our “No Gift” policy mandates that employees and directors of the Group, their family members and any agents acting on their behalf may not accept any direct or indirect gifts from external parties which have business dealings with the Group. These parties are similarly prohibited to giving gifts to external parties, and any activities deemed as “Entertainment” are declared and logged on a register, which is then validated against claims made with the Human Resources department. In seeking to inculcate integrous and ethical behaviour across our workforce, our Code of Conduct (“Code”) contains policies and guidelines relating to the standards and ethics that all employees are expected to adhere to in the course of their work. The Code outlines expectations and standards in areas including confidentiality, conflicts of interest, harassment and bullying, insubordination and employee efficiency, and outlines disciplinary actions that may be taken in the event of any breaches. Ultimately, our strictures can only be effective if all employees feel empowered and protected in reporting any suspected wrongdoings. To this end, our Whistleblowing Framework and Policy provides a structured mechanism for employees and all stakeholders of the Group to raise suspected instances of fraud, waste and/or abuse anonymously, without fear of retaliation or victimisation. It dictates that all issues raised should be considered without bias and be brought to the attention of the Chairman of the Whistleblowing Committee for further action to be considered and taken if necessary. The Board continuously seeks to strengthen its approach to business ethics in order to uphold the Group’s reputation as a transparent and clean organisation. To this end, a Directors’ Code of Ethics and Conduct and a Directors’ Fit and Proper Policy were introduced in FY2022, governing the standards of behaviour and qualities expected in Directors of the Group. For this reporting period, no legal notices were received or actions taken by government authorities relating to anticompetitive behaviour, anti-trust or monopolistic practices. BUSINESS MODEL RESILIENCE We are operating within a global environment in flux, with geopolitical uncertainty, economic instability and the climate emergency combining to increase risks to our businesses and our ability to create value for our stakeholders. Therefore, as we continue with our corporate transformation and expansion efforts, it is crucial that we also safeguard the resilience of our business against unforeseen events and shocks in the global economy. By taking proactive measures to prepare for such events, we can minimise their disruption to our operations, while also improving our standing in the eyes of our stakeholders. In the interests of ensuring continuity, we have established a Business Continuity Management (“BCM”) Framework and Policy, which was approved by the Board in May 2022. The BCM Framework contains several key elements: • A Crisis Communications Management (“CCM”) plan; • A Business Continuity Plan (“BCP”); and • An Emergency Response Plan (“ERP”) The BCP is a key component in our overall approach to business resilience. It sets out several possible scenarios which may threaten our business, and details guidelines for training, awareness and testing along the lines of these scenarios. It also complements the Disaster Recovery Plan that we have in place. In striving towards progressive improvement in our approach to BCM, we are guided by the ISO 22301 standard for Business Continuity Management, which provides a framework for us to implement, operate, monitor and review, and ultimately improve our processes over time. Our Enterprise Risk Management processes are guided by ISO 31000:2018 – Risk Management Guidelines, and the Committee of Sponsoring Organisations of the Treadway Commission (“COSO”) Enterprise Risk Management Integrated Framework. On an ongoing basis, we also monitor around 24 key risks which have the potential to disrupt our business operations, which collectively span seven categories: Operational, Business Information, Technology, Legal, People, Strategy and Financial. These risks are reviewed quarterly to ensure that updated and business critical information is available and disseminated across the Group. 185 DNeX INTEGRATED REPORT 2022
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