POLICY AND GOVERNANCE DOCUMENTS

Governance

Anti-corruption and Gift policy: (Click to download)

Growthpoint’s commitment to compliance by the group, and its officers, directors, employees and agents with local and international anti-bribery or anti-corruption laws that may be applicable.

Breach of the company’s business practice:

Growthpoint believes that it employs people who perform to the best of their ability and act in accordance with Growthpoint’s philosophies. Any transgression of our practices will be dealt with on an individual basis, in the best interests of the company. If any of the company’s standards are breached and such a breach requires formalised intervention, Growthpoint will, where appropriate and practical, intervene and act in accordance with the guidelines for fair procedure set out in the relevant policies and legislation.

Business Code of Conduct:

Employees are expected to conduct all internal and external dealings with integrity, consistently and uncompromisingly displaying moral strength and behaviour which promotes trust. Integrity and confidence are critical to our reputation and sustainability.

Closed Periods:

When Growthpoint is in a closed period (prior to the half year and the year end results), or events as determined by the JSE Listings requirements, no director or employee may trade (buying or selling) in Growthpoint shares or any derivative thereof. Directors are to obtain approval from the Chairman and employees from the Group CEO before trading in Growthpoint shares. The rules apply to personal account dealings undertaken by any employee or any of their associates, either for their own account or for the account of an associate.

Code of Ethics:

The Growthpoint Code of Ethics (“Code of Ethics”) applies to all Employees. This Code of Ethics is based on our core values and is a promise to all our Stakeholders that we will combine our entrepreneurial spirit with a commitment to responsible business practice. It stipulates morally acceptable behaviour within an organisation. It defines the moral standards or guidelines that need to be respected by all members of an organisation in their dealings with internal and external stakeholders.

Confidentiality:

Confidentiality obligations on directors, officers and employees of Growthpoint and its subsidiaries who come into possession of material, non-public / price sensitive information concerning the company who are required to safeguard the confidentiality of the information and may not intentionally or inadvertently communicate it to any person unless such a person has a need to know the information for legitimate company-related reasons. This duty of confidentiality is important to both Growthpoint’s competitive position and the insider trading laws and JSE regulations applicable to Growthpoint as a public company.

Conflict of Interest: (Click to  download)

Should Directors, members of a Board Committee, Executive Management or employees believe that a potential transaction /activity that may constitute a conflict of interest or interfere with their responsibilities to the company, such a Director, Committee member, Executive or employee is expected to disclose this. The company maintains that disclosure and transparency mitigate against and avoid conflicts of interest.

Corporate social responsibility:

Guidelines and assistance for implementing the socio-economic development (SED) elements of CSR, and the enterprise and supplier development (ESD) elements of broad-based black economic empowerment (B-BBEE). The policy also specifies the exclusions of funding:

Profit making companies, unless in the case of enterprise and supplier development

  • Animal-related organisations or programmes
  • Religious organisations;
  • Political parties or associations with political affiliations;
  • Labour movements/ Unions;
  • Organisations that have been in existence for less than one year

Disclosure and crisis management:

Dealing with, inter alia, price-sensitive information, in line with the JSE Limited (JSE) Listings Requirements (Listings Requirements), as well as other recognised best practices. Addresses elements such as the communication framework and authorised spokespersons, dissemination of information, fair distribution of information, price-sensitive information and profit forecasts, dealing with the media, unexpected circumstances or events, crisis management and communication.

Environmental Policy: (Click to download)

Growthpoint’s commitment to responsible environmental conduct. Areas of consideration include climate change and carbon emissions, energy, water, waste, renewable energy and biodiversity.

Human Rights Position Statement: (Click to download)

Growthpoint acknowledges its responsibility to respect human rights in its business. Our human rights position statement elaborates on the requirement within our Business Code of Conduct and Ethics to treat everyone whom we encounter with fairness, respect and dignity

Memorandum of Incorporation (MoI) (Click to download) 

Growthpoint’s Memorandum of Incorporation (MoI) sets out the rights, duties and responsibilities of the shareholders, directors and other persons involved in the company structure to ensure that the business in conducted in a manner that complies with the provisions in various Acts, which include the Companies Act, No.71 of 2008 (as amended),  Companies and Intellectual Property Commission established in terms of section 185 of the Act, The Broad Based Economic Empowerment Act , No. 53 of 2003 as amended, re-enacted or replaced from time to time (BEE Act) and its codes of Good Practice gazetted from time to time under the BEE Act, Electronic Communications and Transactions Act, No. 25 of 2002, Financial Markets Act, Income Tax Act, and the JSE Listings Requirements. 

Risk Management:

The Board has overall responsibility for the adoption, oversight and reporting of Growthpoint’s risk management framework. Growthpoint’s risk framework encompasses four distinct categories.

Treasury policy:

The purpose of this policy is to set up a framework for managing financial risks across the Growthpoint group.
The policy:

  • Defines the financial risks to be managed.
  • Specifies the objectives in managing these risks.
  • Delegates responsibilities to those managing the risk.

Whistle-blowing and protected disclosure:

Encourages Growthpoint employees to raise concerns about workplace malpractice without fear of victimisation or reprisal. Growthpoint seeks to protect all employees who disclose unlawful or irregular conduct by the company, its employees or other stakeholders. All stakeholders can use our whistle-blowing hotline: 0800 167 463

Operations

Business Rescue Strategy:

Highlights Growthpoint’s business rescues strategy in line with Chapter 6 of the Companies Act 71 of 2008, as amended (“Companies Act”). This legislation was mainly introduced to reduce the amount of liquidations in the industry, to save employment and to replace the old “Compromise of creditors” in terms of section 155 of the Companies Act.

Credit Policy and Processes:

Provides guidance on leasing facilities to our clients with the minimum of risk and the ongoing improvement in processes and service to enable a secure and sustainable return to our shareholders.

Health and safety Policy:

Our policy prepared in line with the Occupational Health and Safety Act No 85 of 1993, which provides for the health and safety of people at work and when using plant and machinery, as well as the protection of people other than those at work against hazards to health and safety arising out of or in connection with the activities of people at work.

Local Economic Development and Transformation strategy:

This policy document is intended to outline the principles and procedures to be adhered to when engaging with businesses in local communities within which Growthpoint operates. 

Managing of Covid-19 Policy:

This policy sets out:

  • Growthpoint’s approach to COVID-19 and how the business, its employees and its stakeholders are to act in order to decrease the spread of this illness and lower its impact in the workplace.
  • The related measures and controls which have been implemented within Growthpoint’s operations, workplaces and facilities with immediate effect, in order to address and manage the risks and hazards posed by this coronavirus.

Procurement Policy:

This policy supports the basic principles associated with procurement i.e. value for money, open and effective communication, ethical and fair dealing, accountability and reporting within the ambit of superior service delivery. The policy is committed to:

  • A fair and transparent process
  • Contributing to economic empowerment as per the B-BBEE Code of Good Practice
  • Management and monitoring progress against procurement objectives
  • Holding individuals accountable for purchasing decisions meeting full requirements

Sponsorship policy and procedure:

This policy highlights that the RSA Exco will consider and agree on sponsorship proposals as and when suitable opportunities present themselves. It further highlights sponsorship criteria and guidelines.

Supplier Code of conduct:

Growthpoint is strongly committed to full compliance with Global human rights, labour standards, environmental laws and ethical business practices as related to goods or services provided to Growthpoint, or to any activity undertaken as a licensee, distributor, representative or as one having similar rights. Growthpoint further conducts business strictly in accordance with its Code of Business Conduct, and expects all parties involved to strictly comply with such Code of Conduct and will further and without limiting the foregoing comply with the following principles:

  • Legal requirements
  • Health and safety
  • Employment practices
  • Environmental practices
  • Ethical conduct
  • Compliance

The Board

Audit Committee Terms of Reference:

Assists the Board in ensuring adequate processes are implemented and maintained, adequate accounting records are maintained and managed, design-effectiveness of internal financial controls, and the integrity of the Annual Financial Statements.

Board Charter:

Provides the overall purpose and objectives of the Board, membership and responsibilities, accountability, and self-assessment

Board Gender Diversification Policy:

Growthpoint’s commitment to gender diversification on the Board. In the event that the size of the board is increased and/or any of the current non-executive directors retires or steps down, preference will be given to women with the necessary skills, experience, independence and knowledge, taking into account Growthpoint’s circumstances and needs. Growthpoint’s aim is that at least 30% of the Board should comprise women.

Board Racial Diversity Policy:

Growthpoint’s commitment to racial diversification on the Board. The Board shall at all times and to the extent practically possible, strive to meet the legislated and/or regulated Employment Equity targets applicable from time to time at Board level.

Governance and Nominations Committee Charter:

Responsible for the establishment, reviewing, and monitoring of the adequacy, efficiency and appropriateness of the corporate governance structure and practices and ensuring compliance with the King IV Report on Corporate Governance for South Africa, 2016 (“King IV”), the Listings Requirements of the JSE, the Companies Act, 71 of 2008, as amended (“Companies Act”) and the Companies Regulations, 2011 (“Regulations”), the Growthpoint Memorandum of Incorporation (“MOI”), Environmental, Social and Governance (“ESG”) criteria, and any other applicable laws and regulatory provisions.

Guides the Nomination Committee in the appointment of board members and ensures consideration is given to the knowledge, skill, experience, diversity and independence of appointees. The policy also refers to gender diversity targets, the issue of multiple directorships and tenure

Nomination Policy: (Click to download)

The policy guides the Nomination Committee in the appointment of board members and ensures consideration is given to the knowledge, skill, experience, diversity and independence of appointees. The policy also refers to gender diversity targets, the issue of multiple directorships and tenure.

Property and Investment Charter:

This committee will assist in the consideration of proposed acquisitions and disposals of Investments, annual budgets including capital expenditure and refurbishments and reviewing annual investment valuations. Recommendations are provided to the Board.

Risk Management Committee Terms of Reference:

Ensures ensuring that the Board is assisted in the discharge of its duties relating to corporate accountability and the associated risks in terms of management, assurance, and reporting.

Social Ethics and Transformation Committee Charter:

The Committee acts for the Company and its subsidiaries, other than subsidiaries or controlled entities that are not managed by the Company or any of its subsidiaries. Considerations, evaluations and monitoring are continuously done on broad-based economic empowerment, enterprise development, social and economic development, oversight of values and the ethical framework, good corporate citizenship, the environment, climate change, procurement, consumer relations, transformations charter, employment equity, and the stakeholder-inclusive approach.

HR

Cell phone policy:

Determines eligibility and outlines the reimbursement process as well as income tax legislation and SA Revenue Services (SARS) practice.

Conditions of employment:

The information contained in this document is intended as a guide to understanding the principles that underline the “way of life” at Growthpoint Properties. It will include policies and procedures to guide employees conduct as well as indicate the legislative compliance from Growthpoint.

Confidentiality of employee information:

The confidentiality of employee information will be maintained at all times:

  • The employee’s right to privacy will be upheld and always respected.
  • All employee information will be maintained in alignment with the Protection of Personal Information Act, 4 of 2013
  • Checks will be conducted only where there is a reasonable and justifiable business requirement.

Disability policy:

This policy serves as a guideline to promote equal opportunities and fair treatment for people with disabilities or those suffering from ill-health as prescribed by the Employment Equity Act (the Act). The objective is to assist the employer and employees to understand their rights, obligations, and the process to ensure fairness and consistency.

Disciplinary policy:

This policy is intended to provide a guideline to employees in terms of what is deemed as unacceptable behaviour. This policy outlines a fair and equitable disciplinary code and procedure for all employees in compliance with current employment legislation. There is a documented level of offences used in alignment with this policy.

Diversity and inclusion forum constitution:

The Diversity and Inclusion Forum has been established to represent employees in matters which relate to Employment Equity and Skills Development. The purpose of the forum is to:

  • Facilitate the achievement of the Employment Equity and Growthpoint’s transformation agenda.
  • Create awareness and support the organisation’s initiatives in relation to transformation.
  • Promote the empowerment and advancement of designated groups.
  • Consult on matters related to Skills Development and Employment Equity in line with legislation.

Education bursary scheme:

The focused educational opportunities available to employees to enable them to obtain qualifications necessary for career advancement within Growthpoint.

Employment Equity (EE):

Growthpoint is committed to creating a diverse and transformed working environment, which will provide equal opportunity to all its employees, whilst giving special consideration to employees from designated groups. Growthpoint will take steps to:

  • Promote equal opportunities in the workplace by eliminating unfair discrimination in all its employment policies and or practices;
  • and implement Affirmative Action (AA) measures, to redress imbalances in employment experienced by designated groups, to ensure their equitable representation in the workplace

Employee Risk Management:

People are our most important asset and in order to comply properly with acceptable standards of corporate governance and international best practice, we continuously review our practices and ensure that employees comply with the required standards. Where necessary from a business perspective, the following checks will be conducted from time to time:

  • Verification of qualifications and experience
  • Credit checks.
  • Criminal record checks.
  • Potential conflict of interest.
  • Other checks as may be required.

Financial assistance:

Set out the conditions under which Growthpoint may provide financial assistance to employees, which include, undue personal hardships. Situations of undue personal hardships are those that are unforeseen/unanticipated (emergency situations), which the employee could not have provided for and no other institution will provide for.

Flexible Working Policy:

Provide employees with the flexibility to work at their most productive time and to give balance to all aspects of employee’s lives. This policy will apply to employees who are eligible by the nature of their role, this means that their day-to-day job will not be affected negatively by the flexible working options detailed further in the policy.

Grievance Policy:

Growthpoint is committed to promoting effective working relationships and an environment in which employees feel comfortable to raise work-related grievances, without prejudice or victimisation. A grievance can be raised in the following instances:

  • When an employee has a matter affecting them as individuals in the course of their employment where they have concerns, problems, or complaints, or
  • When an employee has matters affecting their personal dealings or relationships with colleagues (junior or senior) which affect their work.

Human Resources and Remuneration Charter:

Responsible for facilitating and determining the essential components of remuneration and the criteria for the review of performance of executive Directors and senior management in discharging their functions and responsibilities

Insider Information:

From time to time, employees may be privy to price-sensitive and unpublished information relating to the company and its clients. Trading on the basis of such information is prohibited.

Job Grading and PayScale Guideline and Process:

Explanation of the Paterson Grading System which is used by Growthpoint to evaluate positions and classify them according to their relative significance.

Leave policy:

Leave provisions for employees. The objective is to ensure that all staff are clearly informed of the procedures regarding eligibility for leave and the leave application process. Leave types specified are annual leave, sick leave, family responsibility leave, bereavement leave, maternity leave, adoption leave, paternity leave, study leave, religious leave, special leave, unpaid leave and disability leave.

Medical aid:

The requirement for all permanent employees to become a member of one of the company’s medical aid schemes, unless an employee is entitled to medical benefits in terms of another scheme as a dependent and proof of such membership is provided annually.

Personal Relationship Policy:

This policy is intended to provide guidance in cases where personal relationships may exist or form between employees in the professional working environment. Boundaries between personal and business interactions are necessary to achieve a productive, comfortable and professional work environment. Growthpoint would like to encourage fair treatment and the avoidance of actual, potential or perceived favouritism, conflict of interest and opportunities for collusion in the event of personal relationships in the work environment. It is not the intention of Growthpoint to infringe on personal freedoms nor to intrude on the privacy of individuals.

Privacy Policy:

This policy provides direction and guidance to Growthpoint employees by providing minimum requirements for Growthpoint employees to identify, control, monitor, report, and maintain information privacy across Growthpoint’s business. This policy prescribes the scope, minimum privacy standards, and roles and responsibilities which must be implemented and adhered to in order for Growthpoint to meet its legislative obligations to Process Personal Information in a manner that is lawful and fair and mitigate its other information privacy risks.

Recruitment Policy:

Gives guidance to management on attracting the most suitable candidates to fill vacant positions. In addition, the policy aims to provide guidance on the recruitment of candidates so as to comply with the provisions of the Labour Relations Act No 66 of 1995 (as amended) and the requirements of the Employment Equity Act No 55 of 1998 (as amended).

Benefits:

We reward employees for the value they add through payment of an industry-competitive remuneration package, a variable performance reward and employee ownership in the form of share incentive scheme participation. Any additional benefits are granted in line with the Income Tax Act of 1962. These benefits include rewards for exceptional performance gifts, ongoing service awards, professional memberships, and clothing allowances.

Representing the Company:

All employees are required to represent the company to external persons and / or clients, you are expected to ensure that all information shared is not confidential and is factually correct

Retirement Policy:

This policy provides guidance on the group’s retirement (provident and pension) fund, early retirement benefits, the low-risk portfolio option, the staff incentive scheme, retirement counselling and financial planning in the event of retirement.

Serious illness insurance Policy:

Growthpoint provides cover to employees with serious illnesses such as cancer, kidney failure, and heart attacks The policy lays out the terms and conditions of this benefit.

Sexual Harassment Policy:

Highlight whether the conduct reported is sexual harassment using the definition set out in the Code of Good Practice on the handling of sexual harassment cases. Notice 1367 of 1998 in terms of Section 203(2) of the Labour Relations Act 66 of 1995. It further highlights the investigation process (in a confidential manner) and how a formal grievance can be laid.

Share dealings Policy:

Governs share dealings by directors and executive members and the imposition of closed periods. Prior clearance to deal is required from the Board Chairman and / or Group CEO. Deal disclosure is dealt with in terms of the Listing Requirements of the JSE Limited.

Social Media Policy:

This policy governs the use of social media by Growthpoint Properties Limited and all its subsidiaries or affected company’s employees, associates and contractors, in both a personal and professional capacity.

Substance abuse Policy:

Stipulates behaviour that constitutes a breach of company policy and a breach of an employee’s duty to act in good faith towards Growthpoint.

Travel Policies:

International Travel Policy

This policy sets out the travel and accommodation arrangements for Growthpoint employees or other authorised persons while away on international business travel.

Local Travel Policy

This policy sets out the travel and accommodation arrangements for Growthpoint employees or other authorised persons while away on local business travel. 

IT

Information Technology:

Employees are required to comply with the company’s practice on issues relating to the legitimate use of computers, software, electronic information and networks. In the interests of supporting the availability, integrity and confidentiality of information systems and associated data, the company has established controls to protect its computing resources.

IT Governance Policy:

Our IT governance for stakeholders and, its principles, practices, processes and governance structures. The purpose of this policy is to embed IT governance as a subset of corporate governance within Growthpoint, to outline the scope, required effort and responsibility with regards to developing, implementing, and maintaining Growthpoint IT governance and to identify the commitment to the development and maintenance of Growthpoint IT governance.

IT Demand Management Policy:

Outline areas of responsibility for the management of IT demand. It

supports King IV requirements to oversee the adequacy and effectiveness of technology and information management with specific reference to assessing return on investment. It further ensures IT investment selection is aligned with business priorities and that all IT programmes and projects undertaken will deliver value to the business.

Information Management Policy:

The purpose of this policy is to provide a foundation for; and allocate responsibility for information management within Growthpoint. Additionally, this policy aims to:

  • Outline the benefits of effective and efficient information management.
  • Provide principles to assist with managing information.
  • Provide guidance and policy for information management within Growthpoint.
  • Define roles and responsibilities with regards to information management.

POPI Policy:

This Policy is in line with the Protection of Personal Information Act which aims to:

  • To promote and protect the right of privacy for all persons and companies.
  • Identify, control, monitor, report and maintain information privacy.

Information Security Policy:

The purpose of this policy is to outline Growthpoint Properties (Growthpoint) principles regarding information security management and ensure all parties are aware of their responsibilities with regards information security management within Growthpoint. This policy applies to all employees, functions and departments within Growthpoint, including Third Parties acting on behalf of Growthpoint. The policy serves to govern information security as part of responsible internal asset use and good governance within Growthpoint.

Acceptable Usage Policy:

This sets out employees’ obligations to safeguard Growthpoint’s competitive advantage and business continuity as well as to ensure the ongoing confidentiality, integrity, and availability of all

Growthpoint’s computer resources. All employees are bound by the terms and conditions of this policy. Compliance to this policy is mandatory.

Computer usage:

Sets out employees’ obligations to safeguard Growthpoint’s competitive advantage, business continuity, and to ensure the ongoing confidentiality, integrity and availability of all Growthpoint’s computer resources.

Information Security Incident Response Policy:

This Policy ensures that information security incidents are appropriately and consistently responded to. When information security incidents (including cyber security incidents) are imminent or do occur, it is imperative to ensure they are dealt with in an effective and efficient manner, to limit and reduce their impact, whether financial, reputational, regulatory, legal, or otherwise.

Cyber Security Policy:

This policy ensures that Growthpoint IoT network is secured on various levels.

Business Continuity Management Policy: (Click to download)

The purpose of this policy is to formalise the Business Continuity Management (BCM) programme for Growthpoint Properties (GPP) and to provide guidelines for developing, maintaining, and exercising the Business Continuity Plans (BCPs) for all divisions/departments at Head Office, and the Regional Management Offices. It further ensures the establishment of basic principles and framework necessary to ensure emergency response, resumption and recovery, restoration and permanent recovery of the operations and business activities during a business interruption event.

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Johannesburg:

The Place, 1 Sandton Drive, Sandton

011 944 6000

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Durban:

4th Floor, Lincoln on The Lake, 2 The High Street, Parkside, Umhlanga Ridge

031 584 5100

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Cape Town:

4th Floor, MontClare Place, Main Road, Claremont

021 673 8400