How often do you see people doing things that you know are not right? How do you feel about this when you are trying to live a life that your family can be proud of?

We believe that everybody who works in the Transaction Capital group should behave in a way that we can all be proud of. This means that all of us must comply with the law and the rules, practices and ethics that govern our country, company and industry. It also means that we must treat the people, assets and stakeholders of our group with respect and care. Failing to do so will damage our reputation.

Your personal reputation and the reputation of our group have taken many years to create. As we have seen so often, a reputation that takes a lifetime to build can be lost in one foolish act. Too many people in this group have worked too hard for too long to allow the poor behaviour of one of us to tarnish the reputation of the rest of us or the reputation of the Transaction Capital group.

To ensure this, we have established policies and procedures to maintain control and high standards of behaviour within the group. We monitor these controls and standards through day-to-day management, internal and external auditors and oversight by boards of directors.

Occasionally, these are ignored and individuals behave badly. When this happens you have a role to play in upholding our reputation by bringing this bad behaviour to the attention of the directors of the company.

All staff members are entitled to complain about, report and escalate all incidents considered to be inappropriate, fraudulent or dishonest through the appropriate channels and by application of the correct procedures.

Reporting to senior management

The first and most obvious of these is to bring the matter to the attention of your direct supervisor. If you are not comfortable with this you can bring it to the attention of the head of Internal Audit, your company CEO, a director of Transaction Capital or me.

In each of these cases you can do this in writing, by email or by phone but you will have to identify yourself and be prepared to enter into a discussion on the matter. You have my assurance that your confidentiality will be respected and the matter will be handled sensitively. Under no circumstance will any manager in the Transaction Capital group respond to anonymous letters or calls. They will be ignored.

Fraud hotline function and operation

If you are uncomfortable reporting to line management you can use anindependent, confidential whistleblowing hotline service operated by Deloitte South Africa 24 hours a day, 365 days a year. Although no one will know that you have reported a fraud or an incident of bad behaviour, there is a mechanism for the tracking of tip-off’s by the person making the call.

The Transaction Capital group hotline was launched in 2009 for all the companies in the group. The group whistleblowing hot line can be used to report fraud and inappropriate activities in a safe, confidential and secure way. This includes email, online reporting to a secure website and calls to a confidential 0800 line. The service is available to all stakeholders including employees, shareholders, suppliers and customers.

In 2010 Transaction Capital published the “Transaction Capital Group Ethics Charter, our business survival guide” which was approved by the Ethics Institute of South Africa on 4 March 2010. The charter is applicable to the entire Transaction Capital group as well as each of its subsidiaries, employees, contractors and nonexecutive directors. The charter seeks to be our ethical compass and clearly outlines our core values of integrity, respect, competence and innovation.

Conclusion

When you come across unacceptable behaviour at any level of the Transaction Capital group you have a choice. You can ignore it or you can report it. My hope is that your own family values are such that you report it and in doing so protect the assets, people and reputation of Transaction Capital.

Mark J Lamberti, CEO

Tip-off Information