LGIT Smart Solutions

This Code of Ethics sets forth legal and ethical standards for directors, officers and employees of LGIT Smart Solutions. This Code is intended to deter wrongdoing and to promote the ethical conduct of all Company business.

 

If you become aware of the violation of any law, rule or regulation by the Company, whether by its officers, employees, directors, or any third party doing business on behalf of the Company, it is your responsibility to promptly report the matter to your supervisor.

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Our customers

 

Our customers must be at the center of everything we do.

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Privacy

 

We are transparent about how we handle customer data. Our business can succeed only if our customers trust us to protect their privacy and use their data in the ways that they permit us.
 

• We follow local privacy and data protection laws.

• We provide clear and accurate privacy notices when collecting or processing personal data.

• We honor privacy choices by using customer data to provide the services customers have agreed to.

• We protect our customers’ data by using secure products and services.

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Payments

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We are truthful and transparent in our interactions with customers, and do not influence their decisions through improper payments. Corruption harms society, and our customers in many ways.

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• In some parts of the world, paying a bribe to get business may be something that others are doing. We won’t. We would rather lose the business than secure it through a bribe, kickback, or other improper benefit.

• We refuse to offer or pay bribes or kickbacks to anyone.

• We prohibit corrupt payments of all kinds, including payments to secure permits or approvals, and small payments to speed up a routine government process (often known as a “facilitating payment”).

• We avoid hidden terms or arrangements and reduce complexity wherever possible, because transparent transactions reduce the risk of a bribe or kickback.

• We use partners that have a reputation for integrity, and we report signs that a representative is unethical or could be paying a bribe.

• We make sure that any gifts, hospitality, or travel we offer to government officials are reasonable and appropriate, and pre-approved where necessary.

• We hire the best candidate for the job, and do not make hiring decisions to benefit a customer or official.

• If we make charitable donations, we do so to support a legitimate charitable cause, not as part of an exchange of favours.

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Competition

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Competing fairly ensures that we meet our business objectives with our integrity intact.

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• We avoid any formal or informal agreements with competitors that limit competition.

• We respect competitive bidding processes, and do not rig or fix the outcomes or help anyone else do so.

• We do not dictate the prices that our independent channel partners charge their customers.

• When gathering competitive intelligence, we use appropriate sources, are truthful, and do not misrepresent who we are.

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Governments & Communities

 

Achieving our mission depends on governments and communities knowing that we will follow the laws and customs of the countries where we operate, and respect human rights across the globe.

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Global laws

 

We operate around the globe and respect the laws where we do business.

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• This helps us to build trust with governments, strengthen the communities where we live and work, and contribute to a fair society where we enjoy the protection of these same laws.

• We follow the laws and regulations of South Africa and of all the places where we operate.

• We are honest and transparent in our discussions with government representatives and officials.

• We respond truthfully, appropriately, and promptly to government inquires and requests for information. tell the truth when responding to government inquiries. We respond appropriately and promptly to requests for information.

• We comply with global trade controls and economic sanctions that prohibit us from doing business with certain countries, governments, entities, and individuals. We comply with laws that govern how our services may be used internationally.

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Accessible Services

 

We prioritise inclusive design in the development of our services.

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• We make our products accessible to all users, including users with visual, learning, age-related, mobility, hearing, and speech disabilities.

• We provide accurate information about the accessibility of our products, and do not promise future improvements unless we are sure that we will deliver.

 

Human Rights

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We are committed to respecting and promoting human rights to ensure that learning plays a positive role across the globe.

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• We believe that we can more effectively advance human rights through our presence in, rather than absence from, countries with significant human rights challenges.

• We advocate for the rule of law, including consideration of international laws and norms.

• We respect the rights to freedom of expression and privacy on all of our online services.

• When we face requirements from governments to provide user data or remove content, we verify whether the government demands are valid, binding and otherwise comply with the rule of law.

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Our Workforce

 

The strongest contributions come from teams who trust each other—those that can be open, honest, and constructive with one another. It takes all of us working together to cultivate an atmosphere of mutual respect, inclusion, and collaboration.

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Diversity

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We work better together because of our differences, not despite them. We believe that we best serve everyone on the planet and enrich our own culture through the diverse skills, experiences, and backgrounds that each of us brings to the company.

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• We provide equal employment opportunities to all qualified candidates and employees.

• We do not discriminate based on age, ancestry, colour, family or medical care leave, gender identity or expression, genetic information, marital status, medical condition, national origin, physical or mental disability, political affiliation, race, religion, gender (including pregnancy), sexual orientation, or any other characteristic protected by applicable laws, regulations and ordinances.

• We are committed to hiring people with disabilities and provide reasonable accommodations to qualified employees.

• We examine our unconscious biases and take steps to create an inclusive culture that makes every employee feel welcome.

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Safe & Productive Workplace

 

We maintain a work environment that enables everyone to do their best work. A safe workplace inspires trust and allows us all to contribute and succeed. Discrimination, harassment, and unsafe working conditions diminish what we can achieve together.

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• We treat others with respect and do not tolerate harassment or discrimination.

• We integrate sound safety and health practices into our operations and comply with workplace safety regulations.

• We resolve problems respectfully, and never resort to acts or threats of violence.

• We do not work under the influence of drugs or alcohol.

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Conflicts of Interest

 

We make good decisions for our teams, our work, and for LGIT Smart Solutions.

Conflicts of interest can arise when our personal relationships or financial interests overlap with our job responsibilities. If we don’t navigate potential conflicts of interest carefully, these situations can impact the decisions we make, erode trust within teams, and harm the Company’s reputation.

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• We act in the best interests of LGIT Smart Solutions.

• We avoid situations where a personal relationship or financial interest in another company might influence how we make decisions in our jobs.

• We understand that a conflict of interest can exist even if we are convinced that our decisions will not be affected by the outside relationship.

• When conflicts of interest arise, we disclose them and get advice or approval.

• Before taking on outside work, we ensure that the work does not harm LGIT’s business interests or break any employee agreements we have signed.

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Our Resources

 

We protect our assets and information.

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Safeguard LGIT's Resources

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We are responsible stewards of LGIT’s resources.

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• We spend LGIT’s funds wisely, and guard against waste and abuse.  

• We exercise good judgment when using company-provided technology resources, and use them for personal reasons only if it does not interfere with our job responsibilities or harm our work environment.  

• We use our corporate accounts and services, not personal accounts or services, for business correspondence and data.  

• We understand that business-related data is LGIT’s property, and that it may be accessed, preserved, and reviewed in accordance with our polices and applicable laws.  

Confidential Information & Intellectual Property

 

We protect and respect the business value of information and ideas, whether they belong to LGIT Smart Solutions or another company.

We might lose our competitive advantage if we disclose LGIT’s confidential information. We lose trust if we disclose confidential information we learn from the companies we do business with. Protecting information and ideas, whether our own or those of others, is crucial to our business success and builds our reputation as a trustworthy partner.

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• We use best practices to protect access to confidential information, and avoid discussing it in common spaces, or with colleagues who don’t need to know it.  

• We do not use confidential information for non-LGIT business use, and we maintain confidentiality even if we stop working for LGIT Smart Solutions.  

• We preserve LGIT’s own intellectual property rights through copyrights, and other forms of intellectual property that protect the value of our innovation.  

• We respect the confidentiality and intellectual property rights of others, and do not use others’ confidential information without authorization.  

• We do not use or copy third-party copyrighted materials, like software, graphics, videos, and music, without a license or permission from CELA. 

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Our Representatives

 

We hold ourselves to high ethical standards, and we expect our representatives, who are the partners, vendors, consultants, and other companies who work on our behalf, to meet the standards we set for ourselves. We earn trust with our representatives when we return value to them, and don’t ask them to do anything we would not do ourselves.

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Trustworthy Representatives

 

We use honest, ethical representatives who commit to doing business ethically when working on our behalf.

Our business relies on a network of representatives - such as vendors, facilitators and consultants. Their actions reflect on our company’s reputation as much as our own. When our representatives do business with integrity, we retain and strengthen the trust we’ve established with our customers and the public.

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• We understand our representatives’ qualifications and reputation before we engage them to work on our behalf.

• We cultivate trust with our representatives and never ask or suggest that they do things that are not allowed under the law or our policies.

• We report signs that a representative could be engaging in corrupt or unethical behavior while representing LGIT Smart Solutions.

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Gifts, Hospitality & Travel Responsibly

 

We demonstrate sound judgment and moderation when exchanging business courtesies.

Giving and receiving gifts, hospitality and travel can build strong working relationships and goodwill between LGIT and those we do business with. But gifts, meals, or trips that are extravagant or lack transparency or a legitimate purpose may be viewed as bribes or as simply inappropriate. These things erode trust and harm our business.

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• We develop positive relationships free of corruption and commercial bribery.

• When we offer or accept gifts, hospitality, or travel, we make sure they are reasonable, appropriate, and have a legitimate business purpose.

• We never give or accept cash.

• We do not solicit gifts, hospitality or travel from third parties, or put them in a position where they feel obligated to provide something in order to do business with us.

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Suppliers with Integrity

 

We rely on our supplier relationships for our success. To achieve our mission, we need suppliers that are as committed as we are to building trust with our customers, that will do great work, and that will follow the law.

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• We select the best suppliers for the job, by carefully considering their proven track record, reputation for integrity, and other merits - not based on favouritism.

• We work to eliminate child labor, human trafficking, and other labour abuses in our supply chain.

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Raising Integrity Concerns

 

Part of building a culture of trust is learning to speak up when something’s not right, so that we can address the problem.

Choose whichever reporting option you are most comfortable using. Whichever option you choose, your confidentiality will be protected:

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Phone: +27 11 802 1636

Email: concerns@lgitsmart.co.za

Natascha Prussen - Owner of LGIT

Sonja Joubert - Head of Global Projects

In addition, you can always raise concerns with your manager, any LGIT manager, or CELA.

 

No Retaliation

 

Our success depends on you letting us know if something’s not right, so we can fix it. But we understand that it’s not easy to speak up—you might be uncomfortable or anxious. That is why we do not tolerate retaliation.

You will not suffer adverse consequences for:

 

• Refusing to do something that violates these Standards, LGIT’s policies, or the law, even if your refusal results in the loss of business to LGIT.  

• Raising a concern in good faith about potential misconduct.  

• Cooperating with an investigation.  

• Anyone who retaliates against an employee for engaging in any of these activities will be subject to disciplinary action, up to and including termination.

 

How Managers Should Handle Concerns

 

If someone comes to you with a concern, you have a special responsibility to listen and act. Handling concerns appropriately is critical to preserving trust and protecting LGIT Smart Solutions.

As a manager, you should feel empowered to resolve performance issues yourself, but you should escalate integrity concerns about business ethics or misconduct to Natascha Prussen.

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If someone raises a concern, take these specific steps:

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• Remove distractions and listen carefully. Thank the person for speaking up – remember that they’ve just done something difficult and very important for the company.  

• Respond respectfully and take every concern seriously, even if you disagree. Show that you are committed to solving the problem.  

• Take steps to protect the person’s confidentiality - avoid discussing the conversation with others on your team.