Sanctions Policy

Print this Article

---

1. Definitions The following words and phrases have these meanings in this document:
1.1. “ABC” refers to Anti-Bribery, Corruption and Sanctions.
1.2. “Bribery” or “Bribe” means offering, giving, receiving, or soliciting something of value to influence the actions of an individual holding a public or legal duty.
1.3. “Corruption” or “Corrupt Activities” means the abuse of entrusted power for private or personal gain.
1.4. “Clients” means any individual or entity that concludes an agreement with DiaMatrix for the provision of services.
1.5. “End-User” means any individual or entity that ultimately uses or is intended to use the products or services provided by DiaMatrix.
1.6. “Employees” means all employees, (which includes, permanent employees, casuals, and management), executive and non-executive directors of DiaMatrix, affiliated third parties (including but not limited to contractors, consultants, service providers and outsourced employees).
1.7. “Facilitation Payments” means usually small payments made to expedite or secure the performance of a routine governmental action.
1.8. “Sanctions” or “Sanctions Laws” means restrictions or prohibitions imposed by governments or international bodies on dealings with certain countries, governments, groups, entities, individuals, or controlled goods/services due to breaches of international law or human rights violations. Sanctions can include trade embargoes, asset freezes, and travel bans.
1.9. “Us”, “we”, or “our” means DiaMatrix CC, a close corporation incorporated in terms of the laws of the Republic of South Africa with registration number 2001/064910/23 and also includes reference to any of our subsidiaries, holding companies and their subsidiaries.
1.10. “Website” means Internet World Wide website at URL https://www.diamatrix.co.za (including subdomains).
1.11. “You” or the “user” means any person who accesses DiaMatrix’s Website for any purpose.

2. DiaMatrix’s Commitment DiaMatrix commits itself to:
2.1. Zero-tolerance against fraud, theft, corruption or any similar illegal behaviour;
2.2. Comply with all applicable ABC laws, regulations, rules, related self-regulatory organisation standards and codes of conduct in the jurisdictions in which it carries out operations;
2.3. Conduct business in full compliance with all applicable competition and antitrust laws;
2.4. Conduct business transparently and in an honest and ethical manner;
2.5. Embed its business relevant ABC compliance framework and process in its daily activities;
2.6. Continuously enhance its ABC risk-based monitoring programme that seeks to provide assurance to the Board; and
2.7. Continuously monitor the regulatory environment and to implement appropriate responses to changes and developments.

3. Applicability
3.1. This policy applies to all Clients and End-Users of DiaMatrix. Clients agree to inform respective End-Users of their obligations under this policy, where applicable. By engaging with DiaMatrix, you agree to abide by this policy.
3.2. Further, this policy also applies to all Employees.

4. Obligations of Clients, End-Users and Employees
4.1 Clients and End-Users of DiaMatrix are obligated to:
4.1.1 Not engage in any bribery, corruption, or actions that violate applicable Sanctions Laws;
4.1.2 Conduct their business transparently and ethically;
4.1.3 Report any suspected bribery, corruption, or Sanctions violations to DiaMatrix immediately;
4.1.4 Ensure compliance with all applicable Sanctions Laws and regulations in their business dealings; and
4.1.5 Not use DiaMatrix’s products or services in any manner that would result in a breach of Sanctions Laws.
4.2 Employees of DiaMatrix are obligated to:
4.2.1 Act with integrity and honesty at all times and to safeguard the assets for which they are responsible;
4.2.2 Protect DiaMatrix’s reputation;
4.2.3 Perform their functions in accordance with any applicable laws;
4.2.4 Refrain from accepting any unauthorised gifts, travel and accommodation from any supplier or business associate;
4.2.5 Report (without delay) where the employee is approached, either directly or through a nominee, to act in any way which could be to DiaMatrix’s disadvantage, and/or when an employee is offered a bribe or personal inducement;
4.2.6 Assist in an investigation, as and when necessary; and
4.2.7 Read this policy carefully and to familiarise themselves with the requirements.

5. Bribery and Corruption
5.1 DiaMatrix does not permit Bribery and Corruption regardless of the form or manner.
5.2 DiaMatrix does not permit facilitation payments, regardless of value.
5.3 Clients and End-Users must not offer or accept Bribes or Facilitation Payments or engage in Corrupt Activities in dealings with DiaMatrix.
5.4 The following are examples of frequent high-risk areas that require careful attention:
5.4.1 Facilitation payments:
5.4.1.1 Facilitation payments (regardless of value) are a form of bribery and ordinarily involve a payment made to a public or government official to expedite or facilitate a result or an administrative process; and
5.4.1.2 Facilitation payments are prohibited in many countries and as such are not permitted by DiaMatrix.
5.4.2 Donations:
5.4.2.1 DiaMatrix does from time to time make donations to worthy causes or as part of its corporate social investment programme; and
5.4.2.2 Donations may only be made in accordance with applicable policies as prescribed.
5.4.3 Sponsorships:
5.4.3.1 DiaMatrix grants corporate sponsorships on occasion to entities or events that enhance its reputation or promote business development;
5.4.3.2 All sponsorship and applications for sponsorships are made in accordance with the rules and procedures as prescribed; and
5.4.3.3 Employees should be wary of giving sponsorship to entities associated with political parties, trade unions, regulatory bodies, supplier or customer bodies.
5.4.4 Dealing with Third Parties and Cross Border Dealings:
5.4.4.1 Employees, Clients and End-Users must exercise diligence when conducting business with third parties, especially those from foreign countries; and
5.4.4.2 Employees, Clients and End-Users must ensure their third-party or cross-border dealings do not involve bribery, corruption, or Sanctioned entities.
5.4.5 Politically Exposed Persons (“PEPs”):
5.4.5.1 PEPs are individuals who are or have in the past been entrusted with prominent public functions in a particular country. Due to this, PEPS are considered high risk and therefore an enhanced due diligence should be conducted when dealing with them; and
5.4.5.2 Employees, Clients and End-Users acknowledge that enhanced due diligence or background checks are required when dealing with PEPs due to their high-risk nature.

6. Incident Reporting
6.1. All employees within DiaMatrix have a duty to immediately report any Bribery, Corruption or violations of Sanctions Laws that is suspected or discovered. Employees can report possible corrupt activity directly to the fraud manager or their line manager; and
6.2. Clients and End-Users should immediately report any Bribery, Corruption or violations of Sanctions Laws that is suspected or discovered and can be reported directly to the following email address: abuse@domains.co.za.

7. Sanctions Compliance
7.1. DiaMatrix complies with all relevant Sanctions laws in the countries where we operate.
7.2. Sanctions place restrictions on dealings with certain countries, governments, groups, entities, individuals, or controlled goods/services.
7.3. DiaMatrix complies with all economic and trade Sanctions applicable to our business activities.
7.4 Client and End-User Obligations:
7.4.1 Clients and End-Users must not engage in transactions or dealings with Sanctioned countries, entities, or individuals;
7.4.2 Immediately disclose to DiaMatrix any knowledge or suspicion of transactions involving a Sanctioned person, group, or country;
7.4.3 Ensure that no goods or services are procured from suppliers on a country Sanctions list;
7.4.4 Seek advice and guidance from DiaMatrix on the impact of Sanctions on their business or if there are concerns about a particular transaction or supplier; and
7.4.5 Not engage in any action that would cause DiaMatrix to violate any Sanctions Laws.
7.5 Employees Obligations:
7.5.1 To ensure that no goods or services are procured from suppliers on a country Sanctions list;
7.5.2 To disclose any knowledge or suspicion of a transaction involving a Sanctioned person, group or country to risk and compliance services; and
7.5.3 Seek advice and guidance from Risk and Compliance Services about the impact of Sanctions on the business or if any employee has any concerns about a particular transaction or supplier.

8. Due Diligence
8.1 Clients, End-Users and Employees must conduct appropriate due diligence or background checks on their customers, suppliers, and third parties to ensure compliance with Sanctions laws.
8.2 Clients, End-Users and Employees must immediately report any red flags or suspicions that may indicate the involvement of a restricted territory or party. Red Flags are indicators that suggest the possibility of bribery, corruption, or Sanctions violations. Examples include unusually high commissions, lack of transparency in expenses, and business with entities in high-risk jurisdictions.

9. Non-Adherence to Policy
9.1 Non-compliance with this policy can result in termination of services, business relationships and reporting to external regulators. DiaMatrix may take civil and/or criminal action against non-compliant Clients or End-Users.
9.2 Any employee or relevant person who is involved in or assists with committing a corrupt act and fails to comply with internal policies, procedures and any other regulatory requirements, whether knowingly, negligently or recklessly, will be subject to disciplinary procedures. Involvement in corrupt acts is a dismissible offence for employees under the applicable disciplinary codes.

10. Policy Update.
10.1 This policy is reviewed and updated annually. The policy can be found on the Website or can be requested.

11. Indemnification
11.1 The Client, End-User and Employee agree to indemnify, defend, and hold harmless DiaMatrix, its affiliates, officers, directors, employees, agents, and representatives from and against any and all claims, liabilities, damages, losses, costs, and expenses, including reasonable attorneys' fees and expenses, arising out of or related to:
11.1.1 The Client’s or End-User’s use of DiaMatrix’s products or services;
11.1.2 Any breach of this Policy by the Client or End-User; and
11.1.3 Any violation of applicable laws, regulations, or third-party rights by the Client or End-User.

12. Policy Queries
12.1 For any queries regarding this policy, please contact us at abuse@domains.co.za
12.2 Reviewed and approved in February 2025