Conduct and Ethics

Conduct and Ethics Policy Background

Warning

This policy applies to all members employed by Glucode.

Commitment

This Conduct and Ethics Policy is supported by our other policies and procedures relating to specific issues, processes and situations.

You must commit to maintaining, in all your activities, the highest standards of competence, integrity and ethical behaviour, thereby ensuring that its reputation is beyond reproach. You must commit to being law-abiding corporate citizens.

Ethics

Ethics involve applying moral standards such as standards of good, right and fair conduct which are supported by values that shape the decisions and actions of individuals within Glucode in the pursuit of our business objectives.

Recognising that our public reputation is one of our most important assets, we are committed to achieving the highest ethical standards in all our business operations.

Maintaining the trust and confidence of all of our stakeholders is the responsibility of every team member. In all of our actions, the values and associated behaviours must be used to guide and direct the way we conduct ourselves.

We will monitor ethical performance regularly, in order to ensure that irregular or unethical business practices are eliminated.

Core Behaviour

Integrity means that we must build trust and form strong relationships with all stakeholders. It entails acting consistently with our values, i.e. to be honest, trustworthy and open, and to always act in accordance with the highest ethical standards. All employees are therefore expected to act with the highest integrity, which essentially means that we must do the right thing, even if nobody is watching us.
Respect means that we must actively listen to others, respond appropriately to what they have to say, work effectively with diverse people and be willing to learn from others.
Accountability means that we must be prepared to take responsibility for our work, make commitments, find solutions and be held accountable for delivery and results.
Professionalism means that we must act with the necessary skill, care and diligence required from members of our profession and that we must understand and comply with all applicable laws, rules and regulations and the codes of conduct issued by the regulatory authorities that govern us.
Passion is pushing beyond boundaries where we are e passionate about our work and committed to achieving our goals, always looking for innovative and creative ways to realise Glucode’s vision.

Diligence

You should always act in good faith. You are required to carry out your duties in a diligent, efficient and conscientious manner by:

Maintaining and developing an in-depth knowledge and understanding of your area of expertise and/or the professional field within which you are active;
Being present at work as required and only be absent from the workplace with proper authorisation;
Carrying out official decisions and policies faithfully and impartially using the information available to you;
Endeavour to attain the highest possible standard of performance; and
Complying with all lawful and reasonable instructions.

Info

If you are a member of a professional body, you need to adhere to the professional code of such professional body.

Equity and Respectful Treatment

Glucode endeavours to actively foster impartiality and create an environment where people are treated equitably and with respect, where an individual’s rights are respected, where effort is encouraged and where achievements are recognised. We conform to the practises in our Equity Policy in all aspects of work, from recruitment and performance evaluation to interpersonal relations.

In this regard, you should:

Be responsive, courteous and prompt when dealing with others;
Make fair decisions when dealing with subordinates, respect and value a diversity of views and opinions;
Not unfairly discriminate on the basis of race, language, gender, religion, sexual orientation, disability, medical condition, cultural background, marital status and/or political affiliation; and
Not harass or intimidate other employees, students or members of the public.

Communication

Professional communication, encompasses written, oral, visual and digital communication within a workplace context.

Listening: Being a good listener is one of the best ways to be a good communicator. When you really listen to the ideas, concerns, and opinions of others your communications will become more meaningful. Colleagues and clients are more open to quality communication if they know that you authentically care about them as an individual and the success of the goal that they are trying to achieve.
We also at times need to engage in “difficult conversations” in the workplace but it’s how the message is conveyed which should be “non-attacking,” non-judgmental and with an openness for shared dialogue to reach consensus or a compromise.
Communication involves honesty, openness and to a degree directness (candor), however, we always need to be mindful of how we are carrying the message across or giving feedback to a team member and/or client. No one is perfect. Mistakes happen and hiding them only causes problems to snowball. Once they are out in the open damage control can be done, then a solution can be found to work together to figure out what caused it and how to do better next time. We always need to bear in mind that respect and humility are the foundation for any communication.
With our written communication we should strive to be clear and concise in our writing but at the same time being aware of our tone and making use of “Capital Letters” when typing a sentence or the “highlighting” of certain words can be seen as rude or impolite.
All our communication with our colleagues and clients is conducted with the highest professionalism.
We need to be extremely mindful of the information shared with our clients and not to overstep the boundary of “over-sharing” personal information. There is a time and place for everything and in a business setting we need to keep our communication professional and not include our clients in any of our personal issues/dilemmas that we are faced with or our personal comings and goings. Over-sharing does not promote healthy communication, instead, it tends to make people feel awkward and uncomfortable. Crossing the boundary line of over-sharing can adversely affect a professional relationship with a client who might even start to question your competency and professionalism. We do have the necessary support channels available to talk about personal issues or if counselling is required, you can reach out to Solace who administers our employee assistance program for additional support.

Outside Work

Glucode acknowledges the desirability (and even the necessity in some instances) for you to be exposed to and to be involved in fields of professional practice. Outside work must not have a negative impact on your ability to render your services.

You will not be allowed to do outside work without the written consent of Glucode and if your performance is not on a satisfactory level.

Outside work done in a private capacity may not be advertised or performed in a way that creates or may create the impression that it is done in the name of Glucode or in the name of a business department of Glucode and/or underwrites the project.

You must obtain permission from Glucode for the use of any company asset in the execution of outside work. If permission is granted, you are obliged to compensate Glucode for the use of such asset.

Where you do outside work in a private capacity at other institutions where you are rendering a service or serving in a managerial capacity, in such institutions the written permission from Glucode must be obtained.

You must annually apply via the People Operations team for permission to do outside work. Permission granted lapses at the end of the calendar year or specific period for which it was approved.

Contravention or abuse of the above-mentioned provisions may lead to a summary withdrawal of the permission and/or appropriate disciplinary proceedings.

Directorship

It is the policy of Glucode to allow you to serve on the Boards and Councils of other organisations.

You must obtain approval from the People Operations Team to serve as a Director. Glucode is entitled to, in its discretion, decline such a request in appropriate circumstances.

Conflicts of Interest

You are obliged to notify Glucode in writing, and whenever a new interest arises, any business, commercial or financial activities, undertaken for financial or other gain that may raise a conflict of interest or a possible conflict of interest with Glucode.

Info

A “conflict of interest” can be defined as “Any situation in which an individual or corporation (either private or governmental), is in a position to exploit a professional or official capacity in some way, for their personal or corporate benefit.” In order to prevent situations where your conduct is induced, or appears to be induced by a conflict of interest or a potential conflict of interest, and to determine whether an “interest” of yours indeed fits this category, a full disclosure of interests is mandatory.

During your employment with Glucode, you must declare to Glucode in writing of any conflict and/or possible conflict of interest, before Glucode procures any goods or services from you or an organisation in which you hold an interest.

Declarations of any possible conflicting interest must be made immediately upon arising or as soon as you become aware of the possible conflict of interest.

You must prepare an annual declaration of possible conflicts of interest that affect Glucode and yourself personally that you may be aware of.

Warning

You must recuse yourself from any decision-making process where an actual or deemed conflict of interest is present. The nature of the conflict of interest and the fact that you recused yourself must be noted fully in the minutes of the proceedings.

With regard to the sale of goods and the rendering of services to Glucode, in circumstances where a conflict of interest exists or may exist on your part in respect of the transaction, the following will apply and you are not entitled to: conduct business directly or indirectly with Glucode that entails or may entail a conflict of interest with Glucode, unless Glucode is of the opinion and takes a decision that:

The goods, product or service in question are unique;
The supplier is a sole provider; and
It is in the best interest of Glucode

With regard to the conduct of business with or rendering of services to Glucode, the following is applicable:

You may not, on behalf of Glucode, contract with yourself, or your relative, or any entity in which you, or any relative has a direct or indirect financial or personal, fiduciary or other interest.

The following is indicative of a direct personal or financial interest in such an entity: Where the employee is the Director or a shareholder of a private company, the general partner in a partnership or the claimant of the profit of an entity.

The following is indicative of an indirect personal or financial interest: Where an employee has no direct personal or financial interest in a private company (or other entity) but uses the said private company (or other entity) as a mere conduit or front, in order to receive personal or financial gain from doing business with Glucode.

Contracting as referred to above relate to conduct that is aimed at receiving any direct or indirect financial, personal, fiduciary or other gain by the employee, which does not form part of the employment relationship between the employee and Glucode.

You may not sign any document related to the conduct of business or the rendering of services on behalf of Glucode if you do not have the designated authority to do so.

Transactions by yourself that do business with Glucode, which meet the stipulated criteria as determined by Glucode and this Code, are not prohibited.

Direct or indirect transactions by employees with Glucode resulting in direct or indirect personal gain on the part of the employee, but which form part of the employment relationship ,are not prohibited.

The trust that is placed by Glucode in you, requires you to conduct yourself with integrity, objectivity, professionalism and due care. You should therefore avoid conflicts between your company duties and private interests.

Gifts and Benefits

You are allowed to accept gifts on behalf of Glucode, provided that these gifts are not given with the purpose of improperly influencing you. If the slightest possibility exists that a gift is given as a quid pro quo to induce preferential treatment, it must be declined.

Before you receive a gift, approval must be obtained from the People Operations Team. The gift should be disclosed on a prescribed form and recorded in a gift register.

Fraud and Detection

Glucode has a policy of zero tolerance towards fraud and corruption.

You must act honestly and protect the Company from fraud, corruption and misconduct.

Warning

You are obligated to report any suspected fraud, corruption, criminal activity, unethical conduct, maladministration or mismanagement.Failure to report suspected misconduct may lead to disciplinary action

Improper Influencing and Bribery

You may not bribe or improperly influence or attempt to improperly influence any person who is or may be assumed to be in a decision-making position regarding company matters.

You may not create the impression that you have the power to improperly influence the outcome of or the people entrusted with appointments and selection decisions, the procurement of goods or services and the awarding of tenders and/or drawing up of quotations.

You are obligated to immediately report any attempt by another person to bribe or to improperly influence to Senior Management.

Use of Official Confidential and Personal Information

You have access to information owned by Glucode. You are expected to know and understand the relevant access and privacy requirements, and to take measures to enforce the confidentiality and security of information throughout the institution.

Glucode is committed to keeping personal information regarding its employees confidential. Access to and knowledge of the content of employee records will be limited to persons who need the information for legitimate company business or legal purposes.

Employees dealing with personal information must be aware of the purposes for which the information has been collected, and only process the information for that purpose in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA) and the Promotion of Access to Information Act 2 of 2000 (PAIA).

You may not impart, without authorisation, confidential and/or personal information (including business strategies, pending contracts, unannounced services, research results and information on students and personnel) to any person, company or entity where such person, company or entity is not legitimately entitled to the information.

All reasonable precautions must be taken, including the use of both physical and electronic barriers, such as locks, passwords and file protection measures, to prevent any unauthorised access or misuse of confidential information.

Confidentiality do’s and don’ts

Confidentiality do’s

Lock or secure confidential information always.
Confidential information should be safely stored on OneDrive where specific people are granted access to files and folders.
Shred confidential documents when they are no longer needed.
Clean whiteboards after use to erase any confidential information.
Ensure that confidential information is viewed on secure devices only, I.e., your laptop and if your personal mobile device is used to receive work emails or other work-related confidential information, ensure that your mobile device is encrypted.
Always lock your phone and laptop when not in use, even when stepping away for 2 minutes to grab a cup of coffee. An open laptop screen with personal or confidential information will be exposed for all to see if not locked.
When at the office and confidential information is being mapped on a whiteboard, make sure to clean the whiteboard when you are done using it.
Only disclose confidential information to other employees if they are privy to such information. If in doubt or you are unsure, speak to Head of Department, explain the situation, and get an understanding whether that individual can have knowledge of the information and if the information can be shared if it is requested. Get the correct authorization first before sharing any confidential information.
Keep hard copies of confidential documents inside the company premises unless it is necessary to move them then request authorization from your Lead and Head of Department.
When sharing confidential information with external parties who are privy to such details ensure that the email is password protected to safeguard that the correct recipient is the receiver of such information.
Always be aware of your surroundings when discussing sensitive information. Somebody might be lurking around eavesdropping on your conversation and important information could be used in a malicious manner.

Confidentiality don’ts

Salary information is a sensitive subject and should be treated with the utmost confidentiality. We encourage our employees not to share salary information whether in conversation or in writing.
Never leave confidential documents in desk drawers that are not locked at the office. Do not leave important documents lying around. Always ensure that desks are cleared at the end of the day and that confidential documents/information is stored in the appropriate manner, i.e., in a locked drawer.
Do not throw confidential documents in the dustbin. Dispose of it in the proper manner, i.e., by shredding it.
Only approved devices may be connected to our network, refer to our Information Technology policy. That is why we never write our WiFi password down on a piece of paper. Your laptop and your cellphone are the only devices authorized to access our network. Please do not share our network password and do not give out our WiFi password. Do not write down our WiFi password on a piece of paper and through it in the dustbin.
Do not allow anyone to remote access your work computer. Get the correct authorization from our IT support team.
You are the only person authorized to use your computer. Do not allow a third-party access to your computer where they might have access to loads of confidential information.
Do not access free public WiFi when working on confidential material.
Do not leave your laptop unattended when working on confidential material. In fact, never leave your laptop unattended and unlocked.

Health and Safety

You are required to take reasonable care of your personal health and safety, as well as the health and safety of others at Glucode. For this purpose, you are required to follow safe workplace practices, including participating in applicable training sessions, using appropriate personal safety equipment where required, and reporting accidents, injuries and unsafe situations.

You should protect Glucode and the surrounding environment from pollution and contamination. This includes the careful handling of hazardous waste and other potentially harmful agents and materials.

You should ensure that you do not attend work or perform duties while under the influence of alcohol, drugs or any other intoxicating substances or the after effects thereof.

You are expected to familiarise yourself with Glucode’s internal Alcohol and Drug policy, Smoking Policy, and Health and Safety policy.

Compliance with the Code of Conduct

All employees and other individuals acting as volunteers and representatives on behalf of Glucode must familiarise themselves with this Code and ensure that they comply with the letter, as well as the spirit, being the intention and the content, of the Code.

The People Operations team, is responsible for providing guidance to individuals affected by this Code.

All breaches of this Code may be regarded as misconduct and may result in disciplinary action up to and including dismissal as per Glucode’s Disciplinary Code and Procedure for employees.

Monitoring and Enforcement

The primary responsibility for ensuring compliance with the Code of Conduct rests on you.

You have the right and responsibility to ask questions, seek guidance and express concerns regarding compliance with the Code.

You should promptly report all suspected breaches of the Code of Conduct to your Head of Department. If this is not possible, you may report the suspected breach anonymously as set through the Grievance process.

Associated Documentation

You are expected to familiarise yourself with your role, duties, internal policies and procedures, as failure to comply with them may be considered to be misconduct and you may be subject to disciplinary action that could lead to dismissal.

In addition, this Code is not intended to comprise an exhaustive list of what constitutes ethical conduct, nor is it intended to contain a comprehensive list of offences or contraventions on which Glucode will take appropriate legal action. Glucode respects the right of an individual to retain their anonymity when reporting non-compliance with this Code through the grievance process.

Summary of offences and consequences

Review the Code of Conduct - Summary of offences and consequences here -> https://3.basecamp.com/4403717/buckets/15114612/uploads/6847008461