Ethical governance

We have several policies and frameworks to ensure ethical governance throughout the JSE Group. Please refer to our Human Resource compliance declaration for more details.

As a Financial Market Infrastructure, we are required to implement appropriate arrangements to avoid, eliminate, disclose and otherwise manage possible conflicts of interest between our functions as the regulator of issuers and markets and our commercial services.

This includes identifying possible conflicts of interests, and how to avoid, eliminate, manage or disclose or these conflicts. The conflicts of interest policies for the Issuer and Market Regulation divisions are published on the JSE website.

At all Board and committee meetings, directors must table any changes to their directorships and declare any conflicts of interest they have encountered or anticipate.

Our JSE dealing policy prohibits directors and employees from trading in our shares during closed periods when they could be privy to price-sensitive information. Trading in our shares is permitted during two limited open periods. This is immediately following the release of the annual financial statements and the interim financial statements. A director must obtain written permission to trade in our shares from our Chairman, and the Chairman must obtain permission from the lead independent director. 

The dealing policy also governs the trading by directors and employees in all JSE-listed securities. Employees need to receive written approval from their relevant executive head and the director for market regulation before trading in these securities. Employees in specific divisions, such as Market Regulation and Issuer Regulation, cannot trade in any JSE-listed securities due to their ongoing exposure to non-public company information.

We have a strict zero-tolerance approach to unethical conduct, and do not engage in, accept or condone any illegal acts. This includes, among others, any form of bribery, facilitation payments, political donations or any corrupt practices in the conduct of our business.

The Board’s policy is to actively pursue and encourage the prosecution of the perpetrators of fraudulent and other illegal activities.

Actual or potential breaches can be reported through our whistle-blower hotline.

The JSE Ombud Scheme is recognised in terms of section 194 of the Financial Section Regulation Act, as an industry ombud scheme. The rules of the JSE Ombud Scheme regulate the resolution of complaints and disputes between authorised users and between authorised users and their clients. The governing body of the scheme is the JSE Exco. 

The scheme allows the JSE to facilitate the resolution of complaints that are made by or against clients and authorised users in a timely and cost-effective way and reduces the need for either party to resort to formal legal proceedings.