Code of Ethics
PURPOSE:
This policy acts as an ethical guideline for the Flowmax Ltd. Group which incorporates Petroy B.V.
Scope
This policy applies to the Group and all of its subsidiaries (hereafter the “Group”).
INTRODUCTION
Our Ethical Code guides our decisions and actions. We ultimately rely on the individual actions of our employees around the world to protect our integrity, credibility and reputation. Each employee is personally accountable for compliance with our Ethical Code.
The guidelines must be interpreted and applied within the framework of the laws and conditions of countries in which we operate as well as taking into consideration our Group policies. We should at all times avoid circumstances or actions that give the appearance of dishonesty or wrongdoing.
ETHICAL GUIDELINES
- Employees
The Group is an equal opportunity employer. SA Bias will recruit without regard to race, creed, colour, national origin, sex, age, marital status, handicap or disability, sexual orientation or religion. However, in South Africa, recruitment will be influenced and guided by the company’s employment equity targets. Employees are expected to carry out the business of SA Bias in a diligent and loyal manner consistent with Group policies and guidelines. Our employees will be held accountable for their actions and are expected to act openly, honestly and with integrity. Employees are expected to comply with the law.
The Group is committed to ensuring that all company facilities operate under safe working conditions. The Managing Director (MD) or General Manager (GM), as the case may be, of each company is responsible for ensuring that the company is compliant with all provisions of local health and safety laws. - Confidentiality
It is vital to protect the privacy of the Group’s confidential information. Confidential information includes proprietary, technical, business, product, IP, computer system, production, financial, joint venture, customer, employee and other information that is not available publicly. It is the employee’s responsibility to know which information is confidential and to obtain clarification when in doubt. Employees must not disclose confidential information to any person including family and friends outside the Group unless authorised to do so. Within the Group confidential information should be disclosed only on a need to know basis. Employees must not use confidential information for unauthorised purposes and must take care to protect confidential information against loss, theft and misuse. - Customers and Suppliers
Group employees must deal with suppliers, customers and others conducting business with the company in a manner that avoids conflict between personal interests and those of the company. Employees are specifically prohibited (without the written approval of senior management and subject to relevant Group policies) from:
a) seeking or accepting gifts or any form of compensation from suppliers, customers and others doing business or seeking to do business with any company in the Group
b)acting as an intermediary for the benefit of a third party in transactions involving any company in the group,
c) owning shares directly or indirectly in Group suppliers, customers or competitors, except of the case of public companies where employees may own up to 5% of the shares of these companies.
The Group is committed to not supporting suppliers who use forced or child labour, or any form of modern slavery or human trafficking.
It is our responsibility to assess our customers’ needs and offer quality products and services at appropriate terms and prices. We will sell products and services honestly and will not pursue any sale that requires us to act unlawfully or in violation of these standards. We will not offer financial incentives to our customers’ personnel to induce them to purchase products or services from us.
We will engage in free and fair competition and are to refrain from collusion in any form.
Group policy is to purchase all equipment, supplies and services on the basis of professionalism, value for money and reputation. Our suppliers and sub-contractors will be treated with integrity and without discrimination. We should only engage sub-contractors whose operating and safety standards local management have reviewed and confirmed to be consistent (within practical reasonability) with our own standards.
- Worldwide Communities
We shall act as a responsible corporate citizen by respecting the law, the environment and the communities in which we operate.
a) Human Rights – The Group is committed to the protection of human rights globally and does not accept any form of child labour, any form of forced labour, or forms of coercion, fraud, deception, abuse of power, or other means to achieve control over another person for the purpose of exploitation. The group has a zero-tolerance approach to modern slavery in all its forms.
b) Political Activities – The Group does not make financial contributions to or support any political parties and is politically neutral. It provides full support to the laws of the country and to the Government of the day.
c) Contributions – It is our policy that no employee of the company should make or agree to make any contributions, payments or gifts to any third party in contravention of the law. The Group will support worthwhile civic and charitable causes and encourages employees to do the same in their personal capacities. - Protection and Use of Property
All Group employees are responsible for the proper use, conservation and protection of corporate assets both tangible and intangible which includes property, vehicles, equipment and business technical information such as computer programs, marketing information, customer lists and other related information. The management of each company is responsible for establishing and communicating to employees the policies and procedures necessary to meet these responsibilities. - Financial Reporting
The Group requires honest and accurate recording and reporting of financial and other information to make sound business decisions. Business transactions throughout the world must be properly authorised and our records must accurately reflect these transactions and events and conform to required accounting principles and Group financial policy. Budgets, forecasts and financial proposals must accurately represent all information relevant to the decision being requested or recommended. Secret and unrecorded cash funds or other assets are forbidden under any circumstances. To the extent that any form of offsetting or smoothing of results from one month to another in management accounts is to be undertaken or if any material financial event is not recorded in the management accounts timeously, such action must be specifically communicated to and approved by the Group CFO in advance.
Company books and records must be kept in accordance with IFRS and the guidelines established by the group financial department.
- Compliance
Group employees must comply with the Ethical Code. Any questions of validity or interpretation should be brought to the attention of the group MD and CFO. Failure to comply with the code and associated group policies may result in disciplinary action.
An anonymous “tip-off hotline” has been established to ensure that allegations of breaches of regulations or group policies are dealt with responsibly (refer to our anti-corruption policy and statement).
Whistleblowing – all employees of the Group and its subsidiaries, suppliers and customers are encouraged to report any concerns relating to unlawful conduct, malpractice, unethical conduct, dangers to the public or the environment, and any other matter relating to a breach of regulation or policy to the Group Compliance Officer.
The Group has a reputable Social and Ethics Committee with a well-established Social and Ethic’s Charter. This Committee annually reviews a wide range of compliance feedback from all companies in the Group. A Group Compliance Officer, the CFO of the Group, has been appointed by the Committee to coordinate and oversees compliance.
All Group employees are expected to understand and to adhere to the Ethical Code.
ADMINISTRATION RESPONSIBILITY:
The Head Office Executive is responsible for the administration of this policy.