Anti Bribery and Corruption Policy

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our relationships and business dealings wherever we operate and to implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption. We remain bound by the laws of Nigeria, including the Corrupt Practices and Other Related Offenses Act 2000 Act No 5.

To address these risks, we have taken these steps to:

a) Implemented an anti-bribery and corruption policy;

b) Undertaken a risk assessment exercise, which will be subject to on-going review;

c) Undertaken a training programme of senior management;

d) Implement a training programme for all individuals operating in areas of the organisation that are perceived as high risk;

e) Appointed a Compliance Manager to ensure compliance with Corruption Practices issues;

f) Reviewed and amended policies related to this Anti-corruption and Bribery Policy

g) Prepare standard clauses relating to Corruption Practices issues for inclusion in key contractual documentation.

• Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
• Give, promise to give, or offer, a payment, gift or hospitality to a client, agent or representative to "facilitate" or expedite a routine procedure;
• Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
• Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
• Engage in any activity that might lead to a breach of this policy.

Managing Director
January 2nd 2020