Ethics

Sun International employs the services of a reputable external auditing firm to operate a 24-hour toll-free Ethics Line, which employees may call anonymously.

CODE OF ETHICS

The company’s internal Code of Ethics and its policy in respect of its stance against fraud, corruption and dishonesty in general is manifested in this code and the policy documents. To give effect to this stance the company launched and maintains an awareness campaign with management and staff as reminders of the ills which fraud and corrupt practices can bring to companies if these practices are not brought to book.

Management and staff are expected to remain committed to the highest ethical standards of conduct (refer to code of ethics) and this clearly confirms the company’s commitment to all its stakeholders. Additionally, the other guidelines of the Code of Ethics emphasise the importance of enlightened employment practices.

The group intends to enhance its Code of Ethics on a regular basis and ensures that the values on which it prides itself will always be an integral part of the culture of the company.

ETHICS LINE

Sun International employs the services of a reputable external auditing firm to operate a 24-hour toll-free Ethics Line, which employees may call anonymously. Any crime or incident of fraud or misconduct within the group that might be reported to Ethics Line is brought to the attention of dedicated resources and the Chief Executive.

The reporting procedure is highlighted in an awareness campaign and is published in our staff magazine.

During the year, the group refreshed its policy with regard to whistle blowing and the procedures to be followed in response to reported fraud. The objective of the whistle blowing policy is to encourage reporting of matters which may cause financial or non-financial losses to the group and to provide guidelines which seek to protect whistle blowers against reprisals as well as establishing clear disclosure guidelines and an appropriate reporting infrastructure. The policy embraces the Protective Disclosures Act.

FRAUD RESPONSE PLAN

The fraud response plan provides all employees with a clear procedure for reporting fraud or misconduct and the appropriate escalation of that reporting. The policy further establishes the factors to be considered in investigating the fraud/misconduct, the mitigation of further losses as well as the involvement of insurers.

FICA AND POCDATARA

Money laundering remains a global problem. Due to the increasing sophistication of technical and electronic financial systems, opportunities for money laundering have escalated and so has the potential to finance undesirable activities.

This has resulted in renewed attention from governments to establish legislation to curb this potential. In South Africa the relevant legislation is effected through the Financial Intelligence Centre Act (FICA) and the Protection of Constitutional Democracy against Terrorist and Related Activities Act (POCDATARA). The group has an obligation to assist the country in preventing and curbing attempts at money laundering and the financing of undesirable activities.

Sun International meets all of its obligations and requirements in respect of reporting procedures, specific controls and administration as well as staff training.

As a member of CASA, the group liaises and interacts with the FIC and other member companies to ensure that industry-wide compliance with the legislated requirements are met and maintained.

The group considers it critical to maintain and protect its reputation in society and within the regulatory environment. This is of particular relevance to the gaming industry in which the group operates and is directly linked to the casino licence requirements to which the group must ensure compliance.

CODE OF ETHICS

The group recognises the vested interest of all stakeholders in the manner in which its various businesses are conducted. This Code of Ethics will assist in fulfilling our responsibility to these stakeholders.

The group will act in a way that will earn it and its subsidiaries the reputation of being:

•	Open and honest in all dealings
•	Consistent in fulfilling its moral and legal obligations
•	Socially responsible
•	Environmentally responsible
•	Non-sectarian
•	Non-political
•	Supportive of loyalty and long-standing relationships
•	Protective of the quality of its services and products

With respect to its people resources, the group is committed to enlightened employment policies and practices whereby:

•	Discrimination is eliminated
•	Training and skills development is emphasised
•	Employees have an uncontested right to organise and negotiate their conditions of employment

Management and staff are expected to remain committed to the highest ethical standards of conduct.