ANTI-CORRUPTION AND FRAUD POLICY
By Johanette Rheeder
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2. SCOPE OF THE POLICY
4. ACTIONS CONSTITUTING CORRUPTION, FRAUD, THEFT AND MALADMINISTRATION
5. RESPONSIBILITY TO CONDUCT INVESTIGATIONS
7. REPORTING PROCEDURES AND RESOLUTION OF REPORTED INCIDENTS
8. PROTECTION OF WHISTLE BLOWERS
9. APPLICATIONS OF PREVENTION
10. TRAINING, EDUCATION AND AWARENESS
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1.1 This policy is intended to set down the stance of the Company to corruption, fraud, theft and
maladministration as well as to reinforce existing rules and regulations aimed at preventing,
reacting to, and reducing the impact of corruption, fraud, theft and maladministration where
these dishonest activities do subsist.
1.2 The spirit of this document is to support and foster a culture of zero tolerance to corruption,
fraud, theft and maladministration by all individuals covered by it as reflected in the scope
detailed in Section 2 below.
2. SCOPE OF THE POLICY
This policy applies to all corruption, fraud, theft and maladministration or suspected irregularities of
this nature involving the employees of the Company, consultants, suppliers, contractors and other
providers of goods or services to the Company.
3.1 It is policy of the Company that corruption, fraud, theft, maladministration or any other dishonest
activities of a similar nature will not be tolerated. In addition such irregular activities must be
immediately reported by employees and managers.
3.2 Managers will continuously communicate this policy and the values thereof to employees.
3.3 Once corruption, fraud, theft, maladministration or any other dishonest activities of a similar
nature are reported to a manager or the Company, it will be investigated and followed up by the
Company and the Company will apply all remedies available to it within the full extent of the law,
which can include disciplinary-, civil or criminal action.
3.4 The Company will apply appropriate prevention and detection controls within all of its
departments and branches or divisions.
3.5 These prevention controls include the existing financial, commercial and/or other controls and
checking mechanisms as prescribed in the policies relevant to the activities of the individual
departments of the Company.
3.6 It is the responsibility of all managers in the Company to propose and set up controls within their
departments to detect and prevent corruption, fraud, theft, maladministration or any other
dishonest activities of a similar nature.
3.7 It is the duty of managers to report all incidents of corruption, fraud, theft and maladministration
to his/her manager at head office.
3.8 All managers at head office are responsible for the detection, prevention and investigation of all
corruption, fraud, theft and maladministration.
4. ACTIONS CONSTITUTING CORRUPTIONS, FRAUD, THEFT AND MALADMINISTRATION
4.1 Actions constituting corruption, fraud, theft and maladministration collectively refer to, but are
not limited to:
a. Any dishonest, fraudulent or corrupt act recognized in law or in the disciplinary code of the
b. Bribery or corruption;