Page 103 - Capricorn IAR 2020

We implement our ethics strategy and reporting framework according to four focus areas:
2020 INTEGRATED ANNUAL REPORT
LEADERSHIP COMMITMENT
We want to attain increased maturity in our ethical culture year-on-year as measured by our independent ethics risk assessment to be conducted every two years. Leadership buy-in will enable us to put structures in place to facilitate the establishment of an ethical culture and demonstrate tone at the top.
SETTING ETHICAL STANDARDS
Capricorn Group’s ethical standards are clearly defined on our Group Code of Ethics and Conduct, values and ethics-related policies. We aim to increase employees’ knowledge of acceptable and unacceptable behaviour and ultimately reduce unethical behaviour.
As with any organisational culture change exercise, entrenching an ethical culture could take several years to reach maturity. The Group is in its second year of implementing its ethics strategy and programme. The initiatives for the year are set out below.
We enhanced ethics reporting by building trust in existing safe reporting structures and procedures. The fraud hotline was repositioned as an anonymous tip-off line, managed by Deloitte
as an independent partner. Any alleged fraud, corruption, or unethical conduct can be reported to the line via landline or mobile. We conducted a survey into the effectiveness of and perceptions regarding the fraud hotline, followed by awareness campaigns to explain how the repositioned anonymous tip-off line works. The emphasis was on anonymity and protection of whistleblowers as these were the main concerns raised by the survey.
We embedded ethical standards for suppliers and business partners through the Suppliers’ Code of Conduct. The Suppliers’ Code of Conduct was approved and implemented at Bank Windhoek as a start.
Labour
The Group does not use child labour, migrant workers or forced labour. The rights of workers are protected by internal policies and labour laws, which regulate employment in all jurisdictions. The risk of violating the rights of workers is low. Workers have a right to organise themselves through labour unions, as protected by law.
The HR committee has oversight of labour-related matters, including the policy framework. New employees are made aware of policies through an induction programme, and policy changes are communicated to all employees as and when they occur. A formal grievance procedure protects employee rights.
The Remuneration Policy outlines the Group’s remuneration principles and is the guiding document in terms of fair and equitable remuneration.
Read more about these aspects in the section on material matters from page 41 and the remuneration report from page 90.
Environment
As a financial services provider, the Group’s operations have a limited direct environmental impact. However lending activities can have
an indirect impact on society and the environment if this is not managed. Bank Windhoek manages environmental and social impact through the Environmental and Social Management System Policy and Procedure.
Due diligence is done on all medium and high risk loans to ensure environmental and social compliance with national laws and international best practice, particularly for industries such as mining and construction. Due diligence on high risk loans includes checking
EMPLOYEE ETHICS AWARENESS
We promote and communicate Capricorn Group’s ethical standards through leadership, training and awareness campaigns, and provide effective and trusted safe reporting mechanisms. Our plan is to design and implement a three-year awareness and communication strategy to increase ethics awareness.
MANAGE ETHICS RISKS
We manage ethics risks and opportunities as identified in the most recent ethics risk assessment. This involves identifying and prioritising ethical risks and opportunities and implementing a risk management plan with remediation actions.
continually improve the integration of the UNGC and its principles into business strategy, culture and daily operations.
Human rights
Human rights are enshrined in the constitutions of Namibia, Botswana and Zambia. Capricorn Group is committed to upholding human rights and the laws of the jurisdictions in which we operate. Our internal policies and procedures protect employees’ human rights and detect and remedy violations of policies. Key performance indicators are tracked through the sustainability dashboard to support the advancement and protection of human rights. These include the percentage of permanent female employees, women in middle and senior management, the percentage of employees with disabilities, racially disadvantaged permanent employees and racially disadvantaged persons in middle and senior management.
Read more about these aspects in the section on our material matters from page 41.
We provided focused ethics training for management and non-managerial employees. Board training for Group directors and executives was conducted by the Ethics Institute of South Africa. We are investigating Group-wide online ethics training solutions aimed at all employees.
Ethics is an agenda point in the employee induction programme.
Ethical content and videos now form part of the Fraud and Risk Culture agenda items at induction.
We plan to conduct the annual ethics risk assessment to measure ethics objectively. During the last quarter of the financial year the Ethics Institute of South Africa started assessing the Group’s mode of ethics management to produce an ethics risk profile. This will inform the next steps in our management of ethics. The completion of the ethics assessment was impacted by the COVID-19 pandemic and a report will be published the next year.
We designed and implemented a sustainable, consistent annual ethics communication campaign for internal stakeholders. The campaign will run as soon as possible after COVID-19 restrictions have been lifted and will consist of interactive assessments, competitions and other communication elements.
Capricorn Group’s commitment to
the UNGC principles
Capricorn Group reaffirmed its support of the 10 principles of the United Nations Global Compact (“UNGC”) in the areas of human rights, labour, environment and anti-corruption.
The following examples provide a summary of the Group’s communication on progress and describe the Group’s actions to
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