The company is fully committed to ethical business practices and abides by a policy of fair dealing, honesty and integrity in the conduct of its business. As a responsible and ethical corporate citizen, the company entrenches a culture of organisational integrity that supports an ethical corporate environment.


The company operates within a formal Code of Business Conduct and Ethics, which has been reviewed and approved by the Board, communicated and distributed to service providers and all employees across all levels in the company. The Code is based on a fundamental belief that all business transactions should be legal and conducted beyond reproach in the spirit of honesty and fairness. The company has a zero tolerance approach to theft, fraud, corruption and any violation of the law or unethical business dealing by employees and suppliers. The Code also addresses conflict of interest situations and encourages employees to report on any conflict or perceived conflict of interest situation. This may arise due to employees being offered and receiving gifts in return for favours, employees not being independent from business organisations having a contractual relationship or providing goods or services to Tongaat Hulett, and employees’ personal investments taking priority over transactions for the company and its clients.


The Audit and Compliance Committee assists the Board in overseeing the consistent application of and compliance with the Code through reports compiled by the corporate security manager and reported to the committee by internal audit. Incidents of fraud, corruption or unethical practices that are reported or detected through management controls are formally investigated, followed by formal disciplinary processes. In severe instances, criminal proceedings are instituted. Management is strict in ensuring the implementation of the Code across all operations in a day-to-day context. Compliance by directors, all employees and suppliers to the high moral, ethical and legal standards of the Code is mandatory, and if employees become aware of, or suspect, a contravention of the Code, they are urged to promptly and confidentially report it to the Company Secretary or officials at management level.


As part of the fraud and corruption prevention approach, Tongaat Hulett has engaged the services of an independent whistle- blowing service provider to report on any unethical and unlawful behaviour or non-compliance with the Code. The independent whistle-blowing service, which is anonymous, is operational in South Africa, Zimbabwe, Botswana, Mozambique, Swaziland and Namibia. Continuous training and awareness are important aspects of a successful ethics management programme, to this end, each centre has recently been provided with the official Tip-Offs Anonymous DVD, describing the whistle-blowing process, stickers and posters, which have also been translated into Portuguese for the Mozambican operations.

During the period under review, 58 tip-offs were reported through the whistle-blowing service across the business. Information relating to a significant fraudulent activity was reported in detail to the Audit and Compliance Committee and appropriate steps, including disciplinary action, have been taken.