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Compliance and ethics

Regulatory and legislative compliance

New and proposed legislation impacting the group includes the following:

  • Insurance Laws Amendment Act - mainly affecting the group’s insurer, Monarch Insurance Company Limited.
  • Consumer Protection Act - An analysis of the legislation has been concluded and owing to the high ethical standards adopted by the group in its dealings with customers, it is anticipated that limited refinements will be required. The Act contains a number of transitional provisions which allows for businesses to effect implementation by October 2010.
  • Companies Act 2008 - Comment was submitted on the Companies Act Regulations and the group awaits the finalisation of the Companies Act.
  • Financial Advisory and Intermediary Services Act: Implementation of the Act relating to the fit and proper requirements for staff is in progress

Behavioural code

The group conducts business with the highest levels of professionalism and integrity:

  • The Lewis Group pledge is a behavioural code outlining the standards of honesty, integrity and mutual respect which employees are required to observe.
  • The corporate fraud policy sets out the responsibility of staff and management towards the detection and prevention of fraud.
  • A confidential hotline is available to all employees to report suspected incidents of fraud or dishonesty.
  • All employees who interact with suppliers or are involved with entities conducting business with the group are required to sign a declaration of conflict of interest. The declaration covers issues ranging from employees owning shares in a supplier to receiving gifts from suppliers. The declaration by employees has been noted in the group’s risk register.

Personal share dealings


  • In terms of the group’s insider trading policy, directors and specifically identified staff are restricted from dealing in the shares of Lewis Group during closed periods.
  • Directors are required to obtain written clearance from the chairman of the board prior to dealing. The chairman is required to obtain written permission from the chairman of the Audit and Risk Committee.
  • It is also mandatory to notify the company secretary of any dealings in the company’s shares. This information is then disclosed to the JSE Limited within 48 hours of the trade being effected and the details published on SENS.
  • A register of share dealings by directors is maintained by the company secretary and reviewed by the board.