Compliance Framework

Naspers has established a legal compliance programme formalising practices followed for some time. The programme involves preparing and maintaining inventories of material laws and regulations for each business unit, implementing policies and procedures based on these laws and regulations, establishing processes to supervise compliance and mitigate risks, monitoring compliance, implementing effective training and awareness programmes and reporting to the various boards and management on the effectiveness of these efforts.

The compliance programme is managed by the general counsel, André Coetzee, acting as the chief compliance officer, while implementation at each business unit is undertaken by a local compliance officer and compliance committee. Each local compliance committee reports to the chief compliance oficer who, in turn, reports to the relevant risk committees.

Litigation in the business units is reported monthly by the respective heads of legal affairs to the general counsel, but material litigation is notiied to the general counsel as soon as possible after it arises. The general counsel, in turn, reports regularly on material litigation to the applicable boards and risk and audit committees.