Cape Town
SOUTH AFRICA
Trusted Partners provides hands-on professional ESRM/ESG Risk management and Impact advice across Africa. The Partners have extensive experience assessing and managing ESRM/ESG risks and impacts across the continent in all major sectors on-behalf of investors, development finance institutions and businesses. Our in-depth understanding of ESRM/ESG Risks and Impacts coupled with our extensive knowledge of the Equator Principles, International Finance Corporation (IFC) Performance Standards, World Bank Environmental and Social Safeguards, European Bank For Reconstruction and Development (EBRD) Performance Requirements, and the Development Bank of Southern Africa (DBSA) Environmental and Social Safeguards as well as other International Development Financial Institutions Standards, and country specific environmental and social related regulations across Africa and Middle East make us Trusted Advisors to our clients.
This Professional Conduct and Ethics Policy applies to all Partners, Associate Partners, Sub-Consultants and Sub-Contractors (herein referred to as Representatives) of Trusted Partners (the Company) at all times.
1 Policy Statement
Trusted Partners takes a zero tolerance approach to un-professional and un-ethical conduct and will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
Trusted Partners is committed to ensure that its business is conducted, in all respects and all the times, according to rigorous ethical, professional and legal standards, which prevail from time to time, in the same industrial sector in which Company conducts its normal business. Trusted Partners is also committed to create a workplace, at all of its working locations, that, at all times, is free from harassment and discrimination, where co-workers are respected, and provided an appropriate environment so as to encourage good performance and conduct.
To achieve this goal all Representatives are expected to:
This Policy has been formulated in order to foster and maintain trust and confidence in the professionalism and the integrity of the Representatives of Trusted Partners by ensuring that all Representatives adhere to appropriate standards of conduct as set out in this Policy, that maintains and enhances the reputation of the Company.
This Policy aims to provide guidance to all Representatives of Trusted Partners on how and in which manner shall the conduct of Representatives be when they are undertaking business on behalf of the Company.
The circumstances of conducts as set out below in this Policy, although not exhaustive, are intended to cover those situations, which are most likely perceived to be encountered by Representatives. In case any Representative encounters any circumstance which is not covered hereunder or in case of any doubt, Representatives shall seek guidance from any Partner and act accordingly.
A breach of the Policy may result in disciplinary action against the Representative concerned including, potential dismissal or termination of employment or any other legal action as may available to Trusted Partners or all of the above together.
2 Who is covered by the Policy
This Policy applies to all the Representatives of Trusted Partners, i.e. all Partners, Associate Partners, Sub-Consultants and Sub-Contractors.
Trusted Partners also expects its Representatives to lead by example and perform their duties in accordance with this Policy and ensure that the content of this Policy is communicated to all persons reporting to them. If a business location or region has policies, practices, laws or regulations that require more than what is stated in this Policy, then the Representatives must follow this policy as a minimum and comply with such policies, practices, laws, or regulations in that particular region/ country.
Trusted Partners reputation and credibility are based upon its total commitment to ethical business practices and also on ethical conduct of its Representatives. To safeguard the Company’s reputation, Representatives must conduct themselves in accordance with the highest ethical standards and also be perceived to be acting ethically at all times. Compliance with all policies of Trusted Partners, relevant applicable laws and regulations is the minimum standard which shall be adhered to by all the Representatives all the times.
3 Clauses under the Policy
Professionalism
The personal and professional behaviour of Representatives shall conform to the standards expected of persons in their positions, which includes:
Conflict of Interest
Each Representative is expected to avoid situations in which his or her financial or other personal interests or dealings are, or may be, in conflict with the interests of Trusted Partners. Accordingly, Trusted Partners expects its Representatives to act in Trusted Partners interest at all times.
Representatives are advised not to engage in any other business, commercial or investment activity that may conflict with their ability to perform their duties to tTrusted Partners. Representatives must also not engage in any other activity (cultural, political, recreational, social) which could reasonably conflict with Trusted Partners interests and interfere with the performance of their duties.
Representatives must not use any of Trusted Partners property, information or position, or opportunities arising from these for personal gains or to compete with or to tarnish the image of Trusted Partners.
Representatives shall not engage in any business activity, which could be detrimental to, or in competition with, Trusted Partners business activities.
All Representatives must avoid situations in which their personal interest could conflict with the interest with Trusted Partners. If, under any circumstance, Representatives’ personal interests conflict with those of Trusted Partners‘, in all such cases the Representative must seek advice from any Partner.
Confidentiality of Information
As a result of engagement with Trusted Partners, Representatives may be entrusted with confidential information; with regard to Trusted Partners and/or its affiliates, its customers and suppliers. Upon joining, Representatives are required to separately read, acknowledge and sign the “Non-Disclosure Agreement” that shall explicitly mention the terms and conditions of the confidentiality obligation and treatment of confidential information and intellectual property of Trusted Partners.
Integrity of Financial Information
Shareholders, management and other interested parties must have complete and accurate financial information in order to make informed decisions. Representatives may not participate in accounting processes that directly impact the integrity of external financial statements and internal management reports.
All Representatives have a responsibility to ensure that all transactions are recorded in Trusted Partners accounts accurately and promptly and they must immediately report any known inaccuracies.
Misrepresentations by Representatives that result from intentional acts that may conceal or obscure the true nature of a business transaction are clear contraventions of this Policy.
Protection and Use of Company Property
All Representatives of Trusted Partners are responsible for protecting and taking reasonable steps to prevent the theft or misuse of, or damage to Trusted Partners assets, including all kinds of physical assets, movable, immovable and tangible property, corporate information and intellectual property such as inventions, copyrights, patents, trademarks and technology and intellectual property used in carrying out their responsibilities.
All Representatives must use all equipment, tools, materials, supplies, and Representative time only for Trusted Partners legitimate business interests.
All Representatives must use and maintain Trusted Partners property and resources efficiently and with due care and diligence.
Acceptance of Gifts and Other Benefits
All Representatives are bound by and shall abide by the Trusted Partners Anti-Bribery and Corruption Policy.
Harassment
Trusted Partners is committed to provide a work environment that is free of inappropriate behaviour of all kinds and harassment on account of age, physical disability, marital status, race, religion, caste, sex, sexual orientation or gender identity. Representatives are responsible for supporting Trusted Partners in its endeavour to protect others from any form of such harassments.
In the course of business conduct of any Representative, wherever harassment occurs to any such Representative as a result of an act or omission by any third party or outsider, Trusted Partners shall take all steps necessary and reasonable to assist such affected Representative in terms of support and preventive action.
Alcohol & Substance Abuse
The use or possession of alcohol, illegal drugs, and other controlled substances in the workplace and being under the influence of these substances on the job and during working hours is strictly prohibited. However, possession of prescription medication for medical treatment is permitted.
There may be Trusted Partners-sponsored events where management approves the serving of alcoholic beverages. In these cases, all appropriate liquor laws must be followed, including laws regarding the prohibition of serving of alcohol to those under the legally permissible age. However, under all such cases, excessive drinking, intoxication and misbehaviour at these events is prohibited and will be dealt with severely.
Fraud
Fraud or the act or intent to cheat, trick, steal, deceive, or lie, is both dishonest and, in most cases, criminal. Intentional acts of fraud are subject to strict disciplinary action, including dismissal and possible civil and/or criminal action against the concerned Representative.
Some examples of Fraud include:
Compliance with Laws and Agreements
All Representatives shall conduct business in compliance with all applicable laws and regulations of the particular region or Country.
Health, Safety and Environment
All Representatives shall comply with Trusted Partners health and safety norms as communicated to them from time to time. Representatives shall bring to the attention any Partner, any workplace safety or health hazard. All Representatives are bound by and shall abide by Trusted Partners Health and Safety Policy.
Trusted Partners takes a zero-tolerance approach to any and all activities within the sphere of its direct control that result in preventable pollution or contamination of the natural environment, wasteful use of resources or the disruption of ecosystem service. All Representatives are therefore required to be cognisant of their behaviour, to uphold the principle of “Duty of Care”, and to uphold all laws applicable to environmental protection in all the jurisdictions in which we operate.
4 Misconduct and Non-Conformance with the Policy
Non-observance of this Policy shall be construed as misconduct that could warrant disciplinary action, including dismissal in deserving cases. The decision in this regard will lie exclusively with the Partners of Trusted Partners.
5 Accountability
It is a condition of an appointment and/ or employment that all Representatives must understand and adhere to Trusted Partners Code of Conduct and at all times and abide by the standards, requirements and procedures laid down herein. They must:
6 Training and Communication
All Representatives will receive relevant awareness training on how to implement and adhere to this policy.
Our zero-tolerance approach to un-professional and un-ethical conduct will be communicated to all Representatives, grant recipients, associates, suppliers, and contractors at the outset of our relationship with them and as appropriate thereafter.
7 Who is Responsible for the Policy
The Partners of Trusted Partners have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Partners of Trusted Partners, have primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
8 Risk, Assessment, Monitoring, and Review
As part of its internal risk assessment process Trusted Partners will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness.
All Representatives are responsible for the success of this policy and shall ensure they use it to disclose any suspected danger or wrongdoing.
This policy does not form part of any employee’s contract of employment and it may be amended at any time.
This Policy applies to all Partners, Associate Partners, Employees and Sub-Consultants and Sub-Contractors (herein referred to as Representatives) of Trusted Partners (the Company) at all times.
1 Policy Statement
Trusted Partners takes a zero tolerance approach to bribery and corruption and will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
Trusted Partners welcomes the international community’s efforts to stamp out bribery and corruption and support the implementation of the United Nations Anti-Corruption Convention and the Group of Twenty Anti-Corruption Action Plan. As an organisation we remain committed to abiding by the anti-bribery laws of all the jurisdictions in which we operate, including the provisions of the US Foreign Corrupt Practices and the UK Bribery Act 2010 (the “Act”), as well as guidance and the Laws of the Republic of South Africa. We undertake due diligence on our partners, customers and clients, and take reasonable steps to ensure that they apply all applicable anti-bribery and anti-corruption laws.
The purpose of this policy is to:
a) set out our responsibilities in observing and upholding our policy on bribery and corruption; and
b) provide information and guidance to our partners, associate partners, sub-consultants and sub-contractors, customers and clients, on how to recognise and deal with bribery and corruption issues.
Bribery and corruption harm legitimate business activities and are serious criminal offences. Under the Act, bribery and corruption are punishable for individuals by up to ten years’ imprisonment. Organisations which are subject to the Act and which have committed an offence under the Act could face an unlimited fine, be excluded from tendering for public contracts, and face damage to their reputation. Trusted Partners therefore take our legal responsibilities very seriously.
2 Who is covered by the Policy
This policy applies directly to our partners, associate partners, employees sub-consultants and sub-contractors and to all individuals working for our company (herein defined as Representatives). The policy is provided to our Representatives, customers and clients, who will be required to take reasonable steps to ensure that in carrying out activities supported by the company, they and their employees, directors and associates comply, with all applicable anti-bribery and anti-corruption laws. In this policy, “third party” means any “individual or organisation we come into contact with during the course of your role”.
3 What is Bribery and Corruption?
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
Corruption is the misuse of public office or power for private gain or the misuse of private power in relation to business outside the realm of government.
Acts of bribery or corruption are intended to influence an individual in the performance of their work to act dishonestly and/or improperly. The person being bribed is usually someone who can obtain, retain or direct business for example during a tender or contracting process or it may be through the handling of administrative tasks or customs matters.
A bribe can take many forms, for example, a direct or indirect promise or offer of something of value, the offer or receipt of a kickback, fee, reward or other advantage, the giving of aid, donations or voting designed to exert improper influence.
Those engaged in bribery and corruption can include an employee, officer or director, any person acting on behalf of an organisation i.e. our employees, individuals or organisations who authorise someone else to carry out these acts, Government or public officials whether foreign or domestic.
4 Gifts and Hospitality
This policy does not prohibit gifts, entertainment, hospitality or other promotional expenditures (given and received) to or from third parties which are proportionate, transparent, reasonable and for bona fide purposes related to the aims and objectives of the Institute.
The giving or receipt of gifts is not prohibited if all of the following requirements are met:
a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
b) it complies with local law;
c) it is given in the name of Trusted Partners, not in your name;
d) it does not include cash or a cash equivalent (such as gift certificates or vouchers);
e) it is appropriate in the circumstances. For example, it is given as a ceremonial gift on a festival or at another special time;
f) taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
g) it is given openly, not secretly; and
h) gifts shall not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior written approval of the Partners of Trusted Partners (i.e. the registered Directors of Trusted Partners).
We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
Gifts to a value of more than R 250.00 per event, per person or of comparable value in a different country should not be given or offered (to or from a single source on a single occasion) unless they have the written approval of a member of the Partners of Trusted Partners. In deciding whether a gift is of comparable value, the relevant Representative should consider all surrounding circumstances including, but not limited to, the average income in the location where the recipient of the gift is based.
All gifts and hospitality to a value of more than R 250.00 per event, per person (or of comparable value in a different country) accepted or offered by any Representative should be entered on the register of gifts or described in email correspondence to the Partners of Trusted Partners.
5 What is Not Acceptable
It is not acceptable for you (or someone on your behalf) to:
a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope or that this will influence the decision-making of the organisation or that a business advantage will be received, or to reward a business advantage already given; or
b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure; or
c) accept payment from a third party that you know or suspect is offered with the expectation that the Company’s decision making will be influenced in any way and that it will obtain a business advantage for them; or
d) accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that the Company’s decision making will be influenced in any way and that a business advantage will be provided by us in return; or
e) threaten or retaliate against another Representative who has refused to commit a bribery offence or who has raised concerns under this policy; or
f) engage in any activity that might lead to a breach of this policy.
6 Facilitation Payments
Trusted Partners does not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.
If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Founding Partners of Trusted Partners.
If such a payment is extorted or forced under duress or because of a threat to personal safety then the payment may be made provided that Founding Partners of Trusted Partners is promptly informed, a written report submitted, and the payment recorded in the Company’s financial records.
Kickbacks are typically payments made in return for a business favour or advantage. All our Representatives, clients and suppliers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
7 Your Responsibilities
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Institute or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify Project Lead Partner as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if an employee, supplier or client offers you something to gain an advantage with us or indicates to you that a gift or payment is required to secure their co-operation with Company supported activities.
Any Representative who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with our Representatives, clients and suppliers if they breach this policy.
8 Record Keeping
Trusted Partners must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
You must declare and keep a written record of all hospitality or gifts to a value of more than R250.00 per event, per person (or of comparable value in a different country) accepted or offered on the gifts register or via email to any member of the Founding Partners of Trusted Partners, which will be subject to managerial review.
You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.
9 How to Raise a Concern
You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with any member of the Partners of Trusted Partners. Concerns should be reported as a protected disclosure to the Partners of Trusted Partners. Statutory protection of whistle blowers may be afforded under local law.
10 Protection
Representatives who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Trusted Partners are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform a member of the Partners of Trusted Partners immediately.
11 Training and Communication
All Representatives will receive relevant awareness training on how to implement and adhere to this policy.
Our zero-tolerance approach to bribery and corruption will be communicated to all Representatives, grant recipients, suppliers and clients at the outset of our relationship with them and as appropriate thereafter.
12 Who is Responsible for the Policy
The Partners of Trusted Partners have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Partners of Trusted Partners have primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
13 Risk, Assessment, Monitoring, and Review
As part of its internal risk assessment process the Partners of Trusted Partners will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness.
All Representatives are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
This policy does not form part of any employee’s contract of employment and it may be amended at any time.
This Policy applies to all Partners, Associate Partners, Employees and Sub-Consultants and Sub-Contractors and Suppliers of Trusted Partners (the Company) at all times.
1 Policy Statement
Trusted Partners takes a zero tolerance approach to Modern Slavery in all its forms and will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Trusted Partners has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.
Trusted Partners are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. Trusted Partners expects the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, and we expect that our suppliers will hold their own suppliers to the same high standards.
2 Who is covered by the Policy
This policy applies directly to our partners, associate partners, employees’ sub-consultants and sub-contractors and to all individuals working for our company (herein defined as Representatives). The policy is provided to our Representatives, customers and clients, who will be required to take reasonable steps to ensure that in carrying out activities supported by the company, they and their employees, directors and associates comply, with all applicable anti-bribery and anti-corruption laws. In this policy, “third party” means any “individual or organisation we come into contact with during the course of your role”.
This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
3 The Universal Declaration of Human Rights
Trusted Partners supports the Compact’s Ten Principles which are based on The Universal Declaration of Human Rights. The UNGC specific Ten Principles are:
1. Support and respect the protection of internationally proclaimed human rights.
2. Ensure the company is not complicit in human rights abuses.
3. Uphold the freedom of association and the effective recognition of the right to collective bargaining.
4. Uphold the elimination of all forms of forced and compulsory labour.
5. Uphold the effective abolition of child labour.
6. Eliminate discrimination in employment and occupation.
7. Support a precautionary approach to environmental challenges.
8. Undertake initiatives to promote greater environmental responsibility.
9. Encourage the development and diffusion of environmentally friendly technologies.
10. Work against corruption in all its forms, including extortion and bribery.Under the UNGC, Human rights are the same as labour rights; human trafficking and slavery assessments adopt UNGC assessment approach and definitions.
4 Grievance Mechanism
Trusted Partners maintains a web-based, Grievance Mechanism (https://www.trustedpartners.africa/grievance-mechanism), providing any stakeholders a confidential reporting mechanism to communicate issues regarding Modern Slavery or any other matters.
This Policy applies to all Partners, Associate Partners, Employees and Sub-Consultants and Sub-Contractors and Suppliers of Trusted Partners (the Company) at all times.
1 Policy Statement
Trusted Partners is an Environmental & Social Risk Management Advisory firm that advises in the areas of Environmental, Social, Health & Safety, and Working Conditions primarily within the framework of the Equator Principles and the International Finance Corporations Environmental & Social Performance Standards and similar Development Safeguard Standards.
Trusted Partners are driven by a deep commitment to sustainability and a desire to make a positive impact on the world. We lead by example, that’s why we strive to integrate sustainability into everything we do, from our own operations to the products and services we offer to our clients. We are ambitious in our sustainability goals and believe that by taking a holistic and inclusive approach to sustainability, we can create real and lasting change for the better.
Trusted Partners recognises that by integrating sound environmental and sustainability management practices into all aspects of our business, we can offer distinguished consulting services.
Inasmuch as the Representatives of Trusted Partners are persons of professional standing and capability, it is understood that all Representatives are capable to understand and implement this policy without limitation or constraint.
To achieve this goal all Representatives have a duty of care to themselves and others potentially affected by our activities and are expected to be aware of, and contribute to, the delivery of this policy.
This Policy has been formulated by the Company to ensure that all Representatives adhere to appropriate environmental and sustainability standards that maintains and enhances the reputation of the Company.
2 Who is covered by the Policy
This Policy applies to all the Representatives of the Company, i.e. all Partners, Associate Partners, and Sub-Consultant and Sub-Contractors.
The Company also expects its Representatives to lead by example and perform their duties in accordance with this Policy and ensure that the content of this Policy is communicated to all persons reporting to them. If a business location or region has policies, practices, laws or regulations that require more than what is stated in this Policy, then the Representatives must follow this policy as a minimum and comply with such policies, practices, laws, or regulations in that particular region/ country.
The Company’s reputation and credibility are based upon its total commitment to ethical business practices and also on ethical conduct of its Representatives. To safeguard the Company’s reputation, Representatives must conduct themselves in accordance with the highest ethical standards and also be perceived to be acting ethically at all times. Compliance with all policies of the Company, relevant applicable laws and regulations is the minimum standard which shall be adhered to by all the Representatives all the times.
3 Climate Change
At Trusted Partners and through the services we provide gives us the opportunity to address climate change in an impactful way. Specifically, we provide advise on Climate Risk Assessment to Lender funded projects in our bid to become a more sustainable organisation. We partner with clients to drive climate and environmental impact.
4 Acountability
It is a condition of an appointment and/ or employment that all Representatives must understand and adhere to the Company’s Environmental & Sustainability Policy and at all times and abide by the standards, requirements and procedures laid down herein. They must:
5 Training & Communication
All Representatives will receive relevant awareness training on how to implement and adhere to this policy.
Our environmental impact management and sustainability will be communicated to all Representatives, grant recipients, associates, suppliers, and contractors at the outset of our relationship with them and as appropriate thereafter.
6 Who is Responsible for the Policy
The Partners of Trusted Partners have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Partners of Trusted Partners have primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
7 Risk, Assessment, Monitoring and Review
As part of its internal risk assessment process the Partners of Trusted Partners will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness.
All Representatives are responsible for the success of this policy and shall ensure they use it to disclose any suspected danger or wrongdoing.
This policy does not form part of any employee’s contract of employment and it may be amended at any time.
This Policy applies to all Partners, Associate Partners, Employees and Sub-Consultants and Sub-Contractors (herein referred to as representatives) of Trusted Partners (the Company) at all times.
1 Policy Statement
Trusted Partners takes a zero-tolerance approach to any and all situations or activities that endanger the health and safety of its Representatives or other third parties within the Company’s sphere of control and will uphold all laws relevant applicable to health and safety in all the jurisdictions in which we operate.
Trusted Partners is committed to ensure that its business is conducted, in all respects and all the times, according to rigorous health and safety standards, which prevail from time to time, in the industrial sectors in which Company conducts its normal business. Trusted Partners is also committed to create a workplace, at all of its working locations, that, all the times, provides for a healthy and safe working environment.
Trusted Partners recognises that by integrating sound health, and safety management practices into all aspects of our business, we can offer distinguished consulting services.
Inasmuch as the Representatives of Trusted Partners are persons of professional standing and capability, it is understood that all Representatives are capable to understand and implement this policy without limitation or constraint.
To achieve this goal all Representatives have a duty of care to themselves and others potentially affected by our activities and are expected to be aware of, and contribute to, the delivery of this policy by:
This Policy has been formulated in order to safeguard the health and safety of the Representatives of Trusted Partners by ensuring that all Representatives adhere to appropriate health and safety standards of conduct as set out in this Policy, that maintains and enhances the reputation of Trusted Partners.
The circumstances of conducts as set out below in this Policy, although not exhaustive, are intended to cover those situations, which are most likely perceived to be encountered by Representatives. In case any Representative encounters any circumstance which is not covered hereunder or in case of any doubt, Representatives shall seek guidance from any Partner and act accordingly.
A breach of the Policy may result in disciplinary action against the Representative concerned including, potential dismissal or termination of employment or any other legal action as may available with the Company or all of the above together.
2 Who is covered by the Policy
This Policy applies to all the Representatives of Trusted Partners, i.e. all Partners, Associate Partners, and Sub-Consultant and Sub-Contractors.
Trusted Partners also expects its Representatives to lead by example and perform their duties in accordance with this Policy and ensure that the content of this Policy is communicated to all persons reporting to them. If a business location or region has policies, practices, laws or regulations that require more than what is stated in this Policy, then the Representatives must follow this policy as a minimum and comply with such policies, practices, laws, or regulations in that particular region/ country.
Trusted Partners reputation and credibility are based upon its total commitment to ethical business practices and also on ethical conduct of its Representatives. To safeguard Trusted Partners reputation, Representatives must conduct themselves in accordance with the highest ethical standards and also be perceived to be acting ethically at all times. Compliance with all policies of Trusted Partners, relevant applicable laws and regulations is the minimum standard which shall be adhered to by all the Representatives all the times.
3 Project Health & Safety Plan
Representatives shall all prepare and submit the Project Health & Safety Plan on a project for project basis and submit it to the Project Leader or Project Partner for approval.
Whereas there may be any changes in the scope of work or other matters pertaining to the Project Health & Safety Plan, the Representative shall update the Plan and submit it to the Project Leader or Project Partner for reapproval. The Project Health & Safety Plan form is attached as Appendix A to this Policy and is obtainable as a Stand-alone Document the Project Leader or Project Partner.
4 Travel
Land Travel:
Where land travel is local to South Africa, a Trusted Partners vehicle should be first preference. Whereas, a vehicle needs to be rented:
Where client provide land travel/vehicle it is essential that any person from Trusted Partners first assess the vehicle in terms of road worthiness, general safety and driver competence. Any person from Trusted Partners has the right to refuse to board any vehicle if they feel/believe it to be unsafe. Where the driver may be driving recklessly or dangerously any person from Trusted Partners must advise the driver to act responsibility and if necessary, get the driver to stop to vehicle.
Air Travel:
Due to the nature of Trusted Partners business requiring extensive and regular travel and for Health & Safety reasons, where the total flight travel time exceeds four hours, Business Class travel must be selected.
Travel on any EU Blacklisted airline is strictly prohibited (https://ec.europa.eu/transport/modes/air/safety/air-ban_en). In addition, travel on the following airlines is not permitted due to poor safety track records: Aerolink (Uganda); Air Zimbabwe (Zimbabwe); Arik Air (Nigeria); Dana Air (Nigeria); Eagle Air (Uganda); Egypt Air (Egypt); El Al (Israel); Fastjet (Africa); and TAAG (Angola).
Any person from Trusted Partners has the right to refuse to board any aircraft if they feel/believe it to be unsafe. This is especially important when travelling on small bush-craft outfits to remote sites in Africa/Middle East.
5 Misconduct and Non-Conformance with the Policy
Non-conformance of this Policy shall be construed as misconduct that could warrant disciplinary action, including dismissal in deserving cases. The decision in this regard will lie exclusively with the Partners of Trusted Partners.
6 Accountability
It is a condition of an appointment and/ or employment that all Representatives must understand and adhere to Trusted Partners Health and Safety Policy and at all times and abide by the standards, requirements and procedures laid down herein. They must:
7 Training and Communication
All Representatives will receive relevant awareness training on how to implement and adhere to this policy.
Our zero-tolerance approach safety and health will be communicated to all Representatives, grant recipients, associates, suppliers, and contractors at the outset of our relationship with them and as appropriate thereafter.
8 Who is Responsible for the Policy?
The Partners of Trusted Partners have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Partners of Trusted Partners have primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
9 Risk, Assessment, Monitoring, and Review
As part of its internal risk assessment process the Partners of Trusted Partners will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness.
All Representatives are responsible for the success of this policy and shall ensure they use it to disclose any suspected danger or wrongdoing.
This policy does not form part of any employee’s contract of employment and it may be amended at any time.
