Code of Ethics 2019-11-05T09:00:31+00:00

Code of Ethics

Infrastructure Commodities (Mauritius) Limited (ICML)

Code of Ethics



Vision: Infrastructure Commodities (Mauritius) Limited (ICML) will continue to manage a substantial asset base aggregated from a series of closed end funds in the mining industry which are currently illiquid but substantially due to unwind over the coming years.  In the meantime, the objective is to select, invest in and develop new clients in the infrastructure commodities sector globally but with particular attention to opportunities arising in the growing markets of Africa.

VALUES: ICML will operate in the long term interests of its shareholders to build value in existing assets and develop new profit generating opportunities within an ethical, environmentally and socially aware, proactive framework.  That framework, ICML Code of Ethics is outlined below and will be maintained prominently in the methods and processes of ICML doing business with clients, associates, contractors and in managing staff wherever they may be located round the world.

Client Focus: Our clients and their success are at the heart of our future success and our partnership with them to support and aid their success will be at the root of ICML’s success.

Innovation and Creativity: ICML encourages value creation and initiative from staff, clients, associates and staff that contributes positively to that process for clients and shareholders.

Responsibility: The Board and staff of ICL will always strive to take responsibility for their direct actions within the legal and social frameworks of the international jurisdictions they operate in around the globe.     ICML will also endeavour to influence and encourage clients to take a similar view of their responsibilities.

Quality: We understand the importance of performance and the trust our clients and shareholders place in us. With this in mind, we will strive for continuous improvement and respond vigorously to change.

Entrepreneurship: We will utilize our ability to combine strength with speed in responding, reviewing, analysing and confirming any proposed action to every new opportunity that we are presented with and each new challenge they represent.

Dedication: We will strive to be committed in everything we do, whether in providing the latest and best options and services to our clients, in delivering value to our shareholders or in contributing to the communities and environments in which we work globally.

Proactivity: Directors and staff at ICML will demonstrate individual leadership through a positive approach to every task, a “can-do” attitude to conduction our business.


As a business operating internationally and with shareholders from around the globe ICML seeks to embrace the UN Global Compact’s ten principles in the areas of human rights, labour, the environment and anti-corruption enjoy universal consensus and are derived from:

  • The Universal Declaration of Human Rights
  • The International Labour Organization’s Declaration on Fundamental Principles and Rights at Work
  • The Rio Declaration on Environment and Development
  • The United Nations Convention Against Corruption

The UN Global Compact (UNGC) asks companies to embrace, support and enact these principles within their sphere of influence.

ICML is committed to the UNGC and will report annually on the progress made in the support of the principles:


  1. Businesses should support and respect the protection of internationally proclaimed human rights; and Principle.
  2. Make sure that they are not complicit in human rights abuses.


  1. Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
  2. The elimination of all forms of forced and compulsory labour
  3. The effective abolition of child labour;
  4. The elimination of discrimination in respect of employment and occupation.


  1. Businesses should support a precautionary approach to environmental challenges;
  2. Undertake initiatives to promote greater environmental responsibility;
  3. Encourage the development and diffusion of environmentally friendly technologies.


  1. Businesses should work against corruption in all its forms, including extortion and bribery.

ICML has adopted a Code of Conduct, supporting its commitment to a policy of fair dealing, honesty and integrity in the conduct of its business. The present Code of Conduct lists and details the standards of behaviour which all members of the Company and its associates are expected to uphold in conducting the company’s business. They go beyond the requirements of the law. This Code has been actively endorsed by the Board of Directors, distributed to all employees across all levels in the Group and placed on the Company Web Site. Compliance by all employees to the high moral, ethical and legal standards of the Code is mandatory and if employees become aware of, or suspect, a contravention of the Code, they must promptly and confidentially report to a Non-Executive board member by the confidential channels provided.


  1. Members of the Company will observe the laws of Mauritius in everything we do. We must not try to bribe any public official in any circumstances anywhere.
  2. Our dealings with all who have contact with us must be straight, fair, honest, courteous and efficient.
  3. No member of ICML will ask for any gift or favour from anyone if that gift or favour has an influence on the way that person does his job.
  4. No member of the Company will accept any gift or favour from anyone in connection with the way we do our job. As the refusal of a token of appreciation for a job well done may sometimes appear impolite, we will comply with company rules and seek and heed the guidance of our personnel manager/ethics adviser on whether it is appropriate to keep that token.
  5. No member of the Company will offer any gift or favour to anyone in order to influence that person in the way they do their job.
  6. While moderate business entertaining is acceptable, all members must guard against hospitality that appears to be aimed at influencing us in the way we do our job. Whenever possible, hospitality should be reciprocated.
  7. We generate, receive and store substantial volumes of information that is valuable us and to outsiders. We must not disclose such information without permission. We all have a responsibility to ensure that such information under our control or to which we have access is always properly safeguarded.
  8. We must not allow our personal interests to conflict with our official duties in the company. If any of us has a personal interest that may influence, or appear to influence, the way we do our job, we must declare that interest and take appropriate steps to resolve the conflict of interest. We must all make sure that our dealings with clients, financial institutions, consultants, contractors and colleagues do not place us in a position of obligation that may lead to a conflict of interest.
  9. The company’s property and products belong only to the company. They do not belong to us. If any of us takes company property or products for our own use or to give or sell, they commit theft and are liable to dismissal and prosecution. The company’s services and facilities are not to be used for private purposes except with prior permission.
  10. Personal conduct, whether on or off duty, that adversely affects work performance is not acceptable.
  11. It is good practice for an employee to seek advice and permission before undertaking a secondary employment.
  12. A competitive employment or economic activity, paid or unpaid, regular or casual, must not be undertaken without prior permission.


Relations with Clients, Co-funders And Consultants

  1. We aim to provide efficient and courteous service to our clients.
  2. We aim to keep our clients truthfully informed about the company’s capabilities without misrepresentation, exaggeration or overstatement.
  3. We aim to provide our clients with products and services that meet high standards of quality, integrity and reliability. We take full responsibility for our products and services and are committed to make every possible effort where those products and services that fail to meet these required standards.

Relations with Suppliers And Contractors

  1. We believe in fair and open competition. We treat our competitors honourably and we aim to develop and maintain long term relationships with suppliers and contractors based on mutual trust.
  2. Our procurement of finance, services, partnerships, consultants, is done to the highest ethical standards and endeavours to assure clients can be confident a quality end-product and to underpin continued confidence of clients, suppliers and the public in ICML. We must ensure that the hire of services and the purchase of goods are based solely on price, quality, service and need. We will ensure that our suppliers and contractors are paid in a timely fashion and according to agreed terms of trade.


Responsibilities to Shareholders and Financial Responsibilities to Shareholders and the Financial Community


  1. The aim of our company is to achieve growth in earnings for our shareholders over the long term by productive, efficient and competitive operations.
  2. We acknowledge that our shareholders and potential shareholders are entitled to know all information that is necessary to evaluate how their investments are or would be managed. We make available true and accurate information on the management of the company, its financial position and its general plans to all who have a legitimate interest in the company.
  3. It is the policy of the company to maintain complete and accurate records and accounts and to present them in accordance with all applicable laws and professional accounting standards. We will not tolerate any false, artificial or misleading statement or entry in any of the company’s books, accounts, records, documents or financial statements.
  4. No member of the Company must ever make use of insider information, namely information that has not been made public, for our personal advantage.


Employment Practices Employment Practices

  1. The occupational health, safety and welfare of its employees are a prime concern of the company. It is the responsibility of us all to comply with all occupational health and safety laws and provide good and safe working conditions in all the countries in which we operate.
  2. The Company aims to achieve equality of opportunity and treatment for all its employees in recruitment, training, promotion, transfer, benefits and discipline. All employees will be treated as individuals according to their ability to meet job requirements.
  3. The dignity and individuality of every employee will be respected. The privacy and confidentiality of employee records will be safeguarded.
  4. An employee who believes they are being required to act in a way that is inconsistent with the standards in this code or who believes others are breaching the code should report the matter through an appropriate channel, defined in the whistle-blowing policy. The company undertakes to ensure, to the best of its capacity, that no prejudice whatsoever results to an employee who makes such a report on reasonable grounds or in good faith. Community action Community action

Compliance and Enforcement

  1. It is the personal responsibility of every director and employee to understand and comply with this Code of Conduct.
  2. Managers and supervisors are also responsible for ensuring that those they supervise understand and comply with the code. Problems encountered in complying with the code and suggestions for improving it should be made promptly to the manager responsible for keeping the code in good working order.
  3. Any breach of the Code will be promptly dealt with.
  4. Channels of complaint are open to shareholders and potential shareholders, customers and consumers, suppliers, contractors and directors and employees of the company. All complaints will be considered impartially and efficiently.

We will strive to promote high standards in order to prevent any accidents and injuries in the course of our business whether in the commercial environment or the operational sites or processing plants where we may work with our client partner’s on.  The participation of our employees in our safety and health activities on our own facilities but especially in all aspects of those of our clients and prospective client’s sites we visit, will be a priority for all members of ICML staff and appointed consultants and associates. Every employee must follow the prescribed safety practices and report immediately any hazards, unsafe conditions, accidents, injuries and illnesses to his superior.  It is also essential that they familiarize themselves with hazards involved in the actual job or the working environment. All job related accidents and injuries and their causes must be immediately reported to the relevant Safety and Health Officer.  No employee shall be subjected to interference, coercion, discrimination or reprisal for identifying unsafe or unhealthy working conditions.


We acknowledge our duty, as a responsible corporate citizen, to protect the natural environment for future generations and we take this responsibility very seriously. Our objective is to better understand our adverse environmental impact, to inform and educate all our people about it and to set ourselves achievable goals for reducing it.


We have identified our potentially most significant adverse environmental impacts potentially arising from our client relationships now and in future as:

  • depletion of natural resources through the procurement and use of goods and services;
  • carbon emissions to the atmosphere from the extraction and use of fossil fuels for energy generation;
  • production and management of waste streams and effluents from the mining and processing of metals and minerals exploited by our clients;
  • discharge of process-waters to the environment

We have also identified our positive environmental impacts we can create and influence as part of our client relationships as:

  • the reduction of waste through the promotion of responsible mining, processing, recycling and waste management activities;
  • the utilisation of effective energy-saving practices, tools and systems;
  • the implementation of practices reducing ours and our client’s carbon footprint.

We are committed to managing our environmental impacts and continuously improving our environmental performance by:

  • complying, as a minimum requirement, with relevant legislation, regulations and other relevant procedures with our clients in their local environments;
  • where possible, cooperating in implementing systems with clients that meet the requirements of ISO 14001 as a certified environmental management system (EMS) and regularly reviewing them;
  • setting realistic objectives and targets for each of our most significant environmental impacts;
  • minimising our energy consumption, carbon footprint and encouraging the use of less polluting forms of transport whenever possible;
  • minimising the amount of waste produced by way of reduction, recovery, reuse and recycling (3Rs);
  • communicating our Environmental Statement and relevant procedures to employees and other stakeholders and promoting environmentally-sensitive behaviours with our clients;
  • where possible, reporting our environmental commitment and performance.