Document Code: NeftalyP490
Approved By: Neftaly Malatjie, Chief Executive Officer
Date Approved: 1 December 2025
Next Review Date: 1 December 2026
Neftaly Policy Owner: Neftaly Chief Human Capital Officer (NeftalyCHCR)
NeftalyP490-1: Neftaly CEO Neftaly Malatjie Speech on the Purpose and Rationale for Launching the Policy
To the Chairperson of Neftaly, all Neftaly Royal Committee, all Neftaly Royal Chiefs, and all Neftaly Human Capital,
Kgotso a ebe le lena.
I am honored to launch the Neftaly Human Capital Trading Management Policy (NeftalyP490), which provides a structured framework for managing, monitoring, and regulating trading activities involving Neftaly Human Capital.
This policy ensures that all trading, business, or commercial activities conducted by, with, or through Neftaly Human Capital comply with organizational values, ethical standards, legal regulations, and operational procedures. It provides clarity on responsibilities, accountability, permissible activities, conflict of interest management, and reporting requirements.
By implementing this policy, Neftaly demonstrates its commitment to fostering ethical trade practices, transparency, and compliance in all trading and commercial engagements involving Human Capital.
My message shall end here.
Neftaly Malatjie | CEO | Neftaly
NeftalyP490-2: Scope
This policy applies to:
- All Neftaly Human Capital engaging in trading, buying, selling, or commercial activities within or connected to Neftaly operations.
- Supervisors, Officers, and management responsible for monitoring and approving trading activities.
- Vendors, contractors, or third-party partners involved in trade with Neftaly Human Capital.
- Compliance with national and international trade laws, organizational ethics, and conflict of interest regulations.
NeftalyP490-3: Definitions
Trading Management:
The structured oversight, regulation, and monitoring of commercial, business, or trade activities involving Neftaly Human Capital.
Human Capital Trading:
Buying, selling, bartering, or engaging in any form of commerce by employees, contractors, or volunteers within or linked to Neftaly operations.
Conflict of Interest:
A situation where personal, financial, or external interests could improperly influence professional duties or decisions.
Officer:
Neftaly personnel responsible for approving, monitoring, and reporting on trading activities.
Neftaly Human Capital:
All individuals employed or engaged by Neftaly, including management, officers, staff, interns, and volunteers.
NeftalyP490-4: Objectives
- Ensure ethical, transparent, and compliant trading practices among Neftaly Human Capital.
- Mitigate risks associated with trading, including conflicts of interest, fraud, and reputational damage.
- Establish clear procedures for approval, monitoring, and reporting of trading activities.
- Promote accountability, transparency, and fair trade practices within the organization.
- Safeguard Neftaly assets, intellectual property, and operational integrity during trading activities.
- Provide structured mechanisms for dispute resolution and corrective action related to trading.
NeftalyP490-5: Roles and Responsibilities
5.1 Neftaly Chief Human Capital Officer (NeftalyCHCR)
- Approve trading management policies, procedures, and regulatory compliance standards.
- Monitor trading activities to ensure alignment with organizational values and legal requirements.
- Provide guidance and training to Officers and Human Capital on trading compliance.
5.2 Supervisors and Officers
- Review, approve, and monitor trading activities within their teams or units.
- Ensure trading practices comply with policy, ethical standards, and legal regulations.
- Report non-compliance, conflicts of interest, or risks to NeftalyCHCR.
5.3 Neftaly Human Capital
- Comply with all trading management policies, procedures, and approval requirements.
- Disclose potential conflicts of interest before engaging in trading activities.
- Report unethical, illegal, or unauthorized trading practices.
NeftalyP490-6: Procedures
6.1 Approval of Trading Activities
- Obtain prior approval from the relevant Officer before engaging in any trading activity.
- Submit a Trading Approval Form detailing the type, scope, and participants involved.
- Ensure alignment with organizational objectives and ethical standards.
6.2 Monitoring and Oversight
- Conduct regular audits of trading activities to verify compliance with policy and regulatory requirements.
- Maintain records of all trading approvals, transactions, and reports.
- Implement corrective actions in case of policy violations or non-compliance.
6.3 Conflict of Interest Management
- Identify and disclose any potential or actual conflicts of interest.
- Restrict or manage trading activities where conflicts may compromise professional responsibilities.
- Apply disciplinary or remedial measures where conflicts are not properly managed.
6.4 Compliance with Legal and Ethical Standards
- Ensure all trading activities comply with national, regional, and international trade laws.
- Prohibit fraudulent, deceptive, or exploitative trading practices.
- Adhere to Neftaly codes of ethics, Human Capital values, and contractual obligations.
6.5 Dispute Resolution
- Establish procedures for addressing complaints, disputes, or conflicts arising from trading activities.
- Investigate disputes promptly and implement fair resolutions.
- Document all actions, findings, and corrective measures.
NeftalyP490-7: Templates, Documents and Forms
NeftalyT490-01: Trading Approval Form
NeftalyT490-02: Trading Activity Record Log
NeftalyT490-03: Conflict of Interest Disclosure Form
NeftalyT490-04: Compliance Monitoring Checklist
NeftalyT490-05: Trading Audit Report Template
NeftalyT490-06: Dispute Resolution Form
NeftalyT490-07: Corrective Action Record for Trading Violations
NeftalyT490-08: Annual Trading Activity Summary Report
NeftalyT490-09: Officer Trading Oversight Log
NeftalyT490-10: Training Attendance Record on Trading Policies
(Expanded to 2000+ templates covering approval, monitoring, compliance, conflict management, disputes, and reporting.)
NeftalyP490-8: Compliance
- All Neftaly Human Capital must comply with trading management policies and procedures.
- Non-compliance may result in disciplinary action, administrative penalties, or legal consequences.
- NeftalyCHCR and designated Officers are responsible for monitoring compliance, investigating violations, and reporting outcomes.
NeftalyP490-9: Frequently Asked Questions (FAQs)
- Who can engage in trading activities under Neftaly policy?
- How are trading activities approved?
- What constitutes a conflict of interest in trading?
- How is compliance with trading policies monitored?
- What are the consequences of unauthorized trading?
- How are disputes related to trading addressed?
- Are third parties involved in trading subject to the same policies?
- How often are trading activities audited?
- What training is provided on trading management?
- How does trading management support transparency and ethical practices at Neftaly?