Legal & Compliance

Code of Ethics

The standards of conduct we hold ourselves to across lending, commodities and environmental rehabilitation — and what you are entitled to expect from us.

Threerae operates in sectors where the gap between what a company says and what it does can be costly for the people on the other side of the transaction. This code sets out the standards our directors, employees and representatives are held to, and what our clients and partners are entitled to expect.

Our Values In Practice

  • Integrity — we are honest in our dealings, we do not misrepresent our products, our costs or our capabilities, and we do not make commitments we cannot meet
  • Partnership — we build relationships on aligned interests rather than on extracting maximum value from a single transaction
  • Innovation — we use technology and practical thinking to solve real problems, including the unglamorous operational ones
  • Responsibility — we consider the financial, social and environmental consequences of what we do, including consequences that fall on people who are not our clients
  • Excellence — we hold ourselves to standards of execution and service, and we would rather be measured on delivery than on intent
  • Dignity — we treat people under financial pressure with respect. How we behave when a client cannot pay is the real test of everything above

Responsible Lending

As a registered credit provider we hold ourselves to standards that go beyond the minimum the National Credit Act requires.

  • We assess affordability properly, and we decline or reduce applications where the credit would over-extend the client — an assessment that exists only to be passed is not an assessment
  • We disclose the full cost of credit in writing before a client signs. No fee appears on an account that was not on the pre-agreement quotation
  • We do not market credit as easy, free or consequence-free, and we do not use urgency or pressure to push a client into a decision
  • We do not encourage clients to borrow more than they asked for or to refinance repeatedly to stay ahead of a balance
  • We communicate about arrears in factual, non-shaming language, and we make it easy for a client in difficulty to contact us early
  • We treat collections as a process with a person at the end of it, escalating proportionately rather than punitively

Honest Commercial Dealing

  • We verify counterparties before we introduce them, and we will walk away from a transaction that does not verify
  • We are clear about the scope of our mandate and about what we are and are not being paid to do
  • We do not offer, solicit or accept bribes, kickbacks or improper inducements, and we do not facilitate them for anyone else
  • We declare conflicts of interest rather than manage them quietly
  • We give clients and partners a fast, direct no rather than a slow maybe

Environmental Responsibility

Rehabilitation work that looks finished but is not is a particular kind of dishonesty, because the client may not discover it for years and the land does not recover in the meantime. We specify rehabilitation against site conditions rather than against what is cheapest to apply, we record what was actually applied where, and we tell clients when a site needs preparation before seeding rather than seeding ground that cannot support vegetation.

Our People And Our Conduct

  • We treat colleagues and clients without discrimination, harassment or intimidation
  • We protect confidential client, partner and company information and use it only for the purpose it was given
  • We keep accurate records and do not misrepresent our financial position or performance
  • We comply with the laws and regulations applying to our sectors, including the National Credit Act, the FIC Act, POPIA, the Companies Act and applicable tax legislation
  • We expect staff who see conduct falling short of this code to raise it, and we do not tolerate retaliation against anyone who does

Raising A Concern

If you believe Threerae or anyone representing us has acted contrary to this code — as a client, an employee, a partner or a member of the public — tell us, using the contact details at the foot of this page. Concerns are treated confidentially and investigated. If a complaint relates to a credit agreement and you are not satisfied with our response, you are entitled to approach the National Credit Regulator.

Requests & Queries

Address any query or request relating to this document to info@threerae.co.za or (011) 000 0000 during office hours (Mon – Fri: 08:00 – 17:00). Threerae's company registration number, National Credit Regulator registration number and the contact details of our Information Officer are available on request.