Ethics Management & Tip-offs

Ethics management

Aspen NDB and Aspen Group have a zero tolerance approach to unethical behaviour and is committed to ensuring that the Group and its employees uphold Aspen’s laudable reputation.

The Group has appointed an Ethics Officer in Aspen NDB . To download contact details, click on Aspen Regional Ethics Officers

Aspen is a member of the Ethics Institute of South Africa.


Ethics Institute logo


Codes of conduct

The Code of Conduct governs the conduct of all Aspen’s employees throughout the Group and is aligned with the Organisation for Economic Co-operation and Development recommendations regarding corruption. Furthermore, Aspen’s service providers and suppliers are required to adhere to the Group’s Code of Conduct in accordance with relevant clauses included in agreements with these stakeholders.

The areas covered by the Group Code of Conduct include:

  • acting in accordance with Aspen’s values;
  • equitable treatment for all;
  • acting as ambassadors of Aspen;
  • business integrity;
  • gifts, entertainment and bribery;
  • integrity of qualitative and quantitative information;
  • protection and use of property;
  • business controls;
  • confidential information;
  • insider trading;
  • safety, health, quality and the environment;
  • competition law;
  • political activities;
  • compliance;
  • accountability; and
  • corporate governance.

Aspen Group Code of Conduct (French)

Aspen NDB Code of Conduct for Suppliers and Service Providers (French)

In line with King III recommendations, a formalised ethics management programme has been initiated at all of the Group’s businesses. This programme is managed by the Group Governance Officer under the direction of the Social & Ethics Committee and is aimed at:

  • assisting the Audit & Risk Committee and the Social & Ethics Committee in assessing the Group’s ethics profile, risks and opportunities; and
  • assisting the Social & Ethics Committee to monitor implementation and compliance with the Group’s policies which guide expected ethical behaviour.

Aspen’s induction programme educates new employees on the ethics, values and the business philosophy of the Group. All new employees are given a copy of, and are required to sign an acceptance of, the Code of Conduct on commencement of their employment with the Group. The Code of Conduct is available to all employees on the Group’s intranet and is also contained in the employee handbook.

The Group conducts its business in a highly regulated environment, however, one in which the potential for unethical marketing and promotional practices remains inherent. Aspen endorses the ethical marketing of medicines and subscribes to the rigorous application of the Marketing Code of Practice of the Pharmaceutical Industry Association of South Africa. Aspen has a written policy on gifts and benefits in terms of which employees of the Group, including directors, are prohibited from accepting or giving gifts or hospitality that are not of a nominal value or participating in events sponsored by current or prospective customers or suppliers. Any employee of Aspen NDB who receives a gift or other benefit exceeding the local currency equivalent of 80€ is required to disclose this in writing to the Ethics officer. Some types of gifts, benefits or entertainment are prohibited even if the value falls below this threshold. A register of gifts is maintained by the Ethics officer and is noted by the Social & Ethics Committee on a periodic basis. This register is also made available for inspection by the Board or any member of senior management on request.

Aspen does not make payments or other contributions to political parties, organisations or their representatives or take part in party politics. Employees are free to participate in the political process in their private capacity provided it does not constitute a breach of the principles set out in the Code of Conduct and/or the relevant employee’s obligations to Aspen under contracts of employment and does not negatively influence their productivity or the credibility of the Group.

Tip-offs Anonymous Hotline

Aspen Poster
Aspen endeavours to promote a culture of openness and transparency throughout the Group. Employees and other stakeholders are encouraged to report unethical conduct and any transgressions of which they become aware.

An independently monitored whistle-blowing hotline, Deloitte’s Tip-offs Anonymous, has been rolled out to employees across the Group’s businesses, whereby employees can report suspected fraud and/or activities which are considered to be transgressions of the Group’s Code of Conduct. Tip-offs training and awareness sessions are conducted periodically to promote utilisation of the facility where necessary.

The Tip-offs service has also been extended globally to customers and suppliers of Aspen’s businesses.

All logged calls are timeously reported to Aspen’s Group Ethics Committee for consideration. Where wrongdoing, unlawful conduct or a breach of Aspen’s policies or procedures is identified, corrective action is implemented in all instances to improve controls and to prevent recurrence of the incident.

The PDFs below provide additional information required to raise any concerns about unethical behaviour at Aspen.

Tip-offs Letter to Suppliers 2015 (French)

Or click here to be redirected to the french Deloitte Tip-offs website.


Conflicts of interest

According to the requirements of the Group,  Aspen NDB company has set up a procedure for managing Conflicts of Interest.