We continue to make progress in our sustainability journey and
each year strengthens our understanding and measurement of key
sustainability indicators across our business. Internally this journey has been guided by the social, ethics and
sustainability committee, Imperial’s unifying and controlling
factors the group’s Sustainability Framework and Strategy, and its
sustainability roadmap.
Social, ethics and sustainability committee
The role of the social, ethics and sustainability committee
encompasses all aspects of sustainability.
The committee performs statutory duties as set out in the
Companies Act, 71 of 2008 for Imperial Holdings Limited and
on behalf of subsidiary companies in the group. In addition
to its statutory duties, it assists the company in discharging its
social, ethics and sustainability responsibilities and implementing
practices consistent with good corporate citizenship, with particular
focus on the following:
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The King III Code of Corporate Governance. |
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Imperial’s sustainability commitments. |
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Broad-based Black Economic Empowerment (B-BBEE)
requirements as described in the Department of Trade and
Industry’s Combined Generic Scorecard (excluding ownership
targets) and associated Codes of Good Practice. |
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Imperial’s transformation commitments as described in the
group transformation strategy document and division-specific
B-BBEE plans. |
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Environmental commitments as described in Imperial’s
environmental policy framework. |
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Corporate social investment (CSI) commitments as described in
Imperial’s CSI policy. |
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Imperial’s Code of Ethics and Corporate Values. |
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Health and safety compliance. |
The committee has a standard agenda item at every meeting
covering material breaches of the group’s code of ethics, if any,
as well as the steps taken to prevent such breaches. No material
breaches of the group’s code of ethics were reported during
the year.
During the year, the committee discharged its statutory duties
as set out in the Act and Regulations thereto by monitoring the
company’s activities relating to:
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social and economic development, including the company’s
standing in terms of the goals and purposes of the 10 principles
set out in the United Nations Global Compact Principles, the OECD
recommendations regarding corruption, the Employment Equity
Act and the Broad-Based Black Economic Empowerment Act; |
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good corporate citizenship, including the company’s promotion
of equality, prevention of unfair discrimination, and reduction
of corruption, its contribution to development of the
communities in which its activities are predominantly conducted
or within which its products or services are predominantly
marketed and its sponsorship, donations and charitable giving; |
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the environment, health and public safety, including the impact
of the company’s activities and of its products or services; |
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consumer relationships, including the company’s advertising,
public relations and compliance with consumer protection laws;
and |
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labour and employment, including the company’s standing in
terms of the International Labour Organisation Protocol on
decent work and working conditions and the company’s
employment relationships, and its contribution towards the
educational development of its employees. |
The committee comprises non-executive directors who are not
involved in the day-to-day business of the group, executive
directors as well as other members of senior management of the
company and is chaired by a non-executive director.
Business integrity and ethics
The board has adopted a written code of ethics for the group.
Without satisfactory profits and a strong financial foundation, it
would not be possible to fulfil our responsibilities to shareholders,
employees, society, and those with whom we do business.
However, our corporate actions are not governed solely by
economic criteria, but also take into account social, environmental
and political considerations.
We strive to innovate and adopt best practice, wherever we
operate, working in consultation with stakeholders.
Management and employees operate within a framework that
requires complying with all applicable laws and maintaining the
highest integrity in conducting the group’s business.
Our core value is to act with uncompromising honesty and integrity.
Our code of ethics provides guidance to all staff, management and
directors of Imperial and its subsidiaries on adhering to this core
value, although we recognise that no single code can address every
situation individuals are likely to encounter. As such, this code is
not a substitute for employees’ responsibility and accountability
to exercise good judgement and obtain guidance on appropriate
business conduct.

Our divisions also include aspects of ethics in their induction
programmes. In addition, the group regularly conducts climate
surveys among its employees and ethics forms an integral part
of the surveys.
The group also maintains a confidential tip-off facility where any
instances of criminal activity of breaches of the code of ethics can
anonymously be reported. Reports in this regard are considered by
divisional management structures, internal audit and responsible
board committees.
Our code of ethics
At all times the group and, where appropriate, our employees will:
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Respect others and avoid any form of discrimination. |
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Abide by the laws of the country in which we operate and
comply with the code of conduct of all professional and
industry bodies to which we belong. |
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Avoid any waste, damage and private use of company assets
and resources (including time). |
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Neither give nor receive bribes. |
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At the earliest opportunity, disclose in writing to the
appropriate management all gifts received from clients or
suppliers beyond a token value. |
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Not divulge any confidential information to any party, or
improperly use company and client information. |
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Market our products and services accurately and charge the
agreed fee or a fair fee where no fee was agreed. |
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Not seek to advance our personal interests at the expense of
the company or our clients. |
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Not engage in any activity, directly or indirectly, which
results or might result in a conflict of individual interests with
the interests of the group. |
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Not participate, or involve the company in any way, in
any scheme that would cause embarrassment to the company
or harm its reputation. If we believe public disclosure of
any action would be detrimental to the company, this action
should be avoided. |
Employment and labour rights
The group subscribes to the principles of fair labour practices at our
workplaces, and our conditions of service comply with applicable
laws and industry standards.
The group recognises representative trade unions and has
established forums for communication.
Safety, health and environmental
stewardship
We report regularly at executive, board level and through the
SHE committee on our safety, health and environmental (SHE)
performance. Senior executives and line management are
accountable for the group’s SHE issues and for allocating adequate
financial and human resources within their operations to address
these matters.
We work to keep SHE at the forefront of workplace concerns.
Our objective is to prevent fatalities, work-related injuries and
health impairment of our employees.
Work-related fatalities are comprehensively investigated by
management and considered by the social, ethics and sustainability
committee.
We recognise the need for environmental stewardship to minimise
consumption of natural resources and waste generation, and to
minimise the impact of our operations on the environment.
Unifying and controlling factors
Imperial consists of a number of diverse transport and mobility
businesses, each with its own challenges, stakeholders and
operating environments. In addition to functions controlled or
initiated at group level, each business has its own sustainability
initiatives, designed to address areas of importance in that business
and the community in which it operates. This stems from the
group’s philosophy to empower local and divisional management
who are best placed to make decisions relevant to their business
and industry.
However, this decentralised management approach is balanced
by Imperial’s unifying and controlling factors. These outline the
general principles that govern how the company conducts its
business, stipulating the requirements to which all employees
must adhere regarding business integrity, quality, health, safety
and environmental protection, human rights, commitment to
the community, employment practices and compliance with the
local law.
It also provides for periodic review and audit to ensure the
continued relevance of and conformance to the guidelines.
Sustainability Framework and Strategy
Our Sustainability Framework outlines the key social, economic
and environmental areas in which our activities have a material
impact and facilitates group-wide measurement, reporting and
management of our performance in these areas. The primary focus
areas defined in the Sustainability Framework are:
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Energy and climate impacts – carbon output. |
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Social issues – transformation, diversity and skills development. |
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Health and safety – road safety and HIV. |
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Waste produced by group operations – discharges to air, landfill
and water. |

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