Compliance Framework

Spur Corporation has an in-house legal and compliance officer whose responsibilities include proactively and systematically managing compliance.

The board relies on the group chief financial officer who, with the assistance of the legal and compliance officer, is responsible for monitoring compliance within the organisation, to highlight any significant matters relating to non-compliance with mandatory laws and rules and to report the potential consequences or risks associated with new legislation.

While the group does not have a formal structured stakeholder engagement process in place, as recommended by the King Code of Governance Principles (King III), operationally, most of its key stakeholders are dealt with on a regular basis. Where significant issues or concerns are raised by stakeholders, these are brought to the attention of the group chief executive officer who will consider whether the matter will be addressed at a board level.

King III recommends that the chairman of each board committee should be present at the annual general meeting. In instances where this is not practicable, as certain chairmen are not ordinarily resident in South Africa and the cost of travelling outweighs the benefits of having such chairmen available, a member of the committee will be available to field questions and the relevant chairmen will be available telephonically. As a principle, the group insists on the use of alternate dispute resolution processes (most commonly, arbitration), in all contracts with stakeholders to the extent possible.

Directors and employees are restricted from trading in the shares of the company during two formalised closed periods ahead of the interim and annual results. The group’s insider trading policy requires directors to obtain formal clearance from the chairman prior to dealing in the company’s shares. All share dealings are disclosed to the company secretary and this information is released on SENS within 48 hours of any trade being completed.