© 2019 LGIT Smart Solutions.

Our ethics

We make ethical choices when integrity, honesty, and compliance guide our decision making. We strive to be transparent with our motives, learn from our mistakes, and ask for help when faced with a difficult situations. We foster a culture where employees feel free to challenge the status quo, ask questions and raise concerns, with leaders and managers, when something doesn’t seem right.

Business Code of Ethics

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.

Our customers

 

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

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.

Payments

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.

  • 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.

Competition

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

  • 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.

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.

Global laws

 

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

  • 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.

Accessible Services

 

We prioritise inclusive design in the development of our services.

  • 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

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

  • 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.

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.

Diversity

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.

  • 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.

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.

  • 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.

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.

  • 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.

Our Resources

 

We protect our assets and information.

Safeguard LGIT's Resources

We are responsible stewards of LGIT’s resources.

  • 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.

  • 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. 

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.

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.

  • 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.

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.

  • 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.

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.

  • 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.

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:

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.

If someone raises a concern, take these specific steps:

  • 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.

Supplier Code of Conduct

LGIT Smart Solutions aspires to be more than just a good company - it aspires to be a great company with integrity. Toward that aim, we are committed to our mission of uplifting people, business and community. Achieving our mission isn’t just about delivering quality learning solutions. It’s also about who we are as a company and as individuals, how we manage our business internally, and how we work with customers, partners, governments, communities, and suppliers.

Compliance

 

Suppliers and their employees, agents, and subcontractors (collectively referred to as “Suppliers”) must adhere to this Supplier Code of Conduct while conducting business with or on behalf of LGIT Smart Solutions. Suppliers must promptly inform their LGIT contact (or a member of LGIT management) when any situation develops that causes the Supplier to operate in violation of this Code of Conduct. While LGIT Suppliers are expected to self-monitor and demonstrate their compliance with this Code of Conduct, LGIT may audit Suppliers or inspect Suppliers’ facilities to confirm compliance. LGIT may require the immediate removal of any Supplier representative(s) or personnel who behave in a manner that is unlawful or inconsistent with this Code of Conduct or any LGIT policy. Compliance with this Code of Conduct is required in addition to any other obligations in any agreement a Supplier may have with LGIT Smart Solutions.

Compliance Practices

 

All LGIT Suppliers must conduct their business activities in full compliance with the applicable laws and regulations while conducting business with and/or on behalf of LGIT, and must, without limitation:

 

  • Trade: Comply with all applicable trade controls, as well as all applicable export, re-export, and import laws and regulations.

  • Antitrust: Conduct business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which they conduct business.

  • Boycotts: Not participate in international boycotts that are not sanctioned by the South African government or applicable laws.

  • Anti-Corruption: Not participate in bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. LGIT is committed to observing the standards of conduct set forth in the anti-corruption and anti-money laundering laws of the countries in which LGIT operates. Suppliers must comply with all applicable anti-corruption and anti-money laundering laws, as well as laws governing lobbying, gifts, and payments to public officials, political campaign contribution laws, and other related regulations. Suppliers must not, directly or indirectly, offer or pay anything of value (including travel, gifts, hospitality expenses, and charitable donations) to any official or employee of any government, government agency, political party, public international organisation, or any candidate for political office to (i) improperly influence any act or decision of the official, employee, or candidate for the purpose of promoting the business interests of LGIT in any respect, or (ii) otherwise improperly promote the business interests of LGIT in any respect.

  • Accessibility: Creating products and services that are accessible to people with disabilities is a core tenet of LGIT culture, to fulfill not only our legal obligations but also our mission of empowering every person on the planet to do more.
    LGIT Suppliers must:

    • Comply with the international standard for web accessibility, Web Content Accessibility

    • Guidelines (WCAG) 2.0, Level AA when creating a website deliverable.

    • Comply with all LGIT requirements and standards for creating accessible products.

Business Practices and Ethics

 

LGIT Suppliers must conduct their business interactions and activities with integrity and must, without limitation:

  • Business Records: Honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy. Create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements. Be honest, direct, and truthful in discussions with regulatory agency representatives and government officials.

  • Press: Speak to the press on behalf of LGIT only if the Supplier is expressly authorised in writing to do so by LGIT.

  • Gifts: Avoid gifts to LGIT employees because even a well-intentioned gift might constitute a bribe  under certain circumstances, or create conflicts of interest. Do not offer anything of value to obtain or retain a benefit or advantage for the giver, and do not offer anything that might appear to influence, compromise judgment, or obligate the LGIT employee. If offering a gift, meal, or entertainment to LGIT employees, always use good judgment, discretion, and moderation. Any gifts, meals, or entertainment must comply with applicable law, must not violate the giver’s and/or recipient’s policies on the matter, and must be consistent with local custom and practice.

  • Conflicts of Interest: Avoid the appearance of or actual improprieties or conflicts of interests. Suppliers must not deal directly with any LGIT employee whose spouse, domestic partner, or other family member or relative holds a significant financial interest in the Supplier. In the course of negotiating the Supplier agreement or performing the Supplier’s obligations, dealing directly with a Supplier personnel’s spouse, domestic partner, or other family member or relative employed by LGIT is also prohibited.

Labour Practices

 

LGIT expects its Suppliers to share its commitment to human rights and equal opportunity in the workplace. All LGIT Suppliers must conduct their employment practices in full compliance with all applicable laws and regulations, and must, without limitation:

  • Cooperate with LGIT’s commitment to a workforce and workplace free of harassment and unlawful discrimination. While we recognise and respect cultural differences, we require that Suppliers not engage in discrimination in hiring, compensation, access to training, promotion, termination, and/or retirement based on race, color, gender, national origin, religion, age, disability, gender identity or expression, marital status, pregnancy, sexual orientation, political affiliation, or union membership.

  • Use only voluntary labour. The use of forced labor whether in the form of indentured labour, bonded labour, or prison labour by LGIT Suppliers is prohibited. Also prohibited is support for any form of human trafficking of involuntary labor through threat, force, fraudulent claims, or other coercion.

  • Ensure worker access to work-related documents. Suppliers are prohibited from requiring workers to lodge “deposits”, holding employee identity or immigration papers (including but not limited to passports or work permits), or destroying, concealing, confiscating or otherwise denying worker’s access to such documents. Workers should be free to resign their employment in accordance with local and national laws or regulations without unlawful penalty.

  • Comply with all local and national minimum working age laws or regulations and not use child labour. Suppliers cannot employ anyone under the age of 15, under the age for completing compulsory education, or under the legal minimum working age for employment—whichever is higher. LGIT only supports the development of legitimate workplace apprenticeship programs for the educational benefit of young people and will not do business with those who abuse such systems. Workers under the age of 18 cannot perform hazardous work and may be restricted from night work, with consideration given to educational needs.

  • Not engage in physical discipline or abuse. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment, and verbal abuse or other forms of intimidation are prohibited.

  • Pay applicable legal wages under humane conditions. All workers must be provided with clear and understandable written information about their employment conditions in a language understood by the worker with respect to wages, benefits, location of work, living conditions, housing and associated costs, including any costs charged to employee and, if applicable, the hazardous nature of any work before they enter employment and as needed throughout their term of employment. Deductions from wages as a disciplinary measure will not be permitted nor will any deductions from wages not provided for by national law or local law be permitted without the express, written permission of the worker concerned. All disciplinary measures should be recorded. Wages and benefits paid for a standard working week must meet local and national legal standards.

  • Not require workers to work more than the maximum hours of daily labour set by local and national laws or regulations. Suppliers must ensure overtime is voluntary and paid in accordance with local and national laws or regulations. A workweek should not be more than 60 hours a week, including overtime, except in emergency or unusual situations. Workers should be allowed at least one day off per seven-day week.

  • Keep employee records in accordance with local and national laws or regulations and provide in a timely manner, via pay slip or similar documentation, the basis on which employees are paid.

  • Respect workers’ rights to freedom of association and collective bargaining in accordance with legal requirements. As noted above, we require that Suppliers not engage in discrimination in hiring, compensation, access to training, promotion, termination, and/or retirement based on union
    membership.

Health and Safety

 

LGIT Suppliers are expected to integrate sound health and safety management practices into all aspects of business, and must, without limitation:

  • Provide a safe and healthy work environment and fully comply with all safety and health laws, regulations, and practices including those applicable to the areas of occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene, physically demanding work, machine safeguarding, sanitation, food, and housing. Adequate steps must be taken to minimise the causes of hazards inherent in the working environment.

  • Prohibit the use, possession, distribution, or sale of illegal drugs while on LGIT-owned or -leased property.

Environmental Regulations

 

LGIT recognizes its social responsibility to protect the environment and expects its Suppliers to share its commitment by responding to challenges posed by climate changes and working toward protecting the environment. As a part of this commitment, all LGIT Suppliers must, without limitation:

  • Comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste, and wastewater discharges, including the manufacture, transportation, storage, disposal, and release to the environment of such materials.

  • Endeavor to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures in their facilities, through their maintenance and production processes, and by recycling, re-using, or substituting materials.

  • Obtain, maintain, and keep current all required environmental permits and registrations and follow the operational and reporting requirements of such permits.

  • If applicable, identify the chemicals or other materials being released that pose a threat to the environment and manage them appropriately to ensure their safe handling, movement, storage, use, recycling, or reuse and disposal.

  • Adhere to all applicable laws, regulations, and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal.

Protection of Intellectual Property

 

Protection of intellectual property rights is vital for any company. LGIT depends on intellectual property such as information, and processes. All LGIT  Suppliers must, without limitation:

  • Protect and responsibly use the intellectual assets of LGIT, including intellectual property, tangible property, supplies, consumables, and equipment, when authorized by LGIT to use such assets.

  • Use LGIT-provided information technology and systems (including email) only for authorized LGIT business-related purposes. LGIT strictly prohibits Suppliers from using LGIT provided technology and systems to (i) create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate, or (ii) send any false, derogatory, or malicious communications.

  • Comply with all LGIT requirements and procedures for maintaining passwords, confidentiality, security and privacy as a condition of providing LGIT with goods or services or receiving access to the LGIT internal corporate network, systems, and buildings. All data stored or transmitted on LGIT-owned or -leased equipment is to be considered private and is the property of LGIT.

  • LGIT may monitor all use of the corporate network and all systems (including email), and may access all data stored or transmitted using the LGIT network.

  • Comply with the intellectual property ownership rights of LGIT and others including but not limited to copyrights, patents, trademarks, and trade secrets; and manage the transfer of technology and know-how in a manner that protects intellectual property rights.