Corruption: SO2 - SO4

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

    Integrated Report 2014:
    Corporate governance report 2014:

    In addition to its Code of Ethics and Barloworld Worldwide Code of Conduct, Barloworld has an Anti-Bribery and Corruption policy and other related policies to take into account higher expected global standards for preventing bribery and this has been communicated and is now 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 a high level assessment of ethics and compliance risks and key priorities. All business units that are owned through the group's UK investment company have also conducted an in-depth assessment of bribery and corruption risks.

    For more detail also see policies.
  • SO3 Percentage of employees trained in organisation's anti-corruption policies and procedures.

    Integrated Report 2014:
    Corporate governance report 2014:

    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 is an ongoing process conducted 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 Code of Ethics, the Barloworld Worldwide Code of Conduct and anti-fraud policy, Barloworld has also adopted 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 have been communicated and are now applied throughout the Group.

    For more detail also see policies.

    Communication and training of the group's Worldwide Code of Conduct and Code of Ethics has been conducted at all divisions and business units.

    The group's ethics and compliance programme 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 6 431 employees were covered by these processes and training 4 264 within South Africa and 2 167 outside South Africa. Management teams in all operations across the group participated in related assessment and training as part of the group ethics and compliance programme rollout. Since the 2012 reporting period, a total of 21 113 employees have been covered. This training is also incorporated in various programmes which include our Induction and orientation, as well as diversity training.

    A key focus continues to be on improvements 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.