CODE OF ETHICAL CONDUCT

At Petra, we believe in conducting our work ethically and legally, free from bribery, corruption, other financial crime and human rights violations. Petra’s commitment to ethical behaviour is clearly set out in the Group’s Code of Ethical Conduct (the Code).

Download the Group’s Code of Conduct

The Code was extensively updated in FY 2022 so that it now integrates our policy on anti-bribery and corruption and serves as a useful guide and summary of other internal policies, standards and procedures that are relevant to the way we work and the ethical conduct that is expected from all staff as well as other business partners who work with us or act on our behalf.

Compliance with the Code is mandatory for all staff who are expected to ensure that the Code is embedded in Petra’s activities and operations.  All staff are encouraged to discuss the Code amongst their teams and raise awareness with our business partners where relevant, such as our suppliers.

The Code explains the steps we need to take to ensure that we always demonstrate transparency and good governance in our work. We draw on diamonds’ characteristics of clarity and purity in our day-to-day work. Not doing so could cause immeasurable harm to Petra, our reputation, industry and product. It is therefore important for any concerns, whether actual or suspected, of any potential violation of ethical standards, the law, or the Code to be reported.

We will always protect those who report concerns in good faith and the Speaking Up section of the Code explains how this can be done confidentially and, if preferred, anonymously. Petra has an external, confidential and independent service provided by Deloitte which is called Tip-Offs Hotline for any individual worried about raising concerns internally.  Petra also has a Whistleblowing Policy in place that explains how people can speak up and raise any concerns they may have and also ensures that those raising concerns in good faith are protected from reprisals or victimisation.

Download the Group’s Whistleblowing Policy

Human Rights

Petra acknowledges the global problem with regard to human rights abuses, such as slavery, gender-based violence, child labour and other abuses committed against vulnerable members of society. The Company is committed to upholding the human rights of all of its stakeholders, as set out in its Human Rights Policy Statement, and risk assessments in the working environments across the Group are critical to the security of personnel, local communities and assets, as well as to promote and protect human rights.

Download the Group’s Human Rights Policy Statement

In FY 2022, Petra updated its Human Rights Policy Statement and adopted its new Human Rights Defenders Procedure, reiterating our commitment to respecting the rights of human rights defenders or anyone raising concerns about our activities, and reflecting the need to continually ensure that effective training on human rights is provided throughout our organisation.

Our commitment includes all applicable internationally recognised human rights but particularly the International Bill of Rights (which includes the Universal Declaration of Human Rights), the International Labour Organization Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the UN Declaration on Human Rights Defenders, the Voluntary Principles on Security and Human Rights (VPSHR), and all legislation pertaining to human rights in the countries where it operates.

UK MODERN SLAVERY ACT TRANSPARENCY STATEMENT

Petra is committed to ethical and responsible business practices with all our stakeholders. We monitor and manage each step in our diamond production process. Modern slavery, human trafficking and human rights abuses are not tolerated in our business.

Section 54 of the UK Modern Slavery Act, 2015 requires Petra to annually make a statement on the steps that it has taken to prevent occurrences of slavery or human trafficking in its businesses.  Petra’s FY 2022 Modern Slavery Act Transparency Statement, which has been approved by Petra’s Board of Directors, can be accessed by clicking on the link below.  This statement also sets out a range of procedures Petra intends to implement in FY 2023 to further prevent occurrences of slavery or human trafficking in its businesses.

Download the Group’s Modern Slavery Act Transparency Statement

Anti-Bribery and Corruption

Petra does not tolerate any form of fraud, bribery or corruption. We conduct our business fairly and transparently and we do not exercise improper influence on any individual or entity.

We comply with the anti-bribery and corruption laws of the countries in which we operate, including the South Africa Prevention and Combating of Corrupt Activities Act 2004, and the Tanzania Prevention and Combating of Corruption Act 2007, CAP 329 R.E. 2019 and the UK Bribery Act 2010, with the latter having potential extra-territorial application throughout our business. As we operate and report in US dollars, we also need to ensure that we do not breach the US Foreign Corrupt Practices Act 1977 (FCPA) which also has wide extra-territorial scope.

We do not offer, promise or give, nor do we request, agree to receive or accept, any bribe of any description or value to reward the improper performance of someone’s duties or for any other purpose. This applies to anyone who works for, or provides services to, Petra.

During FY 2022, Petra reviewed and updated its anti-bribery and corruption policies and procedures which resulted in our policy on anti-bribery and corruption being integrated into the Group’s Code of Ethical Conduct and has resulted in the following new policies being adopted:

Download the Group’s Gifts and Hospitality Policy

Download the Group’s Declaration of Interest Policy

Download the Group’s Public Officials Expenditure

Compliance with these polices is facilitated through online registers that enable all staff to declare the giving and receipt of gifts and hospitality, declaration of actual or perceived conflicts of interest and declaration of expenditure relating to public officials.