Introduction

As the Board of Buildmax Limited (the "Group") is committed to the highest standards of good Corporate Governance and honesty, integrity and transparency, it has taken a decision to introduce an outsourced, anonymous and confidential disclosure service. 

In taking this decision, the various reports of the King Commission on Corporate Governance, section 159 of the Companies Act, 2008, the Protected Disclosures Act, 2000 and the Prevention and Combating of Corrupt Activities Act, 2003, have been taken into account.

Scope

 
This policy applies to all companies within the Group (including all countries where they operate) and all subsidiaries including service organisations and operations. 

Purpose

The purpose of this policy is to provide employees and other stakeholders of the Group with channels to report practices and activities that are unlawful, inappropriate and in conflict with the Group’s policies and procedures. 

This service should not be seen to replace existing communication channels within the Group for employees and other stakeholders to report concerns, but has been introduced to provide channels where such concerns can be communicated anonymously and confidentially where face-to-face reporting may not be appropriate. 

The service

The service to the Group is provided by Be Heard®, a division of Honey Badger Solutions (Proprietary) Limited, which is independent of the Group and our internal and external auditors. 

The service operates 24 hours a day, 7 days a week and persons wishing to make use of the service can make disclosures via telephone, email, SMS, fax, post and via a template on the service provider’s website –www.beheard.co.za.

At no stage do persons making disclosures need to make their identity known to Be Heard® and the contents of the disclosure will be managed confidentially by the service provider and the Group. 

Management of reports

Be Heard® will send reports to the CEO of Buildmax Limited and the Group Company Secretary who have been designated to receive and process such reports. If the report concerns this designated person, Be Heard® will send the report to the second and possibly even the third designated person. 

As a report is just an allegation, an initial investigation will take place to confirm whether the report has substance and appears to be authentic. Once this has been done the designated person will report to his superior that a report has been received and will outline his intentions in terms of follow-up and investigation. 

A summary of all reports received and the actions taken will be submitted to every meeting of the Group’s Audit and Risk Committee. 

Protection of persons making disclosures

 
The provisions of the Protected Disclosures Act, 2003, will be followed to the letter throughout the process of managing and investigating reports. 

Awareness

 
The CEO will ensure the introduction of a continuous process of advertising the existence and functioning of the service to all new and current employees and, where appropriate, other stakeholders.