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JSE code: EQU

Anti-bribery and corruption programme

At Equites, we conduct our business with integrity, fairness and accountability. We maintain a zero-tolerance approach to bribery and corruption, supported by a formal Anti-Bribery and Corruption Policy and a robust system of governance and oversight.  

Policy compliance is monitored by management and oversight provided by the Board through the Audit and Risk Committee. This structured approach ensures that we maintain the trust of our stakeholders and uphold international best practice in ethical business conduct.   

Key elements of our programme include: 

Risk assessments 

We evaluate bribery and corruption risks across our operations and value chain with a specific focus on high-risk transactions, geographies and counterparties. 

Screening of partners and suppliers 

All new business partners and suppliers undergo due diligence and integrity screening through independent, region-specific risk providers, with ongoing monitoring where appropriate. 

Employee commitments and training 

All employees must sign off on our Anti-Bribery and Corruption Policy annually and complete regular training to ensure awareness of obligations and emerging risks. 

Monitoring and detection 

Internal control systems and audit processes are in place to identify potential misconduct. 

Consultation and reporting channels 

Employees have access to confidential mechanisms to seek guidance or report concerns without fear of retaliation. 

Managerial and executive accountability 

Managers are responsible for embedding the policy within their teams, with oversight by senior leadership and the Board’s Audit and Risk Committee. 

Continuous improvement 

We benchmark against best practice, including the ISO 37001 Anti-Bribery Management System as a reference for potential future alignment. While not yet formally certified, ISO 37001 provides a reference framework for continuous improvement.   

ANTI-BRIBERY AND CORRUPTION POLICY

Business ethics and whistleblowing

We are committed to the highest standards of ethical business conduct, guided by a comprehensive Code of Business Ethics that applies to all employees, contractors and stakeholders. The Code is reinforced through annual training and ongoing awareness campaigns to ensure that ethical principles are embedded throughout the organisation. 

Oversight of business ethics rests with the Board of Directors, supported by management, who are responsible for embedding ethical standards in day-to-day operations. Ethical risk assessments are conducted regularly, supported by clear operating guidelines, and all reported incidents are investigated promptly with corrective actions implemented where required. A fraud risk attestation is also submitted to the Board annually. 

To strengthen accountability and protect stakeholders, we have implemented the Ethics Defender programme, an independent whistleblower platform that allows employees and external parties to report concerns confidentially and securely. All submissions made through this platform are escalated directly to the Board, ensuring independence, transparency and protection against retaliation. 

Together, these policies, systems and platforms are designed to deter non-compliance, reduce exposure to unethical behaviour and safeguard the trust of investors, tenants, employees and communities. 

Key elements of the framework include: 

Annual training 

All employees are trained on the Code of Business Ethics, covering key topics such as conflicts of interest, insider trading and anti-corruption. 

Board oversight 

The Board of Directors is accountable for business ethics and reviews the adequacy of policies and implementation annually. 

Risk assessments 

Ethical risks are assessed regularly as part of our broader risk management framework, with results reported to senior leadership and the Audit and Risk Committee. 

Managerial responsibility 

Managers are accountable for reinforcing ethical behaviour in their teams and for reporting suspected misconduct. 

Incident management 

All incidents of unethical behaviour are formally investigated, with corrective and disciplinary actions taken where necessary. 

Deterrence measures 

Strong internal controls, approval processes, segregation of duties and clear sanctions are in place to deter non-compliance. 

Operating guidelines 

Detailed guidelines support accurate record-keeping, transparent approvals and expected behaviours in line with our Code of Business Ethics. 

Commitment to continuous improvement 

The programme is benchmarked against international best practice to ensure relevance and effectiveness. 

Code of Business Ethics Policy

Application of King IV

As a strong proponent for outcome-based corporate governance practices, we align with the principles, practices and governance outcomes contained within the King IV Report, which addresses fundamental governance concerns on a holistic basis.

King IV Policy

Our governance framework

Our Board forms the foundation of our corporate governance system and is accountable and responsible for the performance of the Group. The following principles have been approved by the Board, and together with the charters of each subcommittee, provide the framework for the governance of the Group.

  1. Board of directors

    Executive governance

  2. Audit committee
    • Achieve operational, profitability and liquidity objectives
    • Effective commercial and other stakeholder relations
    • Accurate and timely reporting
  3. Risk and capital committee
    • Effective risk management approach
    • Comply with legislation and governance requirements
    • Optimisation of capital
  4. Investment committee
    • Achieve growth objectives
    • Ensure credibility of investments
  5. Nominations committee
    • Appropriate appointments to the Board
    • Ensure the appropriate size, structure and composition of the Board
  6. Remuneration committee
    • Ensure the fair remuneration of directors
    • Effective policy to help achieve objectives and promote performance
  7. Social, ethics and transformation committee
    • Social mandate to operate
    • Sound reputation and ethics
    • Effective social stakeholder relations
  8. Executive committee
    • Achieve company strategy
    • Achieve growth objectives

Critical elements of governance

We defined seven critical elements of governance when drafting our governance framework, and aggregated these into specific and measurable goals, with areas of responsibility assigned to the Board, the subcommittees or the Executives.

ELEMENT 1

Strategy and management

ELEMENT 2

Governance structures and oversight

ELEMENT 3

Sustainability and resilience

ELEMENT 4

Corporate citizenship framework

ELEMENT 5

Risk and compliance framework

ELEMENT 6

Transparency and disclosure

ELEMENT 7

Ethical leadership and culture

Political contributions and lobbying

We do not engage in political lobbying and do not make financial contributions to political parties, candidates or related organisations. Our Political Involvement Policy prohibits the use of company funds, resources or assets for political purposes. 
 
We engage with regulators, municipalities and industry bodies only to support transparent policy development, regulatory compliance and the advancement of sustainable real estate and energy practices. This ensures that our business decisions remain fully aligned with our values, stakeholders’ interests and our long-term sustainability strategy.

Political Involvement Policy

Memberships

Equites is a member of the South African Property Owners Association, Green Building Council of South Africa, SA REIT Association, and a signatory to the UN Global Compact. Three Equites executives hold positions at the SA REIT Association on the Legal & Competition Commission Committee, the Accounting & JSE Committee, and the Marketing & Conferencing Committee, respectively. 
 
Through these bodies, the Group is involved in furthering the objectives of good governance and sustainability as it relates to the built environment. 

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