Since 1925, when my father Max Pupkewitz first opened his doors for business, our guiding principle has been, and remains, Customer Satisfaction Through Service Excellence. It has been the key to the growth and diversification of our customer base and a firm foundation for the success of our various businesses, and the Pupkewitz Group, through establishing our reputation for reliability, credibility and integrity. Consequently we have earned the reputation of being the most respected trading house in Namibia.

To ensure that the sound foundations of the Group are maintained and strongly projected into the future, the Board of Pupkewitz Holdings (Pty) Ltd consider it wise and necessary to entrench the unwritten principles and practices of the past into this Statement of Business Principles. This will give all employees throughout the Group an infallible guide and the confidence to make the right decisions with all stakeholders at all times, thus promoting the Group’s good reputation.

The Statement of Business Principles will, we trust, be used to the advantage of all stakeholders and we regard it, therefore, as an important milestone in our endeavour to improve the corporate governance of the Pupkewitz Group.

Standard of Conduct: We conduct all our operations with honesty, truth, integrity and transparency (i.e. no underhand or unrecorded dealings), and with respect for the rights and interests of our employees whilst holding each employee responsible for his/her job performance and behaviour. We similarly respect the legitimate interests of all other stakeholders.

Obeying the Law: The Group, its subsidiaries and all employees are required to comply with the laws and regulations of the countries in which we operate. All employees are, therefore, required to know the applicable laws and to abide by them even if they do not agree with the law.

Employees: The Group values diversity in its workforce and promotes a working environment of mutual trust and respect where everyone feels responsible, and will be held accountable, for the performance and reputation of our Group. We recruit, employ and promote employees on the sole basis of the competencies needed to perform the job with particular attention to identifying and developing employees from previously disadvantaged groups. We are committed to safe and healthy job design and working conditions for all employees. We respect the dignity of the individual and the right of employees to freedom of association. We will maintain good communications with employees through Divisional based information and consultation procedures.

Customers: At all times, and in all its market sectors, the Group companies and employees will act in a manner that earns the Group the reputation of being beyond reproach in the quality of its products and services. We will jealously guard our standing as regards credibility and integrity and consistency in honouring our ethical and legal standards of conduct. We are keenly aware of the need to foster customer loyalty and enduring relationships. The Group aims to serve customers from all walks of life and is therefore non-racial and non-political.

Shareholders: The Group will conduct its operations in accordance with internationally accepted principles of good corporate governance as detailed in the King II Report. We will provide timely, regular and reliable information on our activities, structure, financial situation and performance to all shareholders.

Business Partners: The Group and its subsidiaries are committed to establishing mutually beneficial relations with our suppliers, customers and joint venture business partners. In our business dealings we expect our partners to adhere to business principles consistent with our own.

Community Involvement: The Group strives to be a welcome and trusted corporate citizen and, as an integral part of Namibian society, to fulfil its obligations to the communities within which it operates.

Public Activities: The Group and its subsidiaries are encouraged to promote and defend their legitimate interests through co-operation with the Government, both directly and indirectly through bodies such as the NEF, NCCI, IOD, LAC and PEAC in the development of legislation which may affect our business interests. The Group is non-political and does not make contributions to political parties or groups promoting party interests.

The Environment: The Group recognises that the sustainable use of the environment is essential to our businesses’ future survival. It is therefore committed to continuously looking for ways of designing and managing its operations in order to achieve sustainability. We will work in partnership with others to promote environmental care and increase understanding of environmental issues in Namibia.

Competition: The Group believes in vigorous but fair competition and supports the development of appropriate competition laws. The Group and subsidiary companies and employees will conduct their operations in accordance with the principles of fair competition and all applicable regulations.

Business Integrity: The Group, its subsidiaries and employees do not give or receive, directly or indirectly, bribes or any other improper advantage for business or financial gain. No employee may offer, give, solicit or receive any gift or payment which is, or may be construed as being, a bribe. Any demand for, or offer of, a bribe must be rejected immediately and reported to the most senior manager in the business concerned. The Group and subsidiary accounting records accurately describe and reflect the nature of all transactions. No undisclosed or unrecorded account, fund or asset will be established or maintained.

Conflicts of Interest: All employees are expected to avoid personal activities and financial interests which could conflict with their responsibilities to the Group and/or Division. Employees must not seek gain for themselves or others through misuse of their positions.

Compliance, Monitoring and Reporting: Compliance with these principles by all employees is an essential element in our business success. The Pupkewitz Holdings (Pty) Ltd Board is responsible for ensuring that these principles are communicated to, understood and observed, by all employees. Day-to-day responsibility is delegated to Management and Supervisors who may develop implementation guidelines suitable to local requirements. Compliance will be monitored through the Board Audit Committee.

The Pupkewitz Holdings (Pty) Ltd Board will not criticize Management for any loss of business resulting from adherence to these principles and any other mandatory policies or instructions. The Board expects any employee to bring any breach of these principles directly to the Chairman’s attention and no employee will suffer as a consequence of having done so. Approved by Exco decision number 28-06-03-02 dated 28th June 2003.

Harold Pupkewitz
Executive Chairman
Pupkewitz Holdings PTY(Ltd)