Corruption: SO2 - SO4

  • SO2 Percentage and total number of business units analysed for risks related to corruption.

    Integrated Report:
    Corporate Governance:

    In addition to the Barloworld Worldwide Code of Conduct and the Code of Ethics, Barloworld has an Anti-Bribery and Corruption policy and other related policies to address the fight against bribery and corruption and this is applied throughout the group.

    The group's internal audit function, whilst not responsible for the identification of fraud and/or corruption, considers potential indicators of corruption and fraud in the planning of their reviews.

    All divisions have conducted have an ethics and compliance programme that is risk based and directed towards key priorities.

    All legal entities that are owned through the group's UK investment company are subject to divisional and group monitoring and reporting requirements for ethics and compliance matters and more specifically for compliance with anti-bribery and corruption legislation.

    For more detail also see the Barloworld Code of Conduct and policies.

  • SO3 Percentage of employees trained in organisation's anti-corruption policies and procedures.

    Integrated Report:
    Corporate Governance:

    Induction and other staff training programmes address expected behaviour in terms of the company's ethics, codes, policies and procedures. Ongoing communication through the intranet, employee handbooks, letters of appointment, management briefings and structured team forum meetings reinforce our commitment to our values and expected behaviour. New employees are required to attend induction training and orientation.

    There is an ongoing process at the divisions in which ethics and compliance priorities are identified and actioned in order to manage any perceived risk areas.

    In addition to the group's, Worldwide Code of Conduct, the Code of Ethics, Barloworld has also adopted and implemented an Anti-Bribery and Corruption policy and related policies such as the Group Gifts and Hospitality policy and the Due Diligence policy for doing business with third party service providers to take into account higher expected global standards for preventing bribery and these are applied throughout the Group.

    For more detail also see the Barloworld Worldwide Code of Conduct and related policies.

    Communication and training of the group's Worldwide Code of Conduct , the Code of Ethics and anti-bribery and corruption policies has been conducted at all divisions and business units.

    The group's ethics and compliance framework requires this training for all employees as appropriate to their functions in the business. This aspect is being coordinated by the ethics and compliance managers in each of the Barloworld divisions in conjunction with the divisional Human Resources departments.

    Employees are advised through Letters of Appointment, Induction training and the Barloworld Worldwide Code of Conduct of the severe consequences of unacceptable behaviour (including corruption). Certain levels of employees also attended training courses on this subject. During the year 7 200 employees were covered by these processes and training 3 627 within South Africa and 3 576 outside South Africa. This training is also incorporated in various programmes which include our Induction and orientation, as well as diversity training.

    An ongoing focus is the improvement to procurement procedures and conducting due diligence reviews on third party service providers and suppliers, which is largely aimed at addressing anti-bribery and corruption.

  • SO4 Actions taken in response to incidents of corruption.

    Barloworld has a process for reporting any allegations of unethical behaviour and this would include allegations of corruption. The Audit Committee has oversight of this reporting process that includes the Barloworld Ethics Line. Any proven cases of corruption would constitute a criminal act which would be dealt with accordingly in terms of the group's disciplinary procedures. After due process the appropriate sanction would be applied which could include dismissal. Criminal charges would also be laid, where appropriate. During the period seven cases were reported. None of the cases involved public officials and all resulted in dismissal of the employees involved.