Business should support and respect the protection of internationally proclaimed human rights.
As stipulated in our Group Human Rights Policy and Group Human Resources Policy, we endorse the principles entrenched in the Universal Declaration of Human Rights and the International Labour Organization (ILO).
We also conform to, and in many cases, exceed prescriptions in labour legislation in the countries in which we operate.
Our Group Human Resources Policy recognises the right of all people to be treated with dignity, and prohibits harassment in the workplace.
Hotlines in all regions allow employees and suppliers to report human rights abuses in full confidentiality.
SSA is involved with a National Business Initiative project to identify a set of priority SDGs and sector-level objectives for the agri-processing sector against which the sector can measure and scale impact. We are contributing to align these with Sappi's priority SDGs. This is a two-year project and could result in a few projects where Sappi would be collaborating with other industry players to improve the livelihoods of rural communities.
Make sure their own corporations are not complicit in human rights abuses.
Our commitment to ensuring that we are not complicit in human rights abuses is encapsulated in our Group Human Rights Policy. This extends to suppliers and states that we:
- Require our suppliers to respect human rights and act in full accordance with our policies and guidelines on social responsibility, labour standards and human rights, and
- Commit to openly and transparently reporting on human rights violations in our value chain, should these occur.
This policy further commits us to working with communities to address indigenous people's interests and to resolving land claims in South Africa by working with the claimants to achieve resolutions that benefit all parties.
In terms of our Group Supplier Code of Conduct, we also encourage our suppliers to uphold the principles of human rights as set out in the United Nations Universal Declaration on Human Rights.
The World Justice Project Rule of Law Index® measures rule-of-law adherence in 126 countries and jurisdictions world-wide based on eight factors: constraints on government powers, absence of corruption, open government, fundamental rights, order and security, regulatory enforcement, civil justice and criminal justice.
The fourth factor, fundamental rights, encompasses adherence to the following: effective enforcement of laws that ensure equal protection, the right to life and security of the person, due process of law and the rights of the accused, freedom of opinion and expression, freedom of belief and religion, the right to privacy, freedom of assembly and association, and fundamental labour rights, including the right to collective bargaining, prohibition of forced and child labour, and elimination of discrimination.
Under this index, the countries in which we have manufacturing operations are classified as set out in the table below. This confirms our understanding that human rights violations in these countries are limited. Scores range from 0 to 1, with 1 indicating the strongest adherence to the rule of law:
(out of 126 countries)
|United States of America||0.71||20|
We have identified no operations or significant suppliers where the right to exercise freedom of association and collective bargaining has been violated or is at significant risk, nor have we identified operations and significant suppliers as having any significant risk for incidents of child labour. Similarly, we have identified no operations and significant suppliers as having significant risk for incidents of forced or compulsory labour, and measures to contribute to the elimination of all forms of forced or compulsory labour.
Businesses should uphold freedom of association and the effective recognition of the right to collective bargaining.
We promote freedom of association and sound labour practices by engaging extensively with representative trade unions. Protecting the right to freedom of association and collective bargaining is fundamental to the manner in which we do business. In 2019, globally, 62% of our workforce was unionised, with 69% belonging to a bargaining unit.
We focus on maintaining constructive relationships with trade unions, believing that this is essential to long-term sustainable development. Discussions range from remuneration issues, to training and development, health and safety and organisational changes.
Given the complex labour situation in South Africa, we have established a number of structures to enhance ongoing positive engagement with union leadership. This is facilitated by structures such as the national partnership forum which includes senior members of management and senior union leaders who hold regular meeting where business, safety and union challenges are discussed.
Disciplined behaviour is essential for individual wellbeing, and to achieve our group goals and objectives. In each region, disciplinary codes ensure appropriate procedures are applied consistently, while grievance policies entrench the rights of employees, including the right to raise a grievance without fear of victimisation, right to seek guidance and assistance from a member of the human resources department or their representative at any time and the right to appeal to a higher authority, without prejudice.
Communicating operational changes
Operational changes are of key concern to all employees, particularly those represented by trade unions or bargaining units.
In terms of career endings, access to retirement planning services is provided on a regional basis and, in some instances, this is supported by financial wellbeing programmes. To the extent that there are employee lay-offs, we provide severance pay to all employees and, in some instances, outplacement assistance.
Overall, we aim to communicate any changes to our people timeously and transparently.
In SEU, information about significant operational changes is only communicated when these are concrete enough to enable proper consultation. Finland is the only country in which we operate where the process is followed through according to a set timeline.
Across all countries, information about significant operational changes needs to be provided at a time when planned changes are concrete enough to inform about reasons for changes, planned measures with impact on employees, number of affected employees and timing, but early enough to still enable proper consultation.
In SNA, the notice period in terms of federal law is 60 days. Details on operational changes are not specified in collective bargaining agreements.
In SSA (including Sappi Limited), the implementation of significant operational changes is governed in terms of section 197 and section 189 of the Labour Relations Act, 66 of 1995. The act does not prescribe a specific notice period. However, the standard practice is a minimum of 30 days, and a maximum of 60 days’ notice for consultation of a large-scale restructuring process. The recognition agreement concluded with the majority union, Chemical, Energy, Paper, Printing, Wood and Allied Workers Union (CEPPWAWU) recognises the provision of the act in this regard.
SSA is party to the bargaining council for the wood and paper sector as well as forestry in South Africa. In the case of sawmilling and pulp and paper, collective bargaining is conducted at industry level under the auspices of the bargaining council. The constitution specifies when parties should submit issues of bargaining for the particular year and when the negotiations must commence. Forestry conditions of employment are implemented on 01 April every year and regulated by ministerial sectoral determination. The normal notice period applies.
Most of the countries in which Sappi Trading is based are not covered by collective agreements except for Austria, Brazil and South Africa. In Austria, the notice period follows labour law and individual employment agreements. In the case of senior and general staff, notice periods of four and three months respectively are required. Based on local legislation, these notice periods increase according to years of service. A notice period is not set up in collective labour agreements. In Brazil, a minimum notice period on operational changes is required for large companies, but there is no particular need to communicate to unions in advance.
Involving health and safety committees
Health and safety committees are in place at all our operations. Through these committees, our people are consulted about the development/review of policies and procedures and changes that affect workplace safety or health.
- In Europe, formal health and safety committees are in place at different levels of the business in line with statutory requirements. All employees are represented by the safety committees.
- In North America, all unions have the opportunity to participate in joint management worker safety committees.
- In South Africa, (including Sappi Limited), health and safety representatives are elected from non-supervisory staff. In line with legislation, there is one representative for every 50 workers.
- Sappi Trading does not have formal joint management worker health and safety committees due to the small size of the offices, but there are appointed safety officers.
The elimination of all forms of forced and compulsory labour.
Our Group Human Rights Policy explicitly forbids the use of compulsory and forced labour. Our Group Supplier Policy states that we encourage our suppliers to adhere to national labour law and to internationally proclaimed human rights, including those relating to forced labour (including prison and slave labour).
Our labour standards ensure that our remuneration practices are fair, with compensation levels set to reflect competitive market practices and internal equity as well as company and individual performance.
In all three regions, labour is sourced on the open market. In rural areas, forest products companies like Sappi are often the only, or major, employers which makes the local population very dependent on the company and which could, in turn, lead to exploitative behaviour and an indirect form of forced labour.
In South Africa, as in the other regions where we operate, Sappi pays market-related wages in line with or above local legislation. In 2013, in South Africa, we made it a contractual obligation for our forestry contractors to pay their workers in accordance with the minimum wage stipulated by government for the agricultural sector. We check compliance with this stipulation regularly. SSA adjusted the minimum wage in the forestry division by 4.5% in addition to the 5.6% adjustment in June 2018. This has resulted in an average increase of 10% for the minimum wage in forestry. In 2019, employees earning above the minimum wage in the forestry division received a wage increase of 6.5%.
Furthermore, in this region, our plantations are 100% FSCTM-certified or controlled and this forest certification system stipulates the protection of indigenous peoples’ rights.
Promoting economic inclusion
We are focused on promoting economic inclusion and eliminating poverty through our Abashintishi programme and Sappi Khulisa enterprise development scheme which has been in operation since 1983.
The latter initiative is aimed at community tree farming and has successfully uplifted impoverished communities in KwaZulu-Natal and the Eastern Cape.
The total area currently managed under this programme 34,139 hectares. In 2019, under the programme, 425,001 tons (2018: 483,359 tons) of woodfibre worth ZAR382 million (2018: ZAR387 million) was delivered to our operations. Since 1995, a total volume of 4,221,941 tons to the value of ZAR4.2 billion has been purchased from small growers in terms of this programme.
We also work actively with the authorities and communities on land reform projects to promote the inclusion of previously disadvantaged South Africans into the economy.
Land claims in South Africa
Sappi is currently engaged in 75 land claims in South Africa. Four claims have been settled and the extent of the land agreed, but we are waiting for finalisation from the KZN and Mpumalanga regional land claims commissioners. To date, 19 claims have been agreed but the extent of the land still has to be finalised with regional commissioners or claimants.
Of the 75 claims, 22 have been referred to court, either because we questioned their validity or the extent of the claim. In the past 10 years, we have settled 37 claims involving 33,992 hectares of which claimants took ownership of 8,151 hectares and claims for 11,629 hectares in which claimants preferred to seek compensation. The balance of the land has either been withdrawn from the claim by the Restitution on Land Rights Commission or the claim rejected by the Land Claims Court.
First established in KZN in 2015, the Abashintshi (isiZulu for 'change agents') programme includes life skills training for the youth, the Ifa Lethu programme for the elderly (protecting cultural heritage), holiday programmes for school children and asset-based community development (ABCD). The latter is based on the premise that communities can drive the development process themselves by identifying and mobilising existing, but often unrecognised, assets. Go to the People section for further details.
The effective abolition of child labour.
Our Group Human Rights Policy explicitly forbids the use of child labour. Our Group Supplier Policy states that we encourage our suppliers to adhere to national labour law and to internationally proclaimed human rights, particularly those relating to child labour.
Sappi Limited scored well in the 2019 Corporate Sector and Children's Rights Benchmark study, achieving a score of 7.7 out of 10 compared with an industry average of 5.9 and also reaching 'Leader' status.
The elimination of discrimination in respect of employment and occupation.
We recognise that the creation of an equitable working environment, in which the dignity of all individuals is respected and the diversity of all employees is valued, represents an essential foundation for sustainable growth and competitive advantage.
We are committed to promoting diversity and inclusion so that all employees can develop their full potential, irrespective of their gender, ethnicity, disability, age, religion, belief or sexual orientation. We administer our people policies, programmes and practices in a non-discriminatory manner in all aspects of our relationship with our employees, including recruitment, hiring, assessments, work assignments, promotions, transfers, terminations, wage and salary administration and selection for training and development.
The Group Human Resources Policy and Group Human Rights Policy state that Sappi prohibits discrimination based on race, gender, colour, ethnicity, age, religion, political and sexual orientation, union membership, physical disability or HIV/AIDS status.
Where an unfair or discriminatory practice has occurred, employees are able to use the grievance procedure to lodge their grievance. Employees also have access to a hotline telephone number where they can report incidents of this nature.
In South Africa, we have employment equity targets to promote economic and social transformation of the previously disadvantaged.
Females tend to be under-represented in our workforce due to the nature of our operations– a manufacturing environment which involves shift work. In 2020, we will be establishing a 2025 global target to enhance gender diversity.
In terms of disability, we focus on creating physically and socially 'disability ready' work environments. When we constructed our corporate headquarters in Johannesburg, for example, we consulted disability experts to ensure that our new offices are disability friendly.
Statement on modern slavery
Modern slavery is defined as slavery, servitude, forced or compulsory labour and human trafficking. The 2016 Global Slavery Index estimates that 45.8 million people in 167 countries are living in modern slavery today. The majority are victims of exploitation in private-sector activities, such as manufacturing, construction and agriculture. The UK Modern Slavery Act requires commercial organisations in any sector with a global annual turnover of £36 million or more that do business in the United Kingdom to disclose the steps they are taking to address modern slavery in their business and supply chain.
To demonstrate our commitment to preventing the occurrence of modern slavery and human trafficking in our operations and supply chains, Sappi is publishing this voluntary modern slavery statement: Modern slavery (slavery, servitude, forced labour and human trafficking) is a global concern with long-lasting impacts on affected individuals and communities.
There is an increasing focus by consumers on ethical fashion and the social and environmental impacts of the products they use. Given that our products are an indispensable part of daily life and given that we have direct and indirect customers in over 150 countries, we recognise that we have a responsibility to ensure that slavery does not enter our supply chain.
While we do not currently see this as a material issue, we take a zero-tolerance approach towards modern slavery in any form. Our policies and operational processes embed our commitment to respect for human rights. As stated in our Group Human Rights Policy, we subscribe to the principles of the International Labour Organization (ILO), uphold and commit to the ten principles set out in the United Nations Global Compact, and support the observance of human rights as set out in the Universal Declaration of Human Rights.
We do not tolerate any form of workplace discrimination, harassment or physical assault, or any form of child, forced, or compulsory labour. We seek to reflect the diversity of the communities in which we operate in our workforce. We respect the rights of our employees and contractors, including freedom of association and collective bargaining. Throughout our operations, we seek to avoid complicity in human rights abuses, and to uphold relevant international standards.
We have intensified this focus with the rollout across the group in 2019 of a newGroup Supplier Code of Conduct requiring our suppliers to implement policies such as freely chosen employment which prevents the use of forced, slave, bonded, indentured or involuntary prison labour and to align with the United Nations Universal Declaration on Human Rights, as well as the ILO Convention No 138 on Minimum Age.
Businesses should support a precautionary approach to environmental challenges.
As stated in our Group Sustainability Charter and Group Environmental Policy, we acknowledge that we do have an environmental footprint, but are committed to managing and mitigating the environmental, climate and biodiversity impacts of our operations.
The precautionary approach places the onus on Sappi to anticipate harm before it occurs and to take active steps to prevent any harm from occurring. We achieve this by:
- Minimising the environmental impact of our operations in terms of raw materials and energy use
- Developing new production methods and products, and finding innovative ways of beneficiating waste
- Saving water and energy at every step in production processes. This begins in our South African plantations, where we apply best-practice management techniques to produce woodfibre with properties that allow it to be pulped using less energy and water
- Ongoing investment in research and development
- Monitoring environmental performance and legal compliance at each mill, by constantly assessing our performance in terms of energy dashboards, integrated water and waste management plans, air emissions and effluent
- Taking appropriate, pre-emptive action to avoid or mitigate identified environmental risks
- Ensuring that we keep up with environmental best practice through an internal environmental 'cluster' comprising experts in various fields
- Having environmental targets in place in each region. Progress towards targets is reported to management teams in each region regularly, quarterly to the Global Sustainable Development Council (GSDC) and to the Social, Ethics, Transformation and Sustainability (SETS) Committee biannually, and
- Using internationally recognised, independently verified certification systems including the Forest Stewardship CouncilTM (FSCTM), the Programme for the Endorsement of Forest CertificationTM (PEFCTM) and the Sustainable Forestry Initiative® (SFI®), as well as ISO 9001, ISO 14001, OHSAS 18001 and, in Europe the Eco Management and Audit System (EMAS) and ISO 50001 in Europe and South Africa.
We view conducting our business in an environmentally sustainable manner as an obligation—one that is integral to our licence to operate on an individual, community, country and global level. It also makes sound business sense, given that we depend on natural resources such as water and woodfibre for our ongoing viability as a business and it is in our interest to use these resources as responsibly as possible.
This obligation includes investing in new technology and upgrading mill processes as these become feasible or pre-empting changes in manufacturing regulations. Please click here to view the environmental benefits that will result from our expansion project at Saiccor Mill.
Undertake initiatives to promote greater environmental responsibility.
At the heart of our business is a renewable, recyclable natural resource-woodfibre. We use this to create pulp, paper and dissolving wood pulp solutions that enhance the lives of consumers around the world.
We take a holistic approach to protecting the environment, beginning with the responsible procurement of wood that is grown and harvested sustainably and sourced only from well-managed forests and plantations. We are committed to reducing our use of traditional fossil fuels, lowering both our environmental footprint and energy costs. We focus on the efficient use and recovery of materials used in the manufacturing process to minimise waste.
Our energy efficiency is enhanced through our ongoing drive to make process improvements and install more efficient equipment, as well as through our extensive use of co-generation.
We track key metrics for fibre, emissions, energy use and the impact of our operations on air, water and solid waste.
We use this data when setting improvement goals for either our operations or interactions with our key stakeholder groups—employees, customers and our local communities. In 2015, we established 2020 global goals in addition to regional goals to deal with specific issues. Progress against these goals are disclosed in our annual integrated report, our Group Sustainability Report, Sappi North America Sustainability Report and Sappi Southern Africa Corporate Citizenship Report, all available on www.sappi.com/sustainability.
Land, air and water are shared resources. By motivating and encouraging people—particularly those close to our operations—to share our commitment to treading more lightly on the Planet, our aim is to enhance the sustainability of the natural resources and ecosystems on which our business depends.
At global level, in 2015, we became a signatory to the Paris Pledge for Action.
In SEU, we:
- Continue with our eco-effectiveness campaign whereby Sappi people share their stories about achieving greater levels of environmental responsibility (see www.sappi.com/eco-effective-stories).
- Communicate information internally about sustainability-related topics through our green ambassadors, who keep colleagues informed about industry developments that could be of interest to customers.
- Are closely engaged in the Confederation of European Paper Industries (CEPI) Roadmap 2050 which works to implement the transition to an effective low-carbon economy.
- Belong to the Save Food initiative which signals a firm commitment to better protection of all foodstuffs the world over. Save Food is a joint initiative of the Food and Agriculture Organisation of the United Nations (FAO), United Nations Environment Programme (UNEP), Messe Düsseldorf and Interpack, the world's leading trade fair for processes and packaging.
- Are actively contributing to the development of an industry standard for delivering chemical information through the paper and pulp supply chain and the development of a paper and pulp industry declared substances list. The consortium is a joint working group under CEPI and the European Pulp and Paper Chemicals Group (EPCG), with Sappi as chair.
- We will be participating in CEPI's Evergreen Project which launched shortly after year end. The project seeks to be a cross-industry alliance that includes brand owners to boost the role of fibre-based packaging in a circular and sustainable economy—that minimises climate and environmental impact. It will work to advocate for fibre-based packaging, address the challenges of recyclability and facilitate value chain cooperation.
In SNA, we:
- Play an active role in Living Lands & Waters, a non-profit, environmental organisation focused on cleaning up America's great rivers and forest restoration ( www.livinglandsandwaters.org/ who-we-are/sponsors.html).
- We are a long-standing supporter, together with publishers, cataloguers and other paper companies, of Recycling Works in Publishing (RWIP). We have now joined The Recycling Partnership as a funding partner and, together with the organisation, will be working to help transform recycling nation-wide, increase materials recovery, and reduce the creation of greenhouse gases that add to climate change ( www.recyclingpartnership.org).
- The Sappi Maine Forestry Program and the Sappi Lake States Private Forestry Program assist forest landowners to meet their objective for managing their woodland. Sappi's trained foresters are able to develop a forest management plan geared to the interests of the landowner including wildlife management and aesthetics, marketing timber to generate maximum return and providing an extensive network of environmental and marketing resources.
- Our Cloquet Mill has had a long-standing relationship with the University of Minnesota Extension Service. In terms of this partnership, boiler ash and lime mud are diverted from landfill and put to beneficial use as a soil amendment. The alkaline pH of these materials helps adjust the pH of crop soil and allows for better absorption of nutrients—ultimately resulting in better yield of alfalfa used in dairy farming.
In SSA, we:
- Set approximately 30% of our land aside for the management and conservation of natural habitats, including indigenous forests, and the biodiversity they contain.
- Have established a group forest certification scheme for small- and medium-sized growers. There are currently 44 members in the scheme with plantations ranging from less than a hundred hectares to several thousand hectares. While our own plantations are 100% FSC-certified, we recognised that we needed to obtain certification over and above the FSC group scheme certification, based on the difficulty of getting small growers certified and on customers' requests for PEFC labelled products. PEFC endorses national certification schemes, which meant South Africa had to develop a new certification scheme including a forest management standard. This is now known as the South African Forest Assurance Scheme (SAFAS).
- Qualified extension officers work with growers in Sappi Khulisa, our supplier and enterprise development scheme, providing them with growing advice and practical assistance
- Participate in the national stewardship programme through which six areas on our land have been declared nature reserves
- Promote multiple use of our landholdings. Our land provides a resource for planned recreational activities. We support non-motorised activities such as mountain biking and bird watching on our land, aligning with our commitment to promoting a healthy lifestyle and nurturing an appreciation for nature and the sustainable use of renewable resources. We have partnered with mountain biking clubs and event organisers, allowing access to our plantations and natural areas in Mpumalanga and KZN.
- Support the Pepper Bark Tree (Warburgia salutaris) project which in turn supports the efforts of the Kruger National Park to protect South Africa's most endangered tree by reintroducing it into communities. Sappi's intervention has enabled seedlings to be grown on a large scale. An annual target of 15,000 seedlings/trees distributed is ensuring that the tree is reintroduced across many communities in sustainable numbers.
- We provide support to various environmental organisations including SANBI (South African National Biodiversity Institute), Birdlife SA, WWFSA, the Honorary Rangers of the Kruger National Park, and the UCT animal demography unit (ADU) indigenous tree mapping project.
- Annually, we provide information to CDP's carbon disclosure and forest footprint disclosure projects and make our submission publicly available. In each region, we sponsor environment-related publications accessible to the general reader.
Encourage the development and diffusion of environmentally friendly technologies.
Technology is a cornerstone of our business and is supported by technology centres in each region covering each section of the value chain, as set out in the box below.
The development and use of environmentally friendly technologies underpins research at all these centres.
Our R&D centres across the world
We spent US$42 million on R&D in 2019. Technology is a cornerstone of our business and is supported by technology centres in each region covering each section of the value chain:
Maastricht centre of excellence
- Papermaking processes
Westbrook centre of excellence
- Coated woodfree paper and speciality casting and release paper development
Forestry research centre (Tweedie)
- Tree breeding
- Propagation techniques
Sappi technology centre (Pretoria)
- Fibre processing
- Paper sciences
- Chemical sciences
Sappi DWP's centre of excellence (Umkomaas)
- Applications testing
- Fundamental cellulose properties
The annual global Technical Innovation Awards, promote a culture of internal innovation.
Businesses should work against corruption in all its forms, including extortion and bribery.
Maintaining a sound ethical culture forms the foundation of Sappi's long-term sustainability and creation of value for our stakeholders.
We recognise that building an accountable organisation underpins our ongoing viability as a business. Accordingly, the Social, Ethics, Transformation and Sustainability (SETS) Committee monitors our activities on matters such as social and economic development, including the United Nations Global Compact (UNGC) and the OECD Guidelines on Bribery and Corruption, with particular emphasis on section VII of the OECD guidelines for multinational enterprises dealing with combating bribery, bribe solicitation and extortion.
No issues have been raised for Sappi on compliance with the convention either externally or internally.
We regularly review the Code of Ethics (Code) to ensure that it remains aligned to current governance and business trends. Accordingly, in September 2016, we launched a revised Code which incorporated the new Sappi values: At Sappi we do business with integrity and courage; making smart decisions which we execute with speed. In 2018, in light of our increased focus on safety, we added: Our values are underpinned by an unrelenting focus on and commitment to safety. Sappi's ethics management strengths include:
- The completion of mandatory online ethics management training for all employees
- Sappi hotlines, operated by independent service providers, are available to all stakeholders
- Retaliation against whistle-blowers is not tolerated
- An anti-fraud policy provides guidance to Sappi management in identifying and managing fraud
- Annual fraud and ethics risk assessments are conducted to identify potential weaknesses. These assessments are integrated into Sappi's control framework that covers 100% of our operations
- For forensic incidents, independent investigations are done which include due consideration for ethics management and forensic lessons learned, and
- Employee engagement surveys, held every second year, provide insight into employee and management ethics application.
The internal audit (IA) department is responsible for performing or assisting with forensic investigations. During forensic investigations, particular attention is paid to the circumstances contributing to the incident and management's tone in responding to these incidents. IA pays also reviews the ethics management arrangements and ethics controls for particular units and processes during certain audits. Audit steps include confirming the status of our Code and hotline communication, completion of ethics training by employees and reviewing processes for employees to disclose potential conflicts of interest.
In March 2019, we again rolled out the employee engagement survey, which includes an evaluation of values and ethical leadership as perceived by employees. The results in this area will be a useful guide to understanding the culture of ethical behaviour and conduct in Sappi and where improvements can be made.
We are also of rolling out a Group Supplier Code of Conduct which calls on suppliers to commit to ethical behaviour, human rights, health and safety, diversity and equal opportunity and environmental awareness.
In 2018, Sappi Limited signed the Business Leadership South Africa Integrity Pledge, thereby committing ourselves to actively combating corrupt practices wherever encountered, preventing anti-competitive behaviour, adopting a zero-tolerance approach to corrupt behaviour and protecting whistle-blowers.