Entrenching an ethical culture
- The board is committed to entrenching an ethical culture throughout the group and sets the tone by formulating our values and ensuring ethical business standards. The directors, overseen by the chair, hold one another accountable for decision-making and ethical behaviour. Directors, both individually and collectively, seek to demonstrate integrity, competence, responsibility, accountability, fairness and transparency to ensure effective leadership.
It is our policy to conduct business dealings on the basis of compliance with applicable laws, rules, codes, standards and regulation, and proper regard for ethical business practices.
The board has a code of ethics and conduct (the code), which sets out the standards for business conduct throughout the group and is supported by a wide range of group policies.
Management teams across the group understand and apply the code and create and maintain awareness of the code and associated policies, such as the whistleblower policy. Reference to the code is included in the contracts of new employees and in their induction process. The code applies to the recruitment, performance evaluation and reward processes. Management teams are required to monitor adherence to the code and apply a zero-tolerance policy to violations. Sanctions are in place and action is taken when necessary, which includes prosecuting to the fullest extent of the law when appropriate. Reference to our code is included in third-party procurement contracts of certain major subsidiaries. Contractors, agents and consultants who work with any group company are expected to follow the same standards of conduct.
Management focuses on policies and procedures addressing key ethical risks, such as conflicts of interest, accepting inappropriate gifts and acceptable business conduct. The social and ethics committee is responsible for overseeing and reporting on business ethics in relation to the group, considering specific disclosures and best practice as recommended by King IV.
As the group conducts business in various countries, the group and our employees are subject to the laws and regulations of those countries. Group policies are supplemented by local policies and procedures. Ensuring group companies adopt appropriate processes and establish supporting policies and procedures is an ongoing process. The board delegated responsibility for regular review of the code and an ethics communication plan to the board’s nomination committee.
As a leading company that empowers people and enriches communities, MultiChoice does not tolerate any form of bribery or corruption and aims to prevent any and all unethical business practices. Our group anti-bribery and anticorruption policy stresses the importance of our commitment to combating these transgressions. We consider any violation of this policy to be extremely serious, and any allegations relating to bribery or corruption are thoroughly investigated. Any non-compliance with the policy results in disciplinary action, including dismissal and/or criminal proceedings.
The risk management function monitors the group’s whistleblower facility operated by Deloitte Tip-offs Anonymous, which is available in English, Setswana, IsiZulu, Tshivenda, Sesotho or IsiXhosa. Where appropriate, internal audit and/or external forensic consultants investigate reported matters. Significant allegations and fraud are reported to the audit and risk committees. Furthermore, the social and ethics committee receives reports on whistleblower activity and ethics.
The social and ethics committee assumes responsibility for the governance of ethics by setting the direction of how it should be approached within the group. Internal audit and risk management functions support the social and ethics committee, and the group ethics officer, supported by the segment CFOs acting as ethics officers, reports to the committee regularly. Ethics training is included in onboarding for new employees, who are also introduced to the principles of the code and related policies, and relevant case studies are discussed. Ethics-related eLearning modules on the code and the whistleblower policy are part of the MultiChoice Academy platform, which is available to all employees. The effectiveness of the eLearning training modules is monitored closely.
Performance and future focus
Our key areas of focus during the reporting period were:
- Approval of the code by the board, which was integrated into the group’s strategies and operations
- Translating ethics-related policies into Portuguese, including the legal compliance policy, anti-bribery and corruption policy, competition compliance policy and sanctions export controls policy
Going forward we will be focusing on:
- Continually reviewing the adequacy and effectiveness of the group’s monitoring activities
- Conducting an opportunity ethics risk assessment, which will culminate in an updated ethics risk profile
- Ensuring ethics are entrenched throughout the business through training and awareness campaigns
- Reviewing our whistleblowing and internal speak-up mechanisms to identify areas of improvement
- The group’s ethics performance will be monitored and reported to the social and ethics committee quarterly