiality, customer and supplier relationships, anti-bribery measures, and legal compliance. The policy also defines reporting procedures for unethical conduct and reinforces the Company's commitment to maintaining an ethical, respectful, and transparent workplace culture in line with South African legislation and recognised corporate governance principles.

1. Introduction

• Commitment to ethical business practices
• Workplace integrity and professionalism
• Employee responsibilities
• Application of the Code

2. Purpose

• Objectives of the Code
• Standards of conduct
• Ethical decision-making
• Employee accountability

3. Commitment

• Company commitment to ethics
• Ethical culture
• Corporate governance principles
• Ongoing compliance monitoring

4. Application & Scope

• Individuals covered by the Code
• Employees, management and directors
• Suppliers, customers and stakeholders
• Company-wide application

5. Guiding Principles

• Ethical business practices
• Corporate citizenship
• Employee responsibilities
• Compliance expectations

6. Policy

• Workplace safety
• Human rights and diversity
• Environmental responsibility
• Anti-corruption
• Responsible use of company assets
• Accurate record keeping

7. Company Values

• Responsibility
• Accountability
• Excellence
• Equity
• Respect
• Diversity
• Integrity
• Customer focus
• Commitment to people
• Environmental responsibility
• Trustworthiness
• Compliance
• Leadership

8. Employee Obligations

• General responsibilities
• Shared obligations
• Workplace conduct
• Equality and inclusion
• Confidentiality
• Responsibilities to management and shareholders

9. Code of Conduct for Employees

• Customer service standards
• Supplier relationships
• Gifts and hospitality
• Anti-bribery requirements
• Financial integrity
• Professional conduct
• Workplace behaviour
• Community responsibility
• Drug and alcohol expectations
• Weapons prohibition
• Whistleblowing obligations

10. Confidentiality of Customer Information

• Protection of confidential information
• Client confidentiality
• Responsible information handling

11. Independent Advising

• Objectivity
• Conflict disclosure
• Independent decision-making
• Customer interests

12. Quality Delivery

• Service excellence
• Employee competency
• Quality assurance

13. Conflict of Interest

• Identifying conflicts
• Disclosure requirements
• Ethical decision-making

14. Relationships with Customers, Suppliers & Competitors

• Ethical business relationships
• Fair competition
• Gifts and inducements
• Tender processes
• Confidentiality
• Anti-competitive conduct

15. Relationships with Shareholders

• Shareholder protection
• Honest reporting
• Corporate transparency

16. Relationships with Employees

• Professional conduct
• Respect and diversity
• Employment equity
• Health and safety
• Conflict of interest disclosures

17. Compliance

• Compliance expectations
• Reporting concerns
• Confidential investigations
• Employee responsibilities

18. Reporting Procedure

• Reporting unethical conduct
• Investigation process
• Corrective action
• Disciplinary consequences

19. Ethical Decision-Making Guidelines

• Ethical decision framework
• Key evaluation questions
• Assessing business decisions
• Managing ethical dilemmas

20. Employee Declaration

• Employee acknowledgement
• Acceptance of the Code
• Commitment to compliance