ETHICS POLICY

PREAMBLE

1.1 Delta Corporation has a long –published Code of Ethics which demands high standards of business ethics ,morals and integrity from all its employees in the conduct of business affairs.

1.2 In terms of this Code, fraud, theft ,dishonesty, corruption or abuse of company assets by any employee is totally unacceptable and will not be condoned under any circumstance.

1.3 Any form of dishonesty or deceit compromises the necessary relationship of trust between Delta Corporation and the employee concerned. Dishonest conduct by definition implies an element of intent.

1.4 All employees are expected to maintain necessary relationship of business controls to protect all Delta Corporation assets ( including intellectual property, cash, monies, product, containers and other physical assets) from crime and loss.

1.5 Where matters are referred to the criminal or civil courts, Delta Corporation must be seen to have a firm and consistent policy in respect of fidelity crime, especially fraudulent activity, whether by employees or the public.

POLICY

2.1 All employees and more particularly those in managerial positions are responsible for, and are required to account for all assets, products and monies entrusted to their custody, care or possession during the course of their employment.

2.2 No employee is permitted to make any secret profit or gain any personal advantage in connection with Delta Corporation’s business, purchases or procurement.

2.3 Any employee or any other person involved in any criminal activity against Delta Corporation , will be prosecuted in terms of the Ethics Guidelines. Employees shall also be subject to disciplinary action.

2.4 Any employee who assists any third party in the execution of any crime against Delta Corporation will also be dealt with in terms of paragraph 2.3 above.

2.5 It is the responsibility of any employee who becomes aware of theft, fraud, dishonesty or corruption by any other employee to report this immediately either to an appropriate Manager or to the Ethics Hotline. Such reports shall be treated with discretion and a high level of confidentiality.

2.6 Appropriate, prompt and thorough investigations will be implemented, firstly to verify the report, secondly to determine the extent of the loss and thirdly to identify those involved.

2.7 Where any negligence or relaxation of normal controls by any employee/s, (in addition to the perpetrator), assists in the execution of a crime (or serious loss), to the detriment of Delta Corporation, an inquiry will be convened as a matter of urgency to determine the extent of such negligence, to identify any complicity, and to make recommendations as to the action to be implemented. A full report will be made to the respective Managing Director, who will in turn advise the appropriate Executive Director.

2.8 Every effort will be made to recover any loss as a result of crime by an employee in terms of the Pension Fund Act and/ or by civil action where appropriate.

2.9 All employees of Delta Corporation and its managed associates must be fully aware of this policy.

3. ETHICS HOTLINE

3.1 In order to provide complete assurance that all reports will be treated with strict confidentiality an independent organization has been hired to deal with all reports made. All employees, and many suppliers and customers, will be given a personal card providing details of how to contact Tip-Offs Anonymous by telephone, fax, post or e-mail. Vouchers will be supplied for this until freecall numbers are available in Zimbabwe.

3.2 All calls will be confidential and reports to management will be worded so as not to identify the caller.

3.3 The Ethics Hotline will deal only with contraventions of the Ethics Policy and circumstances where Delta Corporation is at risk of loss. In particular: Theft, Fraud, Corruption, Nepotism and Sexual Harassment.