Tiger Brands is committed to ethical business practice, and building a culture in which ethical behaviour is promoted, expected and naturally expressed through everyday interactions and engagements.
We are proactive in building an ethical workplace and culture, and have mechanisms in place to ensure that the principles expressed in our ethics-related policies are known, accepted, and put into practice every day by our people. Tiger Brands is a member of the Coalition for Ethical Operations, through which we support actions to combat unethical behaviour and corruption in our industry.
Our key policies
All our ethics policies, including our code of conduct, are regularly reviewed and updated, and made easily accessible for staff on our intranet. Ethics awareness activations feature routinely as part of internal communications, including through the placement of posters and banners online and at our facilities. We ensure that our ethics policies are translated into practice through routine and targeted ethics training, robust and expeditious Ethics Line investigations, and internal publication of our ethical behaviour trends and actions taken against perpetrators.
OUR CODE OF CONDUCT
Our code of conduct (code) represents a clear commitment to upholding good ethical practice in the workplace. All our employees subscribe to the code, which aligns with, inter alia, our human rights policy, diversity policy, and disciplinary code. Similarly, all or suppliers are required to acknowledge compliance with our supplier code of conduct, which aligns with our human rights policy and ethical sourcing policy. The code clearly frames all aspects of workplace-related ethics and provides explicit guidance on putting these ethical principles into practice in everyday and work-related situations. The code foregrounds respect for human rights, and encourages the fostering of diversity and the provision of equal opportunities. All forms of discrimination and harassment are prohibited, whether based on gender, race, nationality, ethnicity, age, religion, marital status, sexual-orientation or disability. The code was last updated in 2020.
Consistent with our code and other ethics policies, we ensure that:
We ensure that our employees receive regular training on ethics, including targeted training on human rights and to combat corruption and bribery among senior managers. Ethics learning is undertaken in-person at various sites, and online via a digital e-learning platform. This year, we rolled out in-person ethics training across our Grains business, after completing the same for Bakeries and part of Milling. The annual completion of an e-learning module on our code of conduct is mandatory for all employees, including all new employees. Prior to Covid-19, there was a mandatory in-person induction session on compliance and ethics for new employees, and this is being re-introduced. Looking forward, we plan to increase the total number of employees trained, and strengthen consequence management for those who do not complete the training. Our corporate communications department runs routine ethics awareness activations annually. In 2022, 65% of employees completed the ethics training.
Recent years have brought significant changes in the business and human rights landscape, including stronger public scrutiny, the emergence of new legislative instruments and more detailed disclosure requirements. While the South African Constitution is strong on human rights, all of our markets in Africa are widely considered high-risk for human rights abuses. Crises like climate change and Covid-19 further destabilise society, and threaten to heighten the risk of human rights abuses.
Human rights is a key concern for Tiger Brands, with our exposure to human-rights risk potentially greatest in our supply chain. We are committed to promoting and protecting human rights in our own operations and through our supply chain, and aim to steadily improve our related management approach and processes. Taking action to protect human rights aligns with our core purpose and corporate values, and we fundamentally believe that upholding human rights helps build a society worth doing business in.
Our human rights policy is regularly reviewed and updated, with the most recent iteration published in 2020. The policy has been developed to uphold the inviolable rights of people and to protect the group, our stakeholders, assets and reputation. The policy establishes the principles and responsibilities for monitoring, managing and reporting on human rights’ impacts and risks. It aligns with our ethical code, and applies to our own operations and to our suppliers, as well as all employees, temporary employees, contractors, service providers and consultants.
The policy is available online at www.tigerbrands.com
Human rights awareness is a regular feature of our annual internal communications programme, including the promotion of our whistleblowing Ethics Line, through which all employees and any person in our extended stakeholder network can report a potential human rights abuse. Content on human rights that relates to our code of conduct is integrated into our annual ethics-training calendar, is included in our induction programme for new employees, and is available as an online learning module for staff to access.
We watch the media and keep abreast of Corruption Watch reports to obtain visibility on potential human rights abuses in our supply chain. Audits for compliance with our ethics policies, including our human rights policy and code, are conducted as part of combined assurance plan. Should the need for a specific human rights impact assessment be identified, it will be managed through our risk and internal audit function. As part of our ethical sourcing programme, we request that all our tier 1 suppliers sign an annual declaration of conformance to our supplier code of conduct, which integrates the protection of human rights see ethical supply chain. Going forward, we plan to strengthen the integration of human rights due-diligence processes into our risk and internal audit plan for own operations and our suppliers. We recorded no human-rights-related infringements in 2022, nor received any human-rights-related complaints through our ethics line.
We have a zero-tolerance approach to any action that goes against our code, including any acts of bribery and corruption. Our anti-bribery and anti-corruption policy, strictly prohibits lobbying, facilitation payments, and political donations in alignment with our code. Our declaration of interest policy sets out situations that may constitute a conflict of interest, and stipulates mandatory declaration of any conflict of interest on an annual basis, or as soon as is reasonably possible after awareness of the conflict of interest arises. Our gifts, entertainment and hospitality policy sets out the parameters within which gifts, entertainment and hospitality may be received or given, and creates an obligation to disclose such.
We have a tailored fraud risk register, and an informal fraud risk management programme as part of our combined assurance plan, and run specific analytics to highlight any potential areas of concern. Audits for compliance with our ethics policies, including our gifts policy and code, are conducted as part of combined assurance processes. Monthly reports on the results are made to Exco, with Exco reporting quarterly to the board. In 2022, we subscribed to a procurement tool that helps us run checks on current and potential suppliers to determine any conflict of interest, sanctions, criminal activity or other ethical red flags.
We run specific anti-bribery and anti-corruption training every two years for all senior management employees (above Grade DL) in risk-prone roles. The latest round of mandatory ethics training was held during Q2 and Q3 2022 and the next training cycle planned for 2023.
Promoting, supporting and protecting whistleblowers is an essential to achieving our aims for an ethical culture at Tiger Brands, particularly in the context of South Africa and Africa where fraud, bribery, crime and corruption represent real risks to the business. Providing a protected channel for whistleblowers to report unethical behaviour, empowers the people in our network to seek respite or do the right thing, and enables the company to discover and act on ethical transgressions that threaten our integrity and reputation. We protect whistleblowers as stipulated in South Africa’s Protected Disclosures Act, and our whistleblowing policy upholds the principle of non-retaliation.
We have an established whistleblowing facility that supports the secure and anonymous reporting of unethical behaviour, including any ethical transgression, dishonesty or fraud relating to our business activities, personnel or relationships. The whistleblowing facility is an independently run service that makes use of the services of Tip-offs Anonymous, a division of Deloitte. The service includes an ethics hotline (Ethics Line) that supports all local languages, and is available 24/7 for all employees, suppliers, customers, consumers and members of the public. We regularly communicate the availability and anonymity of Ethics Line to all employees, and are looking to strengthen our communication of this facility to our wider network in future. The service excludes customer product complaints, which are reported through a separate channel see food safety and quality.
Ethics Line reporting has been placed under the responsibility of the group compliance director, and our ethics investigation framework guides the management of ethics-related complaints. Through this framework, we have systematised the screening and reporting of all Ethics Line complaints to expedite investigations and ensure satisfactory resolution of matters. All complaints made via the Ethics Line are received by the internal audit and risk director and the chief legal officer. All complaints are actioned within 24 hours, and all investigations are supported by a formal investigative report that is issued to the relevant line manager and CEO. Complaints are categorised to facilitate the management response and support deeper analysis and learning from incidents. Categories include: alleged corruption, fraud, health and safety, human resources (HR), theft and unethical behaviour. Prior to being tabled at Exco and audit committee meetings, a monthly ethics report is presented to Exco, where the status of all cases, including closed cases, are noted and discussed. We also publish the results of ethics reports internally to further encourage ethical behaviour and promote the use of the hotline.
In 2022, 81 cases were reported via the Ethics Line, compared to 62 in 2021. We have investigated and closed 73 of these cases, with 8 still under investigation. There has been an increase in the number of cases reported in 2022. Cases relating to HR issues showed the most significant increase this year, with the highest number of complaints coming from our Grains and Bakeries division. We have learned that some complaints flagged as HR related may more accurately fall into a different category, and we have initiated a re-categorisation of complaints to facilitate more accurate and appropriate analysis and response. Going forward, issues will be categorised as relating to human resources when the complaint concerns a system, process or policy failure. We have planned to allocate resources and run training to address a number of the human resources complaints received.
Our tax objective is to protect and enhance shareholder value by achieving a sustainable tax result that complies with the tax laws in jurisdictions in which we operate. A continued focus on good governance has remained a priority by ensuring that robust and relevant tax controls are embedded within the group’s tax framework. We continuously observe the changing tax landscape across jurisdictions to ensure compliance with all tax regulations to uphold the integrity of the group’s reporting requirements. Our corporate values as a business forms the foundation of the group’s tax objectives to ensure that we uphold and protect our corporate reputation. We will not enter into any transactions that will compromise our integrity and will continue to strive for openness and transparency in all our dealings with tax authorities.
The tax function has embedded tax controls that are subject to an internal audit review every year. These controls are applied across all taxes, including the carbon tax and sugar tax, as well as all the tax reporting responsibilities of the tax team. The controls were co-developed with the group’s internal audit team to ensure that tax risks across the group are adequately mitigated. The external auditors also independently test our controls on an annual basis to ensure we comply with the control activities as defined in the framework. The tax team is required to submit various documents for testing, based on an independent sample selection by the auditor. Any control failures are reported to the audit committee.
The group’s effective tax rate for 2022 is 29,4% (before impairments, non-operational costs and income from associated companies) in comparison to the 2021 effective tax rate of 29,1%.
It is of vital importance that customers trust Tiger Brands with the safety of their information. We highly value the security and privacy of the personal information we hold and process, and are increasingly prioritising the enhancements of these programmes as we adapt to keep pace with a rapidly evolving technology, digital and cybersecurity landscape.
In response to this fast-moving context, we are continuously and iteratively implementing plans to enhance our practices and build our cybersecurity capabilities over time. We remain committed in ensuring compliance with the requirements of the Protection of Personal Information Act 2013 (PoPIA) and EU General Data Protection Regulations.
We have built clear roadmaps to ensure that we are cyber-resilient across our environment, including our manufacturing plants. These roadmaps are underpinned by clear management commitments and are tracked and monitored through the risk and sustainability and audit committees. The group information officer is responsible for ensuring continued compliance to the PoPIA requirements and reports progress to the risk and sustainability committee, in line with the committee’s annual work plan.
We have clear intentions to build a security-smart culture at Tiger Brands, and a key aspect of our approach is to reflect strategically on our actions and apply the lessons learnt. Supporting this practice, we regularly recruit independent assessments of our performance against best-practice and industry standards, ensuring that any gaps are appropriately prioritised and remediated.
Training and awareness is a key focus, as this ensures that the insider threats are addressed. To this end, security campaigns focused on specific security-related topics are run quarterly, via newsletters, videos, podcasts and email inserts. Our policies are enforced through the implementation of our defined roadmaps, which work to instil a strong sense of the cyber-security principles and protocols across the organisation. In terms of readiness, cyber-incident simulations will continue to be run as a core element of our training at all levels. This will ensure we are as ready as possible when faced with a significant cyber-attack or related incident.