Purpose: To define and maintain ethical awareness throughout the company


1. Purpose

    To provide guidance to employees on how the company expects them to conduct themselves when undertaking business on behalf of the STELIOS global strategy.


2. Application
    The Code of Conduct and Ethics shall apply to all employees, managers and directors of STELIOS global strategy as well as all the employees, managers and directors of STELIOS global strategy subsidiaries, referred to as employees in this code.


3. Policy
    To safeguard the STELIOS global strategy's reputation and credibility, all employees must conduct themselves in accordance with the highest ethical standards.


4. Employees

    STELIOS global strategy will respect the human rights of its employees, treat them with dignity and respect, provide safe work conditions, and protect the confidentiality of employee records. Actions that constitute harassment or discrimination will not be tolerated.


5. Customers, Suppliers, Contractors and Joint Venture Partners

    STELIOS global strategy will deal openly and honestly with customers, suppliers, contractors and joint venture partners.


6. Business Integrity


    Business Principle
    STELIOS global strategy employees must avoid conflicts of interest between their private financial activities and the conduct of the Stelios Global strategy’s business.

    Conflict of Interest
    Employees must avoid any activity that could compromise, or appear to compromise their judgement or objectivity in the performance of their duties.     Employees must not use any company property, information or position, or opportunities arising from these for personal gain or to compete with the Group.

    Gifts, Entertainment and Bribery
    Employees should not give or accept gifts, entertainment, or any other personal benefit or privilege that could in any way influence, or appear to influence, their involvement in the STELIOS global strategy’s business dealings. All business units are required to maintain a “Gifts Register” where all gifts valued over R150.00 | US $10 will be reported.

    It is unacceptable to directly or indirectly offer, pay, solicit or accept bribes in any form. Any attempted transaction of this nature should be immediately reported to the supervisor or to the internal audit department.

    Integrity of Financial Information
    Shareholders, management and other interested parties must have complete and accurate financial information in order to make informed decisions.     Employees have a responsibility to ensure that transactions are recorded in the STELIOS global strategy’s accounts accurately and promptly and they must immediately report any known inaccuracies.  

    Protection and Use of Property

    Employees must protect all of the STELIOS global strategy’s property used in carrying out their responsibilities and take reasonable steps to prevent the theft or misuse of, or damage to, such property. STELIOS global strategy’s property is not limited to physical assets, but also includes corporate information and intellectual property such as inventions, copyrights, patents, trademarks and technology. Equipment, tools, materials, supplies and employee time are to be used only for the Stelios Global Strategy’s legitimate business reasons. STELIOS global strategy’s property must not be borrowed, loaned, or disposed of, except in accordance with the appropriate STELIOS global strategy policies.

    Business Controls
    Managers and supervisors must ensure that an effective system of business controls is in place for their area of responsibility. Employees must ensure that transactions are conducted within their level of authority and in accordance with prescribed policies and procedures.

    Confidential Information
    Confidential information includes proprietary, technical, business, financial, joint venture, customer and employee information that is not available publicly. Employees should be aware what information is confidential and obtain clarification when in doubt.

    Employees should not disclose information to any person outside STELIOS global strategy unless authorised to do so. This includes, as prohibited, any disclosure of confidential information to family and friends.

    The employees of the STELIOS global strategy shall abide by the standards and principles of privacy and confidentiality as set out in the Group Human Resources Policy. Employees must take reasonable care to protect confidential information against loss, theft, unauthorised access, alteration, or misuse.

    Departing the STELIOS global strategy, employees who have had access to the Stelios global strategy confidential information will be reminded of their continuing responsibility to protect it and maintain its confidentiality.

7. Accountability
    All employees must understand and adhere to STELIOS global strategy’s Code of Ethics. They must: Commit to individual conduct in accordance with the STELIOS global strategy’s Code of Ethics;

    Observe both the spirit and the letter of the law when dealing on behalf of STELIOS global strategy.
    Recognise the STELIOS global strategy’s responsibility to shareholders, customers, employees, those with whom STELIOS global strategy does business, and to society;

    Conduct themselves as responsible members of society, giving due regard to health, safety and environmental concerns, and human rights, in the operation of the STELIOS global strategy’s business;

    Report any suspected breach of the law or this Code of Ethics to the Internal Audit Department or the Board of Directors who will protect these who report violations in good faith.


8. Contravention of the Code
    STELIOS global strategy regards any contravention of the Code as a serious matter. At the same time, any suspected or illegal contravention under investigation must be treated with the utmost confidentiality. Contravention of the Code may result in disciplinary action, including the termination of employment. Certain breaches of the Code could also result in the institution of civil or criminal proceedings.


Approved by


D. Lubambo | Mr

General Manager





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