Company Code of Conduct & Ethics

DOCUMENT NO: KK-WV-3.00

The Company code of Conduct and Ethics is detailed below. 

The Company subscribes to the highest level of conduct and ethics in all its corporate dealings and charges it’s employees, contractors, suppliers and service providers with the responsibility of meeting these same standards of behaviour in their day to day activities.

In particular the following standards of conduct and ethics are expected of all personnel: -

Employees are expected to;

  • Be honest
  • Be transparent in Company business dealings
  • Have respect for human rights

Corruption and Bribery

Corruption in any of the forms registered below are considered gross misconduct and will result in instant dismissal and prosecution. The Company’s attitude to corruption in any form or size is one of zero tolerance. Corrupt practices include bribery, fraud, theft, abuse of position or authority, embezzlement, extortion, influence pedalling and facilitation payments amongst others. Behaviour that involves the offering, giving, receiving, obtaining or soliciting of any advantage to influence the action of any official in the discharge of his/her duties.

The offering, giving, acceptance or soliciting of a bribe in any form or the use of other routes or channels for the benefit of an employee or that of the employee’s family, friends, associates or acquaintances. The abuse of entrusted power for private gain or any conduct or behaviour in relation to persons entrusted with responsibilities which violates their duties and which is aimed at obtaining undue advantage of any kind for themselves or for others; and the unauthorized dissemination or solicitation of confidential or restricted information for reward.

Some definitions follow below.

(a)   Bribery: Promising, offering, giving or soliciting of any benefit in cash or in kind that improperly affects the actions or decisions of any person.

(b)   Fraud: False representation or concealment of material facts in order to part with something of value.

(c)   Abuse of position or authority. The use of ones vested authority to improperly benefit oneself or an entity or another person.

(d)   Embezzlement. This involves theft of resources by persons entrusted with the authority and control of such resources.

(e)   Extortion. This involves coercing a person or entity to provide a benefit to himself, another person or an entity in exchange for acting or not acting in a particular manner.

(f)     Influence Peddling. The practice of using ones influence with persons in authority to obtain favours or preferential treatment for another, usually in return for payment

(g)   Facilitation payment. These are small, or sometimes large, payments made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement. Also called facilitation, speed or grease.

(h)   Political Contributions. The company and its employees should not make direct or indirect contributions to political parties or individuals engaged in politics as a way of obtaining advantage in business transactions.

(i)     Gifts, hospitality and expenses. Accepting gifts, hospitality and expenses when such an arrangement could affect the outcome of business transactions will be considered in the same category as bribery.

Conflict of interest

1.   Employees will not without the consent of the Company, engage directly in any other business or occupation that conflicts with Kakuzi's operations.  However, the Company accepts employees' right to have a farm of their own, provided they have the consent of the Company, and provided the demands of owning and running the farm do not in any way interfere with their company duties and responsibilities.

2.   Employees will not be involved in the recruitment of relatives to the Company and will be totally transparent in line with the recruitment policy with particular reference to not showing bias on a racial or tribal basis.

3.   Employees will not conduct Company business with relatives.

4.   Employees must declare any business interests that either they directly or their family members are engaged in so that there can be no question of conflict of interest in carrying out their corporate duties and responsibilities.

Additional requirements for management

1.    To carry out the responsibilities assigned to them in a professional and mature manner and set an example to staff of the standards expected of them.

2.     They have an obligation to train and guide the staff in order to enhance their contribution to the Company’s operation and their own career development.

3.     To fully acquaint themselves with the Company’s rules, regulations and policies and ensure compliance by themselves and the staff under their control.

4.     As part of their responsibilities they will under certain circumstances be expected to receive, make payment of and hold in custody money belonging to the Company and maintain up to date and accurate records of transactions involved.

5.     If they should decide to offer themselves as a candidate in either National or Local Government elections and campaigns, they will be required to resign from employment of the Company before undertaking any political campaign.  While exercising their democratic political rights, they should not use their influence in any way to impose their personal views on other staff.

6.     They will use all their expertise and effort to ensure the protection of Company property and assets, and under no circumstances shall they divert such property to personal and/or unauthorised use for themselves or for their personal gain.

7.     They will not use their position or influence to circumvent Company rules and regulations.

To report any cases of breach of the above as per the Whistleblowing Policy

Revision Date: November 2020 || Approved by Kakuzi Board || Revision No. 00/2020