PUTTING THE CODE INTO PRACTICE
THE CODE
A MESSAGE FROM OUR GROUP CEO
PUTTING THE CODE INTO PRACTICE
RECORD KEEPING
COMPLIANCE WITH LAWS AND THE CODE
THE IMPORTANCE OF BEING
HONEST
We are expected to operate with the highest level of honesty and integrity, to foster a culture of trust among our team, and inspire confidence in our Company from our customers, business partners and shareholders.
FAIR DEALING – WE ALWAYS PLAY BY THE RULES
We operate with the highest level of integrity. Any action taken on behalf of GK by a team member, should be fair to all parties involved. While we strive to excel, our accomplishments must be achieved with honesty and fair dealing.
RELATIONSHIPS WITH COMPETITORS
GraceKennedy welcomes competition, which we believe is integral to creative thinking and innovation. We build our brand and position ourselves as market leaders through honest and fair business practices, and by providing superior products and services.
- No false or misleading advertising
- No collusion or price fixing
- No untrue statements about competitors
RECEIVING OR GIVING OF GIFTS
Our business transactions are impartial, objective, and professional and we do not engage in these transactions for personal gain.
Offering and accepting gifts, favours and entertainment is customary in business. Doing so can promote goodwill and enhance a business relationship. However, a gift or favour should not be accepted, or given, if it might create a sense of obligation, compromise your professional judgment, or create the appearance of doing so. In deciding whether a gift is appropriate, we should consider its value and whether public disclosure of the gift would be embarrassing to us or our Company. Sometimes, it may be unclear whether a gift is appropriate. In such instances, clarity should be sought from a manager or supervisor.
Any offer of a gift, hospitality, or other service, that may have a monetary value above US$50, should be declared, including those received by third-party contractors, suppliers and business partners working on our behalf.
We always use tact and diplomacy when declining gifts, so as not to affect our business relationships. If refusing a gift may appear impolite, then we may accept the gesture on behalf of our Company, but not keep it for personal use.
CORRUPTION AND BRIBERY
We always conduct business responsibly, which reinforces our reputation of acting with integrity and fair dealing. We do not offer favours, promises, money or anything of value to any person, government official or entity, with the aim of improperly obtaining or retaining business for GK, or influencing the consideration of any business activity.
CONDUCTING BUSINESS WITHIN GK
When team members are conducting business within GK, the transaction should be handled in the same way as any other customer transaction, unless there is a specific documented benefit or concession pursuant to Company policy.
THEFT
We all benefit when there is a mutually rewarding relationship between team members and management. When trust is broken, we jeopardise our brand and the success of our business. Stealing from our Company, colleagues or customers breaches trust.
Anyone who steals from GK or helps others to do so, is likely to be dismissed and may face criminal prosecution. The improper use of Company benefits, or facilities, is also considered to be a type of theft.
COMPANY REPUTATION
GK respects the rights of team members, but we must be mindful of how our behaviour, in a professional or private capacity impacts the Company’s reputation and our own. Behaviour which brings GraceKennedy’s reputation into disrepute will be dealt with in accordance with the Company’s policies and procedures and may lead to disciplinary action including dismissal where appropriate.
RECORD KEEPING
Properly maintaining accounts and records which accurately reflect our transactions and other business activities is extremely important. This helps us make responsible business decisions and provide truthful and timely information to the investing public, our internal and external auditors, regulators, and other relevant authorities. The information we provide must be complete and not misleading.
If a discrepancy is detected, it must be promptly reported using the appropriate channels.
Company records should only be accessed to conduct Company business and with the required authorization.
USING GK FACILITIES
We should only use GK property, facilities, and time for company business, except in circumstances which are insignificant or nominal, or with the approval of our supervisor.
SAFEGUARDING OUR ASSETS
The GK team is often provided with Company assets to carry out their job functions. Some examples are: Physical assets such as, premises, equipment, supplies, cash, and cash equivalents Intangible assets such as, intellectual property, computer systems, software, internet access, and other information technology We share the responsibility of being good stewards of these assets, which means always taking care to avoid their loss, damage, waste, and improper use, whether at a GK facility or offsite.
GK team members are also responsible for any Company assets that have been entrusted by them to third parties. Should a situation occur that results in loss or damage of any GK asset it should be immediately reported to a manager or supervisor.
CONFLICT OF INTEREST
Conflicts of interest can arise when activities outside of work, ownership interests in other companies, or personal relationships interfere, or appear to interfere, with our ability to do our job, make unbiased decisions on behalf of our Company, or act in its best interest. Even the appearance of a conflict of interest can make others think we are acting improperly and should be avoided.
It is important for GK Team members to disclose their interests, in keeping with the Disclosure of Interests Policy, to allow for the identification and management of potential, perceived or actual conflicts of interest.
CONFIDENTIALITY
As GK team members we may have access to sensitive information. All sensitive information must be treated confidentially.
Only GK team members who need this information to conduct our Company’s business are to be given access to it. This information must only be used for Company purposes. It must not be disclosed to anyone, inside or outside of GraceKennedy, unless there is a legal basis on which to do so, or the required consent/authorization has been given.
We all have a personal responsibility to protect confidential information against unauthorized disclosure or misuse, even if we are no longer employed or associated with GK.
Confidential Information refers to any information of value, in all forms, related to the affairs of the Company, which is not publicly available, and if disclosed could result in a competitive or other disadvantage to GraceKennedy.
It may include:
INTELLECTUAL PROPERTY
INSIDER TRADING AND TIPPING OFF
Insider trading and tipping off Insider information is information that is not generally available to the public, but, if it were, would likely influence a company’s stock price. It is illegal for any person who has insider information to buy or sell that company’s stocks.
Team members who have insider information about any company in the GraceKennedy Group, are insiders. Insiders must not buy or sell the stocks of GraceKennedy, or any other publicly listed company in our Group, when they have insider information. The same rules apply whether you buy or sell the stocks yourself, or you give the information to someone else, who then uses it to buy or sell stocks; the latter is referred to as ‘tipping off’. More details can be found in our Insider Trading Policy.
MONEY LAUNDERING
Money laundering undermines the integrity and functioning of financial systems, good governance, and the fight against corruption. GraceKennedy is committed to full compliance with anti-money laundering and anti-terrorism laws and regulations globally. GK team members have a responsibility to ensure compliance with our Company’s governance framework, applicable regulations, and guidelines for the prevention of fraud and money laundering.
GK’s objective is to only conduct business with customers and partners involved in legitimate business activities, based on the Company’s applicable “Know Your Customer” due diligence processes.
If you become aware of a suspicious transaction, you must report it in accordance with Company procedures.
