1. Purpose and Scope
RAC Human Capital (Pty) Ltd (“the Company”) is committed to conducting its business with honesty, integrity, and in full compliance with applicable laws and regulations, including South Africa’s Prevention and Combating of Corrupt Activities Act, 2004 (Act No. 12 of 2004). The purpose of this Anti-Bribery and Corruption Policy is to ensure that the Company maintains a zero-tolerance approach towards bribery and corruption in all forms.
This policy applies to all employees, directors, officers, contractors, consultants, suppliers, and any other third parties acting on behalf of RAC Human Capital (Pty) Ltd, regardless of their location.
2. Definitions
- Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of an official or other person in a position of authority.
- Corruption: The abuse of entrusted power for private gain, including activities such as fraud, embezzlement, and nepotism.
3. Policy Statement
RAC Human Capital (Pty) Ltd strictly prohibits any form of bribery or corruption. Employees and third parties acting on behalf of the Company must not engage in activities that could be perceived as corrupt, unethical, or illegal. This includes offering, promising, giving, or accepting bribes in any form, whether directly or through intermediaries.
4. Gifts, Hospitality, and Entertainment
- Employees and representatives of RAC Human Capital (Pty) Ltd must not offer or accept gifts, hospitality, or entertainment that could be viewed as an attempt to influence a business decision.
- Any gifts or hospitality that exceed a nominal value must be reported to management and recorded in the Company’s Gift and Hospitality Register.
- The acceptance of gifts or entertainment is only permissible if it is of reasonable value, infrequent, and intended for legitimate business purposes.
5. Third-Party Relationships
The Company expects its business partners, suppliers, and contractors to comply with all anti-bribery and anti-corruption laws. Due diligence must be conducted before engaging with third parties, and any suspicion of unethical behavior must be reported to the Compliance Officer immediately.
6. Facilitation Payments
Facilitation payments, which are small payments made to expedite routine governmental actions, are strictly prohibited by RAC Human Capital (Pty) Ltd. Employees must avoid making any such payments, even in regions where such practices may be common.
7. Political and Charitable Contributions
The Company does not make contributions to political parties, candidates, or organizations with the intention of obtaining or retaining business or securing any other improper advantage. Any charitable contributions made on behalf of the Company must be transparent, lawful, and aligned with the Company’s corporate social responsibility goals.
8. Reporting and Whistleblowing
Employees and third parties are encouraged to report any suspicions or knowledge of bribery or corruption involving RAC Human Capital (Pty) Ltd. Reports can be made anonymously through the Company’s Compliance Officer. No employee will face retaliation for reporting concerns in good faith.
9. Consequences of Non-Compliance
Non-compliance with this policy will result in disciplinary action, which may include dismissal, termination of contracts, and legal action. The Company will cooperate fully with law enforcement in investigating any instances of bribery or corruption.
10. Training and Awareness
RAC Human Capital (Pty) Ltd will provide regular training to all employees on anti-bribery and corruption laws and the Company’s zero-tolerance approach. All employees are required to familiarize themselves with this policy and adhere to its principles.
11. Monitoring and Review
The Company will periodically review this policy to ensure it remains effective and complies with any changes in laws or regulations. The Compliance Officer is responsible for monitoring compliance with this policy and ensuring that appropriate systems are in place to prevent bribery and corruption.
Date of Implementation: 12 February 2024
Approved by: Ronald Joubert
Contact Information: For questions or concerns about this policy, please contact the Compliance Officer at [email protected]
By following this policy, RAC Human Capital (Pty) Ltd aims to uphold the highest ethical standards and ensure the integrity of its operations.