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COMPANY POLICIES
Business Code of Conduct - To be signed by all Employees
MPMR's reputation is one of its most important assets. We want to build our mutual relationship based on values of integrity, transparency and a flawless ethics. We strongly believe that ethics and commercial activity are inseparable.

MPMR's mission is to make sales growth and profits its priority in the long run, by offering high-quality products and services through innovation thereby becoming our customers' preferred choice.

The purpose of this Business Code of Conduct is to provide each employee of MPMR with a proper understanding of our standards and code of conduct for our business and our relationship with partners, vendors and statutory governing bodies of Tanzania (third parties).

Each of us has the responsibility and the obligation to uphold the spirit of the applicable laws to the letter, as well as the rules outlined in the Code of Conduct below.

Introduction

The purpose of the policy and practices implemented by MPMR is to ensure a high level of ethics and standards, to comply at all times with applicable legislation, laws, and standards while functioning internally as a company and when dealing with third parties without compromise.

This Code is applicable to all business divisions and branches, all subsidiaries, our partners, and any other entities over which MPMR has control.

This code applies to all employees, managers and directors all of whom shall sign this without exceptions.

We will make sure that all MPMR staff are correctly integrated and respect the various components of the Group's policy, as well as the rules in force, via regular communication and appropriate training.

Financial and Accounting Documents - Registration and Information Management

All company assets and transactions must be correctly and properly registered. The entries must be made in accordance with the policy of MPMR and the accounting standards and practice in force.

Reports and operational accounts must be reliable, honest, accurate, complete, up-to-date, and in compliance with applicable standards and regulations.

Financial Transactions - All payments of goods and services must be made directly to the supplier. No payment to a third party acting in a fiduciary capacity on behalf of a customer or supplier will be accepted. No payment in cash will be accepted or made.

Employee relations

MPMR will treat its employees in a respectful and dignified manner, and ensure that they do not suffer any abusive or indecent treatment in their workplace, including sexual harassment, sexual abuse, physical or verbal abuse, and have no fear of undergoing such treatment.

No form of harassment at the workplace will be tolerated.

Non-discrimination

With regards to differences, MPMR offers a workplace free from harassment and discrimination. Discrimination on grounds such as sex, race, religion, age, disability, or any other condition that may give rise to discrimination is excluded.

Equal opportunities

Internally, equal opportunities in terms of job, pay and career advancement are granted to all (men and women). Our Equal Opportunity Policy states that recruitment, training and potential promotions are evaluated based on the professional skills, competency, behaviour and performance of the employee or external candidate.

Freedom of association and right to collective bargaining

Employees, without distinction, have the right to join or create a union of their choice and to participate in collective bargaining in accordance with the Laws of the land .

MPMR shall adopt an open attitude towards trade unions and their organizational activities, and ensure that workers' representatives and any staff members involved in the formation of a workers' union are not subject to discrimination, harassment, intimidation or retaliation for membership of a trade union.

Child labour - in line with ILO Convention No. 182

MPMR does not and will not employ children under 15 or under the legal minimum age, whichever is higher. MPMR does not and will not employ minors (under the age of 18) to perform work that is hazardous to health, safety or morality.

Use of company property and resources

The use of the Company's property and resources must be for professional purposes only. They must therefore be returned to the company at the end of the permitted professional use.

Human rights

MPMR endorses and supports the basic principles outlined in the United Nations Declaration of Human Rights and as replicated under the constitution of the United Republic of Tanzania.

Health - Safety and Work Environment

Violence: MPMR is committed to providing its employees with a safe work environment free from violence. No aggression or threat, no violent behaviour of either a physical or verbal nature will be tolerated.

Use of weapons: The possession of firearms or the possession of any other type of weapon within the premises of the MPMR site is strictly prohibited (with the exception of officially designated Security officers).

Prohibited substances: Consumption of alcohol, drugs or any other toxic product is strictly forbidden in the workplace. Any use of these substances by an employee within the company premises or any persistent effects of these substances upon arrival at work may lead to disciplinary action against the employee concerned, including possible dismissal.

Health and Safety: MPMR is committed to providing employees, contractors and temporary staff with a healthy work environment and providing appropriate protective equipment whenever required or necessary. The company's policy is to comply with health and safety regulations and laws. MPMR strives to restrict potential hazards and prevent workplace accidents and occupational illnesses.

Environment

MPMR is aware of the impact of its various activities on the environment. MPMR's policy is to work towards a constant improvement of its environmental performance and thus to limit potential risks in this area. This includes constant efforts to optimize the consumption of energy and raw materials such as chemicals or water and the installation of suitable storage devices for hazardous products and the control of waste and chemical-induced emissions.

Relations with shareholders

MPMR conducts business in accordance with internationally accepted principles of corporate governance. We will therefore provide timely and reliable information about our business, structure, financial position and performance to all shareholders.

Relations with business partners

MPMR is committed to providing our customers with the best possible quality of our precious metal products and services through innovation and an efficient delivery system. All business partners will be treated fairly and in full compliance with the law.

MPMR's policy is to treat its trading partners, regardless of the partner or the situation, in a fair way, without abusing its position in the market.

Conflicts of interest

Conflicts of interest between MPMR and its customers or suppliers and those of employees should be avoided. MPMR employees (with the exception of shareholders and investors) shall not have any outside commercial or financial interest with a supplier, customer or another third party that could create a conflict or appearance of conflict with the interests of the company or alter the judgment of the employee, acting on behalf of the company.

Confidential Information

No confidential information relating to the company, its customers, suppliers or any other business partner may be disclosed or used by MPMR employees, outside of a professional setting or for personal enrichment, whether during or after the contract period. If information is to be disclosed, all necessary measures must be taken to protect its confidential nature.

No employee at MPMR Plant irrespective of his designation or position ( with the exception of shareholders of MPMR) will be allowed to photograph operations or carry data out side the refinery.

No laptops and USB storage devises will be allowed into and shall not be used in the Refinery. All back ups for data shall be done on designated hard disks kept in the safe custody of the Refinery General Manager.

Relations with competitors

MPMR believes in free and open competition in the markets and will in all circumstances respect the competition laws in Tanzania where the company has commercial activity. We will pay particular attention to our relations with our competitors and we refuse to engage in reprehensible or unfair actions.

While we recognize the importance of gathering information on the state of the markets and our competitors, we are committed to prohibiting any collection of information about competitors that would be in contradiction with our ethical principles and the regulations in force.

Internal information

MPMR prohibits the use of internal information for personal purposes or the disclosure of internal information (commercial or financial) to any person outside the company or employed by MPMR, for whom the information would not be intended.

Illicit Payments

It is expressly forbidden to offer, solicit or accept from a customer or supplier, any type of illegal payment or commission such as: money, gift, advantage or privilege of value or any other type of compensation ( financial, material, etc.) so that a commercial negotiation involving the company MPMR, ends favourably, or in order to maintain a commercial relationship. It is strictly forbidden to make or offer, directly or indirectly, any type of illegal payment or commission such as: money, gift, advantage or privilege of value or any other type of compensation (financial, material, etc.) of any representative official (former public servant or politician) in order to influence a decision or obtain a contract, to obtain benefits or as a thank you.

Business gifts and invitations:

Gifts of symbolic value, marketing materials, hospitality and entertainment expenses are acceptable to the extent that they cannot be perceived as having the purpose of influencing a negotiation and are legally permitted.

Communication with third parties

Any request for information made to an MPMR employee from a person who is not yet identified as a customer or prospect, must be immediately forwarded to the General Manager who will immediately inform the Chairman / Chief Executive Officer and then to the Joint Management Committee (JMC). These requests for information include requests from government bodies, lawyers, journalists, legal entities, representatives of non-governmental organizations, or social organizations.

In particular, with respect to transactions involving precious metals where MPMR will only act if the transparency, legitimacy and non-violation of International Anti Money Laundering (AML) laws of the transactions are established.

We will strive to promote and apply a uniform code of professional conduct wherever we operate. However, we recognize that there are significant differences across the world in legislation and standards, and that a rigid code may not be appropriate for all situations without compromise of principles of International ethical conduct.

Relations with third parties in politically sensitive countries/Economic sanctions

We also recognize that in some parts of the world governments are more fragile than others, that legal frameworks and ethical principles may be less developed, and that armed conflicts exist. It is absolutely inconceivable to engage in a commercial relationship that is the result of criminal activity, or one that involves criminal or terrorist groups and would, in turn, promote their funding. However, and in accordance with the guidelines issued by the United Nations, we will not impose embargoes on these regions, thus refraining from depriving these geographical areas of our technical and financial expertise and the opportunity to improve their situation through transparent and legitimate business activity. Instead, we will focus on the utmost diligence in maintaining this policy.

MPMR will comply wherever it operates, with economic embargoes and sanction programs that may be put in place.

Compliance

Respecting these principles and all the aspects of MPMR's policy stated above, is fundamental for our success. All employees must act in good faith, comply at all times with the highest standards and professional practices in carrying out business transactions on behalf of MPMR, and apply the above-mentioned rules of good conduct.

All employees should familiarize themselves with this Code of Conduct and with the national laws that apply to their area of activity, in order to comply with it. It is the responsibility of leaders in each country and each division to ensure that the activities are conducted by the employees reporting to them.

Any breach of this Code of Conduct will result in the application of disciplinary sanctions up to and including termination of employment / legal action with immediate effect.

How do I ask questions - what should I do in case of a Code violation?

No code of conduct can claim to respond to all situations. The purpose of this Code is to establish a corporate culture based on ethical values and to guide our professional conduct when new situations arise. It is important that when an employee is unsure of interpretation of a law, regulation or policy put in place by a competent authority or even one of the rules contained in this Code, that they discuss it with their superior, the head of the legal department or with the internal auditor.

Anyone with any doubt about a potential breach of this Code or about a situation that could be illegal or unethical, should report it to their supervisor or send a written mail to the General Manager of Refinery and copy the Joint Management Committee and the Chairman / CEO of Refinery.