IMPARTIALITY POLICY

1. Policy Statement

1.1 We shall ensure that our shareholders, directors, management and all internal personnel understand and, by way of legally enforceable agreements which binds them to our Code of Conduct, are committed to:

1.1.1 The principles and mechanisms designed to implement and verify all seven elements of Broad-Based Black Economic Empowerment, with particular emphasis on:

• 1.1.1.1 Objectivity;
• 1.1.1.2 Independence;
• 1.1.1.3 The disclosure of conflicts of interest and any other commercial, financial or other pressures which might pose a threat to their impartiality;
• 1.1.1.4 Lack of bias and prejudice and the maintenance of neutrality;

1.1.2 Conducting BBBEE verification exercises fairly and openly, with detachment and balance, in line with recommended best practices set by the industry.

1.2 The composition, terms of reference, duties, authorities and responsibilities of our analysts and verification managers shall be formally documented and shall be authorised by the Managing Director.

1.3 All personnel shall have access to the information necessary for them to perform their duties and functions. Access to information will be regulated by the Managing Director to ensure the confidentiality of clients and the impartiality of our personnel.

1.4 Our personnel shall be recruited in order to represent a balance of interests so that no single interest predominates.

1.5 We undertake not to allow any consultancy body from stating or implying that the ratings service provided by Honeycomb is simpler, faster or less expensive than any of its competitors nor will we state or imply that, if a particular consultancy is used, a BBBEE verification would be simpler, faster or less expensive.

1.6 Honeycomb will not provide both BBBEE verification and BBBEE consultancy services to the same measured entity, unless a period of two years has elapsed following the end of such a BBBEE consultancy.

2. Reference

R47-02 Clauses 10.2.2, 10.2.3, 12.2 and 13.6
Procedure – HR/MPPR0/001