PURPOSE

The primary objectives of this policy are as follows:

• To set the minimum required standards to prevent bribery and corruption within Afromix in terms of legal and regulatory requirements
• To provide a summary of the various policies relevant to address anti-bribery and corruption requirements
• To reflect our cultural and ethical commitment to preventing bribery

 

SCOPE

This policy applies to all employees at Afromix and all business activities conducted by any divisions and business units of Afromix with the private or public sector.

 

REGULATORY BACKGROUND

Bribery is a criminal offence and corrupt acts expose Afromix and its employees to the risk of prosecution, substantial fines and imprisonment. Afromix supports the compliance framework of The King III Report on Corporate Governance which recommends a hybrid form of governance that meets regulatory requirements and incorporates appropriate voluntary standards of excellence as defined in the codes of practice.

 

REGULATORY STANDARDS

Afromix supports the:

• • Prevention and Combating of Corrupt Activities Act 2004
  • The Organisation for Economic Cooperation and Development (OECD) Anti-Bribery Convention
  • The UK Bribery Act 2010, and
  • The US Foreign Corrupt Practices Act

This policy must be implemented whilst complying with all applicable privacy and data protection legislation.

 

VOLUNTARY STANDARDS

The Afromix Code of Conduct sets the tone and provides the overall values-based framework that confirms the common principles applied throughout the Group and the top-level commitment to upholding ethical standards.

 

POLICY STATEMENT

1. The AFROMIX Policy on Anti-bribery and Corruption
2. Afromix is dedicated to upholding the highest standards of honesty, integrity and ethical behaviour.
   1. This policy, as well as, all other Afromix policies are committed to the fight against bribery and corruption, in both the private and public-sector transactions, including facilitation payments.
   2. The Afromix Code of Conduct clearly states that when dealing with public officials, other corporations and private citizens
   3. An employee may not give or receive a gift of substantial magnitude from a source outside the organization that is, in any way connected to the core business or employment of AFROMIX.
      1. An employee may not give or receive anything that can be construed as a bribe, kickback, facilitation payment or other illegal payment.
      2. Employees may not allow a transaction with a vendor/ service provider or others to be structured or recorded in any way that is inconsistent with customary business practice.

 

CULTURAL & ETHICAL COMMITMENT TO PREVENTING BRIBERY

1. Afromix has a zero-tolerance approach to bribery and corruption and is committed to carrying out business in a fair, open and honest manner without undue influence.
2. Afromix does not, either directly or indirectly, through intermediaries or other third parties solicit, receive, offer, promise or provide any financial or other advantage of material value or otherwise exercise improper influence in its dealings with other businesses, or with Government or Public Officials with the intention of obtaining improper advantage in the conduct of its Business.
3. All Interested Persons are required to comply with this Policy and are responsible for ensuring that Afromix Business is undertaken with the utmost integrity regarding the following matters:

 

FRAUD & EXTORTION

Fraud and Extortion are criminal offenses. Afromix prohibits the direct or indirect demand or acceptance of any advantage, through deception or otherwise, which is used for Interested Persons or Afromix’ benefit.

 

BRIBERY

Bribery is unlawful in most countries in which Afromix operates. Irrespective of the jurisdiction Afromix prohibits all forms of bribery whether or not the advantage, benefit or improper performance may have been offered or received indirectly, for example, via a customer, agent, intermediary or supplier.

 

FACILITATION PAYMENTS

Afromix prohibits facilitation payments. A facilitation payment is payment of a bribe to a government or other official to secure or expedite the performance of an action. In circumstances where the payment of a bribe is demanded, whether paid or not, this must immediately be reported to the Afromix Directors.

 

ENGAGEMENT WITH GOVERNMENT OR PUBLIC OFFICIALS

In the normal course of business, meetings may be scheduled with Government or Public Officials for the purpose of discussing legitimate Afromix Business. These meetings must be held in a transparent manner to minimize the perception of any corrupt activity taking place.

 

FINANCIAL BOOKS, RECORDS & INTERNAL CONTROLS

Afromix must maintain detailed and accurate records and a system of internal controls that ensures accountability for all shareholder assets. “Off-the-books” payments and fraudulent accounting practices, for example knowingly falsifying accounting books and records to cover up or disguise any improper payments, are prohibited.

Interested Persons have a responsibility to protect Afromix’ assets from theft, loss, abuse, unauthorized use or disposal. They must use company assets only for the purposes related to conducting their Afromix responsibilities and may use company assets for other (including personal) uses only when properly authorized.

 

REPORTING BRIBERY

It is the responsibility of all Interested Persons to report any breaches, or potential breaches, of this Policy to their line manager or other person to whom they report.

Violations of this Policy, including involvement in any corrupt activities and failure to report actual or potential breaches of the Policy (or associated procedures), will lead to disciplinary action in accordance with applicable disciplinary procedures. In some circumstances, failure to report actual or suspected violations of this policy may itself constitute a legal offence and will be treated as such.

Afromix is committed to reporting all instances of corruption and other forms of dishonesty to the relevant authorities and to facilitating criminal action against the individuals concerned where appropriate.