Raubex : Fraud and Corruption Policy

RAUBEX GROUP FRAUD AND CORRUPTION POLICY

TABLE OF CONTENTS

INTRODUCTION 3 SCOPE OF THE POLICY 3 DEFINITIONS 3 THE POLICY 3 REPORTING PROCEDURES AND RESOLUTION OF REPORTED INCIDENTS 3 CONFIDENTIALITY 5 PROTECTION OF WHISTLE BLOWERS 5 APPLICATION OF PREVENTION CONTROLS AND DETECTION MECHANISMS 5 CREATING AWARENESS 6

INTRODUCTION

The Raubex Group is committed to the highest standards of ethical behaviour in its business conduct and has adopted this policy to ensure consistent and effective investigation, reporting and disclosure of fraud and corruption within the Group. Furthermore, the purpose of this document is to confirm that the Raubex Group has adopted a culture of zero tolerance to fraud and corruption in all of its activities.

SCOPE OF THE POLICY

This policy applies to all attempts and incidents of fraud and corruption impacting or having the potential to impact the Group.

DEFINITIONS

Fraud and corruption includes but is not limited to the following legal definitions:

1. Fraud, i.e. "the unlawful and intentional false representation or concealment of facts resulting in actual or potential prejudice to another";

2. Corruption which can be summarised as: "giving or offering; receiving or agreeing to receive; obtaining or attempting to obtain any benefit which is not legally due to or by a person who has been charged with a duty or power by virtue of any employment, to do any act or omit to do any act in relation to that power or duty"; and

3. Theft, i.e. "the unlawful and intentional misappropriation of another's property or property which is in his/her lawful possession, with the intention to deprive the owner of its rights".

Fraud is often combined with Theft, therefore the need to encompass Theft within the definition of this policy. It should be noted that the definition of Fraud encompasses any manipulation, omission or misrepresentation of financial results or financial reporting.

THE POLICY

The policy of the Group is one of zero tolerance towards fraud and corruption. All allegations of fraud and corruption must be properly investigated and if substantiated must be followed up by the application of all remedies available including disciplinary action in terms of the disciplinary code and prosecution in terms of the law. It is the policy of the Group to take a firm stance against tender award irregularities where corruption is suspected and challenge the award of tenders through formal legal process where awards are not consistent with pricing, technical ability and other tender specific criteria.

REPORTING PROCEDURES AND RESOLUTION OF REPORTED INCIDENTS

It is the responsibility of all employees to immediately report all allegations or incidents of fraud and corruption to their immediate manager or, if the employee has reason to believe that his/her immediate manager is involved, to the next level of management. Should employees wish to report allegations of fraud or corruption anonymously, they may report it to the Raubex Group Fraud Line numbers or

website directly. Raubex Group Fraud Line posters displaying details of the telephone number and website should be clearly displayed at the business premises of all the group companies

South Africa Free Call: 0800 20 53 14

Namibia Free Call: 0800 01 50 05

Malawi Free Call: 50800 (free for Airtel Subscribers only)

Zambia Free Call: 847 (ZAIN TNM) 8000 0847 (MTL)

Email: [e-mail]

Free Fax: [phone] (free for South Africa only)

Free Post: KZN 138 (free for South Africa only) Umhlanga Rocks

4320

Website: www.tip-offs.com

An employee who suspects dishonest or fraudulent activity should not attempt to:

• Personally conduct investigations or interviews/interrogations related to any suspected fraudulent act; or

• Contact the suspected individual in an effort to determine facts or demand restitution.

It is the responsibility of the relevant managers to ensure that all incidents and allegations of fraud and corruption reported to them are reported immediately to the Group Financial Director and Head of Internal Audit. The following contact details are relevant:

Financial Director Head of Internal Audit

Tel: [phone] Tel: [phone]

Email: [e-mail] Email. [e-mail]

All information received will be treated confidentially to the extent possible, while allowing a full investigation to be conducted into the suspected fraud or corruption allegation. The Group reserves the right to pass on any information to the proper law enforcement agency in order that such entity may determine whether criminal charges are warranted.

The Head of Internal Audit, in conjunction with the relevant senior member of management, have the primary responsibility to co-ordinate the investigation of all suspected fraudulent or corrupt acts reported under this policy.

If the investigation substantiates that significant fraudulent or corrupt activities have occurred, the Head of Internal Audit has the responsibility to notify the Audit Committee on a timely basis of such activities. Relevant senior divisional management are also responsible for including details of any such allegations of fraud or corruption in their monthly reporting to the Executive Committee.