Management approach disclosures

Local communities

Barloworld operations are predominantly in urban centres across the world. Their direct influence on local communities is relatively limited.

The group employs local people but, given the size of its operations, it cannot be regarded as the primary employer in any region. At its operations, the group interacts with local stakeholders as appropriate. Given the nature of its operations these usually do not relate to any material negative impacts of its operations.

The group contributes to the socio-economic development of its regions directly though employment, paying local taxes and levies, through its skills development, corporate social investment, supplier diversity and enterprise development programmes (link to EC8, SO1).

In terms of alignment of plans and measuring the impact of development initiatives, the group is committed to spending at least 1% of profits globally on corporate social investment.  Of South Africa profits, a regulated 1% is spent on socio-economic development and 3% on enterprise development initiatives, and 3% of payroll costs is levied for SETA’s for skills development: education, training and learnerships for previously disadvantaged individuals. 

The central and divisional CSI/SED and ED programmes align with elements of South Africa-specific Millennium Development Goals, the country’s National Development Plan, empowerment and transformation objectives and government’s regional and local integrated development plans, the objectives of the latter being increasingly included in public sector tenders.  The central CSI programme tracks the achievement of its non-governmental organisation development partners against KPIs linked to shared strategic objectives.

Corruption

Barloworld is fully committed to preventing dishonest, corrupt and illegal conduct. This is central to its Code of Ethics, the Barloworld Worldwide Code of Conduct and reflected in policies and practices in the group that prohibit corrupt behaviour. This approach applies to all business units and regions where the group operates. Risks are investigated prior to investing in regions where such practices may be more prevalent.

We address all reported allegations and other reports of potential impropriety, breach of the law or breach of Barloworld policy and deal with all cases as appropriate to the circumstances .

The group is a signatory to the UN Global Compact of which Principle 10 addresses corruption. The group Chief Executive has expressed continuing support for the UNGC’s 10 Principles (see GRI 1.1 and Barloworld’s 2014 COP). For details on the UN Global Compact, see: www.unglobalcompact.org.

Criminal behaviour is not tolerated and formal charges are laid against perpetrators. Internal proceedings are instituted against perpetrators who will be dismissed if found to have participated in unacceptable conduct. 

The group’s risk management approach covers all operations and risks associated with corrupt and dishonest behaviour. These are analysed and assessed as part of the risk management process.

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

There are processes in the group to review compliance with legislation, company ethics, codes and policies. 

In addition to our Code of Ethics, the Barloworld Worldwide Code of Conduct and Anti-Fraud Policy, the Barloworld policies on Anti-Bribery and Corruption, Gifts and Hospitality and Due Diligence of Third Party Service Providers are implemented across the group and employees are required to comply.

It is the responsibility of the ethics and compliance managers throughout the group to ensure that the Barloworld Group Ethics and Compliance programme is implemented throughout all operations and regions.

To ensure that conflicts of interest are avoided, employees are required to formally declare any direct or indirect interests in contracts and/or businesses. Barloworld board members and divisional executives are also required to disclose conflicts of interest and gifts received are recorded in gift registers. This also applies to trustees of the group’s retirement and medical aid funds.

Public policy

The group is a member of a number of organisations the objectives of which include policy development and advocacy, such as Business Leadership South Africa.

In addition, our operations across the world belong to organised business associations and advocacy groups where they operate.

The group and its divisions participate in relevant industry forums and industry lobbying and policy development activities.

By participating in these initiatives Barloworld contributes to wider society, has an opportunity to share knowledge, raise concerns and influence policy.

Anti-competitive behaviour

The group does not condone anti-competitive behaviour and has policies and procedures as well as training programmes in place to ensure compliance.

Compliance

Barloworld is driven by the maxim of creating sustainable value for all its stakeholders.  What sets the group apart is its ability to develop and maintain mutually beneficial long-term business relationships. This is called the ‘Barloworld Way’.

The group is committed to responsible business conduct and best practices. All group activities are guided by the governance framework of ethics and a commitment to legal compliance. The group upholds the King III principles that good governance combines both regulatory requirements and voluntary standards of excellence.

The programme is structured to meet the requirements of King III, legal and regulatory requirements and other international best-practice standards. It applies to all group companies, at all locations around the world.

There are two parts to the programme. The ethics framework establishes overall governance standards. It provides an overview of the context for the programme; defines roles and responsibilities; sets out the principles to be applied and standards required to meet these principles. The framework sets the ethical foundation and governance of Barloworld. It includes the Code of Ethics and the Barloworld Worldwide Code of Conduct.

The second part is a detailed compliance standard that defines specific operational requirements for creating, maintaining and improving policies and procedures.  Standards provide a defined and structured approach that aligns with the ethical framework. 

Roles and responsibilities for ethics and compliance have been defined and in each division there are designated executives and managers with specific responsibility for the ethics and compliance programme.

Each division is responsible for planning and executing appropriate actions to manage key priorities for ethics and compliance.

A number of new policies have been developed and approved and these include Anti-Bribery and Corruption, Gifts and Hospitality, Hosting Customer Events, Sponsorships and Donations and a Due Diligence Policy for third party service providers and suppliers.

The monitoring of progress against plans is the responsibility of divisional management, and in addition, summary reports are submitted bi-annually to the Group Risk and Sustainability committee and to the Social, Ethics and Transformation committee as appropriate.

As a global company, Barloworld is committed to upholding international standards and meeting regulatory requirements in the regions and countries in which it operates. The programme provides a framework that consolidates all aspects of governing the business and sets a global standard of excellence.

Entrenched in its Code of Ethics and Worldwide Code of Conduct is the requirement to ‘Obey the law’. This is the minimum requirement and the organisation strives to conduct its operations as a responsible corporate citizen. 

Where possible, the group also participates in formulating responses to draft policy and legislation.