CODE OF CORPORATE CONDUCT AND ETHICS

It is a fundamental policy of the Group to conduct its business with honesty, integrity and in accordance with the highest legal and ethical standards. The Corporate Code of Conduct and Ethics Policy governs the conduct of all employees. RCL FOODS’ induction programme educates new employees on the ethics, values and business culture of the Group. It is a requirement that all employees sign an acknowledgement that they have read and understood the contents of the policy and that contravention of the basic standards contained therein may result in disciplinary action, including dismissal. The Corporate Code of Conduct and Ethics Policy is available to all employees on the Group’s intranet.

Refer to King IV application register: Principle 2 for more detail on the Group’s governance of ethics, available on our website at www.rclfoods.com/financial-results-and-investor-presentations-2019

ANTI-BRIBERY AND CORRUPTION

RCL FOODS has a zero-tolerance policy with regard to bribery, fraud and corruption. The Corporate Code of Conduct and Ethics Policy sets the guidelines that define acceptable and responsible behaviour of the Group and all employees.

The code prohibits:

• all cash gifts;
• the giving or receiving of gifts, loans, favours or any other benefit which may be regarded as influencing business, labour or governmental decisions;
• donations or contributions to a political party; and
• engaging in activities which may involve a conflict of interest with the Group’s employment position.