GROUP SUSTAINABILITY REPORT

2019

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Momentum

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Underground Mining + Oil & Gas + Power & Water

Ensure ethical business conduct

BBBEE STATUS IN SOUTH AFRICA
Level 2

 

GROUP CORPORATE SOCIAL RESPONSIBILITY SPEND

R18,9

       

FY2018: Level 3

 

MILLION

FY2018: R19,1 million

       

THE TRUST AND SUPPORT OF OUR STAKEHOLDERS IS CRITICAL TO OUR SUSTAINABLE SUCCESS. OUR BOARD AND EXECUTIVE LEADERSHIP SET THE TONE FOR AN ETHICAL CULTURE, ENSURING GOOD GOVERNANCE AND APPROPRIATE BUSINESS PRACTICES.

We expect everyone who works for or acts on our behalf to adhere to the highest ethical standards. Our Code of Conduct, incorporating the Values and Statement of Business Principles supports ethically robust and defensible decision-making.

Despite the reality of different local operating environments, our businesses are expected to align to the Group’s Values, frameworks and standards as minimum best practice. Governance frameworks and reporting structures ensure visibility of, and compliance across, all platforms.

The social & ethics committee is responsible for overseeing the entrenchment of the Group’s Code of Conduct and ethical behaviours, as well as the controls needed to prevent and combat bribery and corruption.

The following forums and initiatives ensure ethical business conduct are maintained across the Group.

BUSINESS PRACTICES

Mechanisms to ensure adherence to the code include a declaration that all executives involved in preparing and authorising project tenders are required to sign, to declare that they have not committed and are unaware of anyone else affiliated with the tender having directly or indirectly committed any unethical, unlawful or uncompetitive practice in the preparation and submission of the tender. The declaration is binding throughout the project life cycle. Similarly, all Group executives make written declarations twice a year, specifically in relation to competition law compliance.

CODE OF CONDUCT

Our Code of Conduct clearly defines the behaviours expected of our employees and other stakeholders associated with the Group, including suppliers and subcontractors. Behaviours that depart from these principles are not tolerated. The code and any supporting policies are revised and updated, when required.

The induction programme for new employees and graduates emphasises the importance of the Code of Conduct.


ETHICS

The Code of Conduct was updated during the year. Employees complete online assessments of their understanding of the code every two years. New employees complete Code of Conduct training as part of their induction.


REGULATORY COMPLIANCE

Internal audit found no major issues of non-compliance in its compliance reviews, including for Australia, Canada and the USA. One legal action is pending regarding anti-competitive behaviour, and there were no confirmed incidents of corruption.


WHISTLE-BLOWING HOTLINES

Five cases reported and investigated, with four still under investigation. Appropriate action has been taken in each instance where unethical behaviour was confirmed (FY2018: 14).


HUMAN RIGHTS AND EQUALITY

We have not identified any operations within the Group where human rights violations have been identified as a risk. There were no incidents of violations involving the rights of indigenous peoples.

STANDARDS OF GOOD PRACTICE

We subscribe to and comply with the 10 business principles set out in the United Nations Global Compact and with the principles and standards of good practice set out in the Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises. As a member of Business Leadership South Africa, we support its Code of Good Corporate Citizenship.

REGULATORY COMPLIANCE

We adhere to the regulatory requirements applicable to the sectors and jurisdictions in which we operate. The Group regulatory compliance executive is mandated to investigate and report on:

  • The multiple regulatory environments applicable to our businesses.
  • The organisational controls in the jurisdictions in which we operate that ensure compliance with all applicable laws, rules, codes and standards.
  • The levels of compliance across the Group based on a comprehensive monitoring and review plan.
  • The corrective actions and improvements required, including education and training, to address any identified control weaknesses or compliance failures.
TRANSPARENCY AND WHISTLE-BLOWING

We encourage our employees, suppliers, subcontractors and concerned stakeholders to report any unethical behaviour within our operations. We support anonymous reporting of workplace dishonesty and unethical behaviour, including discrimination, theft, fraud and corruption. Deloitte (Tip-Offs Anonymous) and KPMG (Fair Call) administer our two whistle-blowing hotlines. Fair Call serves Oil & Gas and Tip-Offs Anonymous covers the corporate office, Underground Mining and Power & Water.

HUMAN RIGHTS

We endorse the rights enshrined in the Constitution of the Republic of South Africa, 1996, and all equivalent and prevailing rights in all other jurisdictions, including the right to collective bargaining, the right to peaceful industrial action and all other labour rights. We acknowledge the right of individuals to freedom of association, reject child and forced labour and respect the rights of indigenous people.

UNFAIR DISCRIMINATION AND EQUALITY

Discrimination in any form is viewed in a very serious light and appropriate disciplinary action is taken against offenders. We expect all our employees and service providers to treat those with whom they come into contact with dignity and respect. As a South African domiciled Group, we believe that it is not unfair discrimination to promote affirmative action in line with the national Employment Equity Act or to prefer any person on the basis of an inherent job requirement.