► Management has a written code of conduct that is reviewed and updated regularly. On joining Frung Fring, all employees are required to review the code of conduct and sign off that they have done so. It is also available on the intranet at all times, and therefore we consider it to be appropriately communicated to employees.
► Management monitors compliance with the code and have set procedures in place to deal with any contraventions. Management informed us that they have identified exceptions in the past and have acted upon them promptly.
► We have observed on several occasions how management holds itself to very high ethical standards and how they lead by example. For instance, we reviewed transcripts of several speeches given by management during employee meetings and have obtained copies of the Company’s internal communications. Both included examples of how management emphasized the importance of integrity and ethical behavior to employees in meetings or communications. In addition, we noted that integrity and ethical values are criteria that employees are evaluated on in their annual performance appraisals. We discussed the criteria with management and they indicated that they review performance appraisals for indicators of non-compliance.
► In addition to the code of conduct, management has policies in place for management of conflicts of interest and security practices. These are also communicated to employees via the intranet, with a manager responsible for the maintenance of each policy. The policies also set out who to contact and the procedures to follow for any identified non-compliance.
► Over the past few years, the management has implemented a whistleblower policy and a fraud hotline. Both launches were accompanied by a series of articles in the internal communication that we obtained. Further the policy is available on the intranet, where we have seen the respective pages. We have also seen posters advertising the fraud hotline posted in prominent places at the different offices that we have visited. From our conversation with the Company’s staff, we know that these programs are well known throughout the entire organization. We have seen reports presented to the Board of directors that summarize results from the fraud hotline and reports on follow-up procedures performed by management.