Anti-Corruption: 205-1 to 205-3

  • Management Approach

    Our approach towards social responsibilities is covered by our Purpose, which is ‘Inspiring a world of difference, enabling growth and progress in society’.

    Sustainable development underpins our strategic objectives and we recognise the need to be a Responsible Corporate through our strategy execution by ensuring our value delivery is achieved in a sustainable manner.

    It is also reflected in our sustainable development framework and our commitment to being a responsible corporate and the manner in which we manage Social/ and relationship capital and Natural capital.

    Barloworld’s Worldwide Code of Conduct defines foundational principles of responsible corporate citizenship that include; Obey the law, Respect others; Be fair and also sets out the group’s five core values of integrity, excellence, teamwork, commitment, and sustainability. It determines how our aspirations and values are translated into actions and behaviours. Our code of conduct reminds us of the standards to which employees and the group are accountable. One of the group’s values is Integrity.

    Anti-bribery and corruption
    Barloworld is fully committed to the fight against bribery and corruption and to preventing dishonest, fraudulent, corrupt and illegal conduct. This is central to the Barloworld Worldwide Code of Conduct, our values and ethics and reflected in policies and practices in the group. This approach applies to all business operations and countries in which the group operates.

    Our Barloworld Worldwide Code of Conduct includes the following under the Value of ‘Integrity’

    • We refuse to make or receive improper payments and prohibit all forms of bribery and corruption – In dealing with public officials, other corporations, suppliers and private citizens, we firmly adhere to ethical business practices. We will not seek to influence others, or seek to be influenced by others, either directly or indirectly, by paying or receiving bribes or kickbacks, including but not limited to payments to local officials by Barloworld employees or agents for the completion of routine governmental administrative actions, or by any other measure that is unethical or that will tarnish our reputation for honesty and integrity. Even the appearance of such conduct must be avoided.

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

    In 2018, the Barloworld anti-bribery and corruption policies were reviewed by an independent legal expert and based on this advice, changes were made to strengthen and improve the anti-bribery and corruption minimum requirements.

    The Barloworld anti-bribery and corruption policy includes the following statement:

    • ‘Barloworld is committed to maintaining the highest standards of honesty, integrity and ethical conduct.

      This and other Barloworld policies uphold our commitment to the fight against bribery and corruption, in both private and public sector transactions, including facilitation payments.

      This means that there is a prohibition of all forms of bribery and corruption throughout the group, including facilitation payments. We actively take steps to prevent bribery, extortion and other forms of corruption in our business and our dealings with third parties; and we proactively develop policies and procedures to prevent, investigate and address corruption, where it is suspected or reported.

      The current regulatory environment requires that we not only commit to conducting our business in an ethical and effective manner but that there is credible evidence to support these commitments.

      Evidence of our commitment to our values and building an ethical culture will not be found in any individual act or event but rather in the ongoing combination of activities that are integrated into the way we do business. The focus should be on maintaining a trail of evidence of the activities collectively rather than on any individual specific activity. ’

    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. The group’s Ethics and Compliance programme applies to all operations in the group and addresses corruption.

    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.

    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 the above, the Barloworld Worldwide Code of Conduct, the Barloworld policies on Anti-Bribery and Corruption, Gifts and Hospitality , Due Diligence of Third Party Service Providers and Suppliers, Supplier and Service Provider Code of Conduct, and the Anti-Fraud Management Policy 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 framework is implemented throughout all operations and regions, and includes appropriate training.

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

    Gifts received are recorded in gift registers in accordance with the group Gifts and Hospitality policy.

  • 205-1 - Operations assessed for risks related to corruption

    The reporting organization shall report the following information:
    1. Total number and percentage of operations assessed for risks related to corruption.
    2. Significant risks related to corruption identified through the risk assessment.
    Integrated Report:
    Social, ethics and transformation committee report

    In addition to the Barloworld Worldwide Code of Conduct, 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, while not responsible for the identification of fraud and/or corruption, considers potential indicators of corruption and fraud in the planning of their reviews.

    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.

    Potential risks identified include procurement related risks (e.g. invoice related fraud, bribes for awarding work) and credit card fraud. Risks identified also included collusion, bribery (including so called “corruption by/amongst private individuals”), interaction with public officials and money laundering in international used equipment transactions, which are rated as potentially high risks before management and mitigation procedures.

    All divisions adopt the ethics and compliance programme that is risk based and directed towards key priorities.

    The Group Ethics and Compliance Programme covers all operations. The annual High-Level Risk Assessment incorporates and assessment of ethics and corruption related risks. Within the Automotive operations all (100% - 222 sites) have been assessed for corruption related risks. A separate bribery and corruption risk assessment, which identifies high risk areas prone to bribery and corruption, has also been developed. All operations are covered by our ethics and compliance interventions.

    Within Equipment southern Africa a dedicated ethics, fraud, and anti-bribery risk assessment was conducted through an online assessment available to all regions and legal entities across all (100% - 14) Equipment southern African sites.

    Regular risk assessments are conducted throughout Equipment Russia operations including assessments of risks related to corruption. Two formal High-level risk assessment registers (HLRA’s) are tabled at Board level twice a year for all operations. Formal defalcation reporting is submitted twice a year.

  • 205-2 - Communication and training about anti-corruption policies and procedures

    The reporting organization shall report the following information:
    1. Total number and percentage of governance body members that the organization's anti-corruption policies and procedures have been communicated to, broken down by region.
    2. Total number and percentage of employees that the organization's anti-corruption policies and procedures have been communicated to, broken down by employee category and region.
    3. Total number and percentage of business partners that the organization's anti-corruption policies and procedures have been communicated to, broken down by type of business partner and region. Describe if the organization's anti-corruption policies and procedures have been communicated to any other persons or organizations.
    4. Total number and percentage of governance body members that have received training on anti-corruption, broken down by region.
    5. Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region.
    Integrated Report:
    VALUE CREATION THROUGH THE SIX CAPITALS AND OUR TRADE-OFFS - Intellectual CapitalGovernance - Ethical LeadershipSocial, ethics and transformation committee report

    In addition to the Barloworld Worldwide Code of Conduct, 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 and suppliers to take into account higher expected global standards for preventing bribery and these are applied throughout the Group.

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

    Communication and training of the group’s Worldwide Code of Conduct 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 Capital 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 2 558 (2019: 7 548) employees were covered by these processes and 1 492 (2019: 6 251) employees were trained within South Africa and 1 066 (2019: 1 297) employees were trained 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. Cumulatively, some 32 406 (2019: 29 848) employees have been trained specifically in the group’s anti-corruption policies and procedures.

  • 205-3 - Confirmed incidents of corruption and actions taken

    The reporting organization shall report the following information:
    1. Total number and nature of confirmed incidents of corruption.
    2. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.
    3. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.
    4. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.

    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.

    The Barloworld Worldwide Code of Conduct includes a guide on raising and reporting ethical issues, and actions that violate, or appear to violate the code.

    There is a confidential Barloworld Ethics line, which allows for anonymous reports 24 hours a day, 7 days a week for reporting of any Improper Conduct; and group oversight of the investigations processes.

    The Barloworld Global Whistle-Blowing policy sets out procedures for reporting improprieties or improper conduct so that the rights of employees and other associated persons are protected where such disclosures are made in good faith. All operations have well established grievance procedures in place. These are formal, documented and easily accessible to all employees.

    Given the sensitivity and confidential nature of such incidents and the impact on those involved, details would not be publically disclosed.

    The company can be contacted should there be further enquiries in this regard.