Ethics management and tip-offs

In line with King IV recommendations, a formalised ethics management programme has been initiated at all of the Group’s businesses. This programme is managed by the Group Governance Officer under the direction of the Social & Ethics Committee and is aimed at:

• assisting the Audit & Risk Committee and the Social & Ethics Committee in assessing the Group’s ethics profile, risks and opportunities; and
• assisting the Social & Ethics Committee to monitor implementation and compliance with the Group’s policies which guide expected ethical behaviour.

Aspen’s induction programme educates new employees on the ethics, values and the business philosophy of the Group. All new employees are given a copy of, and are required to sign an acceptance of, the Code of Conduct on commencement of their employment with the Group. The Code of Conduct is available to all employees on the Group’s intranet and is also contained in the employee handbook.

The Group conducts its business in a highly regulated environment, however, one in which the potential for unethical marketing and promotional practices remains inherent. Aspen endorses the ethical marketing of medicines and subscribes to the rigorous application of the Marketing Code of Practice of the Pharmaceutical Industry Association of South Africa. The Group has a written policy on gifts and benefits in terms of which employees of the Group, including directors, are prohibited from accepting or giving gifts or hospitality that are not of a nominal value or participating in events sponsored by current or prospective customers or suppliers. Any employee who receives a gift or other benefit exceeding the local currency equivalent of USD100 is required to disclose this in writing to the Company Secretary. Some types of gifts, benefits or entertainment are prohibited even if the value falls below this threshold. A Group-wide register of gifts is maintained by the Company Secretary and is noted by the Social & Ethics Committee on a periodic basis. This register is also made available for inspection by the Board or any member of senior management on request.

Aspen does not make payments or other contributions to political parties, organisations or their representatives or take part in party politics. Employees are free to participate in the political process in their private capacity provided it does not constitute a breach of the principles set out in the Code of Conduct and/or the relevant employee’s obligations to Aspen under contracts of employment and does not negatively influence their productivity or the credibility of the Group.