Microsoft handles sign-in
You type your password on Microsoft's page to sign in, and COI is only told who you are. Registering is different: COI passes your new password to Microsoft to create your account; it does not store or log it.
COI help
How COI works
You fill in a declaration. What happens next depends on what you answered. Every decision is written down and kept.
What happens to a declaration
Submitting records it. What happens after that depends on what you answered.
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Answer and submit
You can stop and come back while it is a draft. Submitting records your declaration; nothing is sent until then.
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Not every declaration needs a decision
Board and CEO declarations require approval even when nothing is disclosed. For other employee and contractor declarations, whether a decision is needed depends on what you answered. If you did not disclose a conflict, your declaration is kept on record and that is the end of it. If you did, it goes for review.
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Review
Who reviews it first depends on your position, not on what you wrote. Usually it is your line manager.
Board and CEO positions are routed differently
- Employee or contractorYour line manager
- Board memberNominations Committee review, then its chair's decision
- Board chair or Nominations Committee chairThe Lead Independent Director
- Chief Executive OfficerThe Chair of the Board
Board and CEO routes use active assigned attributes. The committee recommends before its chair makes the final decision. Board Chair and Nominations Committee Chair declarations go directly to the Lead Independent Director. The CEO's declaration goes directly to the Chair of the Board.
If the required Board or CEO approver is not assigned yet, submit once. Your declaration stays submitted and read-only, then routes automatically once the required approver attributes are available; you do not need to submit again. Board and CEO cases are not sent to Ethics and have no appeal path. Conflicting CEO and Board attributes must be corrected by an authorized administrator before routing can proceed.
For employee and contractor declarations, a missing manager keeps the submitted declaration waiting until the reporting line is corrected. Older records may retain an Ethics Office fallback because a reporting line is not recorded; their original decision trail stays available.
For employee and contractor cases, your line manager decides each disclosed interest independently. They can approve or not approve an interest, ask you for information, or refer that interest to the Ethics Office for advice. An approved interest ends with the manager; it is not automatically sent to Ethics. If different interests have different outcomes, the declaration shows that mixed outcome without changing any decision already made.
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Ethics advises on escalated interests
Ethics can give private advice to the manager or ask the manager for more information. The interest then returns to the manager for the final decision, which may be approved, approved with a mitigation, or not approved. Where a non-Board case is assigned directly to Ethics because the normal manager route is unavailable, the Ethics Office decides that whole case. Older whole-declaration records keep their original decision trail.
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If an interest is not approved, you can appeal
For employee and contractor cases, you can then appeal one or more interests that were not approved. An appeal is optional and yours to start. Ethics manages the private appeal and may ask you directly for more information. If Ethics asks the manager to reconsider, the manager receives a separate reason but cannot see your appeal grounds or your private conversation with Ethics. The manager's reasoned decision is binding, and Ethics closes the appeal from those outcomes. Older whole-declaration appeals may show that the appeal itself is declined; that decision is final.
Three things COI does not do
It cannot change your details
Your name, position and cellphone number come from your employee record. They have to be fixed there, and COI then uses the new ones.
It does not make the rules
What you must declare comes from Exxaro's Code of Ethics and Anti-Bribery policy, which the Group Company Secretary owns. COI keeps the record; it does not replace or restate it.