ETHICS AND ANTI-CORRUPTION POLICY

As part of our SUSTAINABILITY POLICY STATEMENT, Leading Language is committed to transparency, integrity and accountability, ensuring that our business is conducted according to the highest ethical standards. Our value system is aligned with the Sustainable Development Goals and the principles promoted by the UN Global Compact. In this policy statement, Leading Language sets out the following ethical requirements of all those who govern, are engaged by or contract with the company.

Ethical Conduct Requirement

All who serve Leading Language are to do so in accordance with the highest levels of integrity. This integrity is demonstrated through a consistent commitment by all to the best interests of the company.

More specifically, this ethical commitment includes:

  1. Performing at all times to the best of one’s ability, and doing so in a co-operative manner that promotes the effective performance of others working for Leading Language.

  2. Behaving in a manner that is at all times lawful and consistent with the values of the company, ensuring that all conduct contributes to its good reputation.

  3. Adhering to the conditions of employment and policies and procedures of the company, seeking guidance where these do not provide the necessary guidance in an encountered situation.

  4. Utilising any delegated equipment and resources, including information and intellectual property, only for their intended purpose.

  5. Gaining from the association with Leading Language according to agreed reward arrangements only, never abusing one’s position for illegitimate gain or to compete with the company.

  6. At all times exercising a duty of care and good faith towards Leading Language ensuring that a relationship of mutual trust can be established and sustained.

If adherence to these expectations at any time comes into conflict with any other interest of those who govern, are employed by or contract to Leading Language, this conflict should be immediately be communicated to the Managing Director in order that an acceptable way forward can be agreed upon and formalised.

 

Anti-Corruption Requirements

Consistent with the commitment to ethical conduct described above, our Company has a specific role in working against corruption in all its forms. It does this in terms of Principle 10 of the principles promoted by UN Global Compact (1) and in terms of SDG 16, Target 16.5 (2)It is expected that all who govern, are employed by or contracted to Leading Language will recognise, resist and report any suspected or known corrupt activity affecting or involving the company. In support of this requirement, it is essential that the following definitions of corruption and its methods are understood by all.

Understanding what corruption is

Corruption occurs whenever there is an improper intervention in a process, or the taking advantage of an opportunity, for illegitimate gain. Individuals in any relationship with Leading Language, at any level, may encounter an opportunity or create an opportunity to use this relationship for unethical or corrupt gain, and must desist from doing so.

Understanding the methods of corruption

Corruption takes place through the use of certain methods or tools by which illegitimate gain is achieved. These methods can be used in isolation or in concert to achieve corruption. They are listed and defined as follows:

 

Fraud

Fraud is the attainment of illegitimate gain through intentional misrepresentation and deception. When fraud is committed against an organisation by those entrusted to safeguard its finances, it is referred to as embezzlement.

Abuse of position

Abuse of a position of trust, access, authority, or power. Even those in positions with comparatively little power, as traditionally understood, can play a key role in enabling corruption, for example via their access to information, systems and physical resources. A position can be abused for direct, personal gain, or to benefit others. For example, nepotism occurs where a position is abused to achieve an illegitimate benefit for a family member, and cronyism occurs where this is for the benefit of a friend or associate.

Bribery

Bribery is defined as the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. A bribe or advantage can be anything of value. When a bribe is paid after delivery of the advantage it is known as a kickback. Both parties to a bribe are guilty of the crime of bribery.

Blackmail

The threat of revealing information that would be injurious to a person unless they cooperate with an illegitimate request.

Extortion

The threat of the wrongful use of authority or physical harm unless a person agrees to comply with an illegitimate request.

 

Leading Language Position and Requirements

The company will never engage in corruption in the pursuit of business and will only maintain employment and contractual relationships with those who refrain from engaging in unethical, corrupt and other illegal activities.

Any stakeholders, including employees and contractors, who in their dealings on behalf of Leading Language experiences the direct or indirect solicitation of a bribe or who are threatened or coerced in a corrupt manner, must report such incidents immediately for the attention of the Managing Director.

Where any employee or contractor identifies circumstances that put Leading Language at risk of unethical, corrupt or illegal activity, it is expected that this risk should be drawn to the attention of the Managing Director in order that mitigating measures can be put in place.

An open approach to the discussion of ethical dilemmas encountered in the carrying out of their duties by all who work for Leading Language is encouraged. Such discussion is an important mechanism for achieving shared understanding of the best practices for handling these issues from a Leading Language perspective.

 

Leading Language will guarantee confidentiality and anonymity with the possibility for any employee or contractor to make an anonymous report as per the company’s Policy on Reporting Unethical Activity.

Leading Language will provide employees and contractors with training in support of its expectations as set out in this policy.

Obligation to Report Suspected or Known Unethical, Corrupt and Illegal Activity

Consistent with the legal, contractual and ethical obligations of all who serve Leading Language, it is expected that any suspicions or knowledge of wrongdoing affecting and involving the company must be reported. Having such knowledge and failing to bring it to the attention of the company’s management, constitutes a breach of this policy. Leading Language will provide all stakeholders, including employees and contractors, with direction regarding the avenues that can be pursued to safely make reports of unethical and unlawful activity. Reports of suspected or known misconduct can be made openly, confidentially or anonymously. The rights and obligations of Leading Language and of each employee, contractor, former employee or contractor in terms of the Protected Disclosures Act apply to all reporting of wrongdoing involving and affecting the company.

 

The Policy on Reporting Unethical Activity should be referred to for further details.

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  1. Principle 10 - Working against corruption in all its forms: Businesses should work against corruption in all its forms, including extortion and bribery. That 10th principle is not only to avoid bribery, extortion and other forms of corruption, but also to proactively develop policies and concrete programmes to address corruption internally and within their supply chains.

  2. Sustainable Development Goal 16 is to ‘Promote just, peaceful and inclusive societies’ and Target 16.5 supports this goal by aiming to ‘Substantially reduce corruption and bribery in all their forms’.