CODE OF ETHICS & CONDUCT

Table Of Content

1. ETHICAL VALUES & WHO WE ARE

  • 1.1. Ethical Values
  • 1.2. Personal responsibility

2. HOW WE CONDUCT BUSINESS

  • 2.1. Anti-bribery and corruption
  • 2.2. Selection of and working with third parties
  • 2.3. Gifts, meals and entertainment
  • 2.4. Conflict of interest
  • 2.5. Political activities and donations
  • 2.6. Accurate Records
  • 2.7. Anti-money laundering

3. HOW WE WORK TOGETHER

  • 3.1. Discrimination
  • 3.2. Harassment
  • 3.2. Harassment

4. IF YOU ARE UNSURE

  • 4.1. Ethical Decision Making Guide

5. RAISING CONCERNS

  • 5.1. Reporting violations of the code
  • 5.2. Non-retaliation/Speak up reporter protection

6. ADDITIONAL INFORMATION

  • 6.1. Dissemination and Amendment
  • 6.2. Revision History
  • 6.3. Glossary/definition of key terms

ETHICAL VALUES

  • WE ARE HONEST

We tell the truth to ourselves and the others

  • WE HAVE A SENSE OF RESPONSIBILITY

We recognize that doing the right thing is not always easy

  • WE ARE COMPLIANT

We comply with the law and our policies

  • WE SHOW RESPECT TO PEOPLE

We are tolerant, empathetic and appreciate differences

We should all live up to these ethical values in our day-to-day work. The Code of Ethics and Conduct (the “Code”) describes how to do so in more detail, and describes our expectations of our people, and those with whom we work. The Code supports our strategy, and helps to protect our people and reputation as a responsible beverage bottler.

PERSONAL RESPONSIBILITY

We all have a duty to act in accordance with our ethical values and the Code. Failure to comply with the Code may result in disciplinary action, including, but not limited to, verbal or written warnings, cancellation, demotion and termination, subject to local laws and regulations. Certain violations of the Code may require SLMG to refer the matter to law enforcement authorities for their investigation or prosecution. Any employee who directs, approves or ignores any conduct that violates the Code, or who knows about such conduct and does not immediately report it, will also be subject to disciplinary action, up to and including termination.

HOW WE CONDUCT BUISNESS

ANTI-BRIBERY & CORRUPTION

A bribe is the offering, promising, giving, accepting, or soliciting of something of value, in return for something illegal or a breach of trust. Corruption is the abuse of public authority or power, for private gain, and often takes the form of bribery of public officials.

SLMG has a zero-tolerance approach to bribery. It considers any form of bribery to be dishonest, immoral, unacceptable and such behaviour is prohibited.

The penalties for bribery apply if the illegal conduct is done directly by our employees or by third parties working on our behalf, such as agents, distributors, consultants or intermediaries.

It is also prohibited to make payments that are not supported by real deliverables and correct paperwork.

SELECTION OF AND WORKING WITHTHIRD PARTIES

We are committed to making a positive contribution to society and the environment, by developing and implementing ethical business practices. We take pride in being an ethical business, and we expect our business partners to share our standards. We strive to continuously improve and strongly believe that building long-term, collaborative relationships with our business partners is crucial for our business. We value honest and open communication with them and believe that transparency is vital to successful business relationships. We are careful and fair about how we select and use suppliers, distributors and other business partners. All our third parties are expected to comply with applicable laws & regulations and must act with the highest level of business, professional and legal integrity. Where relevant, we screen our third parties, to ensure there is no indication that they will not adhere to our ethical standards

GIFT, MEALS & ENTERTAINMENTS

Bribery may not only involve cash. It can include anything of value including gifts and entertainment, so these are a high-risk area. Care must be taken when giving gifts, meals and entertainment and also when receiving them. While employees may give or receive modest gifts, meals and entertainment in the ordinary course of their business, it can never be done in return for or in expectation of something improper. You must not accept, or permit any member of your family to give or accept, gifts or other favours from any customer, supplier or other person who deals with SLMG. If immediate return is not practical, such gifts should be given to the HR representative, to be disposed of in an appropriate way. It must never be in return for something improper or compromise your ability to make objective and fair business decisions in the interest of SLMG. Those in Procurement must take extra care, and they are not permitted to accept any gifts, entertainment etc. from third parties with whom we may or are doing business. No services should be used for household / personal work by Contractors / vendors deployed in factory, offices etc.

DO’s DONT’s
Do register gifts and ensure you obtain the relevant approval beforehand. Never give or receive any gifts, meals or entertainment if something improper is expected in return
Do ensure any gifts, meals or entertainment are appropriate and proportionate, given the circumstances. Never give or accept something of value, if this could compromise your ability to make objective decisions in the best interest of SLMG.
Do take extra care when dealing with public officials, as any gifts, meals or entertainment given to them, are extra high risk Don't accept any gift, meal etc. which is not given openly and transparently

CONFLICT OF INTEREST

A conflict of interest occurs when your personal interests such as your family, friends, other work (e.g. consultancy or voluntary work) or your political interests, may influence your ability to act objectively and in the best interest of SLMG. Conflicts of interest can sometimes occur without any action on your part. You must therefore take care to avoid such conflicts in the first place, and not engage in any activity in which may, or could be perceived, to affect your decision-making, for SLMG. Those in Procurement must take extra care, as they make commercial decisions on behalf of SLMG as part of their daily work and those decisions should not be compromised by other factors. Proactively disclosing any actual or potential conflicts of interest is just as important as avoiding them. You must disclose any actual or potential conflict of interest to your manager or HR Representative. If a conflict cannot be avoided completely, appropriate mitigating actions must be identified, to prevent the conflict from affecting decisions in the best interest of SLMG. The mitigating actions must be approved by your manager. You and your manager are responsible for ensuring the approved mitigating actions are properly implemented.

DO’s DONT’s
Do proactively disclose any actual or potential conflict of interest early. Don't be involved in any decisions for SLMG, where there is an actual or potential conflict of interest
Do continue to disclose any conflict of interest, for as long as the situation exists. Don't hide an actual or potential conflict of interest - once we know about it, we can help to ensure the proper safeguards are in place to protect you and SLMG.
Do adhere to any mitigating actions which have been put in place, to minimize the effect of a conflict of interest.

POLITICAL ACTIVITIES & DONATIONS

Like most companies, our business requires political and Government relationships. However, if you as an individual get involved in politics, you must not make statements or make (financial) contributions to political organisations on behalf of SLMG. If you make any political statements on social media or other channels, it is important that you clearly state that those views are your own and not of the organization.

Official spokesperson or specially denoted representatives will represent such views if they are required. Donations to charity are supported, but they must be made in a transparent way.

ACCURATE RECORDS

Accurate and reliable financial and business records and statements are essential, to meet high standards and to ensure compliance with financial, legal, and business obligations. SLMG’s financial books, records, and statements must properly document all assets and liabilities, and accurately reflect all transactions of the company. It is therefore vital that our books, records and other public reports are full, fair, accurate and timely.

HOW WE WORK TOGETHER

DISCRIMINATION

We do not tolerate any form of discrimination based on distinguishing characteristics such as race, colour, gender, religion, political or other opinion, national or social origin, sexual orientation, age or disability. SLMG aims to create equal access to opportunity to all, regardless of social identity. Employment-related decisions, from hiring to termination and retirement, must be based solely on lawful, non-discriminatory criteria, such as performance, potential, qualifications and experience.

HARRASSMENT

SLMG is committed to treating every employee with dignity and respect, and to promoting equal opportunities. We do not tolerate any acts of physical, verbal, sexual or psychological harassment, bullying, abuse or threats in the workplace, nor in any work-related circumstance outside the workplace, by either fellow employees or managers.

WORK PLACE HEALTH & SAFETY

SLMG proactively strives to protect human health and wellbeing, to provide a healthy and safe working environment for our people, and to ensure the highest level of protection and preservation of our assets and the environment. We are committed to promoting a zero-accident culture and aim to prevent all accidents and injuries including process and occupational illnesses in our operations. All SLMG entities seek to achieve our self-imposed strict environment, and health and safety standards, and we always comply with applicable local laws and regulations.

IF YOU AREUNSURE

THE CODE IS NOT EXHAUSTIVE

The purpose of the Code is to ensure that our employees and those with whom we work have a clear understanding of the ethical values that we want to uphold. It is designed to promote the commitment to work with integrity, and in a responsible, honest and ethical way. The Code however cannot directly cover every situation that might arise, and employees and business partners must use sound judgement and common sense in everything they do on behalf of SLMG. To assist those in difficult cases where the “right thing” is unclear, the ethical decision tree below sets out the key questions to ask yourself, to determine whether a particular course of action is consistent with ethical values and the Code.

ETHICAL DECISION-MAKING GUIDE

You may face circumstances where you may not be certain, or SLMG does not have a clear policy or standard. If so, ASK YOURSELF these questions to help you make the right choice and do the right thing.

RAISINGCONCERNS

REPORTING VIOLATIONS OF THIS CODE

You are responsible for asking questions, seeking guidance and reporting any suspected violations regarding compliance with the Code. If you know or suspect that any employee or representative of SLMG has or is engaging in conduct that violates applicable laws or the Code, you should report this to your manager. Any manager who receives a report of a violation of the Code must immediately inform the immediate manager or HR representative and not begin an independent investigation themselves. Reports which are made in good faith will be investigated and accordingly appropriate, relevant action will be taken. You may report actual or suspected violations of the Code anonymously by contacting the immediate manager or HR representative. All reports will be reviewed and investigated by an independent team, to ensure confidentiality of the reporter. Reports will be acknowledged once received and after investigation, the reporter will be informed that the investigation is complete. Investigations of the most serious matters of misconduct reported and received are overseen by the Integrity Committee – an independent body which is chaired by the COO, and includes senior representatives from HR, Audit and Legal & Compliance.

NON-RETALIATION/ REPORTERS PROTECTION

SLMG strictly prohibits retaliation against any employee who report violations of the Code or SLMG policies in good faith or cooperate in any investigation relating to improper conduct. Managers may not dismiss, demote, suspend, threaten, harass or in any other way discriminate against an employee who, in good faith, reports a suspected violation.

ADDITIONALINFORMATION

DISSEMINATION AND AMMENDMENT

This Code will be made available to all new employees of SLMG upon commencement of their employment or other relationship with the company. Each employee must certify that he/she has received, read and understood the Code and agrees to comply with its terms. SLMG reserves the right to amend or terminate the Code at any time for any reason.

REVISION HISTORY

The Code must be reviewed at least every three years and may be amended at any time with the approval of the Executive Committee.

GLOSSARY/DEFINITION OF KEY TERMS

Bribe

A bribe is the offering, promising, giving, accepting, or soliciting of a something of value, in return for something illegal or a breach of trust.

Corruption

Corruption is the abuse of public authority or power, for private gain, and often takes the form of bribery of public officials.

Facilitation payments

Facilitation payments are a type of small bribe, typically requested by a public official, to facilitate or speed up a routine transaction or service

Conflict of Interest

A conflict of interest occurs when your personal interests such as your family, friends, other work (e.g. consultancy or voluntary work) or political interests, might influence your ability to act objectively and in the best interest of SLMG.

Trade sanctions

Trade sanctions are national and international laws restricting business transactions with certain countries, organizations and individuals.

Anti-money laundering (AML)

Anti-money laundering refers to the laws, regulations and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.

Corporate assets

Corporate assets include physical assets (e.g. real estate, buildings, machinery), intangible assets such as its intellectual property (IP) rights (e.g. trademarks, patents, copyright, trade secrets etc.) and other confidential information.

Personal Data

Personal data is any information that relates to an individual. Examples include: name and address, someone’s picture, their date of birth, banking information, social media posts, IP address etc.

Intellectual property right

These are legal right in creations resulting from human ingenuity, creativity and inventiveness.

Inside information

Inside information is information which is non-public, precise, relates directly or indirectly to SLMG, and is likely to have a significant effect on the reputation of SLMG, if the information were made public.