Code of Ethics

The Afrox Code of Ethics was developed by the Linde Group, then approved and adopted by the Company in XX. The Code considers principles of ethical action, honest communication, fair treatment, equal opportunities and a fundamental respect for human rights.

The Board is responsible for the ethical governance of the Company and leads with the assistance of executive management. The Board is held ethically accountable by aligning all activities to this Code. The Ethics and Compliance Committee is a management committee that supports the monitoring and management of ethics related matters.

Contents of the Code and application

The Code sets out clear behavioural and ethical expectations for interactions with customers, suppliers, operating markets, shareholders, employees, communities and society. The Code prescribes that local laws, policies and legislations are adhered to, relative to country of operation. Afrox has a zero-tolerance approach to deviations from this Code. Reported ethical non-conformances and breaches are reported to the executive management, Audit and SET committees for remedial action.

The detailed document sets out:

1. Ethics and compliance requirements within Afrox

The Code applies to all employees, directors and officers. These standards set out in the Code provide clear guidance on how we are expected to act in certain circumstances and ensure that our positive reputation is maintained and enhanced.

2. Appropriate use of the Integrity Line

The Group’s Integrity Line exists for employees to report contraventions of the Code of Ethics and to raise certain qualified concerns that cannot be appropriately addressed at a line management level. Electronic and telephonic access is provided.

3. Guidance for making ethical decisions

Company assets, Company time, government interaction, confidential information, insider dealing, communication, products and financial reporting are some of the topics detailed and outlined for employee guidance.
Supplier Code of Conduct

We apply the Linde Group’s Code of Conduct for Suppliers. This Code, now included in the general terms and conditions of supply agreements details requirements for legal compliance, health and safety, human rights, labour laws and standards, integrity, environmental protection and supply chain matters to which we hold our suppliers accountable. Conflict of interests between employees, affiliates and suppliers is detected through a specialised function in our procurement systems.

Training

Various awareness and training initiatives are conducted on an annual basis to all major suppliers, customers as well as Board members and employees. This includes classroom-based training in a range of South African languages. All employees and suppliers are required to read the Code, and sign to confirm that they understand, and will seek to apply the Code. The Company also makes use of all available communication platforms to alert employees to potential ethical risks and breaches as well as to remind employees of their ethical obligations and expected standards of conduct. The Company ensures that ethics training is specific to address areas of potential ethical exposure identified from tracking security, fraud and employee behaviour trends.

Training is offered on various other supporting policies, namely anti-corruption, business partner compliance guidance and our competition policy. 1 250 training sessions have been completed and Afrox believes that this training further contributes to a consistent ethical culture.

Monitoring and action

Compliance monitoring and risk assessments, including internal control self-assessments, take place on a frequent basis. The table below reflects the ethics operating model which ensures that ethics receive the highest priority in the Company.