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Code of Conduct
1. Purpose and scope
This Supplier Code of Conduct (“Code”) sets out our (“Capitec Bank’s”) principles and expectations as to how companies that supply goods and services to Capitec Bank (“Suppliers”), including their representatives and employees (together “Supplier’s employees”) are to conduct business and deal with us. We offer a simplified and affordable banking solution, promoting accessibility and personal service to our clients and each other. We do this with a work ethic that promotes teamwork to succeed, taking personal responsibility to drive high performance, diversity for growth, transparency, innovation and integrity in everything we do. Our company, including all our employees, has a duty to comply with applicable laws and regulations, and we are expected to behave responsibly and ethically. We expect our Suppliers to operate with values comparable to ours and in a manner that is consistent with prudent business practices.
2. Business integrity
2.1 Compliance with laws
In all their activities, Suppliers must ensure that they conduct business in compliance with the applicable laws, rules and regulations of the jurisdictions in which they operate.
2.2 Conflicts of interest
In their relationship with our employees, Suppliers must not try to gain improper advantage or preferential treatment for other relationships they may have with us (for example, as a client).
2.3 Gifts and entertainment
Suppliers should not use gifts or entertainment, and their quality, quantity or timing, to gain improper advantage or preferential treatment. We expect that Suppliers will keep appropriate records of exchanges of gifts and entertainment with our employees. Gifts and gratuities include (but are not limited to) cash, EFT, vouchers, airtime, liquor, electronics, clothes, food, beverages, promotional items and product discount, and any other benefits that are not extended to all employees.
2.4 Anti-bribery and anti-corruption
Suppliers must not engage in any conduct that would put our company at risk of violating anti-bribery laws.
2.5 Confidential information and information barriers
Should Suppliers become aware of confidential information about us or our clients in their dealings with us, we expect Suppliers to have policies and procedures in place for the proper handling and use of that information (such as information barriers). These policies and procedures must meet the applicable legal and regulatory requirements to prevent inappropriate access to or disclosure of confidential information. Suppliers will also have to enter into a non-disclosure agreement with Capitec Bank.
3. Responsible business practices
3.1 Privacy and information security
Suppliers must comply with the POPI (Protection of Personal Information) Act which seeks to regulate the processing of personal information, and must use any information obtained through their relationship with us only for the purpose defined to them. Suppliers must process information as per the obligations in the POPI Act and have appropriate information security policies and procedures in place to secure access to our information. Suppliers must notify us promptly of actual or suspected privacy breaches, security breaches, or losses of our information.
3.2 Business resumption and contingency planning
For some services performed by Suppliers, because of the significance to our businesses or the types of activities that may be involved, we expect that the Supplier’s business continuity and disaster recovery plans are developed, maintained and tested in accordance with the applicable regulatory, contractual and service-level requirements.
3.3 Outsourcing and subcontracting
We recognise that outsourcing is a practice that Suppliers may use to promote innovation, fill resource gaps, and/or create operational efficiencies. We also recognise that Suppliers may need to use subcontractors in the performance of services. However, we expect Suppliers not to subcontract the services that they perform for us or outsource activities that directly impact on the delivery of goods and services to us, without our prior written approval. In situations where approval is given, it is important for us to know the locations of where the work will be performed and the parties involved in the provision of the services. In addition, Suppliers must monitor the outsourcing or subcontracting arrangement to ensure it complies with the Suppliers’ contractual obligations and with this Code, and must be able to provide evidence of such monitoring upon request.
4. Responsible treatment of individuals
4.1 Respect and diversity
Suppliers must maintain workplaces characterised by professionalism and respect for the dignity of every individual with whom their employees interact. Suppliers must respect the diversity of their employees, clients and others with whom they interact, including respect for profile, language, religion and gender. Suppliers must not tolerate harassment, discrimination, violence, retaliation and other disrespectful and inappropriate behaviour. Suppliers must respect the dignity of their own employees and others, and maintain a respectful workplace that values diversity.
4.2 Employment practices
Suppliers must abide by the applicable employment standards, labour, non-discrimination and human rights legislation. Where laws do not prohibit discrimination, or where they allow for differential treatment, we expect Suppliers to be committed to non-discrimination principles and not to operate in a way that differentiates unfairly. Suppliers must be able to demonstrate that, in their workplaces: child labour is not useddiscrimination and harassment are prohibited, including discrimination or harassment based on any characteristic protected by law employees are free to raise concerns and speak up without fear of reprisal appropriate and reasonable background screenings, including investigations for prior criminal activity, have been done to ensure the integrity and good character of the Supplier’s employees Clear and uniformly applied employment standards are used that meet or exceed legal and regulatory requirements 4.3 Health and safety
We expect Suppliers to provide healthy and safe workplaces and comply with relevant health and safety laws. We expect Suppliers to provide all their employees with adequate information and instruction on health and safety concerns and to enable their employees to meet their responsibilities for the maintenance of a healthy and safe workplace.
Suppliers should work with us to promote environmental sustainability. This includes that they assist in reducing our environmental footprint, conduct business in an environmentally responsible way, and offer environmentally responsible products and services.
Suppliers must not destroy our records that may be relevant to any pending or threatened legal or regulatory proceeding of which the Supplier becomes aware. Suppliers must maintain adequate internal records to ensure proper compliance with their obligations to us.
6. Code compliance and monitoring
We expect Suppliers to comply with this Code. For some services, because of their significance for our business and the type of activities they involve, we may require a Supplier to periodically confirm in writing to our Procurement department that they meet the requirements of this Code. In addition, we must be able to monitor and audit a Supplier’s control environment. Failure to comply with this Code may result in termination of a Supplier’s relationship with us.