Supplier Ethics Policy Issue date: 14 August 2013
Background RCL Foods Limited and its subsidiaries (the Group) are committed to the highest standards of product quality and business integrity in their dealings with customers and suppliers. As a result, all suppliers and employees who work with or for them are expected to conduct themselves with the highest standards of honesty, fairness and personal integrity. It is critical to the Group that suppliers and employees maintain high ethical standards, adhere to all applicable laws, and avoid even the perception of impropriety or conflict of interest.
Introduction This policy applies to all the Group suppliers. “Supplier” here means any business, company, corporation, person or other entity that supplies, or seeks to supply, any kind of goods or services to the Group, including the suppliers of employees, agents and other representatives. Questions concerning this policy may be directed to the Group Legal Department.
Acknowledgement and Application All the Group suppliers must acknowledge this policy and apply it in all dealings with, and on behalf of, the Group. Failure to sign and return the Ethics Certificate Form (a part of the Group’s Vendor Application) may result in supplier disqualification from consideration for business and/or future business with the Group. Suppliers are fully responsible for ensuring that any of their subcontractors, agents or other third parties that are employed in work for the Group, as permitted in terms of applicable agreements, will act in accordance with this policy.
Legal Compliance The Group suppliers must comply with all laws, regulations and policies applicable to them and their dealings with the Group.
Confidentiality and Insider Trading If, through the course of engagement, suppliers become aware of material, non-public information relating to the Group or its business, they may not buy or sell any securities of the Group or engage in any other action to take advantage of information, including the passing on of that information to others. In addition, if suppliers become aware of material, non-public information about any other company, including the Group customers, suppliers, vendors or other business partners, that is obtained by virtue of their interaction with the Group, then suppliers may not buy or sell that company’s securities or engage in any other action to take advantage of that information, including passing that information on to others.
Gifts, Entertainment and Other Suppliers may not offer, promise or provide to any employee of the Group a “kickback”, favour, cash, gratuity, entertainment or anything of value to obtain favourable treatment from the Group. The Group employees are similarly prohibited from soliciting and/or accepting such favours from suppliers. This prohibition extends to the offering, promising or giving of any favours to any family members of both the supplier and the Group employees or with any other persons with whom the Group has or the Group employees have significant personal relationships, in exchange for obtaining or retaining the Group’s business. As long as a gift is not intended to obtain favourable treatment from the Group, and does not create the appearance of a bribe, “kickback”, payoff or irregular type of payment, or otherwise raise any potential conflicts of interest, or break any applicable South African or International law,