ANTI-CORRUPTION AND ANTI-BRIBERY POLICY
ANTI-CORRUPTION AND ANTI-BRIBERY POLICY
Last updated: 01 April 2026
1. Purpose
The purpose of this Anti-Corruption and Anti-Bribery Policy is to ensure that all business activities are conducted with integrity, transparency, and in compliance with applicable laws and regulations.
The Company maintains a zero-tolerance approach to bribery and corruption in any form.
2. Scope
This policy applies to:
All employees, officers, and directors
Contractors, consultants, freelancers and temporary staff
Third parties acting on behalf of the Company, including agents, intermediaries, and partners
3. Definition of Bribery and Corruption
Bribery is the offering, promising, giving, accepting, or soliciting of any advantage to influence improperly the actions of another person.
Corruption includes any abuse of entrusted power for private gain.
This includes both direct and indirect actions.
4. Prohibited Conduct
The following activities are strictly prohibited:
Offering, giving, or receiving bribes or kickbacks
Facilitating payments or unofficial payments to expedite routine processes
Providing anything of value to improperly influence a business decision
Accepting gifts, hospitality, or favors that could compromise objectivity
Using third parties to engage in corrupt practices on behalf of the Company
5. Gifts, Hospitality, and Entertainment
Gifts and hospitality must:
Be reasonable, proportionate, and infrequent
Be given openly and transparently
Not influence, or appear to influence, business decisions
Comply with local laws and internal approval processes
Cash or cash equivalents are strictly prohibited.
6. Third Parties and Business Partners
The Company expects all third parties to operate with the same level of integrity.
Before engaging third parties, appropriate due diligence must be conducted.
Any suspicion of misconduct must be reported immediately.
7. Record Keeping
All financial transactions must be:
Accurately recorded
Supported by proper documentation
Transparent and auditable
False, misleading, or incomplete records are strictly prohibited.
8. Reporting Concerns
Employees and stakeholders are encouraged to report any concerns regarding potential violations of this policy.
Reports can be made through:
Line management
Compliance or legal departments
Confidential reporting channels (where available)
All reports will be treated seriously and confidentially.
9. Protection Against Retaliation
The Company prohibits retaliation against anyone who raises a concern in good faith.
Any act of retaliation will result in disciplinary action.
10. Training and Awareness
The Company will provide appropriate training to ensure understanding and compliance with this policy.
Employees are expected to familiarize themselves with and adhere to this policy at all times.
11. Violations and Disciplinary Action
Violations of this policy may result in:
Disciplinary action, up to and including termination
Legal action where applicable
12. Responsibility
All employees and associated persons are responsible for:
Acting with integrity
Avoiding any form of corruption
Reporting concerns promptly
Management is responsible for ensuring this policy is implemented and enforced.
13. Review
This policy will be reviewed periodically and updated as necessary to ensure continued effectiveness and compliance.
