STEYN CITY PROPERTIES

THIRD PARTY CODE OF ETHICS

July 2022

  1. INTRODUCTION
    Steyn City Properties (Pty) Ltd “Steyn City” operate in a regulated industry and is expected to comply with applicable industry laws, regulations, and international standards. Any Third Party wishing to provide goods and services to, or work for or on behalf of Steyn City must comply fully with all relevant laws and regulations and meet the minimum ethical standards set out in this code of conduct “Code.”
    This Code reflects the universally accepted principles contained in the United Nations Global Compact on human rights, labour, environment, anti-corruption and further describes the minimum standards of ethical and responsible conduct required from our Third Parties1.
    Steyn City is committed to implementing systems and controls to ensure that all suppliers, agents, brokers, partners, consultants, contractors, sub-contractors, jointventure partners, and other representatives (“Third Parties”) working on behalf of Steyn City are appointed and managed responsibly, in accordance with this Code.
    All Third Parties working for and/or on behalf of Steyn City undertakes to be committed to the requirements set out in this Code
  2. APPLICABILITY
    This Third-Party Code of Ethics sets forth Steyn City’s expectations for the Third Parties and is therefore applicable to all Steyn City Third Parties.
    Third Parties are expected to be familiar with the business practices of their own suppliers, agents, sub-contractors and other third parties, and to ensure that these entities also operate within the guidelines of this code.
    Further, Third Parties must understand Steyn City standards and embrace the same high ethical standards of business conduct that has long been at the core of how Steyn City conduct its business/operation.
  3. LEGAL AND REGULATORY COMPLIANCE
    Third parties must comply with all applicable laws, codes, and regulations in the industry in which they operate. This includes, but is not limited to, laws and regulations relating to environmental and occupational health and safety, security, labour practices, anti-money laundering, competition, corruption, and data privacy and protection. Steyn City expects Third Parties to ensure that the principles set out in this Code are implemented and communicated throughout their organization and made available to their employees.
    1. Bribery and Corruption
      Steyn City expects Third Parties to conduct business transparently, honestly, and fairly and further abide by all applicable anti-corruption laws. Third parties must not attempt to influence others, directly or indirectly, through an offer, promise or payment of a bribe or
      anything else of value to gain or retain a business advantage.
    2. Anti-Money Laundering
      Third Parties must be aware of any signs of money laundering when conducting business with their own third parties. Money laundering is the illegal process of concealing the true origin of illicit funds through transactions that appear to be legitimate. Third parties are expected to be alert to red flag any business partners who refuse to provide information about their identities or common transaction details, or who make unexplained changes to transactions.
      Third Parties must also implement robust internal processes to ensure adherence to “Know Your Customer” laws and best practices in identifying money laundering activities.
    3. Fair Competition
      Third Parties are expected to compete fairly and always comply with applicable competition laws and regulations. Whether it is on Steyn City’s behalf or otherwise. Third Parties should not work with or agree to collaborate with competitors to prevent or restrict free and fair competition. When negotiating contracts (with other entities), Third Parties
      must never discuss or engage in price fixing, bid rigging, coordinating with others to restrict business, or allocating customers, markets, or territories.
    4. Trade compliance
      Third Parties must comply with applicable international trade laws and regulations, including import and export controls, sanctions and anti-boycott laws and regulations that could apply to the products, goods and services that relates to Steyn City’s operations.
      Third Parties must further ensure that all valuations, declarations, and documents pertaining to trade and customs matters are accurate and complete.
    5. Data protection
      Third Parties must comply with all applicable laws and regulations when processing, transmitting, or storing personal information. Third Parties must take reasonable measures to ensure that data is protected. In the event of any unauthorised access, disclosure, or breach of personal or sensitive personal information belonging to Steyn City, Third Parties will notify Steyn City without delay and as provided by applicable contractual and legal requirements. Third Parties must further comply with any reporting or disclosure requirements in line with applicable reporting legislation or standards.
    6. Copyrights, Patents and Trademarks
      Third Parties must comply with the intellectual property rights of Steyn City and other entities, including, but not limited to, copyrights, patents, trademarks and trade secrets.
      Software and hardware must be used only in accordance with their associated license
      or terms of use.
  4. ETHICAL BUSINESS STANDARDS AND CONDUCT
    1. Business Integrity
      Third Parties are prohibited in engaging in any illegal or inappropriate activities including, but not limited to, corruption, misrepresentation, extortion, money laundering and bribery as this may result in termination of any or all agreements with Steyn City.
    2. Confidential Information
      Third Parties must protect confidential information that belongs to Steyn City or any other entity with whom Steyn City engage/associate with. This includes any non-public information that might be harmful to Steyn City’s reputation if disclosed. Some examples of confidential information include personal information Steyn City may collect from its
      customers.
      Steyn City expects its Third Parties to carefully manage any personal information, such as identity, medical, employment and financial information, and to never collect, process, use, transfer or disclose personal information outside of a specified business purpose.
    3. Conflicts of Interest
      Third Parties should avoid engaging in any activity that would conflict, interfere, or even create the appearance of a conflict between their business and Steyn City. Third Parties must disclose any potential conflict of interest to Steyn City in writing as soon they become aware of such conflict of interest.
    4. Gifts and Entertainment
      Steyn City expects its Third Parties to avoid being or even appearing to be improperly influenced by gifts and entertainment such as providing gifts and entertainment to improperly influence business decisions. Gifts and entertainment should be of nominal value, never in cash and consistent with local standards and customs.
  5. ENVIRONMENTAL AND SOCIAL REGULATIONS
    1. Labour Practices
      Steyn City follows all laws and regulations governing its employment practices and acceptable treatment of employees, and therefore expects its Third Parties to follow the same standards. This includes laws prohibiting slavery, child labour, bonded labour, human trafficking, as well as regulations related to minimum working wage, working hours restrictions, collective bargaining, workplace conditions and any form of discrimination.
      Third Parties must also maintain a workplace where no harassment of any kind is tolerated. Harassment includes, but is not limited to, unwanted physical contact; making or distributing offensive pictures, videos and spoken or written remarks; and any other unwelcome conduct that could create an intimidating or hostile workplace.
    2. Environmental, Health & Safety
      Steyn City Third Parties must maintain a workplace that complies with all applicable laws and regulations, including any standards established by Steyn City, regarding operational Health and Safety, environmental responsibility, the use, storage and disposal of any hazardous materials. Steyn City encourages its Third-Party partners to consider business processes that reduce the Third Party’s adverse impact on the environment by minimizing waste and conserving natural resources.
      Third Parties are further expected to foster a safe workplace for all, address safety hazards, comply with all applicable laws and regulations and promote a safe working environment.
    3. Human Rights
      Steyn City is committed to respect and support the Human Rights principles and values laid out in the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights) the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the United Nations Guiding Principles on Business and Human Rights.
    4. Relationships with Politically Exposed Persons
      Third Parties agree to disclose any close relationships with individuals who are or have been entrusted with prominent public functions by a country (Politically exposed persons), for example heads of state or ministers, senior politicians, senior government officials, judicial officials, senior executives of state-owned corporations, important political party officials etc. Third Parties should disclose any such relationships with any “Politically exposed persons” to Steyn City.
  6. MONITORING AND EVALUATION
    Steyn City reserves the right to periodically review any third party’s compliance with this Code, including by conducting audits and other reviews of any third party’s environmental, labour practices, and other business practices described in this Code.
  7. COMMUNICATIONS AND REPORTING
    To the extent permitted by law, Steyn City expects Third Parties to promptly notify it of any questions or concerns regarding the Third-Party Code of Ethics, or if they become
    aware of a situation that violates, or appears to violate, Steyn City’s Third-Party Code of Ethics. Third parties and their employees may contact Steyn City’s independently managed and anonymous reporting online whistleblowing portal: [email protected] or 086 111 5653.
    Steyn City prohibits retaliation against anyone reporting a concern in good faith and expects any Third Party to comply with same.
  8. POLICY REVISION
    1. This Policy is subject to review and amendment without prior notice. Any review and update hereof will take account of new laws, regulations, and technological
      developments.
    2. Steyn City undertakes to ensure that any amendments hereto are communicated on our publicly available platforms such as our website, for the benefit of the public who we serve and any other persons who may be affected by this Policy.
  9. VERSION CONTROL
    Last updated July 2022.

1 Third Parties are defined as individuals or entities who are contracted or sub-contracted to work for or on behalf of Steyn City Property or provide goods or services to the Steyn City group of companies