Effective and ethical leadership

At Blu Label, we believe that effective and ethical leadership is centred on integrity and is critical to our long-term success. It is about doing the right thing – being accountable, responsible, fair, and transparent. Responsible business practices support our purpose and enable value creation.

We recognise that ethical leadership within Blu Label improves public trust, enhances risk, compliance and ethics management, and strengthens stakeholder relations. This is achieved through:

our key values:
- innovation;
- inclusion;
- accountability;
- collaboration; and
- customer centricity;
leadership’s commitment to upholding our key values; and
the provision of mechanisms to report and manage unethical behaviour.

WE LEAD

Our strategy this year is to drive an inclusive culture by creating unique experiences for all employees. We understand that business results are driven through people and people are continuously evolving. The Success Management Framework provides the framework for us as an organisation to look after our talent and ensure that we have the right skills, while also providing growth opportunities. We encourage a growth mindset that allows individuals to improve themselves and their skills while contributing to the success of the team and the Group at large.

FOCUS AREAS FOR FY26:

Implement leadership development programmes to embed the inclusive culture further.
Align recruitment efforts to the employment equity plan.
Embed the inclusive leadership traits.

Setting the tone for the Group’s ethics

Blu Label’s Social, Ethics and Transformation Committee is established in compliance with the Companies Act, No 71 of 2008. It, in turn, elevates social and ethical matters to the Board level. This ensures that ethics are treated as a matter of strategic importance.

The Social, Ethics and Transformation Committee maintains oversight of the ethics policies and applications within the Group and the Chairman of the Board sets the ethical tone for the Board as a whole. The primary ethics-related items that are monitored and reported on at the Social, Ethics and Transformation Committee level include:

the 10 United Nations Global Compact principles that influence our alignment;
anti-fraud and corruption policies and procedures;
business integrity with a focus on the Group’s and material suppliers’ ethical culture and complying with regulations regarding combatting bribery and corruption and addressing money laundering risks;
customer experience particularly regarding consumer relations and compliance with consumer protection laws; and
environmental, health, and public safety.

No Blu Label operations have been subject to human rights reviews during FY25.

No human rights grievances have been reported in FY25.

Employees are expected to demonstrate ethical business practices at all times. All new staff members undergo an induction programme that includes training on the code of business conduct and the function of the ethics hotline, emphasising what should be reported and how to report unethical behaviour via this channel.

The ethics hotline is outsourced to Tip-offs Anonymous, a division of Deloitte, and can be accessed by calling 0800 555 221. The ethics hotline is available to all stakeholders. Five incidents were reported during the year ended 31 May 2025, which were investigated by management. All incidents were non-fraud-related and were addressed by management.

In FY25, a key focus area has been revising and continuing to align our policies, supported by re-educating our employees.

A Group-wide anonymous ethics-based survey was rolled out in June 2024. The outputs guided improvements in specific policies, which were enhanced.

The following material ethics-based mandatory training programmes were rolled out throughout the Group:

Protection of Personal Information Act (POPIA); and
Reporting suspicious and unusual transactions in terms of the Financial Intelligence Centre Act (FIC Act).

The following material policies have been reviewed, amended and implemented where necessary:

Code of Conduct;
Ethics Policy;
Suspicious and Unusual Activities and Transactions Policy;
Information Security Policy;
Business Continuity Policy;
Whistleblower Policy;
Data Breach and Response Policy;
Gift Policy
Travel Policy;
Acceptable Usage Policy;
Information Classification Policy;
Intellectual Property Guidelines;
Data Retention Policy; and
Group Privacy Policy.

Key provisions of our policies include the following:

Each employee of Blu Label has an obligation to act in the Company’s best interests and must not let outside activities or outside financial interests interfere with those obligations.
Employees must be open and transparent about all gifts and hospitality and disclose these. When a gift is considered lavish, it could be construed as gratification which immediately places the Company and those individuals concerned at risk of being prosecuted for acts of corruption. A formal approval process exists relating to the receiving and giving of gifts over a certain amount, which is reviewed annually.
Fraudulent, corrupt or illegal practices will not be tolerated. Bribes or any other illicit payments will neither be paid nor accepted. A zero-tolerance policy has been adopted regarding such improper payments.
The Group does not participate in any illegal anti‑competitive activity.
Employees should not authorise or participate in any illegal conduct or action (such as price manipulation or tender fixing) that restricts competition.
Committing to contracts and expenditure; and operating a responsible supply chain.
Efficient resource use and minimising negative environmental impacts.

Maintaining high ethical standards

The Group is non-political. It does not contribute to political parties or allow its assets and services to be used in any way that favours any particular political grouping, other than in the provision of its normal products and services, under its standard terms and conditions and at arm’s length prices.
The Company facilities, equipment and personnel should only be used for the business’s activities and purposes, except Blu Label specifically authorises other uses.
Employees are required always to be mindful of what a payment is for and whether the amount requested is proportionate to the goods or services provided. Any suspicions, concerns, or queries regarding a payment should be clarified.
Employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
The Group does not limit an employee’s right to freedom of association, specifically the right to collective bargaining.
There have been no work stoppages due to disputes between Blu Label and its workforce during FY25.
The Group is against child labour and forced/ compulsory labour.
The Ethics Officer takes responsibility for managing the organisation’s ethics programme. The Ethics Officer reports to the Social and Ethics Committee on progress with the ethics management plan and the state of ethics within the organisation.

Ethical breaches

No material ethical or corruption-related breaches require reporting in FY25 and FY24.

All ethical matters that come to the attention of management are addressed appropriately.

Blu Label is satisfied that its corporate governance framework (including compliance and risk) is at a minimum in keeping with best industry practice and industry norms. Blu Label maintains a zero-tolerance policy regarding any lapses in good corporate governance.

ETHICAL LEADERSHIP FOCUS AREA FY26

Providing ethics advice

Employees can request advice through our newly enhanced ethics advice line, which will be rolled out in FY26, an anonymous platform, managed by Group Ethics. Requests could include:

interpretation of policy;
investigations;
clarity about suspected conflicts of interest;
supplier due diligence;
suspicious transactions and activities;
employment screening;
review of customer codes of conduct; and
responding to ethics questionnaires initiated by material customers.