Ethics

AECI and all its operating companies are committed to a policy of fair dealing and integrity in the conduct of their businesses. In support of this, the Group has adopted a formal Code of Ethics with which all Directors and employees are required to comply. New employees also receive copies of the Code and, to maximise the Code’s accessibility, it has been made available on AECI’s intranet and on the intranets of operating companies, where these are available. The Code can only be amended by the Board. It is reviewed every three years, or more often if necessary, and such a review is currently in progress.

The Code addresses the following:

• compliance with all laws and regulations;
• conflicts of interest: outside activities, employment and directorships; relationships with clients, customers and suppliers;
• business practices: gifts, hospitality and favours; remuneration; anti-competitive behaviour;
• Group funds and property;
• accounting standards; and
• security of information: obtaining and safeguarding information; access to information; insider trading.

A service known as Tip-offs Anonymous is in place. It is aimed at enabling employees, customers, suppliers and managers or other stakeholders, on a confidential basis, to raise concern in cases where conduct is deemed to be contrary to ethical behaviour and the Code of Ethics. The service is administered by Deloitte & Touche. Therefore, it is totally independent of AECI and the anonymity of individuals reporting fraud or dishonest and inappropriate behaviour is protected. Legitimate issues and concerns reported are forwarded for appropriate action to the Financial Director and to the Head of Internal Audit. The service has gained acceptance over time, particularly among employees. It is an effective component of the Group’s efforts to deal with theft, fraud and other misconduct in a professional manner.

The Group has adopted a formal Conflicts of Interest Policy and all employees with the ability to bind the Company (contractually or otherwise) are required to complete and submit a Conflicts of Interest Declaration.

The Group does not engage in or accept or condone engaging in any illegal acts in the conduct of its business. The Group’s policy is to actively pursue and encourage prosecution of perpetrators of fraudulent or other illegal activities should it become aware of any such acts. A zero tolerance approach has been adopted.

Formal training for all employees on the Group’s Code of Ethics, the whistle-blowing service and other applicable policies is conducted on an ongoing basis.