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South Africa * * * * T R A C E B o o k m a r k : C o v e r Due Diligence Report TRACE [email protected] TRACEcertification Due Diligence 151 West Street +1 410.990.0076 Report Annapolis, MD 21401 Page 1 of 280 What Does it Mean to be TRACE Certified? It means that an individual or company has completed a comprehensive due diligence process administered by TRACE, the world’s leading anti-bribery standard setting organization. Certification by TRACE signifies that an entity has completed internationally accepted due diligence procedures and has been forthcoming and cooperative during the review process. The successful completion of TRACEcertification demonstrates a commitment to commercial transparency, allowing the certified entity to serve as a valued business partner to multinational companies. TRACEcertification Report at a Glance Advantages of being TRACE Certified › Detailed company information, including › Gain a valuable compliance credential that information on subsidiaries and affiliated entities. differentiates you from competitors and is widely recognized in the international business community. › Business registrations, as applicable. Receive a copy of your verified due diligence report › Corporate literature or a company description. › to share with an unlimited number of existing and › Beneficial ownership (except for shareholders prospective business partners. owning less than 5% of publicly-traded companies). › Include your name, or company’s name, in the › Identification of directors and key employees. TRACE Intermediary Directory, a publicly searchable › Additional ownerships, directorships and database of potential business partners for employment of all owners, directors and key multinational companies. employees. › Train up to 40 employees using TRACE’s multilingual › Current government employment of owners, online training modules including: Anti-Bribery directors and key employees. Compliance, Avoiding Trafficked Labor, Conflicts of Interest and Conflict Minerals. › Contact information for three business references. › Display the TRACE logo in your marketing materials › One financial reference or audited financial and on your website to showcase your commitment statement. to transparency and supply chain integrity. › Media and litigation searches dating back seven › Attend TRACE Anti-Bribery Workshops at no cost. years in a comprehensive international database. › Denied party screening and two negative media searches. › Evidence of anti-bribery code of conduct and training. TRACEcertification is not a guarantee against past or potential wrongdoing by the certified entity or a guarantee against potential liability. A summary of any “red flags” identified during the TRACEcertification review will be included in the report, but not all red flags preclude TRACEcertification. About TRACE TRACE International and TRACE Incorporated are two distinct entities with a common mission to advance commercial transparency worldwide by supporting the compliance efforts of multinational companies and their third party intermediaries. TRACE International is a non-profit business association that pools resources to provide members with anti-bribery compliance support while TRACE Incorporated offers both members and non-members customizable risk- based due diligence, anti-bribery training and advisory services. Working alongside one another, TRACE International and TRACE Incorporated offer an end-to-end, cost-effective and innovative solution for anti-bribery and third partycompliance. For more information, visit www.TRACEinternational.org. Follow TRACE: Page 2 of 280 * * * * T R A C E B o o k m a r k : T a b l e _ o f _ C o n t e n t s * * * * T a b l e o f C o n t e n t s Table of Contents Due Diligence Summary 4 Business Information 7 Registration Information 9 Ownership Information & Board of Directors 21 Personnel 26 Name Confirmation Document 29 Resumes/CVs 31 Associated Offices & Entities 41 Other Engagements 49 Enforcement Information 51 Literature 54 Financials 93 Business References 144 Compliance Information 146 Reputational Screening 152 Additional Documents 260 Anti-Bribery Training 278 Sturrock Grindrod Maritime (Pty) Ltd certifies that the information provided in the following report is, to the best of its knowledge and belief, accurate, current and complete. Sturrock Grindrod Maritime (Pty) Ltd certifies that to the best of its knowledge, neither Sturrock Grindrod Maritime (Pty) Ltd nor any of its employees or third parties acting on its behalf have offered or given anything of value to a government official in order to obtain or retain business or receive an improper business advantage. Sturrock Grindrod Maritime (Pty) Ltd agrees to notify TRACE promptly of any material changes to the information provided herein. The person whose signature appears below is authorized to certify on behalf of Sturrock Grindrod Maritime (Pty) Ltd that the information is true and correct. Name: Clive James Date: 30 January 2020 Page 3 of 280 * * * * T R A C E B o o k m a r k : D u e _ D i l i g e n c e _ S u m m a r y | D u e D i l i g e n c e S u m m a r y Due Diligence Summary The TRACE due diligence review of com m ercial interm ediaries is thorough. The review m ay nevertheless fail to uncover inform ation which, if available, would have discouraged or prevented com panies from entering into a business relationship with the interm ediary. Com panies requesting TRACE Reports agree that in no event shall TRA CE be liable for any dam ages incurred as a result of relying on TRACE Reports or as a result of any om ission or m isrepresentation by an interm ediary reviewed by TRA CE. This report contains personal inform ation about individuals that is subject to strict legal protections under applicable data protection laws. You m ay only review this report or such personal inform ation if you are appropriately authorized and have a need to know, to access or to otherwise process such inform ation. This report is for the internal use of the requesting com pany only; it m ay not be sold or transferred in whole or in part. You m ust exercise due care in safeguarding this inform ation and take all necessary steps to prevent any loss, theft, corruption or release of this inform ation to unauthorized persons. If you have any questions or concerns regarding these obligations, contact TRACE's Data Protection Officer at [email protected]. Page 4 of 280 Due Diligence Summary Sturrock Grindrod Maritime (Pty) Ltd TRACEcertification ID: TC5152-4203 15 December 2019 - 14 December 2020 Due diligence is not a guarantee against past or potential wrongdoing or against potential liability. Depending on the nature, size, scope and location of the proposed project with an intermediary, more extensive due diligence may be warranted. The following "red flags" or significant areas of concern were identified during the due diligence review: Disclosed intention to work with a third party intermediary See Personnel and Associated Offices & Entities. Owned by, or receives funding from, a government entity Indirectly owned by Government Employees Pension Fund. See Ownership information and Board of Directors. Financial Findings The financial document indicates a loss in 2018. See Financials. Negative Reputational Screening coverage See Reputational Screening Summary and Results from 2015, 2017 & 2020. Reputational Screening coverage See Reputational Screening Summary and Results from 2015. Due diligence undertaken by TRACE International or TRACE Inc. shall not be used to support or promote business in Iran or other sanctioned countries. Page 5 of 280 South Africa Overall Risk Score: 42 Risk Level: medium This score is a composite of the four domain scores discussed below, which are weighted and combined to produce the overall country risk score. Each country is given a score from 1 to 100 for each domain and for the total bribery risk. A higher score indicates a higher risk of business bribery. Assessments of whether a given domain score is “good” or “poor” are made relative to all other jurisdictions within that domain. 1. Business Interactions with Government: South Africa receives a medium score of 65 in this domain, based on a high degree of government interaction, a medium expectation of bribes, and a high regulatory burden. 2. Anti­bribery Deterrence and Enforcement: South Africa receives a good score of 33 in this domain, based on a high quality of anti­bribery dissuasion and a medium quality of anti­bribery enforcement. 3. Government and Civil Service Transparency: South Africa receives a good score of 24 in this domain, based on good governmental transparency and good transparency of financial interests. 4. Capacity for Civil Society Oversight: South Africa receives a good score of 27 in this domain, based on a high degree of media freedom/quality and a medium degree of civil society engagement. Total Score 42 Opportunity 65 Deterrence 33 Transparency 24 Oversight 27 0 20 40 60 80 100 TRACE Bribery Risk Typology: Democracy with simpler economy This group is typified by stable democratic Comparable Jurisdictions Matrix Scores government and an economy largely built on the export of a limited number of simple Jamaica 41 products. Dominica 42 Marshall Islands 42 Learn more about the TRACE Bribery Risk Matrix and Bribery Risk Typology at matrixbrowser.TRACEinternational.org © 2019 TRACE International, Inc. All rights reserved. Page 6 of 280 * * * * T R A C E B o o k m a r k : B u s i n e s s _ I n f o r m a t i o n | Q u e s t i o n S e c t
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