LIMPOPO TOBACCO PROCESSORS CODE OF ETHICS

1. INTRODUCTION

Limpopo Tobacco Processors is committed to achieving environmental, health and safety excellence. We strive to provide a safe and healthy working environment for all the employees, which is tolerant of culture diversity, the right to different opinions and the fair treatment of all employees. Workplace duties, relationships and behaviour which are proper, fair and honest need to comply with all applicable laws, particularly with the provisions of the Constitution and those principles which relate to Limpopo Tobacco Processors, it’s customers and it’s employees.Through its employees, Limpopo Tobacco Processors conducts business on a daily basis with its customers, suppliers and communities. To reflect and enhance Limpopo Tobacco Processors’s reputation, employees have to be committed to maintaining the highest level of integrity and ethical conduct in their actions and relationships with all stakeholders in our business.It should be noted that this Code of Ethics is not a legal contract. It is a moral commitment and a guide for making value-driven decisions. This commitment and guide is in support of personal integrity and ethical judgement, qualities and behaviour we believe those in the employment of Limpopo Tobacco Processors do display. This Code is intended to reinforce these qualities and behaviour.

2. COMPLIANCE WITH LAWS AND REGULATIONS

Employees must comply with all applicable laws and regulations, which relate to their activities for and on behalf of the company. Limpopo Tobacco Processors does not condone any violation of the law or unethical business dealing by any employee, including any payment for, or other participation in an illegal act such as bribery or money laundering activities.

3. CONFLICT OF INTEREST

Limpopo Tobacco Processors expects employees to perform their duties conscientiously, honestly and in the best interest o-f the company. It is not expected of employees to use their positions or knowledge gained through their employment with Limpopo Tobacco Processors for private or personal advantage or in such a manner that there is conflict between Limpopo Tobacco Processors’s interest and the employee’s personal interest.A conflict of interest could arise where an employee, a member of an employee’s family or a business which the employee or his family is associated with obtains, gains advantage or profits by virtue of the employee’s position with Limpopo Tobacco Processors or knowledge gained through that position. If an employee feels that a course of action which they have pursued, are pursuing oi­are contemplating to pursue may result in a conflict of interest, or a perceived conflict of interest, they should immediately make all the relevant facts known to the manager they report to.

3.1 OUTSIDE ACTIVITIES, EMPLOYMENT AND DIRECTORSHIPS

3.1.1 Employees should avoid acquiring any business interest or participate in any activity outside Limpopo Tobacco Processors which:

(a) creates or appears to create an excessive demand on their time, attention and energy which would deprive Limpopo Tobacco Processors of their best efforts in executing their daily tasks; or(a) creates or appears to create an excessive demand on their time, attention and energy which would deprive Limpopo Tobacco Processors of their best efforts in executing their daily tasks; or(b) would interfere or appear to interfere with the independent exercise of judgement in Limpopo Tobacco Processors best interest.

3.1.2 Employees should refrain from using their positions for personal gain or to advance the interests of family members, friends or others.

3.1.3 Employees may not take up outside employment (part-time or full-time) without the prior written approval of the Senior Manager in their respective operating unit or function.

3.1.4 Employees who hold or have been invited to hold outside directorships should take particular care to ensure compliance with all provisions of this code. When outside business directorships are being considered, recommendation an prior approval must be obtained from the functional head, and the final approval vests in the Chief Executive Officer.

3.2 RELATIONSHIPS WITH CLIENTS, CUSTOMERS AND SUPPLIERS

Employees should ensure that they are independent and are seen to be independent, from any business organisation having a contractual relationship with Limpopo Tobacco Processors or providing goods or services to Limpopo Tobacco Processors. If such a relationship might influence or create the impression of influencing their decisions in tl1e pe1formance of their duties on behalf of Limpopo Tobacco Processors, employees should not invest in, or acquire a financial interest directly or indirectly, in such an organisation.

3.3 GIFTS, HOSPITALITY AND FAVOURS

Conflicts of interest arise where an employee is offered gifts, hospitality or other favours which might or could be perceived to influence his judgement in relation to business transactions (such as the placing of orders and awarding of contracts).
An employee should not accept covert profits, bribes any other corrupt, or conscionable benefits or other favours from suppliers of goods or services. However, acceptance of the following would not be considered contrary to this policy:

(a) Advertising material not exceeding R250, 00 in commercial value. The same employee may accept this more than once from the same company.
(b) Occasional business entertainment such as lunches, cocktail parties or dinners.
(c) Occasional personal l1ospitality such as tickets to local sporting events or theatre.

Employees who are involved directly with the business transactions of Limpopo Tobacco Processors should not accept gifts, hospitality or favours that may influence their judgement. Extreme caution should be exercised in such situations and gifts, hospitality or favours should not become the guiding motive. Any gift, hospitality or favour which exceeds a monetary value of R100, 00 should be declared to Limpopo Tobacco Processors.

3.4 REMUNERATION

No employee may receive commission or monetary remuneration related to the sale of any product of Limpopo Tobacco Processors, except as specifically provided for in the individual’s terms of employment.

4. EMPLOYMENT EQUITY

Limpopo Tobacco Processors respects and values the cultural diversity of its employees. Employees should treat diversity as an asset and help every person to reach his or her full potential.

All employees have the right to work in an environment which is free from any form of harassment or discrimination based on race, colour, gender, sexual orientation, place of origin, citizenship, creed political persuasion, age, marital or family status or disability. Limpopo Tobacco Processors will not tolerate any kind of discrimination or harassment.

5. SAFETY, HEALTH AND ENVIRONMENTAL RESPONSIBILITY

Limpopo Tobacco Processors strives to provide a safe and healthy working environment for all our employees and avoids harming or disrupting the environment and the communities in which it operates.
Limpopo Tobacco Processors provides an integrated occupational health system, which is available to all employees. Employee’s right to confidentiality will be recognised and respected.
You can contribute to Limpopo Tobacco Processors’s endeavour in this regard by:
• Complying with environmental health and safety rules and regulations.
• Take measures to prevent workplace injuries and illnesses, thus providing a safe and healthy working environment.
• Co-operating with the general public, the government and any other interested parties to develop regulatory and public policies to protect public health and the environment.

6. POLITICAL SUPPORT

6.1 Limpopo Tobacco Processors supports the principle of Freedom of Association.

6.2 Limpopo Tobacco Processors encourages the personal participation of it’s employees in political processes and respects their right to absolute freedom of association in line with their personal political beliefs. Limpopo Tobacco Processors will not influence or inte1·fere in any such participation provided that it causes there is no disruption to workplace activities and it does not contribute to industrial unrest.

6.3 No employee shall misuse the workplace to force their point of view upon others.

6.4 Limpopo Tobacco Processors is tolerant to clients and employees’ culture and diversity.

6.5 Limpopo Tobacco Processors funds, goods or services may not be contributed to political parties or their candidates. Limpopo Tobacco Processors facilities ma’y not be made available to political candidates or campaigns, for political meetings and distribution of pamphlets.

7. RESPONSIBILITY OF ALL EMPLOYEES AT ALL LEVELS

It is the responsibility and obligation of every employee to abide by the principles, commitments and guidelines set out in this Code of Ethics.
It is expected of every employee to:

7.1 Carry out their duties with honesty, integrity and to the best of your ability;

7.2 Avoid any waste of Limpopo Tobacco Processors’s resources, including time;

7.3 Accept accountability for their actions and decisions;

7.4 Treat the assets and property of Limpopo Tobacco Processors, it’s employees, it’s customers and suppliers with care and respect;

7.5 Treat people with fairness, courtesy and sensitivity with respect to their constitutional rights;

7.6 Use knowledge and skills obtained through employment by Limpopo Tobacco Processors in the best interest of the company.

7.7 Support and assist Limpopo Tobacco Processors to fulfil it’s commercial and ethical obligations as set out in this code;

7.8 Join Limpopo Tobacco Processors in a commitment to improve productivity;

7.9 Comply with all the rules, regulations and procedures that apply to Limpopo Tobacco Processors, its systems and the manner it conducts its business;

7.10 not make a false accusation against a fellow employee;

7.11 not intimidate a fellow employee; and

7.12 recognise fellow employees’ rights to freedom of association and of expression

7.13 report any irregularity against the company by any employee, including members of management.

 

8. RESPONSIBILITIES OF MANAGERS

Apart from their general responsibilities and duties as employees of Limpopo Tobacco Processors, managers have additional responsibilities by virtue of their seniority and the nature of their managerial and supervisory duties.
Managers shall:

8.1 Act in good faith, be honest and act in the best interest of Limpopo Tobacco Processors:

8.2 Carry out their duties and responsibilities with skill care and exercise their careful judgement;

8.3 Not conduct the business of Limpopo Tobacco Processors in a negligent or reckless manner.

8.4 Not place themselves in a position where their personal interest could come in conflict with their responsibility to Limpopo Tobacco Processors;

8.5 Respect and be fair to all employees, customers and suppliers and be sensitive to their diverse cultures.

8.6 Provide working conditions conducive to higher productivity;

8.7 Comply with the laws and policies governing labour relations and conditions of employment;

8.8 Manage his department or function in such a way as not to unreasonably jeopardise job security of employees;

8.9 Communicate on a regular basis with employees regarding company policies and procedures, changes which might have an impact on them, general information that is necessary in the course of their duties, and this code to ensure it’s understanding by all employees.

 

9. INFORMATION

In the regular course of business, Limpopo Tobacco Processors employees accumulate a considerable amount of information. Limpopo Tobacco Processors employees are committed to respect the confidentiality of sensitive information. The obligation not to disclose information still applies after an employee has left Limpopo Tobacco Processors. The following principles are to be observed.

9.1 All employees shall respect the confidentiality of sensitive customer information obtained in the course of business. This information will not be disclosed to any person, business concern or institution without authorisation from the customer.

9.2 Limpopo Tobacco Processors is obliged to record and maintain legally required information relating to it’s employees. Such information must be treated as confidential and used only for legitimate purposes.

9.3 Any confidential or personal information regarding employees, including their salaries may not be disclosed to anyone without proper authorisation from the employee or manager of the function.

 

10. CLOSING STATEMENT

The contents of this document have been compiled with the culture of Limpopo Tobacco Processors and the diversity of the cultures of its people in mind.
Honesty, integrity and transparency were foremost in the intentions behind the wording of important issues.
All readers of this document are encouraged to evaluate themselves in terms of the content and the spirit of tl1is document and to act positively toward improving Limpopo Tobacco Processors’s working environment at all times.

 

C. VAN ST ADEN
MANAGING DIRECTOR
(Limpopo Tobacco Processors)