Our performance in 2009 - Sappi

82 Corporate governance continued
apply from the end of the financial quarters in March, June, September and December
respectively, until two full business days after the release of the results for the respective quarters.
Prior to dealing in Sappi Limited securities (even outside closed periods), clearance is required
from the Sappi Limited chairman through the Sappi Limited group secretary. In practice, the
chairman clears the transactions of directors of Sappi Limited and its subsidiaries and the
chairman himself requires the clearance of the audit committee chairman for his own transactions.
Fraud and illegal acts
The group does not engage in or accept or condone the engaging in any illegal acts in the
conduct of its business. The directors’ policy is to actively pursue and encourage prosecution of
perpetrators of fraudulent or other illegal activities should they become aware of any such acts.
The group has implemented Hotlines to facilitate reporting any fraudulent, illegal acts or unethical
behaviour which are externally managed and administered. A web-based global facility was
implemented during 2009 to supplement the Hotlines. A fraud and irregularity policy is being
developed by management in discussion with internal audit.
Communication
The board is responsible for presenting a balanced and understandable assessment of the
company’s position in reporting to stakeholders. The reporting addresses material matters of
significant interest and is based on principles of openness and substance over form. We
recognise that the reporting and communication is made in the context that society now demands
greater transparency and accountability from companies regarding non-financial matters. The
board strives to ensure that reports present a comprehensive and objective assessment of the
activities of the company so that stakeholders with a legitimate interest in the company’s affairs
can obtain full, fair and honest information regarding its performance. The board takes cognisance
of the communities in which it operates when communicating to its stakeholders. As such the
annual report is seen as an integrated report as referred to in the King III Report. For further details
of our sustainability communication activities please refer to the sustainability report on pages
8 to 13.