2022 Sasol Sustainability Report - Book - Page 21
SUSTAINABILITY PERFORMANCE AGAINST OUR FOCUS AREAS
INTRODUCTION
DATA AND ASSURANCE
SAFE AND ENDURING OPERATIONS (CONTINUED)
Ethics (continued)
Ethics training and awareness
Managing conflicts of interest
Managing gifts, entertainment and hospitality
• Supporting the integration of ethics into all aspects
of business and encouraging ethical behaviour in our
decision making.
• Amending the Sasol Conflicts of Interest Policy to
align with the Sasol 2.0 operating model.
• Working to reduce possible fraud or corruption
by our employees and trading partners by adhering
to the Prevention and Combating of Corrupt Activities
Act, 12 of 2004.
• Providing ethics training and awareness campaigns
for employees throughout the year, including a
course called ‘Exploring Ethics and Economic Crime’
jointly presented by the Group Ethics Office and Sasol
Assurance Services and targeted training on Sasol’s
Conflict of Interest Policy.
• Ensuring employees avoid any actual, potential or
perceived conflicts of interest through the Policy
and the Process Guidelines.
• Declaring and mitigating conflicts of interest should
they arise on the Sasol Declaration System (SDS),
SharePoint Approval Site or manually for employees
who do not have access to the online system.
• Guiding leadership, promoting ethical behaviour thereby
increasing ethics visibility within areas of responsibility
through ‘ethics moments’.
• Assisting employees to understand what conflicts of
interest are and how to declare them using computerbased training, which includes an assessment.
• Providing training to 425 employees in Mozambique,
by the Group Ethics Office, Group Forensics and the
Ethics Institute.
• Creating awareness related to conflicts of interest
as part of the onboarding training for all new Sasol
employees ensuring that actual, perceived or potential
conflicts of interest are identified upfront and
appropriately managed.
• 4 095 employees attended the various ethics training
initiatives in 2022.
• Requiring annual confirmation from a targeted group of
employees as part of the Annual Compliance Confirmation
Process. These employees confirm in writing that they
are aware of and have abided with the Code, Competition
Law Policy, Anti-Bribery Policy, Group Safety and
Environmental Policy, Conflicts of Interest Policy and
the Gifts, Entertainment and Hospitality Policy.
• Providing declaration reports to line management
which include details of conflicts of interest
declarations in their respective businesses and how
these conflicts should be managed and mitigated.
• 6 015 employees confirmed that they had declared all
their conflicts of interest as applicable or that they
had nothing to declare.
• Aligning the Sasol Gifts, Entertainment and
Hospitality Policy with international benchmark
practices to further manage the risk when engaging
with public officials.
• Requiring the pre-approval of all gifts, entertainment
or hospitality – with a value exceeding a specified
limit, or which are offered or received from public
officials, or which may create a conflict of interest
for Sasol employees.
• Obtaining written pre-approval for gifts, entertainment
or hospitality via the SDS, SharePoint Approval Site
or manually for employees who do not have access
to the online system.
• Assisting employees to understand the potential
risks in accepting or giving gifts, entertainment
and hospitality and to seek pre-approval for these
through computer-based training, which includes
an assessment.
• Returning of gifts that do not meet the Policy’s
requirements and which may thus not be retained
by employees through the Group Ethics Office,
or via Ethics Officers.
PERFORMANCE
During 2022, we received 349 calls. The typical
nature of ethics calls related to allegations of fraud
and misrepresentation and conflicts of interest.
To maintain confidence in the EthicsLine and
support Sasol’s ethical culture, we ensure that
all matters are thoroughly investigated, and
appropriate corrective actions are taken on
substantiated ethical transgressions as determined
by the appropriate Employee Relations Specialists.
One investigation, related to substantiated
allegations of fraud and misrepresentation, led
to a service termination.
A total of 120 allegations resulted in management
action being taken.
LIVING BY OUR VALUES
New employees
provided with ethics
training
2 137
SASOL GLOBAL
ETHICS COMMUNITY
SASOL SUSTAINABILITY REPORT 2022
20
Employees provided
with Exploring Ethics and
Economic Crimes training
651
Officers
30
Coordinators
19
Gas Sourcing Operations
employees provided with
customised ethics training
425
Investigators
125