3.3.
COMPETITIVE RELATIONSHIPS
It is unethical
and unlawful to
collaborate with competitors or
their agents or
representatives for the purpose
of establishing
or maintaining rates or prices at any particular level, or
to collaborate in any way in the restraint of trade.
It is prohibited and unlawful
to collaborate or collude with competitors
that are in a horizontal relationship
with Lesaka for
the purposes
of substantially
preventing or
lessening competition
in a market.
Any Employee
of Lesaka
who is
found to
have
violated
the
Competition
laws
in
any
of
the
jurisdictions
in
which
Lesaka
operates,
will
be
subject
to
disciplinary
action.
Employees
are expected
to perform
their
duties conscientiously,
honestly
and
in accordance
with
the
best interests
of
Lesaka to optimize business objectives.
Employees
must
not
use
their
positions,
or
knowledge
gained
through
their
employment
with
Lesaka,
for
private
or
personal advantage or in such a manner that a conflict or an appearance of conflict arises between Lesaka’s interest and
their personal interests.
A conflict could arise where
an Employee’s family, or a business with which an
Employee or his or her
family is associated
obtains a gain, advantage
or profit, or there
is the appearance of a
gain, advantage or profit,
by virtue of the
Employee’s
position with Lesaka or knowledge gained through that position.
Every Employee must promptly inform Lesaka of any business
opportunities that come to his or her attention through
the
use of Lesaka assets, property or information or that relate
to the existing or prospective business of Lesaka.
If
Employees
feel
that
a
course
of
action
which
they
have
pursued,
are
pursuing
or
are
contemplating
pursuing,
may
involve them in a conflict of interest situation or a perceived conflict of interest situation, they should immediately make all
the facts known to the person
to whom they report and
the Head of Human Capital,
or Group Risk, or,
in the case of any
director or officer of Lesaka, to the Audit Committee
of Lesaka.
Where
any
member
of
the
Head
of
Human
Capital,
Group
Risk,
or
the
Audit
Committee
determines
that
a
conflict
of
interest exists, Lesaka reserves
the right to require the
Employee/Director to withdraw
from the conflicting activity
and/or
to terminate the employment/director relationship based on the conflict of interest,
as applicable.
Additionally, directors of
Lesaka should recuse themselves from participation in any decision of the Board in which there is a conflict between their
private interests and the interests
of Lesaka.Any proposed related party
transaction, as such term is
described in Item 404
of Regulation
S-K, involving
Lesaka and
an Employee,
in which
an Employee
has a
direct or
indirect material
interest,
shall be analyzed and reviewed by the Audit Committee
of Lesaka, for potential conflicts of interest.
OUTSIDE ACTIVITIES, EMPLOYMENT AND
DIRECTORSHIP
We
all
share
a
very
real
responsibility
to
contribute
to
our
local
communities,
and
Lesaka
encourages
Employees
to
participate in religious, charitable, educational and civic activities.
Employees should,
however,
avoid acquiring
any business
interest or
participating in
any activity
outside Lesaka
which
would create, or appear to create:
●
An excessive demand
upon their time, attention
and energy which
would deprive Lesaka
of their best efforts
on the
●
A conflict of interest
- that is, an
obligation, interest or distraction which
would interfere or appear
to interfere with their
independent exercise of judgment in Lesaka’s best
interest.
Employees other than
outside directors may not
take up outside
employment without the
prior written approval of
the Head
of Human Capital.
Employees who hold, or have been invited to hold, outside directorships should take particular care to ensure compliance
with
all
provisions
of
this
Code.
When
outside
business
directorships
are
being
considered
by
Employees
other
than