292. Disclosure should also include information on – (a) the performance and evaluation of Board members at Board meetings, the issuance of independent opinions and opinions regarding related party transactions, appointment and removal of directors and senior management personnel and the composition and work of specialized Board committees; (b) the company’s remuneration policy and directors’ […]

290. The company should have a written policy on disclosure. 291. Disclosure should include material information on – (a) financial and operating results of the company; (b) company’s objectives; (c) major share ownership and voting rights; (d) members of the Board and key Executives; (e) material foreseeable risk factors; (f) material issues regarding employees and […]

283. The Board must ensure that an information security management system (ISMS) is developed, implemented and recorded in an appropriate and applicable information security framework. 284. The Board should supervise the information security strategy and delegate and empower management to implement it. 285. The ISMS should include the following high level information security principles – […]

276. Where the interests of the company’s stakeholders and the company’s business conflict, such development should be disclosed subject to materiality thresholds as may be prescribed by the Board from time to time. 277. Every company must ensure that in making disclosures a broad range of communication channels are used bearing in mind the need […]

270. Every company should have a disclosure policy which outlines, among other things, the implementation, monitoring and review of the main disclosure principles set out in this Code. 271. All executive and non-executive directors should have access to Board papers and materials and should be able to respond to any queries raised as promptly and […]

264. The data and information disclosed should enable the company, its shareholders and other stakeholders – (a) to make informed decisions regarding their participation in the company or its business activities; (b) to evaluate the company’s position and its business activities; (c) to check and challenge the company’s compliance with the law and best practice codes […]

Principles 263. The Board should establish systems for- (a) managing the company’s information assets and the performance of its data functions; (b) ensuring the timeous availability of information through effective information systems; (c) implementing a suitable information security management programme; (d) ensuring that all sensitive information is identified, classified and assigned appropriate handling criteria; (e) […]

Preamble: 261. Disclosure relating to the company and its business in all its varied forms, content, and pitch, explicitness of language, relevance, impact, and accessibility to all stakeholders is pivotal to the culture of building confidence, accountability and trust within the company. Disclosure is necessary for the company to remain trustworthy in the eyes of […]

259. The board should – a) take measures to manage whistle-blowing in terms of set procedures, proper analysis of reports received and acting to correct the misconduct reported upon; b) have a fair system, known to the employees, for dealing with reports from whistle-blowers so that an honest individual does not feel under threat when […]

255. A whistle-blowing system that is independent, trusted and anonymous is key to the effective implementation of an ethical corporate culture and fraud risk management strategy. A whistle-blower provides evidence of a waste of funds or mismanagement. 256. People blow the whistle because they have been unable to approach or to get a response from […]