Document Code: NeftalyP186
Approved By: Chief Executive Officer (CEO)
Date Approved: 31 October 2025
Review Date: 28 November 2026
Policy Owner: Neftaly Chief Human Capital Officer, NeftalyCHCR
NeftalyP186-1 Overview
NeftalyP186-1-1 The Neftaly Human Capital Ethics Management Policy (NeftalyP186) establishes standards for ethical behavior, integrity, and accountability within Neftaly. It guides all Human Capital in making ethical decisions and maintaining professionalism in all organizational activities.
NeftalyP186-2 Purpose
NeftalyP186-2-1 The purpose of this policy is to:
- NeftalyP186-2-1-1 Promote ethical conduct and integrity among all Human Capital.
- NeftalyP186-2-1-2 Provide clear guidelines for ethical decision-making.
- NeftalyP186-2-1-3 Prevent conflicts of interest, misconduct, and unethical behavior.
- NeftalyP186-2-1-4 Establish procedures for reporting, monitoring, and addressing ethical concerns.
NeftalyP186-3 Scope
NeftalyP186-3-1 This policy applies to:
- NeftalyP186-3-1-1 All Neftaly Human Capital, including Officers, Deputy Chiefs, Royal Directors, and Non-Executive Members.
- NeftalyP186-3-1-2 External partners, contractors, and vendors engaged with Neftaly operations.
- NeftalyP186-3-1-3 All organizational activities requiring adherence to ethical standards.
NeftalyP186-4 Policy Statement
NeftalyP186-4-1 Neftaly requires all Human Capital to act with honesty, fairness, and integrity. Ethical conduct is expected in all interactions, decision-making, and operational activities. Violations of this policy will result in corrective action or disciplinary measures.
NeftalyP186-5 Core Principles
- NeftalyP186-5-1 Integrity: Maintain honesty and moral principles in all actions.
- NeftalyP186-5-2 Accountability: Take responsibility for decisions and behavior.
- NeftalyP186-5-3 Transparency: Conduct operations openly and communicate appropriately.
- NeftalyP186-5-4 Compliance: Follow legal, regulatory, and organizational standards.
- NeftalyP186-5-5 Respect: Treat all Human Capital, stakeholders, and clients with fairness and dignity.
NeftalyP186-6 Procedures and Processes
NeftalyP186-6-1 Ethical Decision-Making
- NeftalyP186-6-1-1 Use NeftalyF186-01 Ethical Decision Checklist when faced with complex or uncertain situations.
- NeftalyP186-6-1-2 Seek guidance from Officers, Royal Directors, or CHCO when needed.
NeftalyP186-6-2 Reporting Ethical Concerns
- NeftalyP186-6-2-1 Report misconduct, conflicts of interest, or unethical behavior using NeftalyF186-02 Ethics Concern Report Form.
- NeftalyP186-6-2-2 Reports may be confidential or anonymous.
NeftalyP186-6-3 Investigation and Resolution
- NeftalyP186-6-3-1 Officers and Royal Directors investigate reported concerns promptly.
- NeftalyP186-6-3-2 Document all investigations in NeftalyD186-01 Ethics Investigation Log.
- NeftalyP186-6-3-3 Implement corrective or disciplinary actions based on investigation outcomes.
NeftalyP186-6-4 Training and Awareness
- NeftalyP186-6-4-1 Conduct ethics and integrity training using NeftalyT186-01 Ethics Training Template.
- NeftalyP186-6-4-2 Record participation in NeftalyD186-02 Training Log.
NeftalyP186-6-5 Monitoring and Evaluation
- NeftalyP186-6-5-1 Periodically review ethical compliance using NeftalyD186-03 Ethics Monitoring Report.
- NeftalyP186-6-5-2 Identify areas for improvement and adjust policies as necessary.
NeftalyP186-7 Roles and Responsibilities
| Role | Responsibilities |
|---|---|
| Chief Executive Officer (CEO) | Approves ethics policy and ensures organizational commitment. |
| Chief Human Capital Officer (CHCO) | Oversees ethical management, compliance, and investigations. |
| Royal Directors | Monitor ethical behavior within divisions and address reports. |
| Deputy Chiefs | Support Officers and Royal Directors in enforcing ethical standards. |
| Officers | Conduct investigations, provide guidance, and implement corrective actions. |
| Human Capital | Follow ethical guidelines, report concerns, and participate in training. |
NeftalyP186-8 Documentation and Templates
- NeftalyP186-8-1 NeftalyF186-01: Ethical Decision Checklist
- NeftalyP186-8-2 NeftalyF186-02: Ethics Concern Report Form
- NeftalyP186-8-3 NeftalyD186-01: Ethics Investigation Log
- NeftalyP186-8-4 NeftalyT186-01: Ethics Training Template
- NeftalyP186-8-5 NeftalyD186-02: Training Log
- NeftalyP186-8-6 NeftalyD186-03: Ethics Monitoring Report
NeftalyP186-9 Compliance and Monitoring
- NeftalyP186-9-1 CHCO and Royal Directors ensure adherence through audits, reviews, and reporting.
- NeftalyP186-9-2 Violations may result in corrective action, disciplinary measures, or legal action.
NeftalyP186-10 Review and Evaluation
NeftalyP186-10-1 This policy will be reviewed annually by CHCO and approved by the CEO to ensure effectiveness, alignment with organizational values, and continuous improvement.
NeftalyP186-11 Frequently Asked Questions (FAQs)
Q1: Who ensures ethical compliance at Neftaly?
A: CHCO oversees ethical management, with Royal Directors and Officers enforcing compliance.
Q2: How do I report an ethical concern?
A: Use NeftalyF186-02 Ethics Concern Report Form confidentially or anonymously.
Q3: Is ethics training mandatory?
A: Yes, all Human Capital must participate in ethics training programs.
Q4: What happens if unethical behavior is confirmed?
A: Investigations are documented, and corrective or disciplinary actions are applied.
Q5: How is ongoing compliance monitored?
A: Through NeftalyD186-03 Ethics Monitoring Report, audits, and regular evaluations.
Approved By:
Neftaly Malatjie
Chief Executive Officer