TRAC’s internal controls and operating procedures are intended to detect, prevent and/or deter improper and corrupt activities. However, even the best systems of control cannot provide absolute safeguards against irregularities. The Company has the responsibility to investigate all allegations in order to protect the Company from financial and material losses.

The objective of this policy is to encourage and enable employees and subcontractors to report improper and corrupt activities that are doing serious harm to the financial position and image of the Company.

Any person or organization (business, company) that is contracted to TRAC via the payroll or subcontracts. This includes casual and temporary employees.

Cash and other assets, whether tangible or intangibleFacilities and the right to use TRAC facilities TRAC’s records and data bases

Any activity by a TRAC employee that is undertaken in the performance of the employee’s official duties, whether or not the action is within the scope of his/her employment, and that is in violation of any law or regulation of the country, including, but not limited to corruption, malfeasance, bribery, theft and misuse of TRAC Resources.

Any good faith communication that discloses or demonstrates an intention to disclose information that may evidence an improper TRAC employee activity if the disclosure or intention to disclose was made for the purpose of remedying that condition.

A person or entity making a protected disclosure is commonly referred to as a whistleblower. Whistleblowers may be TRAC employees, applicants for employment, contractors or the general public. The whistleblower’s role is as a reporting party. They are not investigators or finders of fact, nor do they determine the appropriate corrective or remedial action that may be warranted. Every effort will be made to protect the complainant’s identity.

A TRAC employee, preferably management, will listen to reports at the dedicated cell number and initiate an investigation by the responsible parties. The Responsible Official will ensure that there is no conflict of interest when the Responsible Manager is notified of a report. Currently the responsible official is Piet Ndlovu.

The Senior Manager who is responsible for the division in which the alleged improper or corrupt conduct took place and who is at least two levels higher than the suspected person. In the case of Senior Management, the report will be handed to the CEO. If the CEO is implicated the report will be handed to the Chairman of the Board.

The Chief Executive Officer is responsible for implementing this policy.

An amount of money up to R10 000, determined by management, may be awarded to each Whistleblower that is the first to report a serious or severe act of improper or corrupt practice and which leads to the internal and/or external prosecution of the guilty party.

Employees and others are encouraged to use guidance provided by this policy for reporting all allegations regarding improper and corrupt conduct leading to losses by the Company.

Allegations that are serious will be reported to the Police for criminal investigations. Any allegations may result in subsequent actions bringing disciplinary charges against any staff member. In all instances, TRAC Management retains the prerogative to determine when circumstances warrant an investigation and, in conformity with this policy and applicable laws and regulations, the appropriate investigative process to be employed.

The following cell number is available for reporting. 082 900 2447. The phone will not be answered. Callers will leave a detailed message. The Responsible Official will listen to all messages at least once a week.

Any person may report allegations of suspected improper and corrupt activities. In order for the caller to qualify for the incentive personal details will have to be recorded. Callers must provide as much correct detail/s as possible. Generalizations are difficult to follow up on. Reports need to be factual rather than speculative or conclusory. Whistleblowers should be prepared to be interviewed during the investigation.

Callers that wish to remain anonymous will not qualify for the incentive, but the incentive will be payable should he/she at a later stage decide to claim the amount due.

A written report can also be submitted to the Responsible Official.

Whistleblowers shall refrain from obtaining evidence for which they do not have right of access to. Such improper access may itself be considered an improper activity.

All calls and investigations will be dealt with as strictly confidential.

The Responsible Official will ensure that each report is promptly reported to the Responsible Manager. Each report will be investigated within 20 days of receiving the report. The Responsible Manager will ensure that a proper and appropriate investigation, using the necessary internal and external expertise is conducted. Each report, with the outcome of the investigation, will be submitted to the CEO within four weeks of receiving the report. TRAC

All employees and subcontractors of TRAC have a duty to co-operate with investigations initiated under this policy.

The Company strictly prohibits retaliation, harassment, or discrimination of any kind against any person who, based on such person’s good faith and reasonably held belief that such conduct or practice has occurred or is occurring and that such conduct or practice is of the type that is subject to disclosure under this Policy, reports that information or takes part in the investigation. Any retaliation, harassment or discrimination must be reported directly to the CEO.

To the extent possible within the limitations of law and policy and the need to conduct a competent investigation, confidentiality of whistleblowers will be maintained. Whistleblowers should be cautioned that their identity may become known for reasons outside the control of the investigators, the Responsible Official and the Responsible Manager. Should the whistleblower self-disclose his or her identity, the Company will no longer be obligated to maintain such confidence.

No protection against disciplinary action can be guaranteed should the whistleblower be involved in the improper or corrupt activity. Indemnity can be negotiated with the Responsible Manager.

Should the whistleblower require it, the Responsible Official will provide feedback on the outcome of the investigation. If, after a reasonable period of time the reporter is not satisfied with the response to the report, or if the reporter is uncomfortable for any reason with the way in which the report has been dealt with, the CEO of TRAC should be contacted directly by the reporter.

The Responsible Manager will, together with the CEO, decide on appropriate action in cases where reports were found to be true and accurate. They will decide on internal as well as criminal action.

If an investigation leads Management to conclude that a crime has probably been committed, the results of the investigation will be reported to the Police.

If the investigation leads Management to conclude that the policy of the Company has been transgressed, a disciplinary investigation will be conducted according to the disciplinary code of the Company.

TRAC Management may decide to reward the person that first reported an improper and/or corrupt activity, which was causing the Company severe financial damage or damage to the image of the Company, up to R 10 000. This reward will be determined at the discretion of TRAC Management and no communication or dispute will be allowed in this regard.

No employee who in good faith reports an improper or corrupt activity shall be subject to harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported such activity is subject to disciplinary action.

The Policy will be communicated to all employees, will be available on the TRAC website and will be displayed on notice boards at the Toll Plazas, Weighbridges, Maintenance Centres, Nelspruit Regional Office and at Head Office. The Policy is valid for South Africa and Mozambique

TRAC’s internal controls and operating procedures are intended to detect, prevent and/or deter improper and corrupt activities. However, even the best systems of control cannot provide absolute safeguards against irregularities. The Company has the responsibility to investigate all allegations in order to protect the Company from financial and material losses. We would like to rely on our employees to assist us on this matter and encourage and enable employees and subcontractors to report improper and corrupt activities that are causing severe damage to the financial position and image of the Company.

TRAC has set up a dedicated hot line 082 900 2447 with an answering service to enable management and employees to report any fraudulent/corrupt activity by a TRAC employee that is undertaken in the performance of the employee’s official duties, whether or not the action is within the scope of his/her employment, and that (1) is in violation of any law or regulation of the country, including, but not limited to corruption, malfeasance, bribery, theft, (2) misuse of TRAC Resources, or willful omission to perform duty, or (3) is economically wasteful or involves gross misconduct, incompetence or inefficiency.

TRAC Management may decide to reward the person that first reported an improper and/or corrupt activity, which was causing the Company severe financial damage or damage to the image of the Company, up to R 10 000. This reward will be determined at the discretion of TRAC Management and no communication or dispute will be allowed in this regard.

Any person may report allegations of suspected improper and corrupt activities. In order for the caller to qualify for the incentive personal details will have to be recorded. Callers must provide as much detail/s as possible. Generalizations are difficult to follow up on. Reports need to be factual rather than speculative or conclusory. Whistleblowers should be prepared to be interviewed during the investigation.

Whistleblower/s that wishes to remain anonymous will not qualify for the incentive.

Whistleblower/s shall refrain from obtaining evidence for which they do not have right of access to. Such improper access may itself be considered an improper activity.

The intentional filing of a false report is considered an improper activity which the Company has the right to act upon.

All calls and investigations will be dealt with as strictly confidential.

The Company strictly prohibits retaliation, harassment, or discrimination of any kind against any person who, based on such person’s good faith and reasonably held belief that such conduct or practice has occurred or is occurring and that such conduct or practice is of the type that is subject to disclosure under this Policy, reports that information or takes part in the investigation. Any retaliation, harassment or discrimination must be reported directly to the CEO.

To the extent possible within the limitations of law and policy and the need to conduct a competent investigation, confidentiality of callers will be maintained. Whistleblower/s should be cautioned that their identity may become known for reasons outside the control of the investigators, the Responsible Official and the Responsible Manager. Should the Whistleblower/s self-disclose his or her identity, the Company will no longer be obligated to maintain such confidence.

Protection against disciplinary action cannot be guaranteed should the caller be involved in the improper or corrupt activity. Indemnity can be negotiated with the Responsible Manager.

It is recommended that you read the complete policy on this issue should you have any further questions.

ARE YOU AWARE OF EMPLOYEES THAT ARE GUILTY OF THE ABOVE?

THEN DO YOUR DUTY AND REPORT WHAT YOU KNOW TO: 082 900 2447>