Our performance in 2009 - Sappi

As part of continuous improvement the company completed a review of the wording of the code
and communicated a new and revised version to all employees during 2008. The revised code
is also available on the company website.
Hotlines and follow up of tip-offs
‘Hotlines’ have been implemented for all the regions in which the group operates. This service,
operated by various independent companies, enables employees to report anonymously
environmental, safety, ethics, accounting, auditing, control issues or other concerns. The followup
of all reported matters is co-ordinated by group internal audit. Matters are resolved
appropriately and reported to the audit committee. Of all complaints reported to the Hotlines
since inception none included fraudulent financial reporting. As the company is listed on the
NYSE and has securities registered under the US Securities Exchange Act of 1934, it is subject
to the US Foreign Corrupt Practices Act (FCPA). The company has ensured that all aspects of
the FCPA have been addressed in its policies.
The pie chart alongside sets out the type of tip-offs received.
There is approximately an even split between allegations that prove founded on investigation and
those where no action is taken as the allegation is unfounded or the evidence available is
inconclusive.
Refer to the pie chart alongside which depicts an analysis of case outcomes during the
2009 financial year.
Legal compliance programme
2009 annual report 81
A legal compliance programme designed to increase awareness of, and enhance compliance
with, applicable legislation is in place. This programme involves the delegation of responsibility
for compliance with country specific legislation to designated people throughout the organisation
and includes a periodic self-assessment process. The self-assessment process includes a review
of any changes in legislation and the impact of these changes on the business. The group
compliance officer reports quarterly to the group audit committee.
IT governance
The need for strong IT governance has been recognised within Sappi and as such the group is
actively involved in reviewing and implementing improved IT governance structures. IT governance
represents one of the pillars of the IT strategy and Sappi adheres to industry recognised best
practices as laid down by the IT governance institute and more specifically the new standard for
governance ISO/IEC 38500. IT governance will be included on the board agenda and will be
subject to audit committee oversight in 2010 in line with King III Report recommendations. The
establishment of an IT steering committee is envisaged for 2010.
Interest in contracts
The group has a policy regulating disclosure of interest in contracts. The policy dictates that all
employees disclose any interest in contracts to assess any possible conflict of interest. The policy
also dictates that directors and senior officers of the group must disclose any interest in contracts
as well as other appointments to assess any conflict of interest in fiduciary duties. During the
year under review, save as disclosed in the financial statements, none of the directors had a
significant interest in any material contract or arrangement entered into by the company or its
subsidiaries.
Insider trading
The company has a code of conduct for dealing in company securities. No employee of Sappi
in possession of material non-public information in respect of Sappi Limited or any of its
subsidiaries, nor any member of his/her family or household may, at any time, buy or sell securities
of Sappi Limited or its subsidiaries, or engage in any other action to take advantage of such
information. All officers, directors and employees who have access to unpublished price-sensitive
information are precluded from trading in Sappi Limited securities during ‘closed periods’, which
governance