What we are doing
Guarding against fraud and corruption
Ethics and anti-fraud and corruption awareness and training, customised for each business segment and region, ensures that our people understand the behaviours we expect of them.
Independent service providers manage our whistle-blowing hotline, which supports anonymous reporting by all stakeholders. Any concerns relating to unlawful, dishonest, disrespectful and environmentally unfriendly behaviour can be reported.
Hotline tel: 0800 666 005
Hotline email: firstname.lastname@example.org
Ethical and responsible business conduct in the value chain
Over 70% of the products we sell are sourced directly from OEMs. In the balance of the supply chain, disruptions due to COVID-19 have meant that our focus this year has been on the ability to supply. Our supplier contacts are mostly long term, and we expect our suppliers to abide by the terms set out in our Code of Ethics and the supply chain code of conduct, which states that Motus considers social, environmental and fair economic business principles as key elements in business award decisions both for new and existing suppliers. We reserve the right to audit supplier sites, whether by an internal team or through the use of a third party appointed by the Group to verify conformance to our requirements. The supply chain code of conduct is communicated to all key suppliers and, where applicable, is attached as an annexure to our contracts.
In summary, suppliers must respect and comply with all laws and regulations that apply to them in all jurisdictions of operation, and when legislation is lower than the international standards outlined in our supply chain code of conduct, suppliers are required to adopt the higher standards. Our suppliers are also expected to prevent any contravention of human rights, ensure that there are no discriminatory practices in their organisations, employ practices that reduce health and safety risks as far as reasonably possible, and prevent or mitigate environmental impacts that their business activities may cause or contribute to, or which may be directly linked to its operations, products or services by its business relationships.
We will not hesitate to terminate or re-negotiate agreements and relationships that contravene international human rights standards.
In South Africa, broad-based black economic empowerment (B-BBEE) status and/or enterprise and supplier development are additional criteria that are considered when selecting suppliers.
During the implementation of the Protection of Personal Information Act (POPIA) project, key supplier contracts were assessed and updated for data privacy and protection clauses, ensuring that our data management responsibility is extended to third parties.
As our supplier contracts are long term and linked to product distribution, our assessment of our suppliers' ESG performance is limited; however, Aftermarket Parts through the Nexus membership (see Automotive products and services that assist environmental improvement) is developing a framework to assess its supply chain, including identifying the most relevant criteria to be screened.
2021 performance and looking forward
- Conducted an internal analysis to understand whistle-blowing trends, and to ensure that the hotline is not abused and that all material matters are being identified and correctly dealt with. Over 80% of the tip-offs outside of the human resources (HR) category are anonymous, making investigations difficult. In our awareness campaigns this year, we reminded employees that we take tip-offs very seriously, that it is important that we conduct thorough investigations to root out wrongdoing, and that we keep whistle-blower identities confidential and ensure there is no victimisation.
- An updated internal tracking tool was launched in November 2020, which enables more efficient whistle-blowing reporting, categorisation and recordkeeping.
- In the first quarter of F2021, we dealt appropriately with one incident where 31 employees were caught selling customer data to an external entity for personal financial gain. Following an in-depth process together with labour consultants, disciplinary action was taken for breach of company policies and certain regulations. All 31 employees received written warnings, some of which led to resignations and dismissals.
- Of the 75 tip-offs registered on the whistle-blowing hotline, all reports were investigated and closed by year-end. Just under 25% of the tip-offs were valid concerns where disciplinary or remedial action was required. Limited public data is available to assess our reporting against similar organisations; however, we are firmly committed to ensuring the highest standards in maintaining a trustworthy and secure whistle-blowing process.
- Enhancements made to the ethics and fraud prevention framework included:
- Developed a formal process to self-declare conflicts of interests and compliance with ethical standards for the top executives and senior managers in the Group, including confirming their adherence to and understanding of the Code of Ethics, the anti-bribery and corruption policy, the supply chain code of conduct, the conflicts of interest policy and the policy statement on workplace relationships. In this process the executives were also required to note any non-compliance matters they are aware of, and were able to highlight where they felt additional training was required in terms of our policies. By the end of August 2021, all senior managers had completed the exercise, which was then extended to Financial Services. To date, 770 out of 1 090 targeted employees have completed their declarations. This will be an annual exercise going forward and will be expanded to all business segments.
- Updated the Code of Ethics to include data privacy requirements in line with POPIA.
- Worked to ensure that employees used the correct channels to report issues, to prevent grievances coming through the whistle-blowing hotline and to avoid employee frustration when wanting to report a grievance. This is reflected in the reduction in HR-related tip-offs from 73 in F2020 to 51.
- Internal audits did not identify any additional material concerns relating to bribery and corruption, unethical business practices or human rights risks. Where appropriate, internal audit assisted with tip-off investigations.
- No public legal cases regarding corruption were brought against Motus, any of its operations or its employees during the reporting period. There are no legal actions pending and none were completed during the reporting period regarding anti-competitive behaviour and violations of anti-trust and monopoly legislation.
- In South Africa, we are working with naamsa | The Automotive Business Council (naamsa) to develop an industry code of conduct.
- Objective: from F2022 the declaration of gifts and conflicts register will be linked to an employee's record rather than per business segment.
- Objective: consider a set of standard ethics-related questions for inclusion in employee engagement surveys.
- Objective: mature our non-OEM supplier sourcing and selection framework.
|Fleet management irregularities||0||0||2|
|Total number of tip-offs registered||75||105||127|
1 Includes incidents of alleged discrimination.