Each employee is accountable for upholding the GBSH Consult Group Code of Conduct and following all applicable laws, regulations, and company policies. GBSH’s Principles of Risk Management suggest that GBSH’s business risk is managed by each and every employee in his or her daily work.  In a second step, Quality Assurance, Finance, Legal, Intellectual Property and Ethics and Compliance provide independent checks and controls. As a third layer, Internal Audit performs periodic reviews to control risk. Ownership of risk therefore stays with every employee, and so does accountability for ethical and compliant behavior – both cannot be delegated.

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Our Ethics and Compliance program is designed to support legal and ethical actions throughout the company. It covers the activities of advice and assistance, education and training, and monitoring and control. Combined, these create a sustainable advantage for GBSH by enabling compliant company performance that is embedded consistently across all geographic locations while building on over 20+ years of GBSH’s legacy of integrity.

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GBSH Consult Group's Ethics & Compliance program ensures the firm and our people engage in and promote ethical behavior and comply with laws and regulations in all jurisdictions where we operate. It also helps us drive business objectives and strategies and enhances our reputation as an ethical and socially responsible company. Our Code of Business Ethics and Conduct and Policies and Programs form the foundation of our program and approach to Ethics and Compliance.

As part of our broader enterprise risk and compliance network, the Ethics & Compliance program covers a broad range of topics including:

• Anticorruption and Anti-Bribery

• Anti-Money Laundering and Counter-Terrorist Financing

• Competition and Antitrust

• Data Privacy and Protection (GDPR and POPIA)

• Ethics

• U.S. Federal Government Contractor Compliance

• Information and Corporate Records Management

• International Trade Compliance

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Performance with integrity

Our activities are guided by our vision and our ambition to perform with integrity. This means setting the right priorities and delivering our commitments while adhering to GBSH’s values and the standards set forth in the GBSH Code of Conduct.

We can do this by:

• Integrating integrity in all we do

• Holding ourselves personally accountable to high, ethical standards

• Demonstrating leadership by fostering an environment focused on performance with integrity and accountability

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Code of Conduct

We are committed to the highest levels of quality and operational excellence across the regions, functions and markets we serve, every day. This commitment is driven by our passion for customer success, empowerment, trust and integrity.  As part of this commitment, the GBSH Code of Conduct establishes the professional standards for GBSH employees at all levels of the company – wherever they are in the world.  It serves to define how we do business and how we interact with each other. At GBSH, we believe that any success we achieve is no success at all if not achieved ethically.

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Anti-corruption and anti-bribery

It is GBSH’s policy to conduct all its business in an honest, fair and ethical manner. GBSH strictly forbids bribery and corruption of any kind and is committed to acting professionally, fairly and with integrity at all times and implementing and enforcing effective systems to prevent bribery and corruption. GBSH provides employees with anti-bribery and anti-corruption training and provides guidance through its Anti-Corruption and Anti-Bribery Policy to ensure compliance with applicable global anti-corruption laws and regulations.

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Supply chain transparency

In accordance with relevant Transparency in Supply Chains Act, the relevant GBSH entities have prepared a statement about supply chain transparency. The statements set out the steps that those GBSH entities have taken during this financial year, and plan to continue taking, to prevent any supply chain discrepancies in their business and direct supply chain.

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Our Ethics & Compliance programs share a common framework to help us achieve our objectives:

• Driven by accountable leadership and supported across the firm
  Our Board of Directors (through the Audit Committee) and the Chief Ethics & Compliance Officer, supported by leadership at all levels, oversee and are accountable for our commitment to compliance and ethical conduct and the Ethics & Compliance program. This includes providing effective tone-at-the top messaging and adequate resources. The Chief Ethics and Compliance Officer reports to and educates the Audit Committee in person twice annually and additionally as needed on our key compliance areas and initiatives, including risk assessment and audit findings.
   

• Informed through regular risk assessments
  Ethics & Compliance coordinates with our enterprise risk management and business teams to proactively identify new compliance risks and conduct comprehensive risk assessments and benchmarking exercises regularly for our key and emerging compliance risk areas. This enables us to identify requirements and risk, determine whether the program is designed to address these requirements and risks, and assess whether the program is operating as designed. Risks identified during these assessments are addressed through tailored program enhancements.
   

• Enabled by standards, controls, tools, and technology
  We establish clear, specific, and documented codes (including our Code of Business Ethics and Conduct), policies, procedures, and controls for directing employee behavior. We promote, enable, and strengthen compliance with laws, regulations, and company standards. Using new and better tools and technology grounded in existing business processes—such as recruiting and hiring, bidding for work, onboarding suppliers—we operationalize compliance systems and provide employees with resources.
   

• Engagement through training and awareness
  We empower our employees to identify, escalate, and mitigate risks through a mix of firmwide and targeted audience training and awareness. We rely heavily on real-world scenarios and regularly adjust our approach based on participant feedback and industry best practices.
   

• Routinely monitored and audited to ensure appropriate response
  We conduct regular compliance monitoring activities to systematically evaluate our programs, monitor trends, and provide independent review to ensure appropriate programmatic and specific response.

All GBSH Consult Group employees are required to report legal or ethical concerns through established firm reporting channels. When notified of a concern, the firm follows our detailed investigative protocols to investigate each allegation of misconduct fully and fairly and assesses and imposes discipline for misconduct. Where appropriate, the firm discloses misconduct to regulatory authorities and escalates issues to senior leadership and the Board of Directors.

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