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APNASPENAspen Pharmacare Hldgs19678275 (1.42%)

Aspen is in a closed period from 1 January until the publication of our interim results on the JSE SENS platform to be released on 4 March 2024.

Ethics & Compliance Management

Our Commitment to Acting with Integrity

“A bright future beckons. The onus is on us, through hard work, honesty, and integrity, to reach for the stars. ” – Nelson Mandela

As we navigate the dynamic business landscape as a leading multinational pharmaceutical company, I want to take a moment to underscore the importance of Integrity as the guiding principle that underpins our actions, decisions, and behaviour.


In practical terms, Integrity means that our actions are guided by the following principles:


  • Honesty: We are truthful and transparent in our dealings with others.

  • Ethical Behaviour: We adhere to a set of moral principles and standards and make decisions that align with these principles.

  • Consistency: We are consistent in how we approach decisions or respond to situations.

  • Accountability: We take responsibility for our actions and decisions, acknowledge our mistakes, and learn from them.

  • Leading by example: We each recognise our own responsibility to set a positive example of honesty, fairness, and respect, thereby actively contributing to a strong ethical culture.

  • Trustworthiness: We build and maintain trust so that others can rely on us to honour our commitments.

  • Respect for Others: We treat others with respect and fairness, we value diversity, and we uphold human rights.

  • Long-Term Perspective: We recognise that some decisions may not offer immediate gains but contribute to long-term positive outcomes. We do what is right, even if it’s not the easiest or most convenient option.


My expectation is that Aspen’s employees and business partners exemplify these principles in their daily interactions and decision-making. This embodiment will not only shape a culture and reputation that we can be proud of, but it will also drive Aspen towards a sustainable future and have a profound impact on society as a whole.


Kind regards
Stephen Saad
Aspen Group Chief Executive
August 2023
Tip-Offs Anonymous Hotline

Aspen endeavours to promote a culture of openness and transparency throughout the Group. Employees and other stakeholders are encouraged to report unethical conduct and any transgressions of which they become aware.

An independently monitored whistleblowing hotline, Deloitte’s Tip-offs Anonymous, is available to employees across the Group’s businesses, whereby employees can report suspected fraud and/or activities which are considered to be transgressions of the Group’s Code of Conduct. Tip-offs training and awareness sessions are conducted periodically to promote use of the facility where necessary.

The Tip-offs service has also been extended globally to customers and suppliers of Aspen’s businesses.

All logged calls are reported to Aspen’s Group Ethics Committee for consideration. Where wrongdoing, unlawful conduct or a breach of Aspen’s policies or procedures is identified, corrective action is implemented in all instances to improve controls and to prevent recurrence of the incident.

The PDFs below provide additional information required to raise any concerns about unethical behaviour at Aspen.

Code of Conduct

The Group Code of Conduct governs the conduct of all Aspen’s employees throughout the Group and is aligned with the Organisation for Economic Co-operation and Development recommendations regarding corruption. Furthermore, Aspen’s service providers and suppliers are required to adhere to the Group’s Code of Conduct in accordance with relevant clauses included in agreements with these stakeholders.

The areas covered by the Group Code of Conduct include:

  • acting in accordance with Aspen’s values;
  • equitable treatment for all;
  • acting as ambassadors of Aspen;
  • business integrity;
  • gifts;
  • entertainment and bribery;
  • integrity of qualitative and quantitative information;
  • protection and use of property;
  • business controls;
  • confidential information;
  • insider trading;
  • safety, health, quality and the environment;
  • competition law;
  • political activities;
  • compliance;
  • accountability; and
  • corporate governance.

In line with King IV recommendations, a formalised ethics management programme has been initiated at all of the Group’s businesses. This programme is managed by the Group Governance Officer under the direction of the Social & Ethics Committee and is aimed at:

  • assisting the Audit & Risk Committee and the Social & Ethics Committee in assessing the Group’s ethics profile, risks and opportunities; and
  • assisting the Social & Ethics Committee to monitor implementation and compliance with the Group’s policies which guide expected ethical behaviour.

Aspen’s induction programme educates new employees on the ethics, values and the business philosophy of the Group. All new employees are given a copy of, and are required to sign an acceptance of, the Code of Conduct on commencement of their employment with the Group. The Code of Conduct is available to all employees on the Group’s intranet and is also contained in the employee handbook.

The Group conducts its business in a highly regulated environment, however, one in which the potential for unethical marketing and promotional practices remains inherent. Aspen endorses the ethical marketing of medicines and subscribes to the rigorous application of the Marketing Code of Practice of the Pharmaceutical Industry Association of South Africa. The Group has a written policy on gifts and benefits in terms of which employees of the Group, including directors, are prohibited from accepting or giving gifts or hospitality that are not of a nominal value or participating in events sponsored by current or prospective customers or suppliers. Any employee who receives a gift or other benefit exceeding the local currency equivalent of USD100 is required to disclose this in writing to the Company Secretary. Some types of gifts, benefits or entertainment are prohibited even if the value falls below this threshold. A Group-wide register of gifts is maintained by the Company Secretary and is noted by the Social & Ethics Committee on a periodic basis. This register is also made available for inspection by the Board or any member of senior management on request.

Aspen does not make payments or other contributions to political parties, organisations or their representatives or take part in party politics. Employees are free to participate in the political process in their private capacity provided it does not constitute a breach of the principles set out in the Code of Conduct and/or the relevant employee’s obligations to Aspen under contracts of employment and does not negatively influence their productivity or the credibility of the Group.

Conflict of Interest

The Board has adopted a formal policy to regulate conflicts of interest and trading in the Company’s securities. The latter policy, which incorporates the requirements of the JSE Listings Requirements and the Securities Services Act, 2004 (as amended), prohibits any trade in the Company’s shares by any director or employee of the Group during a closed period. The Group currently has two formal closed periods, commencing 24 hours prior to the close of the interim reporting period (31 December) and the financial year-end (30 June) up to the end of 24 hours after the respective results announcement is made. In addition, the Group may declare other closed periods or restrict dealing in the Company’s shares at any other time if directors and employees have access to potentially price-sensitive information which is not in the public domain. At all other times, directors (including directors of any of its material subsidiaries) and the Company Secretary may only trade with prior written approval from the Chairman. Such approval is sought and co-ordinated through the office of the Company Secretary An announcement of all directors’ share dealings is published in compliance with the JSE Listings Requirements.

Responsible Supply Chain

In executing our business strategy, we engage with an extensive network of material suppliers, service providers, contract manufacturers, distributors and other business partners (collectively “Suppliers”). Ensuring our goods and services are ethically and responsibly sourced is paramount to our responsible corporate citizenship philosophy. We aim to only work with Suppliers whose values and standards of ethical behaviour are consistent with our own.

The Aspen Code of Conduct for Suppliers and Service Providers (“Aspen Supplier Code of Conduct”) was developed to articulate the ethical, social and environmental performance standards we require from all Suppliers that we have a relationship with. Our approach to maintaining a responsible supply chain includes risk assessment and mitigation, as well as participation in industry collaborations that improve supply chain environmental, social and governance (ESG) practices, such as the Pharmaceutical Supply Chain Initiative (PSCI).

Click to Download:

Supplier Code of Conduct 
Responsible Supply Chain Position Paper

Use of Animals in Research

Medicines and vaccines
The development of vaccines is a complex process that involves many stages throughout the lifecycle of the vaccine. This includes animal experiments in some cases. National and global laws require that new medicines are tested on animals before being licensed for use.
Mice, rats, fish, primates and rabbits are used for this purpose.
Aspen Policy on animal testing
We promote a thorough ethical review of research projects. We promote how to use the 3Rs (replacement, reduction, refinement) to their max potential and to reduce animal use in medical research.
The 3Rs:
  • Replacement. Methods that avoid or replace animal use.
  • Reduction. Make sure that the minimum number of animals is used for the test. Using proper test design and review for correct numbers and avoid wasting animals.
  • Refinement. Reducing suffering and improving welfare throughout animals' lives. This includes procedures, housing, husbandry and care.
We carry out this work with:
  • Government officials
  • Scientists
  • Accredited laboratories
  • Animal welfare groups

Group Statement on Modern Slavery

This statement provides insight into Aspen’s governance approach, risk assessment and mitigation strategy in relation to modern slavery and is aligned to our commitment to respecting human rights and the global legislative framework on modern slavery, including the UK Modern Slavery Act and the Australian Modern Slavery Act.

Aspen Group companies rely upon this statement, where necessary, for satisfying the disclosure requirements of the abovementioned laws, and any equivalent laws in the jurisdictions in which Aspen operates.


Integrated Reporting

Integrated Reporting Suite


Supplementary Documents

Integrated Reporting Suite


Supplementary Documents

Integrated Reporting Suite


Supplementary Documents

Integrated Reporting Suite


Supplementary Documents

Closed Period

Aspen is in a closed period from 1 January until the publication of our interim results on the JSE SENS platform scheduled to be released on 1 March 2023.

The live presentation will take place in Cape Town at 08h30 on 2 March 2023.