Interfront Annual Report 2022

PART C: GOVERNANCE 54 9. ETHICS 9.1 Compliance with Laws and Regulations Compliance with applicable laws and regulations, such as the Companies Act, PFMA, Treasury Regulations, procurement guidelines and instructions, as well as the King Reports, is routinely assessed. In the process of merging the Tax team with Interfront, SARS and Interfront strictly adhered to the regulations and rules in obtaining the necessary approvals for the incorporation of the Tax team, specifically Section 197 of the Labour Relations Act, No. 66 of 1995. The Act requires that the respective rights and obligations of the tax employees and Shandon, the previous employer, are automatically transferred to the new employer, being Interfront. 9.2 Fraud and Corruption Interfront has a Fraud Prevention Policy in place, in conjunction with the Fraud Prevention Strategy. These provide for, inter alia, the detection and investigation of corruption, maladministration and/or fraud. An independent service provider established and currently provides Interfront with a dedicated email address and telephone number for reporting matters of fraud and corruption. The email address and telephone number are monitored by the service provider and anonymity provides for the protection of whistle-blowers. The service provider furnishes Interfront with monthly reports on matters being reported, if any. To date, no incidents have been reported. 9.3 Conflicts of Interest All Interfront employees are annually required to declare any private outside interest which may interfere with or have the potential to interfere with their ability to discharge their duties honestly and openly. The employees’ declarations extend to the interests of their partners, spouses, and dependent children and are reviewed to determine if a possible conflict exists. In such an instance, the conflict is reported to EXCO and the employee is engaged to explain the circumstances and to determine any corrective action. Interfront’s Non-Executive Directors are required to submit a Declaration of Private Interest document at the time of their appointment and these are regularly updated. 9.4 Codes of Conduct The Interfront Code of Ethics and Conduct expresses the set of values and behaviours expected of Interfront employees to ensure that they conduct themselves in an appropriate and ethical manner. No incidences breaching the provisions of Interfront’s Code of Ethics and Conduct have been reported during the year under review. A Supplier Code of Conduct was adopted and all suppliers are required to sign and agree to the code when they submit proposals to do business with Interfront. The code provides for compliance by the service provider with applicable laws and regulations, including anti-bribery and corruption, compliance with human rights and labour standards, as well as health and safety regulations. In terms of the Supplier Code of Conduct, Interfront reserves the right to demand that corrective measures be taken should the service provider not comply. Alternatively, if the transgression is of such a nature that corrective action cannot remedy the situation, Interfront may terminate the contract or take other steps deemed necessary.