Code of Conduct

Lejwe Code of Conduct


This Code and our company terms and conditions describe the standards of conduct expected of everyone at Lejwe. These guiding principles guide daily interactions, empower individuals and teams, scale decision making, provide a shared language, and unite us in our identity. This Code applies to everyone at Lejwe throughout the world, regardless of position or tenure. We also expect Lejwe’s contractors, consultants, suppliers and agents to abide by our Code in connection with their work for Lejwe.

Our Guiding Principles

  • We commit to our craft. Our work has the power to change lives. That’s why we strive to continuously learn and excel at what we do.
  • We minimize waste. Time resources, and energy are precious, so we focus only on what will have the greatest impact.
  • We embrace differences. Diverse teams are stronger, and inclusive cultures are more resilient. When we seek out different perspectives, we make better decisions and build better products.
  • We dig deeper. The best solutions to meaningful challenges are rarely easy or obvious. We stay curious, balance our intuition with insights, and decide with confidence.
  • We lead with optimism. We believe in our mission, and we believe in each other. We see the world as it is, set ambitious goals, and inspire one another with generosity of spirit. Together, we reimagine what’s possible.


Guiding Principles in Action

The following core foundations support our guiding principles and help make Lejwe and the world a better place.

  • We operate with honesty and integrity. We keep our commitments to each other and to members of our Community—that is, Lejwe employees, sellers, buyers, suppliers, neighbors and investors and other stakeholders. We endeavor to communicate in an honest and unambiguous way, and avoid making misleading communications, or creating false impressions. We may make mistakes, but we quickly admit and correct them.
  • We treat others fairly and respectfully. We foster a respectful work environment free from any form of discrimination, harassment, and intimidation. We provide equal opportunity in all aspects of employment. We do not tolerate discrimination, harassment, violence, or threatening behavior of any kind. We always treat all members of our Community with dignity and respect. We read and follow our Employee Handbook.
  • We are responsible and law abiding. We follow the law. This includes international, national, and local laws, rules, and regulations where we do business. We also report wrongdoing, if we encounter it, and follow the reporting procedures described later in this Code.


Responsibilities to Lejwe

We avoid conflicts of interest or even the appearance of conflicts of interest. We have a responsibility to make sound business decisions strictly on the basis of Lejwe’s best interests without regard to our personal interests. A conflict of interest occurs when our personal interests, activities, investments, or associations interfere in any way—or even appear to interfere—with Lejwe’s interest.


We disclose to Lejwe’s Legal Department any relationships, investments, associations or activities that may create actual, potential, or perceived conflicts of interest, as soon as we become aware of any potential for such conflict. Lejwe may also inform you if it believes that you have such a relationship, investment, association or activity.


We respect corporate opportunities. We are loyal to Lejwe and owe Lejwe a duty to advance its legitimate business interests when business opportunities arise. We don’t take opportunities for personal gain that are discovered through the use of Lejwe property, information or position, and we will not use Lejwe property, information or position for personal gain, or compete with Lejwe in any manner.


For example, we don’t divert an investment opportunity or possible acquisition for the company for personal gain. We also don’t compete with Lejwe by consulting for a competitor or starting a competing side business.


We realize that some of the members of our Board are professional investors and may receive various opportunities in the course of their work. We do not expect that such a director would offer an opportunity to Lejwe unless the matter, transaction or interest is presented to, or acquired, created or developed by, or otherwise comes into the possession of that director expressly and solely in that director’s capacity as an Lejwe director.


We safeguard confidential information and care deeply about privacy. Loose lips sink ships! We are committed to protecting the confidential and proprietary information of Lejwe, Lejwe employees, sellers and buyers, and others with whom we do business.


We believe in being clear and upfront about our privacy practices, including how we treat personal information.


We do not disclose confidential information without proper authorization, and we will use such information for legitimate business purposes and in accordance with applicable laws and governing contracts.


We do not trade or tip others when we have inside information.

We do not buy or sell Lejwe stock when in possession of material non-public information, or pass such information to any others, including friends or family. We follow Lejwe’s Insider Trading Policy and ask Lejwe’s Legal Department if we have questions.

We maintain accurate and complete business and financial records.

We create and maintain financial records in accordance with applicable legal requirements and generally accepted accounting practices. Our SEC reports, disclosures, and other public communications must be full, fair, accurate, timely, and understandable.


We are each responsible for Lejwe’s financial integrity and fiscal responsibility. We acknowledge our responsibility to inform appropriate finance or legal personnel in a timely manner of anything that might have a material impact on our financial statements or disclosures.

We also follow our Records Retention Policy when storing or deleting Lejwe information and business records.


We protect and properly use Lejwe assets.

Theft, carelessness, and waste have a direct impact on our profitability. We treat Lejwe equipment and facilities with care. We use Lejwe assets for legitimate business purposes and use good judgment when using Lejwe equipment for reasonable personal use.


We do not speak on behalf of Lejwe unless we are authorized to do so.


Only certain individuals may speak on Lejwe’s behalf. When speaking publicly and using social media, we follow our External Communications Policy and reach out to the VP, Communications, VP, IR and/or the General Counsel with questions.


Responsibilities to Our Community


We deal fairly.

We deal fairly with our Community. We do not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair dealing. We do not misuse our position at Lejwe to circumvent our House Rules or seek special treatment from buyers or sellers on


We respect the environment.

We conduct our business in an environmentally responsible and sustainable manner, and we are committed to proactively countering the planet’s gathering ecological crises. We embrace our responsibility to minimize the ecological footprint of our operations and our duty to empower and incentivize those with whom we do business to do the same.


We uphold human rights.

We respect human rights, provide fair working conditions, and prohibit the use of any forced, compulsory, or child labor by or for Lejwe or our sellers.


We do not permit bribery.

Lejwe’s policy against bribery is clear—we never make or accept bribes to advance our business. We do not offer or give anything of value for an improper or corrupt purpose, whether in dealings with a government official or the private sector, and regardless of the norms of local custom. We follow Lejwe’s Anti-Corruption Policy and ask Lejwe’s Legal Department if we have questions.


We comply with antitrust and competition laws around the world.

We do not discuss or exchange competitively sensitive information with competitors. We also do not participate in other anti-competitive conduct, such as agreeing with competitors on geographic markets, customers or pricing. When interacting with a competitor, we ask Lejwe’s Legal Department any questions about whether our actions are proper and in compliance with the law.

We comply with trade regulations. We comply with import and export laws and act in accordance with Botswana economic sanctions and embargoes that prohibit or restrict trade with certain countries or individuals.


Asking Questions, Reporting Concerns

Lejwe is committed to providing a safe and reliable means for Lejwe employees and others to report concerns they may have about conduct at Lejwe. The guidelines below explain how to raise concerns confidentially and anonymously, if desired, and free of retaliation.


We use our best judgment and ask questions.

We use our best judgment in our business dealings and in upholding this Code. If we are unsure whether something violates our Code, and Lejwe policy or the law, we promptly contact our manager or the General Counsel for answers.


We report violations.

We promptly report any actual or possible violation of our Code, Lejwe policy, or the law to our manager, the General Counsel or via our whistleblower hotline. Failure to report a violation or possible violation may itself be considered a violation of the Code or applicable law.

Reporting options include:

  • Discussing the situation with your manager; or
  • If your manager is involved in the situation or you are uncomfortable speaking with your manager, contacting the General Counsel or VP, Human Resources; or
  • If you do not believe your concern is being adequately addressed, or you are not comfortable speaking with one of the contacts above, you may report your concern via


For reports that are not anonymous, receipt will be acknowledged to the sender within a reasonable period of time. All reports of a violation or possible violation will be taken seriously and investigated. The specific action taken in any particular case will depend on the nature and gravity of the conduct reported and the results of the investigation.

Lejwe will keep reports confidential to the extent consistent with our ability to conduct a full and fair investigation and to comply with our legal obligations. In some locations outside of the Botswana, anonymous reporting may not be allowed by local law.


We do not retaliate.

Lejwe takes its non-retaliatory culture very seriously and will not allow anyone to take adverse action, threaten, intimidate, or retaliate if one of us reports a violation or suspected violation in good faith, or cooperates in an investigation. Lejwe considers retaliation itself a violation of this Code and will respond accordingly. If you believe that you have been subject to retaliation, please report it promptly by one of the methods described above. Reporting retaliation enables Lejwe to honor our guiding principles and promptly investigate. If a complaint of retaliation is verified, appropriate disciplinary action will be taken, up to and including termination of employment or any other working relationship that the accused may have with Lejwe.


We understand the consequences of violations. Anyone who violates the law, our Code, or other Lejwe policies or procedures may be disciplined, up to and including termination of employment and/or his or her business relationship with Lejwe, in accordance with local legal requirements. Certain violations of this Code may be violations of the law, which may result in civil or criminal penalties, and Lejwe will cooperate fully with the appropriate authorities in these situations.


We discourage waivers of the Code of Conduct. Waivers of our Code are considered on a case-by-case basis and are discouraged. Waivers for Board members and executive officers require Board approval by a majority of the disinterested directors and waivers involving any other employee or stakeholder require the written approval of our General Counsel.