EFFECTIVE AND ETHICAL LEADERSHIP

At Blu Label, we believe that effective and ethical leadership is centred on integrity and is critical to our long‑term success. It is about doing the right thing – being accountable, responsible, fair and transparent. Responsible business practices support our purpose and enable value creation.

We recognise that ethical leadership within Blu Label improves public trust, enhances risk, compliance and ethics management and strengthens stakeholder relations. This is achieved through:

our key values:

innovation;
inclusion;
accountability;
collaboration; and
customer centricity;

leadership’s commitment to upholding our key values; and
the provision of mechanisms to report and manage unethical behaviour.

WE LEAD

Our strategy is to continue to drive an inclusive culture by creating unique experiences for all employees. We understand that business results are driven by people, who are continuously evolving. The Success Management Framework provides us, as an organisation, with a framework to look after our talent, ensure we have the right skills and provide growth opportunities. We encourage a growth mindset that enables individuals to develop their skills and contribute to the success of the team and the Group at large.

FOCUS AREAS FOR FY27:

Leadership development programmes to embed the inclusive culture further.
Continue to consider the implications of the new compliance requirements and sectoral numerical targets of the Employment Equity Regulations.
Advance gender diversity within leadership pipelines and management structures.
Drive measurable improvements in diversity and representation across leadership and management levels.

SETTING THE TONE FOR THE GROUP’S ETHICS

Blu Label’s Social, Ethics and Transformation Committee is established in compliance with the Companies Act, No 71 of 2008. It, in turn, elevates social and ethical matters to the Board level. This ensures that ethics are treated as a matter of strategic importance.

The Social, Ethics and Transformation Committee maintains oversight of the ethics policies and applications within the Group and the Chairman of the Board sets the ethical tone for the Board as a whole. The primary ethics-related items that are monitored and reported on at the Social, Ethics and Transformation Committee level include:

how we adhere to the 10 United Nations Global Compact principles that influence our alignment;
anti-fraud and corruption policies and procedures to foster an environment of integrity;
business integrity with a focus on the Group’s and material suppliers’ ethical culture, compliance with anti‑bribery and anti-corruption regulations and addressing money laundering risks;
customer experience monitoring and enhancing, particularly regarding consumer relations and compliance with consumer protection laws;
reviewed the health and safety report, including monitoring and tracking outstanding actions; and
considered the quarterly Group human resources report, including employment equity, employee complement and movements and training and development.

No Blu Label operations have been subject to human rights reviews during FY26.

No human rights grievances have been reported in FY26.

Employees are expected to demonstrate ethical business practices at all times. All new staff members undergo an induction programme that includes training on the code of business conduct and the function of the ethics hotline, emphasising what should be reported and how to report unethical behaviour via this channel. All employees have access to, Blu Galaxy, our digital central repository which contains links to all our policies including ethics- related policies.

The ethics hotline is outsourced to Tip-offs Anonymous, a division of Deloitte and can be accessed by calling 0800 555 221. The ethics hotline is available to all stakeholders. Tip-offs Anonymous is an expert, independent party that specialises in receiving sensitive information and reporting these matters to Blu Label in a manner that protects the identity of the whistleblower. Six non-material incidents were reported during the year ended 31 May 2026, which were investigated by management.

In FY26, Deloitte presented a whistleblower awareness workshop to certain employees highlighting:

What the tip-off line is and why it matters;
How the hotline works;
What kind of concerns or ethical issues to be reported;
What the hotline is not utilised for;
Confidentiality of the tip-off line (employee rights and protections); and
What happens after an anonymous tip-off report has been reported.

The following material ethics-based mandatory training programmes were rolled out:

Whistleblowing hotline training; and
Suspicious transactions and activities.

In collaboration with the policy and risk owners, all material Company policies are reviewed to ensure they remain effective and relevant to the business and to identify policies that will be implemented across the Group. The following material policies were reviewed:

Code of Conduct;
Ethics Policy;
Suspicious and Unusual Activities and Transactions Policy;
Information Security Policy;
Business Continuity Policy;
Whistleblower Policy;
Conflict of Interest Policy;
Data Breach and Response Policy;

Gift Policy;
Travel Policy;
Acceptable Usage Policy;
Information Classification Policy;
Anti-Fraud Policy;
Intellectual Property Guidelines;
Data Retention Policy; and
Group Privacy Policy.

Key provisions of our policies include the following:

Each employee of Blu Label has an obligation to act in the Company’s best interests and must not let outside activities or outside financial interests interfere with those obligations.
Employees must be open and transparent about all gifts and hospitality and disclose these. Gifts considered lavish may be construed as gratification, which immediately places the Company and the individuals concerned at risk of prosecution for acts of corruption. A formal approval process exists relating to the receiving and giving of gifts over a certain amount, which is reviewed annually.
Fraudulent, corrupt or illegal practices will not be tolerated. Bribes or any other illicit payments will neither be paid nor accepted. A zero-tolerance policy has been adopted regarding such improper payments.
The Group does not participate in any illegal anti-competitive activity.
Employees should not authorise or participate in any illegal conduct or action (such as price manipulation or tender fixing) that restricts competition.
Committing to contracts and expenditure; and operating a responsible supply chain.
Efficient resource use and minimising negative environmental impacts.

MAINTAINING HIGH ETHICAL STANDARDS

The Board must demonstrate integrity and the competence to lead ethically and effectively while working closely with management to achieve our strategic objectives.
The Group is non-political. It does not contribute to political parties or allow its assets and services to be used in any way that favours any particular political grouping, other than in the provision of its normal products and services, under its standard terms and conditions and at arm’s length prices.
The Company facilities, equipment and personnel should only be used for the business’s activities and purposes, except where Blu Label specifically authorises, in writing, other uses.
Employees are required to remain mindful of what a payment is for and whether the amount requested is proportionate to the goods or services provided. Any suspicions, concerns, or queries regarding a payment should be clarified.
Employees must avoid any activity that might lead to, or suggest that a facilitation payment or kickback will be made or accepted by the Group.
The Group does not limit an employee’s right to freedom of association, specifically the right to collective bargaining. No employees were covered under collective bargaining arrangements during FY26.
There were no work stoppages due to disputes between Blu Label and its workforce during FY26.
The Group is against child labour and forced/compulsory labour.
The Ethics Officer takes responsibility for managing the organisation’s ethics programme.
The Ethics Officer reports to the Social and Ethics Committee on progress with the ethics management plan and the state of ethics within the organisation.

ETHICAL BREACHES

No material ethical or corruption-related breaches require reporting in FY26 (FY25: No material breaches).

All ethical matters that come to the attention of management are addressed timeously and appropriately.

Blu Label is satisfied that its corporate governance framework (including compliance and risk) is at an appropriate level in keeping with best industry practice and industry norms. Blu Label maintains a zero-tolerance policy regarding any lapses in good corporate governance.