Ethical Code of Conduct

This Ethical Code of Conduct applies to employees of Flowmax Limited and all its subsidiaries, who are collectively referred to as “the Group”.

Introduction

This Ethical Code of Conduct (“Code”) is intended as a guideline to assist all employees of the Group in conducting themselves with honesty and integrity in all matters relating to Group affairs.  Our Group’s reputation, credibility and image is derived from its total commitment to ethical business practices and it is therefore expected of all employees to conduct themselves in accordance with the highest ethical standards.

This Code 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 wrong doing.

Key Principles

The Group is committed to maintaining and perpetuating the highest standards of ethics and business conduct.  This commitment applies to all our dealings including our relationships with employees, customers, suppliers, shareholders, competitors and the communities in which we operate.  We have developed this Code to help further these principles and to illustrate our commitment to them.  The Code establishes the values and standards that guide us in the conduct of our business.  Although we operate in various geographic areas, our values and this Code have universal application.  

People

All employees will treat each other with respect and fairness at all times. We are an equal opportunity employer, committed to promoting diversity. We do not tolerate unlawful discrimination or harassment of our employees.

We are committed to providing a safe and healthy work environment for all employees.

Our employees will be held accountable for their actions and are expected to act openly, honestly and with integrity. 

Confidentiality

It is vital to protect the privacy of the Group’s confidential information.  It is each 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.

Protection and Use of Property

All 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 Group company is responsible for establishing and communicating to employees the policies and procedures necessary to meet these responsibilities.

Business and Accounting

We require honest and accurate recording and reporting of information to make sound business decisions.  Business transactions throughout the world must be properly authorised and must accurately reflect these transactions and events and conform with 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.  Company books and records must be kept in accordance with General Accepted Accounting Principles and guidelines established by the group financial department, currently IFRS.

Customers and Suppliers

We are committed to providing high quality, competitively priced products and services.  All dealings with our customers will be done lawfully and ethically.

We will deal honestly with our suppliers.  We will source products in a manner supportive of a mutually beneficial long-term relationship.  Our suppliers and sub-contractors will be treated with integrity and without discrimination.

All Suppliers are expected to understand, accept and adhere to the Group Supplier Code of Conduct. Any conflict of interest or attempt to improperly influence the procurement process is prohibited and should be reported.

Conflicts of Interest

All 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 Group.  A conflict of interest can be caused by having secondary employment, sideline activities, conflicting personal relations and/or interests in suppliers, customers and/or competitors. Employees must inform senior management of any potential conflict of interest and acquire written consent before proceeding.

Competition

Employees are prohibited from exchanging pricing, market strategies or commercial information with third parties.

Gifts and Hospitality

Employees must exercise caution when accepting or offering gifts or attending events without direct business relevance. All employees must adhere to the Group Policy on Gifts and all gifts must be recorded in the Gifts and Hospitality Register.

Anti-Money Laundering

Employees will not, under any circumstances, be involved in any action (or attempted action) to transfer proceeds from crime into legitimate assets.

Anti-Bribery and Corruption

The Group has a zero-tolerance approach to bribery and corruption. The Group prohibits any conduct which involves the direct or indirect promise or offering of money (or other benefits) in exchange for illegal or improper interest.

Facilitation payments are forbidden. These are payments (or other gifts) made to government officials in order to speed up routine actions that you already have a right to.

Any action or involvement by an employee in bribery or corruption will be be taken very seriously and will lead to disciplinary action.

Compliance

Employees must strive to comply with this Code.  Any questions of validity or interpretation should be brought to the attention of senior management.  Failure to comply with the code and associated group policies will result in disciplinary action.

Speak-Up

Employees are encouraged to raise concerns promptly if something does not feel right. Concerns may be raised with local management, Group leadership or by calling the Group Whistleblowing Hotline on +27 (0)21 702 8220 or emailing compliance@sabias.co.za. Employees wishing to remain anonymous are welcome to do so.