Sasol’s Conflict of Interest Policy
We avoid conflicts with Sasol’s interests, and where it is impossible to avoid such conflicts of interest, we
declare and actively manage them.
Good business practice requires that employees and officials make fair and objective decisions in Sasol’s best
interests. Such decisions can only be made if the official or employee is not unduly influenced by personal benefit
or by benefits for relatives or other associates. In other words, conflicts of interest undermine effective decisionmaking.
The responsibility for evaluating, declaring and managing possible conflicts of interest lies with Sasol’s officials and
employees. All officials and employees, and the stakeholders they interact with, are expected to do the right thing
for the right reasons. Since it is not always easy to determine what the right action is, this policy provides
guidelines for the behaviours and actions that Sasol expects.
Sasol defines a conflict of interest as “a conflict b e t w e e n Sasol’s interests and the direct or indirect private interests
of a Sasol official or employee (or their close relatives), which could improperly influence, or be perceived to
influence, the performance of their official duties or responsibilities.”
A personal interest is generally only deemed to be in conflict with Sasol’s interests if it has the potential to
influence, or could be perceived to influence, a person’s decisions in their role and position in Sasol. A conflict of
interest typically arises when personal, financial or any other interests affect the objectivity and discretion of an
employee or official in performing their duties or making decisions in the best interests of the organisation. This
could also mean that an employee or director
is in a position to make or influence a decision that is not fair and objective in order to benefit personally or to
benefit their relatives or other associates.
There are three types of conflicts of interest:
 A direct conflict of interest – where a person is in a position to be influenced by their private interests when
doing their job.
 A perceived conflict of interest – where a person is in a position to appear to be influenced by their
interests when doing their job.
 A potential conflict of interest – where a person is in a position where they may be influenced in the future
by their private interests when doing their job.
Conflicts of interest are not limited to direct financial interests. They extend to accepting business courtesies,
private business interest in entities that might do business with Sasol, and affiliations with non-profit
organisations.
Officials and employees may not put themselves in a position where their personal interests conflict or could in
future conflict with Sasol’s interests. Where conflicts of interest or potential conflicts of interest cannot be
avoided or the official or employee wants to make a case for working within a situation that represents a potential
conflict of interest, the following procedure applies:
Any case that could represent a conflict of interests must be declared in writing. Officials or employees must obtain
prior written consent from their line manager who must be at least a level 4. If in any doubt as to whether or not
to grant consent, the manager should consult their line manager and ethics officer. In all instances managers must
inform their respective line managers and ethics officers of approvals granted.
An actual or potential conflict of interest should only be approved if:
 It is declared in writing and supported by a written risk mitigation plan and relevant controls.
 It can be responsibly managed without prejudice to the company.
 It is not ongoing.
 It is not in conflict with a material Sasol interest.
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Sasol conflict of interest policy
ethics
These approvals must be resubmitted a n d reviewed annually.
In all other instances where there is any doubt about the prudence of allowing a conflict of interest, the matter
should be referred to the relevant G EC member.
Directors and other officials required to do so by law must declare financial interest annually and at meetings
and when contracting in writing to the boards on which they serve. Declarations of interests required by law
must be recorded in the format required in terms of the applicable legislation (in South Africa Act No. 71 of
2008), and entered into the register managed by Company Secretariat.
All declarations of interests and conflicts of interest (approved and declined) required in terms of this policy, must
be recorded in the business unit registers managed by the respective ethics officers. Ethics officers must submit
these registers to their governance committees for noting. The registers will be made available to employees who
can demonstrate a legitimate business interest in their content.
In addition to getting approval for and declaring a conflict of interest, the official or employee is expected to declare
this conflict in every instance where it has relevance. They are also expected to refrain from participating in
business activities related to the declared conflict of interest, and substitute themselves with a more senior person
should only subordinates be involved. They are required to submit proof of these actions with every annual request
for approval of a conflict of interest.
Although the list is not exhaustive, Sasol deems the following likely to result in unacceptable conflicts of interest:
 Close relationships with people in entities with which Sasol does business and in reporting structures
within Sasol (eg, family members or friends reporting to one another). Such relationships include
family, close friendship and even common private club memberships (eg, leisure, sports or investment
clubs or joint property ownership etc).
 Activities that compete significantly for resources such as time and facilities. This could include non-Sasol
work (for gain or not for gain), positions and membership outside Sasol (eg, directorships, trusteeships,
public office etc), study activities unrelated to the work performed for Sasol, etc.
 Holding investments in businesses contracting with Sasol or competing with Sasol, whether the investor is
the employee, family members or close friends.
 Undue privilege derived by Sasol employees, family members or close friends as a result of being
party to valuable information, receiving or giving gifts or entertainment, being offered business or
other opportunities etc.