Social Media and Disclosure | Glucode Handbook

Glucode conducts its business honestly, ethically with due skill, care and diligence wherever we operate in the Country.

We constantly improve the quality of our services, products and operations and strive to create and maintain our reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment.

We will not compromise our principles for short-term advantages.

The ethical performance of this Company is the sum of the ethics of us all, thus, we are all expected to adhere to high standards of personal and professional integrity by acting in good faith, in the best interest of the Company and avoiding conflicts of interest.

Social Media is a broad term used to describe a range of online tools such as websites, web-based platforms and applications that are designed for online interaction, content consumption and to generate content.

Examples of social media applications, channels and platforms includes but not limited to: Facebook, Google Plus, Twitter, Tumblr, Snapchat, WordPress, Blogger, Wikipedia, Instagram, YouTube, TikTok, LinkedIn, Facebook Messenger, WhatsApp, Google Hangouts, chat rooms, email, etc.

Fiduciary and Ethical Duty

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 Glucode, its clients and members of the public is the responsibility of every employee.

In all of our actions, the values and associated behaviours must be used to guide and direct the way we conduct ourselves. Therefore you must engage in good faith, in the best interests of Glucode and its clients and with the care and skill that can reasonably be expected from a person with your knowledge and experience.

You are seen to be representing not only Glucode but also its clients and should, at all times, act with due care, consideration and responsibility on all social media platforms and to comply with legislation, industry regulations and prescribed practices as well as internal rules and regulations.

Only authorised spokespeople or duly delegated officials may provide comment to the media. If you are contacted by the media or public user on an official or any social media site, you must refer all media enquiries to senior management immediately.

You must respect the corporate identity of the Company and its clients as a whole. You may not post any material that is protected by copyright when posting text and/or images.

Only facts and statements that can be verified - not personal opinions or speculations may be published. Where users ask questions about published information with which you are familiar, ensure that any authorised comment or response you may make is accurate, appropriate to the departmental role you hold, and remains politically neutral.

When it comes to personal use of social media, you must not act in a private capacity to influence public opinion or promote issues of public interest related to the Company and its clients. Personal use of social media must only be used for personal and not professional interest.

When using social media platforms in a personal capacity, you should always think before you post, and you should use your common sense. Even when acting or speaking in a personal capacity, your position as a Glucode employee may be known to anyone in the potential audience and may be misunderstood or misrepresented as an official position.

You may not use personal or official social media platforms to post any confidential or proprietary information of the Company and its clients as a whole.

You must familiarise yourself with the content of any non-disclosure agreements you signed to ensure that all personal social media activities are in alignment and compliance with this Policy and all other applicable regulations, acts and policies.

You can be held legally responsible for all postings on your personal and official social media platforms.

General Conduct

Before engaging with a specific social media platform you must understand its terms of reference, conventions and etiquette.

You may not engage in online communication activities which could bring Glucode and/or its clients into disrepute.

Personal details of yourself, Glucode, its clients and/or other employees should not be given out.

You must act with:

Integrity in that we must build trust and form strong relationships with all shareholders and members of the public. 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.
Respect in 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 in that we must be prepared to take responsibility for our work, make commitments, find solutions and be held accountable for delivery and results.
Professionalism in 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 law, rules and regulations and the codes of conduct issued by the regulatory authorities that govern us.

Use of Company Resources and Privacy Rights

You must ensure that your personal online activities do not interfere with your work duties and performance.

You must use Company resources with the required care. Unless express permission has been granted, Company resources may not be used for private purposes. Electronic resources such as email and internet access are provided to employees and support service departments for their employment activities and should therefore be used for this purpose.

Personal use of the telephone is limited to urgent private calls. You hereby agree that the cost of any other personal calls will be deducted from your remuneration.

Private use of electronic resources is a privilege and should be kept to a minimum and not be abused. Abuse will be regarded as misconduct.

You should be aware that you do not have a legitimate expectation of privacy when using the Company’s email system to communicate with friends and family and most importantly to competitors or other companies alike. The Company owns any of your communication using Company resources and have the right to access any material on your official Company owned resource at any time.

The Constitution gives you the right not to have your communications infringed, however, Section 36 of the Constitution says that if there is a law of general application, a law that applies to all citizens and not to a specific group of people, that general law may limit any rights of a citizen that is contained in the Bill of Rights. The Regulation of Interception of Communications and Provision of Communication- Related Information Act No 48 of 2008 is such a law and, provides that it is not unlawful to intercept communications.

Use of Official Confidential and Personal Information

Disclosing or sharing information with third parties which is against the Company’s business interests will be considered as gross misconduct which may lead to irreparable damage to the continued working relationship. If the trust relationship has been broken, either during or after working hours, the misconduct can become the basis of disciplinary action and justify an immediate dismissal

You have access to information owned by the Company and its clients, you are expected to know and understand the relevant access and privacy requirement, and are expected to take measures to enforce the confidentiality and security of information throughout the institution.

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.

We are bound by the terms and provisions of both Section 51 of the Electronic Communications and Transactions Act, 2002 (“ECT Act”) and 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).

The primary responsibility for ensuring compliance with Company codes of conduct rests on us all.

You have the right and responsibility to ask questions, seek guidance and express concerns regarding compliance and should promptly report all suspected breaches to our People Department.

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You may report the suspected breach anonymously.

Grievances and Whistleblowing

Section23 (1) of the 1996 Constitution of the Republic of South Africa read together with sections 185 and 186(2) of the Labour Relations Act, 66 of 1995 provides that you have the right to fair labour practices.

If you have a grievance, it should first internally bring your grievance to the notice of your Head aligned with our Grievance Process.

Social media platforms should not be used as a parallel mechanism to complain or voice feelings and/or opinions of injustices within Glucode or be used as a whistle blowing communication tool or format.

The courts have taken the view that the internet is not a suitable forum for disclosures of this nature.

The Protected Disclosures Act no 26 of 2000 states that it is safest if concerns are raised internally, that whistle- blowing as a key tool for promoting individual responsibility and organisational accountability but expects whistle-blowers to act in good faith and in the public interest to raise concerns around suspected impropriety within your place of employment.