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Social Reasonability

TAM seeks to be a good corporate citizen in all aspects of its operations and activities. To this end we have brought together a series of operating principles under the broad heading of Corporate Social Responsibility (CSR) to serve as a guide to employees in all aspects of their work for the company.

The principles cover all areas of the Company's operations and have been developed with reference to the relevant codes of corporate governance and best practice, including the revised Combined Code and international statements and guidelines such as the UN Universal Declaration of Human Rights and the OECD Guidelines for Multinational Enterprises. Taken together, these principles form our CSR policy.

The policy can be divided into six main areas:

  1. Ethical Business Conduct
  2. Policies Specific to Employees
  3. Policies Specific to the Group
  4. Fair Employment Practices
  5. Workplace Health and Safety
  6. Environmental Policy


TAM's Contribution

The Mauritian Deputy Prime Minister announced a new social responsibility tax in 2009. Profitable firms will be required to spend 2% of their profits on corporate social responsibility (CSR) activities approved by the government or to transfer these funds to the government to be used in the fight against poverty. TAM views this tax as an additional contribution to their current CSR spend.




Social Reasonability Policies

Policies 1 - Ethical Business Conduct

We value the principles of accountability, honesty and integrity in all aspects of our business. Our policy is to conduct our business in a manner which ensures:

  • fair treatment of all employees and clients
  • transparency of our business policies and practices
  • high standards in all matters relating to health, safety and the environment
  • ethical business practices throughout our operations

We recognise that the involvement of our employees is key to the future success of the business and we have for many years adopted a policy of keeping employees fully informed on all matters affecting them. We have consistently operated a remuneration strategy that recognises both corporate and individual performance. We are also committed to best practice in employment matters, recognising the role this plays in attracting and retaining staff.

To succeed in delivering the best possible service to our clients, every employee is expected to adhere to the Company's core values and to uphold them in the workplace. Employees are expected at all times, to exercise the highest ethical judgment and comply with laws applicable to their duties.


Policies 2 - Specific to Employees

Compliance with Codes and Regulations
In addition to the Company's internal operating principles, employees shall adhere to all national laws and regulations. As investors in more than one investment jurisdiction, investment managers will be required to familiarise themselves with the codes of practice in the domains for which they are responsible as well as those codes and regulations in force in Mauritius. These will include the rules of the FSC and other financial services regulators and the recent stipulations of Sarbanes-Oxley.

Whistle Blowing
In the event that an employee discovers a breach of company policy there is a facility for him/her to report that breach in confidence either via his line manager or via an anonymous email address sent directly to the Managing Director. The Managing Director has a duty to investigate fully the detail behind such a report and as part of the investigation will not normally make reference to the anonymous report. Maliciously motivated reports for which there is no real basis for making a report are not welcomed and may result in disciplinary action being taken against the employee making the accusation.

Outside Interests
The company requires that employees avoid at all times any situation which may involve a conflict of interest between the employee and the company. Employees are expressly prohibited from accepting other paid employment, including directorships in other companies, without the consent of the Board. In general, this does not apply to charitable work or relationships with non-profit organisations unless this has the potential to impact on the employee's normal duties.

Dealing with Customers, Stakeholder and External Parties
TAM is committed to the provision of accurate information and fairness in all its dealings with customers, stakeholders, officials and any other external party having direct business with the Company.

Every employee shall respect any information which is confidential to the company including, but not limited to, trade secrets, confidential knowledge or any information concerning the process or invention used by the company. Breaches of confidentiality may be cause for disciplinary action.

Data Protection
We are committed to complying with the data protection principles established by the 1995 EU Directive on Data Protection. This commitment applies throughout the Company and in all countries in which it operates.& If the Company conducts business in a jurisdiction where stricter rules apply, then it will comply with those rules as a matter of course. All employees and agents of the company are responsible for ensuring compliance with the policy. Information collected may be accessible throughout the company but will not be disclosed to any third party in a form which identifies the individual concerned. It will not be used for marketing purposes without the individual's consent and will not be sold to third parties. Upon request, an individual will be informed of the existence, use and disclosure of his or her personal data and will be given access to that data to confirm its accuracy or amend it as appropriate.

Fair Dealings
Dealing for clients will be undertaken in an order and manner which is unquestionably fair for the client. The buying and selling of equities, for example, will not prejudice any party and should be administered within the compliance regulations governing trading operations.

The Company actively works to deter malpractice in its workplace, with specific attention to activities involving bribery and corruption, fraud, money laundering and insider trading. The company has detailed procedures for staff to follow in order to ensure observance of these principles. The company's compliance manual contains guidance on the value of gifts which may be given (or accepted) by staff to (or from) counterparts in the industry, the frequency with which those gifts may be made (or accepted how they should be recorded.

There are also detailed procedures in place to help staff to identify instances of money laundering and a member of the Compliance Team is designated as the Money Laundering Reporting Officer (MLRO).&nStaff are required to report any unusual patterns of trading activity, which could be interpreted as money laundering, to the MLRO. The MLRO is responsible for investigating any suspicious transaction reports, making a decision as to whether it does constitute money laundering and if so, notifying the FSC. Relevant staff receives training, tailored to their specific roles in the company, to assist them identify activities of money laundering.

The Company also has procedures in place to prevent insider trading by employees. All personal dealing, except for trading in unit trusts or OEICs, by fund management and administration staff who might have access to privileged information, requires prior approval by two senior members of staff. If the Company is dealing in a stock in which the employee wishes to trade, the employee can only do so once the transaction on behalf of the corporate client has been completed. All employee investments must be declared on an annual basis and transactions must be declared at the end of each calendar quarter. Employees should avoid any financial situation that conflicts with the Company's interests or potential interests.

Use of Company Information / Assets
Employees shall use the company's computer systems, internet and intranet, and email systems for business use. Any employee found to have disclosed confidential information, been abusive or malicious in using these facilities, or misusing the systems in any way may face disciplinary action. The Company strictly prohibits the use of its intranet, internet or email systems for acquiring, producing or disseminating pornography or similar material, including the use of abusive language or offensive images.

How the Code of Practice is monitored
As indicated above, there are specific requirements to be observed by investment managers who deal for their own account. In addition to a series of mandatory checks and authorisations prior to placing an order, investment managers and all staff who may have knowledge of the Company's investment activity on behalf of clients, complete a quarterly return on personal dealing. The record of investments held by employees and any relationships with brokers must be updated annually.

Disciplinary Procedure
The Company has a detailed formal disciplinary procedure, full details of which are contained on the Company procedures manuals.


Policies 3 - Specific to the Company

Political Contributions
It is the Company's policy not to make contributions for political purposes. However, employees are not hindered frong politically active in their own time using their own resources.

Corporate Governance
TAM manages assets for both institutional and retail clients. It aims to deliver superior and consistent portfolio performance across a diverse range of assets, including stocks, bonds and alternative investments. Our ultimate goal is to maximise the wealth of our clients through sound business practices. Sininning in 2004, the Company has been committed to its core business values of integrity, transparency, honesty and accountability. These values form the basis of optimum corporate governance.; The Company is committed to complying with good corporate governance policies and to listening to and acting in accordance with the wishes of its shareholders.

The Company places a great deal of importance on communication with its shareholders and aims to keep shareholders informed by means of regular communication. Shareholders are encouraged to attend the Annual General Meeting at which an opportunity is provided to ask questions of the Chairman and the Board.

Internal Controls
The internal controls are designed to cover all risks to achieving the Company's objectives including all business, operational, financial and compliance risks. The internal controls are designed to manage, rather than eliminate, risk of failure to meet business objectives and to provide reasonable, but not absolute, assurance against material misstatement or loss.

The system of internal control is embedded within the day to day operations of the Company and a strong control culture is combined with clear management responsibility and accountabilities for individual controls.

At least once a year the Executive presents a formal risk control report to the Board. This includes a summary of significant risks, key internal controls, the work of the monitoring functions and findings arising during the period.

Community Investment
TAM's Community Investment Programme has two main components, charitable giving and support for a wide variety of local and national organisations. The Company also has a policy encouraging staff to donate their time to local causes and will accommodate reasonable requests for time away from the office to engage in community activities.

Charitable Donations
At the commencement of each fiscal year, the Board of TAM will agree an amount which should be allocated to donations to charity and support for good causes. The Company will aim to grow this core amount over time and, depending on the profitability of the Company, may make specific one-off donations.

Activities in the Community
We encourage employees to be active in the community in their own right and to this end operate a flexible working policy which permits staff to use a certain amount of working time each year to devote to charitable activities. Members of staff act as school governors, or are members of parent/teacher associations; others work as carers or with the various Rotary clubs..

Benefits of Community Involvement
As the Company becomes more involved in the community the company may be invited to propose or participate in new projects. Staff will be updated on these activities on a regular basis and will be given the opportunity to propose new ventures.


Polices 4 - Fair Employment Practices

In formulating employment policy the Company has been guided by the relevant legislation in Mauritius and also the framework established by the OECD in its Guidelines for Multinational Enterprises. The Guidelines encourage companies to foster openness, sustainability, and respect for employees' rights.

Equal Opportunities Employer
The Company is committed to providing equal opportunities to all workers and job applicants. It aims to ensure that no job applicant shall receive less favourable treatment on the grounds of sex, marital status, sexual orientation, race, colour, religion or belief, nationality or ethnic or national origin. The company will not treat an employee or job applicant less than favourably for a reason relating to their disability or part time or fixed term status unless this can be justified. The Company will also take all reasonably practical steps to ensure that disabled applicants or workers are able to participate in its business activities on an equal basis with people who are not disabled.

All employees are responsible for complying with this policy and for ensuring that the standards of behaviour required by the company are observed by:

Treating others on their merits and disassociating themselves from any form of direct or indirect discrimination, victimisation or harassment. Bringing to the attention of their Departmental Manager any suspected working practise in breach of this policy. And working together to promote a harmonious working environment free from discrimination, harassment and bullying.

The Company regards direct or indirect discrimination, victimisation and harassment as a serious matter. Employees who fail to comply with this policy will be subject to the Company's disciplinary procedure. All breaches of this policy will be regarded as serious disciplinary matters and will, if there has been victimisation, intentional discrimination or deliberate harassment be regarded as potential gross misconduct leading to summary dismissal.

The Company recognises that misunderstandings can arise where people of a different sex, interests and cultures work together. Any employee who believes that he or she is being treated in a way that is contrary to this policy should raise the issue with their Departmental Manager. If an employee feels that it is inappropriate to approach their Departmental Manager he or she may contact the Human Resources Department.

Human Rights
TAM supports the Universal Declaration of Human Rights in all of its spheres of influence. It upholds the freedom of association and recognises the right to collective bargaining.

Forced / Child Labour
The Company does not utilise or promote forced or child labour of any kind. We adhere strictly to Mauritian laws governing labour standards.

Discrimination, Sexual Harassment and Other Forms of Harassment and/or Bullying

All staff are entitled to work in an environment which respects their personal dignity and which is free from harassment, bullying or any other type of intimidation. Harassment, whether on the grounds of sex, race, colour, nationality or ethnic origin, religion or belief, or age, disability, sexual orientation, being in an inferior position in terms of power or hierarchy (leading to bullying), willingness to challenge harassment (leading to victimization) or otherwise will not be tolerated by the Company.

Employee Benefits
The Company recognises the value of its employees and has identified and assessed their long term retention as key to the short and long term value of the Company. To this end, the Company aims to attract and retain skilled employees and enhance the life/work balance of each individual. The Company offers its full time staff a range of benefits, including a pension scheme, private health care and generous holiday allotment. Also available to employees are personal development and training programmes designed to enhance the employee's skill base. All such programmes shall relate directly to the specific role of the individual within the Company and are linked closely with his/her annual performance review.

The Company has adopted a grievance procedure to provide employees who consider that they have a problem or compliant about their work with a mechanism for resolving the issue fairly and speedily. The grievance procedure encompasses the statutory grievance procedure.


Policies 5 - Workplace Health &Safety

Health & Safety Policy
The Company aims to provide each employee with a safe place to work and is required to abide by local health and safety regulations. Relevant information on occupational health and safety is provided in the Staff Handbook. Further information on health and safety topics can be discussed with the Company's Human Resources Department.

H& Records
The Company records all accidents and/or near misses and investigates these to determine if preventative action is required to prevent further accidents.


Policies 6 - Environmental Policy

TAM understands that its activities affect the environment and the communities in which we operate. We believe that we have a responsibility to identify and manage these impacts as effectively as possible. We are committed to continually improving our environmental performance and moving towards best practices in corporate sustainability.

Environmental Policy
TAM International aims to:

  • minimise the environmental impacts of our existing operations and ensure that the environmental impacts of new operations are fully assessed and minimised prior to their introduction;
  • reduce consumption of materials in all operations, where practicable, to re-use rather than dispose of materials where possible, and promote recycling and use of recycled materials;
  • seek to improve the energy efficiency of buildings and to manage energy wisely in all operations;
  • reduce, wherever practicable, the level of harmful emissions from our office premises;
  • introduce programmes that aim to minimise waste;
  • dispose of waste and effluents in a responsible manner;
  • promote the ownership and control of environmental issues at business level.
  • provide the necessary training and support in order to ensure that staff fulfil their requirements;
  • work with our suppliers to minimise the impact of their operations on the environment through a quality purchasing policy;
  • support through our community programme the promotion of environmental protection by relevant external groups and organisations;
  • monitor progress and publish an environmental performance report on an annual basis

Environmental Risks
As a Company working in the financial services sector, there are no major environmental risks associated with it. However, important issues for the Company are the use of paper, the constant demand for energy and CO2 emissions resulting from the company's operations. Substantial quantities of paper are used in reports, including newsletters, to corporate and individual clients, the preparation of research materials and in the record-keeping process. Energy used for heating, lighting and cooling of offices and for office equipment is another critical element of the process while CO2 emissions from energy and from travel by employees is also important. The Environmental Policy seeks to mitigate these risks and the Environmental Management System explains further how we seek to achieve this aim.

Transport is a major source of CO2 emissions. To reduce these emissions the Company encourages employees to use public transport wherever possible through the provision of interest free loans for seasonal / annual public transport tickets.. Car sharing is promoted and staffs are encouraged to make use of public transport for regular journeys. Conference calls and video-conference calls are used where possible to reduce the need for regular travel.