Corporate Compliance & Policies

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Stakeholder Relationships

Hulamin subscribes to the principles on stakeholder management expressed in the King III Code. Management has developed a strategy and formulated policies for the management of relationships with each stakeholder grouping, and an integrated approach to stakeholder management within the group is adopted to strive for consistency and balance in treatment across stakeholder categories.

The group communicates its strategy, performance and vision through regular presentations to investors, analysts, employees and other stakeholders. In addition, management regularly meets with investors and institutional stakeholders on a one-on-one basis. Hulamin invites all shareholders to attend its annual general meeting and also facilitates participation by way of focused proxy solicitation.

Hulamin strives to resolve disputes with its stakeholders effectively and expeditiously. Hulamin has a preference to settle disputes rather than to litigate and uses alternative dispute resolution mechanisms whenever appropriate.

Access to Information

Hulamin complies with the requirements of the Promotion of Access to Information (Act 2 of 2000). Please follow the link to see the PAIA manual. During 2015, the Hulamin group received no requests for access to a record under the Promotion of Access to Information Act, 2000.

Code of Ethics

The group’s Code of Ethics requires all directors and employees to be committed to fair dealing, honesty and integrity in the conduct of its business and also outlines the group’s position on gifts and entertainment. The Code of Ethics has been actively endorsed by the board and distributed to all employees in the group. The Code is designed to raise ethical awareness, act as a guide in day-to-day decisions and to assure customers and other stakeholders of the group’s commitment to ethical behaviour.

An important element of the induction process is to communicate to new employees the Code of Ethics, the group’s core values and its compliance procedures. Compliance by all employees with the high moral, ethical and legal standards of the Code is mandatory, and if employees become aware of, or suspect, a contravention of the Code, they must promptly and confidentially report it in the prescribed manner.

Appropriate action has been taken in respect of all reported instances of non-compliance with the Code by employees.

Click here to see The Code of Ethics.

Political Donations

Hulamin does not contribute any funding to political parties, their elected representatives or persons seeking political office.


Hulamin has an established whistle-blowing policy and has an anonymous reporting facility (the Vuvuzela Ethics Line), enabling employees and other stakeholders to report fraudulent, corrupt or unethical behaviour related to any of the group’s activities, without fear of victimisation and retribution. Anonymity is guaranteed and the facility is managed in compliance with the Protected Disclosures Act, No 26 of 2000.

Contact details of the Vuvuzela Ethics Lines are as follows:

Toll-free number:                080 2255 688



All fraud and theft matters are reported to the Audit Committee. There were no significant frauds or thefts during the period under review.

Price-Sensitive Information

No director, officer or employee may deal either directly or indirectly in the company’s shares on the basis of unpublished price-sensitive information regarding the company’s business or affairs. In addition, no director, officer or employee in possession of price-sensitive information may trade in the company’s shares during closed periods. Closed periods are from the end of the interim and annual reporting periods to the announcement of financial and operating results for the respective periods, and while the company is under a cautionary announcement.

Compliance Framework

Hulamin’s compliance framework rests on the company’s comprehensive set of policies in this respect. These are updated when needs be to reflect governance best practice and the changing legal environment. All Hulamin group companies and employees are obliged to comply with these policies.

Non-compliance risks are reviewed by the Risk Management Committee. No judgement, damages, penalties or fines were recorded and/or levied against any group company, directors or employees during the period under review for noncompliance with any legislation.

King Code of Governance Principles for South Africa (King IV Code)

In terms of the JSE Listings Requirements, all JSE-listed companies must comply with the King Code of Governance Principles for South Africa (King IV Code).

Hulamin views the implementation of good corporate governance practices as integral to its business and recognises the need to conduct its business with openness, integrity and accountability.

Hulamin applies all the principles of the King IV Code and the vast majority of the recommended  practices of the King III Code. A summary of how each principle is applied is set out here.

Code of Conduct for Suppliers And Service Providers

See the Code Of Conduct For Suppliers And Service Providers here.