Sasol Limited Sustainability Report 2021 - Book - Page 18
SUSTAINABILITY PERFORMANCE AGAINST OUR FOCUS AREAS: SAFE AND ENDURING OPERATIONS (CONTINUED)
Promoting high ethical standards and
combating corruption throughout our sphere
of influence is an important part of our drive to
deliver social value through our core activities.
We offer employees and third parties the opportunity to make
confidential disclosures to our Ethics Line, Group Ethics Office or trained
Sasol Ethics Officers. The Ethics Line is a confidential and independent
system through which any person can report suspected transgressions
of the Code of Conduct, breaches of law, or allegations of human rights
abuses. The toll-free line is available in South Africa, United States,
United Kingdom, China, Singapore, Germany, Mozambique, Canada and
Italy. Callers are assisted in the local language of their choice, including
English, Afrikaans, Zulu, Sotho, Xhosa, Pedi, Venda, Tswana, SiSwati,
Ndebele, Tsonga, Mandarin, Portuguese, Italian and German.
Ethics investigations are conducted strictly in accordance with the updated Ethics
Investigation Policy and Procedure.
Our Whistle-blower Policy sets out our commitment to protecting
all stakeholders who, in good faith, report unethical conduct and
alleged human rights abuses. This policy is intended to encourage all
stakeholders who have dealings with Sasol to make reports on unethical
conduct without fear of reprisal.
We continuously promote the Whistle-blower Policy across the Group by way of what we
call ‘ethics and compliance moments’ and awareness campaigns aimed at reinforcing our
zero tolerance to retaliation and victimisation of whistle-blowers and those supporting
Sasol has adopted various anti-bribery and competition law policies
which set out the parameters for engagements with external parties
to enable compliance with applicable laws.
We provide training annually to particular employees on matters relating to anti-bribery
and competition (anti-trust) laws. The target audience of employees is linked to the risk
profile of their positions and roles at Sasol. As part of the training, employees participate
in an assessment to test their understanding of the training modules.
The philosophy of our Group Ethics Office is to
enable business success on the earned foundation
and reputation that Sasol is an ethical company that
not only does things right, but does the right things.
Part of Sasol’s ethical culture is expressed in the confidence
that employees have in our ability to address allegations of
unethical behaviour through the Sasol EthicsLine. Our strong
ethical culture is enhance by the Sasol Whistle-blower Policy
which encourages stakeholders to speak up and which clearly
sets out our zero tolerance for any victimisation or retaliation
towards those who do so.
During 2021, we had 458 calls. The typical nature of ethics
calls related to allegations of appointment irregularities,
dishonesty, discrimination, and abusive or disrespectful
•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.
•In three instances the investigations resulted in service
terminations. These related to behaviour such as
bribery and corruption, conflicts of interest, intimidation
and victimisation, fraud and misrepresentation,
•A total of 31 allegations resulted in suspensions, verbal,
written, serious and final warnings.
LIVING BY OUR VALUES
New employees provided with ethics training
Employees provided with Exploring
Ethics and Economic Crimes training
The Sasol Code of Conduct is supported by our values. By acting
in accordance with these values, Sasol fosters a business
culture which everyone can be proud of. Management and
employees who are identified as being in potentially exposed
positions, are required on an annual basis to formally confirm
that they know and understand the Code of Conduct and its
To support the integration of ethics into all aspects of business, and to
encourage ethical behaviour and decision making, we provide employees
with ethics training and run ethics awareness campaigns throughout the
year. Training materials are benchmarked against other leading industry
On an annual basis a targeted group of employees are required to
complete the Annual Compliance Conformation Process, whereby
they confirm in writing that they are aware of and have abided with the
Code of Conduct, Competition Law Policy, Anti-Bribery Policy, Group
Safety and Environmental Policy, Conflicts of Interest Policy and the Gifts,
Entertainment and Hospitality Policy.
In addition, 15 new ethics co-ordinators, and 54 new ethics investigators have been
appointed and trained.
We continued with our efforts to support our employees to make the right ethical choices
and to adhere to Sasol’s expectations in these challenging and extraordinary times. We
further developed ethics moments to guide leadership to promote ethical behaviour, within
their areas of responsibility.
Ethics training is given to all new and existing employees across the Group. During the year,
a total of 1 263 new employees received ethics related training which was provided by the
Group Ethics Office. The Group Ethics Office in conjunction with the Assurance Services
Function present a training course called 'Exploring Ethics and Economic Crime' to promote
ethical awareness. This training was attended by 351 employees this financial year.
In accordance with the Sasol Conflicts of Interest Policy, employees must
at all times avoid any actual, potential or perceived conflicts of interest.
If such a conflict of interest arises this must be declared, mitigated
and approved on the Sasol Declaration System (SDS) or manually in
jurisdictions which do not have access to the SDS.
We continuously raise awareness on this policy through training and awareness campaigns.
Awareness creation related to conflicts of interest is part of the on-boarding training
provided to all new Sasol employees so that actual, perceived or potential conflicts of
interest can be identified upfront and appropriately managed. Ethics Officers provide
reports to their management committees. These reports include the details of the conflict
of interest declarations in the business. In addition, as part of the annual compliance
confirmation process mentioned above, 6 363 employees confirmed that they had made
all their required conflict of interest declarations for the year.
We work to reduce possible fraud or corruption by our employees and
trading partners and to adhere to the Prevention and Combating of
Corrupt Activities Act, 12 of 2004. We require the pre-approval by
Sasol employees of all gifts, entertainment or hospitality – with a value
exceeding a specified limit or which may create a conflict of interest
– that we offer or receive. This must be formally disclosed in the SDS
(or manually where there is no access to this system).
We provide employees with training regarding the Gifts, Entertainment and Hospitality
Policy. Through the Group Ethics Office, or via compliance officers, we dispose of those gifts
that do meet the Policy’s criteria and may not be retained by employees.
Our code of conduct
The role of Ethics Officers is to promote the advancement of ethics as well as ensure proper
and adequate investigation into unethical conduct.
During 2021, more than 5 employees, including the Sasol Group Executive Committee,
completed the anti-bribery and competition law training modules. 38 employees from
our joint ventures also received training. More than 6 363 employees across the Group
completed an annual compliance confirmation, including an undertaking to comply with
anti-bribery and competition law policies.
SASOL ETHICS GLOBAL COMMUNITY
Due to changes in the Sasol operating model, 24 new Ethics Officers in the various business
have been trained.
Sasol Sustainability Report 2021