(“ACI/the company”)



All parties contemplating any contact with ACI are entitled to know in advance its ethical and moral attitudes to conducting business. This Code attempts to provide this information as simply as possible.


This Code applies to all the ACI activities.


All business entities of ACI, its directors, officers, employees and direct representatives are expected to abide by this Code.

Our Core Values

Our core values are:

  • INTEGRITY – to be accountable for our actions, to be consistently fair to others and to be truthful, and respectful.
  • HONESTY – to be reliable, approachable, sensitive to the needs of others, open and honest.
  • TRUST – to be trustworthy in our dealings and interactions with all stakeholders.

These core values are supported by the following:

  • Competency – to develop our skills and abilities, to be effective, efficient and innovative.
  • Cooperation – to work together, to share information, knowledge and resources and to complement overall team and organisational performance and objectives.
  • Commitment – to be committed to our respective jobs, customers and other stakeholders.

Our approach to business ethics

  • We will operate and compete in accordance with the principles of free enterprise and free economies. Free enterprise is, however, constrained by observance of the law (national, supranational and international) and by generally accepted principles governing ethical behaviour in business.
  • Ethical behaviour is founded on the concept of utmost good faith, and characterised by integrity and reliability.
  • Ethical business transactions will benefit all relevant parties by a fair exchange of value or satisfaction of need. The creation and enjoyment of profit is both a legitimate component of this exchange and an incentive to continue in business.
  • Other than the observance of legal and ethical commercial practices, we expect no favours from our competitors, nor should they expect any from us.
  • We expect equivalent standards of ethical behaviour from those with whom we deal.
  • It is incumbent upon us to strive for excellence in our ethical standards, as in any other aspect of our activities.
  • We will at all times adhere to the principle of sound corporate governance and “ZERO TOLERANCE” of fraud or corruption in our business.

The ACI vision for Ethics

For ACI to be regarded as ethical, we will strive towards a shared commitment to the same vision and principles, and behave according to the same ethical standards.

The ACI Code of Business Conduct and Ethics incorporates our core values (INTEGRITY, TRUST and HONESTY) to describe our relationships with our stakeholders (the State, our clients, our shareholders, financial advisers, our employees and our suppliers and the public), focusing on our obligations to stakeholders, and not on rights. We will strive at all times to fulfil these obligations.

Our Obligations

We recognise that we have a number of obligations towards various stakeholders. We also recognise that at times our obligations towards different parties may conflict, and that it is our responsibility to seek appropriate harmony and balance between the parties’ interests.

The State

We will:

  • Obey the law.
  • Cooperate with all supervisory and regulatory bodies duly appointed for our industries.
  • Contribute to the development of the nation and its people, and cooperate with any reasonable government initiative that has this aim.
  • Exercise judiciously any power or influence which we hold.

Our Clients

We will:

  • Honour our contractual obligations.
  • Develop long-term business relationships.
  • Train employees and representatives to be proficient and professional.
  • Deal with our clients in mutual confidence, and ensure that access to confidential information is appropriately restricted.
  • Provide and participate in effective mechanisms to resolve any disputes or difficulties.

Our Shareholders

We will:

  • Acknowledge our shareholders’ entitlement to a reasonable return on their investment.
  • Communicate with shareholders regularly, clearly and honestly.
  • Safeguard the business and its assets. We fully subscribe to the principles of sound corporate governance and zero tolerance. We will apply appropriate internal operating and financial controls.
  • Cultivate a positive public image founded on truth and fairness.

Our Employees

We will:

  • Treat our employees with due dignity, respect and courtesy.
  • Not discriminate unfairly on the grounds of race, gender, sex, ethnic or social origin, color, sexual orientation or age.
  • Remunerate our employees fairly, according to their contributions, their market value and their potential.
  • Provide training and development opportunities appropriate to their needs, ambitions and abilities and in line with the requirements of the Group.
  • Take appropriate measures to improve the prospects of historically disadvantaged employees.
  • Provide a safe working environment.
  • Expect all our employees and representatives to honour the provisions and spirit of this Code of Business Conduct and Ethics in the course of their employment.

Financial Advisers

We will:

  • In all respects deal with our financial advisers fairly.
  • Pay promptly for services in accordance with our contractual obligations.
  • Not accept any financial or other inducements which could be perceived to impair our judgment of the terms on which we conduct business.
  • Provide training and awareness, where appropriate, to our staff to learn about the needs, ambitions and abilities of our financial advisers, in alignment with the company’s strategy.

Our Suppliers

We will:

  • In all respects deal with our suppliers fairly.
  • Pay promptly for goods or/and services delivered in accordance with our contractual obligations.
  • Not accept any financial or other inducements which could be perceived to impair our judgment of the terms on which we conduct business.
  • Provide training and awareness, where appropriate, to our staff to learn about the needs, ambitions and abilities of our suppliers, in alignment with the company’s strategy.

The Public

We will:

  • Communicate with integrity.
  • Not knowingly mislead in our advertising, marketing or selling.
  • Not abuse the public’s trust.
  • Recognise a commitment to corporate social responsibility and to the broader role of business in society.

Contravention and Remedies

Unethical behaviour at ACI will not be tolerated and will be dealt with consistently and decisively at all times.


AMENDED: January 2009

REVISED: June 2011

READOPTED: January 2022