CG-P-001 Business Code of Conduct and Ethics Policy 2021

COMPASS GROUP Guiding Values

Compass Group’s values are the essence of our company’s identity.

They represent how we act, speak, and behave together.

They provide direction and intent towards the way we engage with our community, clients, partners and stakeholders.


We put safety at the heart of everything we do, to safeguard people, assets, and the environment.


We do the right thing, no matter what, and are accountable for our actions.


We work together with our colleagues and Partners and embrace each other’s unique contribution to deliver results for all.


We strive to redefine investment, development, project management, engineering and services in Natural Resources and Energy by thinking effectively, boldly, and differently.


— Robert Beavis, CEO

Dear Colleagues,

In Compass Group (CG) we are committed to doing business the right way. Our Ethics and Compliance program is designed to establish a benchmark in the East African Natural Resources and Energy Services sectors and is an integral part of our daily work and decision-making process. We demand integrity and professionalism of ourselves, just as others – such as our shareholders, clients and partners – expect it of us.

Our revised 2021 Code of Ethics and Business Conduct is one of the tools we have created to strengthen our Ethics and Compliance program. The Code is a living document that we will improve upon annually, and it applies to each one of us – from the Leadership Team and managers to employees and contractors. We are all responsible for adhering to the Code.

You are the voice of our company’s values, so please take the time to read and understand the Code and encourage your colleagues and our partners in Compass Africon and Dura Resources todo the same. We make hundreds of decisions every day, and while most ethics-related decisions are made using good judgment, the correct answer is sometimes unclear.

This Code offers guidance on the right thing to do when faced with those difficult situations. If the answer is still unclear after consulting the Code, speak to your manager, or contact our COO, Ben Salter, in Maputo.

I am proud of the work we have done together with Environmental, Social and Governance (ESG) since 2017 and it is clear to me that the opportunity to become an ethics and compliance leader in Mozambique can make a difference to our results.

Thank you for your commitment to operating with the highest ethical standards, for your help in building a business culture that is based on integrity and transparency, and – of course - for doing business the right way.


Our Code is not a collection of rules, and it cannot cover every situation. It helps us use our judgement and common sense to make the right decisions.

Some decisions are easy to make. However, whenever we are unsure of any work-related actions or decisions, we must ask ourselves the following questions:

If the answer to any of the above questions is not clear and obvious, or if we are uncomfortable with our answer, we must seek guidance from the available Compass Group resources listed in the section entitled Contacts.

  • Does a decision I need to make comply with CG’s values and with our Code and its underlying policies?
  • Is my action legal?
  • Is it fair, ethical, and morally acceptable? What is my “instinct” telling me?
  • How would it look if it were reported on the news or in another public forum? Would my reputation or CG’s be negatively affected?
  • Could someone perceive any action I take as a conflict of interest?
  • Could my action (or inaction) put anyone’s health, safety or well-being at risk?


Everyone Is Involved

Compass Group Code of Ethics and Business Conduct (“our Code”) seeks to ensure integrity and transparency in the conduct of our business and in our relationships with others.

Our Code applies to all Employees, partners, consultants, personnel, and members of the Board of Directors of CG. Complying with our Code and its underlying policies is part of the terms and conditions of our relationship with CG.

On an annual basis, we are required to complete a certification process to ensure that our Code is understood and properly applied to our daily activities.

e expect any third party we do business with, to respect our values and high ethical standards of conduct. Our Code is reviewed and updated yearly and is available in Compass Group’s Intranet Portal and Website.


Operating across Mozambique, we are subject to the laws of the Country and the local regulatory regimes in the Districts and Provinces; we must comply with all of them.

When local laws allow behavior that is not permitted by our Code, our Code prevails.

Should there be a conflict that you do not know how to resolve, or should you be uncertain about the application or interpretation of a law or regulation, Compass Group Executive Management will advise you before any decision is made or action taken.

You should always feel free and able to discuss these matters with your colleagues and line management.

Living Our Values & Code

No matter where we are and what we do, we are all, collectively and individually, the face of CG. Behaving in accordance with our culture and values and adhering to our Code is what will protect our reputation and safeguard our future, allowing us to continue building what matters. Our culture, values, and the way we work, determine whether clients and partners want to do business with us, and whether talented people choose a career with us.

We are committed to support our people in adopting behaviors that are aligned with our Code, values, and culture. Because we care about our people, clients, and reputation, and that sits at the heart of our culture, we commit to take the necessary steps and actions to address non-compliant behaviors.

The way we behave matters. Whether we’re working alongside colleagues, meeting with clients or attempting to attract new talent, we all represent CG, and each other.

How we interact with others is what defines us as a company, and each of us has a part to play in developing and establishing our reputation as Mozambique’s leading Natural Resources and Energy Services company.

We all lead by example and act as role models by adopting behaviors that support our shared values.

Each One of Us Must

  • Work ethically and honestly to do what is right, and comply with the Code, its supporting Policies and Procedures and applicable laws, both domestically and Internationally.
  • Act with integrity always and in all circumstances.
  • Encourage people to take personal ownership and responsibility for the things they control and the decisions they make.
  • Take personal and professional pride in our work and its outcomes and share the responsibility for doing things right the first time and delivering on our promises.
  • Look out for our own health, safety, and security and that of those we work with.
  • Treat others with respect and dignity, as we would like to be treated, and support a diverse workplace in every aspect, which contributes to our collective success; and
  • Protect our environment because the future depends on what we do today, and the communities we work in, to ensure we have a positive impact.

Our Commitment to You, Our Partners, & To All Our Stakeholders

Compass Group promotes integrity and the highest ethical standards in all aspects of its business. To ensure we all live by our values and comply with the obligations set forth in our Code, Compass Group is committed to:

  • Build and foster a corporate culture of integrity.
  • Create appropriate awareness of our Code at all levels.
  • Set up measures to prevent, detect and respond to unethical or non-compliant behavior.
  • Provide globally available support, information, and resources to help you in the application of our Code.
  • Continuously improve our corporate governance standards; and protect people who come forward in good faith with compliance related concerns, from retaliation.


The Diversity of Our People is One of Our Greatest Assets and Opportunities.

We are all entitled to personal dignity, privacy and the preservation of our rights and have zero tolerance for any behaviour or actions that amount to Discrimination, Harassment or Violence.


Mutual Respect in the Workplace

At CG, we will consistently demonstrate respect for all our stakeholders. Our day-today activities require us to interact with individuals of various ethnic backgrounds, cultures, religions, political convictions, ages, genders, disabilities, and sexual orientations.

The diversity of our people is one of our greatest assets, allowing us to benefit from a variety of professional and educational backgrounds and point of views. Embracing those differences contribute to make us more agile and able to respond adequately to changes in our business environment and work in a collaborative manner. We have a commitment to the further development of our indigenous capabilities and competence.

Building and maintaining respectful and meaningful professional relationships by making constructive two-way communication, actively listening to others, and engaging with people, creates a positive work environment where we can enjoy our work, progress our career and develop our full potential.

Health, Safety, Security and Environment

In everything that we do, nothing is more important than the safety of everyone. CG is also equally committed to protecting the environment and our aim is to do business in an environmentally responsible and sustainable manner.

CG ensures that the applicable workplace health and safety and environment legislation is treated as a minimum standard in all areas where we conduct business.

Our health, safety, and environment program, which is based on hazard recognition, risk assessment and the elimination of hazards, seeks to establish an incident-free work environment.

We are all accountable for ensuring that all employees go home safely, at the end of the day.

Drugs & Alcohol

We must never be impaired by alcohol or drugs while on duty
and are strictly prohibited from consuming, selling or purchasing illegal drugs at work. Moreover, and always in accordance with applicable local laws, we are prohibited from consuming or serving alcoholic.

We are committed to protecting our people, assets and information wherever we operate during our business operations or during business travels. We will not knowingly engage in any business activity encompassing a security risk that cannot be properly managed and reasonably mitigated.

Nor will we do business with any security provider that does not meet or adhere to our principles relating to security standards and human rights. We are all accountable for following SML’s security policy, procedures, and protocols.

Personal & Private Info

Compass Group is committed to respecting individual privacy laws. We will ensure that the use of personal information is always explained transparently and is used only for the purpose for which it was collected or to meet legal obligations.


When an actual, potential, or perceived conflict of interest is deemed to exist, management will outline the measures that must be taken to remedy the situation.

The information disclosed will be treated as confidential and only be made available to individuals directly involved in assessing or managing the conflict of interest.


Throughout the course of our activities, we must ensure that we always act in the best interests of Compass Group. We should not let our professional judgment and actions in relation to our duties and obligations toward CG be unduly influenced by secondary interests that would financially, professionally and/or personally benefit us or a family member or someone with whom we have a close personal relationship.

We must therefore avoid any conflicts of interest or patronage whether actual, potential or perceived, in the performance of our duties.

When an actual, potential, or perceived conflict of interest is deemed to exist, management will outline the measures that must be taken to remedy the situation. The information disclosed will be treated as confidential and only be made available to individuals directly involved in assessing or managing the conflict of interest.

We Must Always:

  • Act and make decisions in the best interest of CG.
  • Completely and truthfully disclose, in a timely manner, all information related to an actual, potential, or perceived conflict of interest; and
  • Set up measures to prevent, detect and respond to unethical or non-compliant behavior.
  • Abide by and apply any mitigation measures implemented to mitigate a conflict of interest.

We Must Never:

  • Be guided in our actions or decisions by our own personal benefit or that of a family member or someone with whom we have a close personal relationship.
  • Allow ourselves to be in a position where we cannot be objective towards a family member or close personal relationship, either by supervising them or doing business with a company they fully or partially own or work for
  • Proceed when we know or are unsure whether a situation constitutes a conflict of interest.


We are and intend to continue to be vigorously competitive in all our markets, but we are also fair and act in full compliance with the law.

Unlawful conduct is strictly prohibited. It is sometimes normal to be unsure about the interpretation of a law or regulation or about the correct legal or ethical action to take.

CG is committed to conducting business with integrity and we prohibit corruption and bribery in all its forms. We must not, directly, or indirectly, accept, request, offer, promise, grant or authorise a bribe, kickback, payment or anything that can be considered as such (gifts, entertainment, employment, contracts or benefits of any kind) to or from, any third party that may or appear to, influence action, inaction or a decision, with the intent to obtain an improper advantage, retain business or obtain undue influence over that third party’s actions.

We are all responsible for educating ourselves on how to recognize corrupt activities and ensure that we are not involved in any such type of activities, whether directly or indirectly.

Accounting Practices and Record Keeping

Accurate, complete and reliable records are crucial to our business as they guide decision making and strategic planning.

They are the basis of our financial reports and are necessary to fulfil CG’s obligation to provide full and truthful disclosures to investors, stakeholders and regulatory authorities.

All our records must be complete, accurate and reliable, and prepared in accordance with applicable laws and regulations as well as CG’s accounting and reporting policies and procedures.

Each of us must make the following commitments with respect to our books and records, regardless of the purpose for which the information is used.

We Must Always:

  • Business records, expense reports, invoices, vouchers, payrolls, employee records and other reports are prepared with care and honesty, and in a timely fashion.
  • All transactions are approved in accordance with our Levels of Authority Policy and other applicable policies and in compliance with applicable laws, rules, standards, and regulations.
  • Transactions are recorded based on sound judgement and generally accepted accounting principles and supported by proper documentation.
  • No transaction, asset, liability, suspected liability claim, potential claim, litigation or other financial information is concealed from management, Legal or Corporate Finance, or from CG’s internal or external auditors.
  • All efforts are made to resolve all issues and concerns raised in internal and external audit reports.
  • Any unrecorded funds or assets, suspect accounting or false or artificial entries in our books and records are immediately reported to Ethics & Compliance or Internal Audit.
  • All documents issued and signed are, to the best of our knowledge, accurate and truthful.
  • No secret or unrecorded cash funds or other assets are established or maintained for any purpose; and
  • Access to sensitive or confidential information is restricted to ensure that it is not accidentally or intentionally disclosed, modified, misused, or destroyed.


Engaging in Corporate Social Responsibility Human Rights

We believe that all human beings should be treated with dignity, fairness, and respect.

Compass Group is committed to supporting the protection and preservation of human rights throughout its operations in Mozambique and to ensuring that it is not involved in, or benefits from, human rights abuses.

We will not engage in activities that encourage human rights abuses or that support trafficking in persons or the use of child labour or forced labour, a growing problem in the provinces in which we operate and one which our communities are explicitly concerned about.

Moreover, we will never knowingly do business with subcontractors, Business Partners, suppliers or any other third parties, who do not adhere to the principles regarding human rights put forward in our Supplier Code of Conduct. These principles apply regardless of local legislation and customs.

Community Engagement

CG is committed to building and strengthening sustainable
benefits to the local communities in which we live and work in Mozambique.

By being attentive to community needs and expectations, and by respecting each community’s uniqueness, we build strong and sustainable relationships.

We collaborate with local non-governmental organizations, local District and Provincial Governors, and private-sector partners to develop and implement sustainable programmes around our projects.

We empower local workers, companies and communities through training, mentorship, and capacity-building, transferring valuable expertise and implementing initiatives to enhance project employment and procurement opportunities.

All National employees are offered opportunities for further personal and professional development programmes, mentored by their colleagues on courses aligned with their function, and accredited through international universities.

Free, Prior, Informed, Consent (FPIC)

All our Concession operations, throughout the mineral extraction life-cycle in Mozambique, are governed by FPIC. The aim of Free Prior Informed Consent is to establish bottom-up participation and consultation of an Indigenous Population prior to the beginning of a development on ancestral land or using resources within the Indigenous Population's territory.

To protect Indigenous people’s rights, international human rights law has created process and standards to safeguard their way of life and to encourage consultation and participation in the concession decision making process.

Extractive Industries Transparency Initiative.

Compass Group is committed to the observation and practice of the twelve underlying principles of the EI Transparency initiative.


We all share a personal responsibility and legal duty to protect CG’s information and that of all stakeholders.

Protecting information and assets is vitally important not only to Compass Group, but also to our clients and partners.

It is essential that information such as financial results, business plans, technical information and design outputs, intellectual property and personal information is not compromised in any way and is used and distributed appropriately and responsibly.

Assets must be used responsibly, appropriately, and ethically, and protected from damage and unauthorized access. We must not use CG, SML or our partners assets for any unlawful, unethical, or improper purpose, or for personal or third-party benefit or gain.

You should always:

  • Safeguard personal information, CG’s confidential information and intellectual property.
  • Protect the company’s assets as if they were your own;
  • Ensure assets are maintained to an appropriate standard and not used inappropriately.

You should never:

  • Use or access confidential information or intellectual property belonging to the Government, clients, competitors, Business Partners, or former employers without their written consent or for obtaining an unfair advantage.
  • Fail to report theft, damage or inappropriate use or suspect breach of information; and
  • Proceed when we know or are unsure whether a situation constitutes a conflict of interest.
  • Use or share personal information about colleagues or other stakeholders.


Our confidential information is one of Compass Group's most important assets.

We must prevent inappropriate or unauthorized access to, or disclosure of any confidential information belonging to CG or entrusted to us by third parties.

Our obligation to safeguard the confidentiality of information continues even after the termination of our employment with CG.

To this end, CG has developed a procedure that lays the ground rules on how to properly classify and apply the adequate level of protection on the information we are entrusted with.

Duty to Report

It is the responsibility of each one of us to ensure that we all live by the values of CG and our Code.

We are building a business that has intrinsic value as well as value to the investment community. We all have an important duty and a responsibility to report in good faith any known or suspected violation of our Code and its underlying policies, as well as any violation of applicable laws, rules or regulations or any observed instances of misconduct or pressure to compromise our ethical standards.

If we are involved in a situation or become aware of something that is or may be in breach of our Code or its underlying policies, we must promptly report it via any of the following resources:

  • Our manager or member of the leadership team.
  • Ben Salter, Chief Operating Officer.
  • Robert Beavis, Chief Executive Officer.

In Summary

The Code Belongs to

Our work in Mozambique is underway and the challenges to our integrity and license to operate must not be underestimated.

Our intent has been to set standards that create a benchmark at a time when growth and productivity for many is beginning to slow and the impact of the COVID virus is manifest.

We want to move beyond the traditional concerns about implementation, such as limited State capacity and “the way things are usually done around here."

We can all contribute to an underlying Governance by playing a personal role in the application of our Code.

You must play your part.

The Code in summary

  • Our Code of Ethics applies to all employees and consultants.
  • Discrimination and harassment are prohibited.
  • Violence is prohibited.
  • Drugs and Alcohol are prohibited.
  • Environmental practices: We must apply environmentally sound practices.
  • Giving or receiving bribes is prohibited.
  • Facilitation payments: are prohibited.
  • Gifts, hospitality and patronage: You must never accept or offer a monetary gift.
  • Personal relationships: Direct reporting relationships are prohibited.
  • Company assets: The use of CG assets for personal use is prohibited.
  • Personal information: of employees is protected.
  • External communications: Your opinions are personal and should not involve CG or its affiliates.