CareChamp (Pty) Ltd – Anti-Corruption and Anti-Bribery Policy

1. Purpose

CareChamp is committed to conducting all aspects of its business with honesty, integrity, transparency, and in compliance with all applicable laws.
This policy outlines CareChamp’s zero-tolerance stance on corruption, bribery, and any unethical business conduct. Its purpose is to ensure that all directors, employees, contractors, suppliers, and partners act ethically and in the best interests of the company, its clients, and the communities we serve.

2. Scope

This policy applies to:

• All CareChamp employees, directors, contractors, interns, and temporary staff;

• All vendors, suppliers, consultants, and agents acting on behalf of CareChamp; and

• Any third parties interacting with clients, learners, or public officials on CareChamp’s behalf.

It covers activities across all provinces of operation, including CareChamp College and any affiliated entities.

3. Legal and Regulatory Alignment

This policy aligns with:

• Prevention and Combating of Corrupt Activities Act (No. 12 of 2004);

• Companies Act (No. 71 of 2008);

• Public Finance Management Act (PFMA) (where relevant);

• Protected Disclosures Act (No. 26 of 2000);

• OECD Anti-Bribery Convention; and

• UN Global Compact Principle 10 on anti-corruption.

4. Policy Statement

CareChamp has zero tolerance for bribery, corruption, extortion, facilitation payments, fraud, or any other unethical business practices.
No employee or third party may offer, give, solicit, or accept any form of bribe, kickback, or improper advantage in connection with CareChamp’s operations or Discovery Health-related programmes.

5. Definitions

• Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of another person in breach of duty.

• Corruption: Abuse of entrusted power for private gain.

• Facilitation Payment: A small payment made to expedite routine government action – these are strictly prohibited.

• Conflict of Interest: A situation where personal or financial interests could improperly influence professional judgment or duties.

6. Prohibited Conduct

CareChamp strictly prohibits:

• Offering or accepting cash, gifts, hospitality, donations, or favours intended to influence a business decision;

• Making facilitation or “grease” payments;

• Manipulating financial records or misrepresenting transactions;

• Providing benefits to public officials or clients to gain preferential treatment; and

• Engaging in or ignoring any form of fraud, collusion, or misrepresentation.

7. Gifts, Hospitality, and Donations

• Employees may only offer or accept gifts or hospitality that are reasonable, infrequent, and clearly not intended to influence any decision.

• Any gift or hospitality exceeding a nominal value (R500) must be declared in writing to the Managing Director.

• Charitable donations or sponsorships must be transparent, approved, and unconnected to any business advantage.

8. Reporting and Whistleblowing

CareChamp promotes an open and transparent culture.

• Employees and partners must report any suspected or actual corruption, bribery, or unethical conductimmediately to the Managing Director or HR Director.

• Reports may be submitted confidentially via the HR email channel or an anonymous reporting form.

• All reports will be investigated promptly and handled with strict confidentiality and no retaliation against whistleblowers, in accordance with the Protected Disclosures Act.

9. Record Keeping and Monitoring

• All financial transactions must be accurately recorded in CareChamp’s accounting systems.

• No undisclosed or unrecorded accounts are permitted.

• The company will conduct periodic internal reviews to ensure compliance with this policy.

• Any confirmed violation will result in disciplinary action, which may include termination, legal prosecution, or contract cancellation.

10. Supplier and Partner Compliance

All suppliers, subcontractors, and training partners are required to comply with this policy.
Compliance is a condition of engagement and forms part of CareChamp’s Supplier Code of Conduct.
Vendors found in breach of these standards may be blacklisted or reported to relevant authorities.

11. Training and Awareness

All employees and managers receive annual ethics and anti-corruption training.
New employees are briefed on this policy during onboarding.
Periodic refreshers ensure that awareness and ethical decision-making remain central to company culture.

Anonymous Reporting (you don’t need to add name / email) which goes directly to the Director