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DISTRIBUTION AND WAREHOUSING AND NETWORK LIMITED ("DAWN")
CODE OF ETHICAL CONDUCT

LIVING THE DAWN BUSINESS VALUES
The Dawn Group regards high ethical standards as non-negotiable. Dawn's code of ethical conduct is binding on all directors, managers, employees, independent contractors, agents, service providers and business partners irrespective of their status as natural person, legal person or other entity.

LIVING THE DAWN BUSINESS VALUES MEANS THAT DAWN AND EVERY PERSON BOUND BY THIS CODE MUST COMMIT AND ADHERE TO THE FOLLOWING PRINCIPLES:

OUR CONDUCT SHALL AT ALL TIMES CONFORM TO THE DAWN CORE BUSINESS VALUES

  • Act honestly and fairly with due skill, care and diligence in the interests of Dawn's clients, having due regard and respect for diversity.
  • Avoid any act that reflects adversely on our honesty, trustworthiness or competence.
  • Accept accountability for all our actions and decisions.
  • Refrain from any behaviour that can be classified as unlawful discrimination or harassment.
  • Not tolerate any form of unlawful or criminal conduct including, but not limited to bribery and corruption.
  • Ensure a culture of responsible corporate citizenship including, but not limited to, promoting the importance of a sustainable environment.

WE ARE COMMITTED TO COMPLYING WITH ALL APPLICABLE LEGISLATION AND REGULATIONS

  • We shall comply at all times with all applicable legislation, common law, industry codes and the Group's rules, policies, procedures and regulations.
  • In addition to upholding the letter of all laws and regulations wherever we conduct business, Dawn will also continuously strive to uphold the spirit of such laws and regulations.
  • We shall not knowingly participate in the violation of any laws, rules or regulations.

WE ARE COMMITTED TO FOSTERING AND MAINTAINING AN EQUITABLE AND SUSTAINABLE EMPLOYER-EMPLOYEE RELATIONSHIP, INCLUDING THE PROVISION OF A SAFE, HEALTHY AND PRODUCTIVE WORKING ENVIRONMENT

  • The Dawn Group subscribes to the principles of the International Labour Organisation and complies with all relevant labour laws.
  • We respect the right of employees to work in an environment that is free from any form of unlawful discrimination or harassment.
  • We subscribe to the principle of transformation and equal opportunities.
  • We shall maintain a healthy and productive work environment and comply with all applicable health and safety policies.
  • We shall not tolerate the abuse of controlled substances or liquor or being under the influence of liquor or illegal drugs whilst at work.
  • We shall not tolerate the sale, distribution, possession, or use of illegal drugs or substances in the workplace.

 

WE SHALL PROTECT AND MAINTAIN THE PROPERTY AND INFORMATION OF DAWN, ITS EMPLOYEES AND ITS CLIENTS

  • The assets and property of the Dawn Group, including information gained and collected in the course of business, shall be used only for the business purposes for which they are intended.
  • The protection of property includes ensuring the privacy of client and employee information and the safeguarding of intellectual property.

WE SHALL MANAGE AND MITIGATE ALL CONFLICTS OR PERCEIVED CONFLICTS OF INTEREST

  • We will avoid any conflict of interest and share and declare any information that may cause a conflict of interest.
  • Where it is not possible to avoid a conflict of interest, we shall manage the potential conflict of interest.
  • We will not do anything that may be regarded as an attempt to exert influence in unduly favouring any party, including the offering, giving or receiptof any gift or gratification.

WE SHALL PROVIDE PROTECTION FOR ANY PERSON WHO REPORTS VIOLATIONS OF THE CODE

  • We will not tolerate any form of victimisation or retribution against those who attempt to uphold this code.
  • Any contravention of this code will be regarded as a serious matter and appropriate disciplinary action will follow after due consideration in respect of any breach.

MONITORING AND ENFORCEMENT

DAWN WILL:

  • not tolerate any contravention or violation of the Code of Ethical Conduct;
  • designate a committee to manage, monitor and report on the Group's ethical conduct;
  • designate senior officials to monitor compliance;
  • provide safe mechanisms for reporting breaches of this code;
  • investigate any alleged breach of this code; and
  • take appropriate action to remedy the breach.

WHERE TO OBTAIN GUIDANCE
Every employee has the right and responsibility to ask questions, seek guidance and express concerns regarding compliance with this code or the related implementation instructions of the guidelines. There are detailed Dawn policies regarding the various issues and principles supporting the Code which are available from Dawn HR. These will provide further guidance to employees. If and employee needs guidance on any ethical issue that concerns him/her, they may contact the following sources for assistance:

  • Their own supervisor or manager
  • Their business unit's HR manager / compliance officer
  • The Dawn Fraud and Ethics Hotline at contact no. 0800 86 46 55 operated by an independent third party and guaranteeing anonymity
  • They can also send an e-mail to fraud@kpmg.co.za if they are unable to call the hotline
  • The Dawn Group Ethics Committee

 

ANY EMPLOYEE'S REQUEST FOR HELP WILL BE TREATED AS STRICTLY CONFIDENTIAL

The names and contact numbers of the Ethics Committee members can also be found on the appropriate posters.

APPROVED BY THE DAWN BOARD OF DIRECTORS IN JULY 2016.