Business Ethics & Information Security Policy

INTRODUCTION
United Clearing Company Limited is an AEO, ISO Standard & corruption free entity. Meaning we do not encourage nor tolerate any unlawful or unethical practices within our premises and our operation channels at any given time. To maintain this criteria and level of business, UCCL requires strict adherence to the correct protocol and behavior by the stakeholders. Also take note that this policy goes together with our Antibribery & anticorruption policy.

POLICY STATEMENT
Our professional code of ethics policy aims to give our employees guidelines on our business ethics and stance on various controversial matters. We trust you to use your better judgment, but we want to provide you with a concrete guide you can fall back on if you’re unsure about how you should act (e.g. in cases of conflict of interest). We will also use this policy to outline the consequences of violating our business code of ethics.

SCOPE
This policy applies to everyone we employ or have business relations with. This includes individual people such as employees, interns, volunteers, but also business entities, such as vendors, enterprise customers or venture capital companies

POLICY ELEMENTS
The policy consists of two elements, general work ethics (i.e., the correspondence and behaviour amongst stakeholders) and information security (i.e., the flow and storage of data within and outside the company premises and facilities along with all the relevant carrier devices.).

BUSINESS/WORK ETHICS
We base our business code of ethics on common principles of ethics :

Respect for others. Treat people as you want to be treated.
Integrity and honesty. Tell the truth and avoid any wrongdoing to the best of your ability.
Justice. Make sure you’re objective and fair and don’t disadvantage others.
Lawfulness. Know and follow the law – always.
Competence and accountability. Work hard and be responsible for your work.
Teamwork. Collaborate and ask for help.

Here’s a more detailed overview of our code:

Respect for others

It’s mandatory to respect everyone you interact with. Be kind, polite and understanding. You must respect others’ personal space, opinions and privacy. Any kind of violence is strictly prohibited and will result in immediate termination. You’re also not allowed to harass or victimize others.

What constitutes harassment or victimization? As a general rule, try to put yourself in someone else’s place. How would you feel if someone behaved a specific way to you? If the answer is “I wouldn’t like it much” or “I would never let them behave like that to me”, then we don’t tolerate this behavior no matter the person it comes from.

If someone, be it customer, colleague or stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to HR or your supervisor. You can also report rudeness and dismissiveness if they become excessive or frequent.

Integrity and honesty

We all work together to achieve specific outcomes. Your behavior should contribute to our goals, whether financial or organizational.

Be honest and transparent when you act in ways that impact other people (e.g. taking strategic decisions or deciding on layoffs). We don’t tolerate malicious, deceitful or petty conduct. Lies and cheating are huge red flags and, if you’re discovered, you may face progressive discipline or immediate termination depending on the damage you did.

Stealing from the company or other people is illegal. If you’re caught, you will face repercussions depending on the severity of your actions. For example, if you steal office supplies, you may receive a reprimand or demotion (at a minimum), while if you steal money or data (e.g. engaging in fraud or embezzlement), you will get fired and face legal consequences. The decision is at HR’s discretion on a case-by-case basis.

Conflict of interest

Conflict of interest may occur whenever your interest in a particular subject leads you to actions, activities or relationships that undermine our company. This includes situations like using your position’s authority for your own personal gain or exploiting company resources to support a personal money-making business. Even when you seemingly act to the company’s advantage, you may actually disadvantage it. For example, if an employee uses dubious methods to get competitor intel and raise their sales record, their action will have a positive impact on the company’s revenue, but it will put us at a legal risk and promote unhealthy business practices.

If it turns out you have created a conflict of interest for yourself, you will be terminated. If the conflict of interest was involuntary (e.g. buying stocks from a company without knowing they’re a competitor), we will take actions to rectify the situation. If you repeat the offence, you may be terminated.

Justice

Don’t act in a way that exploits others, their hard work or their mistakes. Give everyone equal opportunity and speak up when someone else doesn’t.

Be objective when making decisions that can impact other people, including when you’re deciding to hire, promote or fire someone. Be sure that you can justify any decision with written records or examples. Seek and use the most objective methods in any case; for example, when interviewing candidates, ask the same interview questions to all of them and avoid judging non-job-related criteria, like dress, appearance, etc.

Also, don’t discriminate against people with protected characteristics. If you suspect you may have an unconscious bias that influences your decisions, ask for help from HR or supervisor.

When exercising authority, be fair. Don’t show favoritism toward specific employees and be transparent when you decide to praise or reward an employee

If you need to discipline an employee, be sure to have prepared a case that you can present to HR. You must not retaliate against employees or applicants (such as in cases when they’ve filed complaints) as this is forbidden by law.

Be just toward customers or vendors, too. If you think our company was in the wrong in a specific instance, don’t try to cover it up or accuse the other side. Discuss with your manager to find solutions that can benefit both sides.

Lawfulness

You are obliged to follow all laws which apply to our organization. Depending on your role and profession, there might be various laws you need to observe. For example, accountants and medical professionals have their own legal restrictions and they must be fully aware of them.

When you’re preparing contracts, clauses, disclaimers or online copy that may be governed by law (such as consent forms), please ask verification from director or supervisor before finalizing anything.

You’re also covered by our confidentiality and data protection policy. You must not expose, disclose or endanger information of customers, employees, stakeholders or our business

Following laws regarding fraud, bribery, corruption and any kind of assault is a given. You are also obliged to follow laws on child labor and avoid doing business with unlawful organizations.

If you’re not sure what the law is in a specific instance, don’t hesitate to ask HR or our legal counsel.

Competence and accountability

We all need to put a healthy amount of effort in our work. Not just because we’re all responsible for the organization’s success, but also because slacking off affects our colleagues. Incomplete or slow working might hinder other people’s work or cause them to shoulder the burden themselves. This comes in direct conflict with our respect and integrity principles.

We also expect you to take up opportunities for learning and development, either on-the-job or via educational material or training. If you are unsure how you can achieve this, have an open discussion with your manager.

Also, take responsibility for your actions. We all make mistakes or need to make tough decisions and it’s important we own up to them. Failing to be accountable on a regular basis or in important situations (e.g. a crucial mistake in our financial records) will result in termination. If you take responsibility and come up with ways to fix your mistakes where possible, you will be in a far better position.

Teamwork

Working well with others is a virtue, rather than an obligation. You will certainly get to work autonomously and be focused on your own projects and responsibilities. But, you should also be ready to collaborate with and help others.

Be generous with your expertise and knowledge. Be open to learning and evolving. If days go by without you consulting or brainstorming with anyone, you are missing out on opportunities for excellence. Instead, work with others and don’t hesitate to ask for help when you need it.

INFORMATION SECURITY

To avoid breach of information and data to the external environment, the company has kept in place programs and protocols to follow. Stakeholders are requested to abide by these security measures.

These programs and protocols are explained further below:

Disposal of documents: Be it physical or soft data, the company requires disposal in a way that is discreet and maintain the company’s confidentiality. Physical papers are requested to be shredded before placing the the respective waste baskets and soft data be completely cleared from devices ensuring no copy has been made in external devices other than the company authorized back-ups.
Anti-virus and device security: Employees are to ensure all the company devices in used are fully protected by authorized anti-virus programs (Kaspersky) and computers have adequate security passcodes.
Individual accounts: The company has provided every individual employee with their office accounts (Office 365) for all online and computerized work as well as individual copy cards for operating the communal devices like copiers and printers. It’s forbidden to share these accounts without the company’s consent.
Surveillance: Employees and other stakeholders are hereby advised and informed that all UCCL premises are under 24/7 surveillance and any improper or out of the ordinary activities will be picked up and acted upon hence we encourage them to respect the premises and avoid any suspicious activities.
Company programs: Employees and stakeholders are strongly urged to not share company applications to unauthorized entities. In the case of UCCL’s internal program i.e. C&F Pro only the authorized client is to be sent the report any diversion from this will lead to severe discipline procedures.

IMPLEMENTATION & IMPROVEMENTS

Stakeholders are advised to follow the policy accordingly and keep in mind that as a growing company there will be room for changes as the company and its stakeholders’ progress. With this said any action or activities that is deemed unfit for the company and its stakeholders will be followed with strict disciplinary action.

Anti-Bribery & Anti-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 business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. In Kenya the applicable laws include but not limited to The Constitution of Kenya 2010 Chapter 6 on Leadership and integrity and the Ethics and Anti-Corruption Commission Act ,2011. In addition to this UCCL upholds and bound by ISO standards as we are an AEO Entity.

DEFINITION

“Agent”: Any individual acting as an agent, paid by the company, acting on the company’s behalf in negotiating with Third Parties.

“Bribery” / “Corruption”: Bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, to induce or reward improper conduct or to gain any commercial, contractual, regulatory or personal advantage. It can be direct or indirect through Third Parties.

“Company”: All subsidiaries and affiliated companies.

“Conflict of Interest”: Occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another.

“Donation”: A Donation is a voluntary contribution in the form of monetary or non-monetary gifts to a fund or cause for which no return service or payment is expected or made.

Contributions to industry associations or fees for memberships in organizations that serve business interests are not necessarily considered Donations.

“Employee”: For the purposes of this policy this includes all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, home-workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or joint ventures or their employees, wherever they are located.

“Facilitation Payments”: A form of Bribery in which small payments are made with the purpose of expediting or facilitating the performance by a Public Official of a routine governmental action and not to obtain or retain business or any other undue advantage. Facilitation payments are typically demanded by low level and low income Public Officials in exchange for providing services to which one is legally entitled without such payments.

“Gifts, Invitations & Hospitality”: Invitations given or received to social functions, sporting events, meals and entertainment, gifts or customary tokens of appreciation.

“Intermediary”: Includes but is not limited to Agents, distributors, associate consultants, sales representatives, implementation partners, sales partners.

“Kickback”: A bribe to obtain an undue advantage, where a portion of the undue advantage is ‘kicked backed’ to the person who gave, or is supposed to give, the undue advantage.

“Public Official”: Officials or employees of any government or other public body, agency or legal entity, at any level, including officers or employees of state-owned enterprises and officers or employees of enterprises which are mandated by a public body or a state-owned enterprise to administrate public functions.

“Sponsorship”: Sponsorship is about partnering with external organizations to deliver mutual benefits through an exchange of monies, products, services, content or other intellectual property.

“Third Party”: Any individual or organization you come into contact with during the course of your work for us. This includes actual and potential customers, suppliers, business contacts, Intermediaries, government and public bodies, including their advisors, representatives and officials, politicians and political parties.

SCOPE

This policy applies to all Employees and relevant Third Parties of UCCL and shall be communicated to them at the outset of our business relationship and as appropriate thereafter.

This policy applies in all countries or territories where the Company operates. Where local customs, standards, laws or other local policies apply that are stricter than the provision of this policy, the stricter rules must be complied with. However, if this policy stipulates stricter rules than local customs, standards, laws or other local policies, the stricter provisions of this policy shall apply.

GIFTS, INVITATIONS & HOSPITALITY

This policy does not prohibit normal and appropriate hospitality (given and received) to or from Third Parties.

You are prohibited from accepting a gift or giving a gift to a third party in the following situations:

it is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favors or benefits;
it is given in your name and not in the name of the Company;
it includes cash or a cash equivalent (such as gift certificates or vouchers);
it is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process); and
it is given secretly and not openly.

We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and is proportionate. The intention behind the gift should always be considered.

FACILITATION PAYMENTS & KICKBACKS

In many jurisdictions, making Facilitation Payments is illegal. We do not make, and will not accept, Facilitation Payments or Kickbacks of any kind anywhere in the world.

Where the facilitation payment is being extorted or you are being coerced to pay it and your safety or liberty is under threat or you feel you have no alternative but to pay for personal or family peace of mind, then pay the Facilitation Payment and report this to your line manager as soon as possible.

YOUR RESPONSIBILITIES

It is not acceptable for you (or someone on your behalf) to:

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 Public Official or Third Party 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;
accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
threaten or retaliate against another Employee 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 or perceived breach of this policy.

It is your responsibility to ensure that all accounts, invoices, memoranda and other documents and records relating to dealings with Third Parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept ‘off-book’.

You must DECLARE and keep a written record of all Gifts, Invitations & Hospitality according to Company practice accepted or offered, which will be subject to managerial review.

You must ensure all expense claims relating to Gifts, Invitations & Hospitality or expenses incurred to Third Parties are submitted in accordance with the Company’s expenses policy and specifically record the reason for the expenditure.

The prevention, detection and reporting of any form of Bribery & Corruption are the responsibility of all Employees. You must notify your line Director, the Project Director as soon as possible if you are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

All Employees have the responsibility to read, understand and comply with this policy. You should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.

Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Employees and associate consultants are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their line Director or Project Director.

PROTECTION

Employees who refuse to take part in bribery or corruption, or report in good faith under this policy their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future will be protected from detrimental treatment/retaliation. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.

GOVERNANCE

The board of directors at UCCL has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Director has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it. Awareness briefing shall also be given to associate consultants.

MONITORING AND REVIEW

The Country Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible.

Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective. The Country Director will report to the CEO at least annually on the application of this policy.

Waste Management & Recycling Policy

INTRODUCTION
United Clearing Co. Ltd has utmost concern for the environment and aims to be a positive impact to its surrounding and the environment at large by doing our part with minimum pollution and proper disposal of any waste generated. To achieve this the company has in place procedures and protocol that need to be followed and adhered to for us to have a clean and suitable working space for our stakeholders.

PROCEDURES & PROTOCOL
To ensure the correct and most effective way of waste management the company has kept in place certain procedures to be followed.

Usage of Printing/Copy Paper: stakeholders are requested to only print or copy when necessary and to make use of the electronic copies as much as possible. When paper is used, the stakeholder is requested to be print on duplex and utilize the used photocopies for future internal printing. This will minimize the amount of paper needed to be disposed of and usage of printing toners.

Electronics: In the event of disposal of an electronic the company has an option to search for a trade-in transaction to replace the electronic or use the appropriate channels available of disposal in relation to the nature of the device.

Waste/Garbage Collection: Any waste/garbage that comes out of the company premises should be disposed of in accordance with the municipal regulations and a valid municipal license bearer to hired for the same. No personal without the municipal/County license will be handed over the waste.

ACTION/RESULT
Stakeholders are required to uphold this policy to their utmost abilities. Any divergence or failure to abide by the policy will NOT be tolerated and strict action taken depending on the level of flout.

Career Management & Diversity Policy

INTRODUCTION
United Clearing Company Limited believes in constant growth and aims to achieve the highest possible level of competence suitable with the current market status. To enable this, UCCL has embraced a career management system and diversity policy that can include this growth and the ever-changing market.

STATEMENT
UCCL is concerned with the growth of stakeholders and inclusion of diverse aspects on recruitment. First opportunity is given to current employees as per their potential to enhance the progress in their career. No discrimination of any kind will be tolerated in the recruitment process.

IMPLIMENTATION
Vacancy opportunities arising in the company will be first presented to the employees and viable to them according to their potentials and skills. This ensures a smooth flow within and across departments. Career moves within the company include:

Lateral move within the same level but different department. This helps broaden the knowledge and skills of the candidate as they will be able to obtain skills in a different department.
Vertical move to management level or level higher than current holding in the same department. These can be promotion moves.
Mentorship: This can be a vertical or lateral move but with assistance from a mentor or supervisor of the field in vacancy.

Further training/education for the employees can be placed forward to the management where and when applicable to enhance the progress and skills of employees. This can include external like KRATI, KRA seminars & WEBEX or internal training programs within the company.

Inclusivity/diversity in hiring or recruitment and training. The company strives to be as non-discriminatory as possible with in its operations and requires the same from its stakeholders with emphasis during recruitment.

RESULT
UCCL requires its stakeholders to adhere to the policy to enable improve on the progress and enhance the growth of both the company and its employees. By abiding by this, we can ensure a well balanced and improved flow of operations which in turn will add to the general growth of the company at large.

Career Management & Diversity Policy

Lateral move within the same level but different department. This helps broaden the knowledge and skills of the candidate as they will be able to obtain skills in a different department.
Vertical move to management level or level higher than current holding in the same department. These can be promotion moves.
Mentorship: This can be a vertical or lateral move but with assistance from a mentor or supervisor of the field in vacancy.

Health Safety & Working Conditions Policy

INTRODUCTION
The Kenya Occupational Health and Safety Act 2007 (OSHA)1 provides for the health, safety and welfare of persons employed, and all persons lawfully present at workplaces and related areas such as location, vessel, land where a worker is in the course of employment. The act mandates employers to provide and maintain plant and systems and procedures of work that are safe and without risk to workers’ health. United Clearing Company Limited recognizes and complies with its moral and legal obligation to provide a safe environment for its employees in line with the OSHA and other relevant guidelines.

POLICY STATEMENT
UCCL is committed to ensuring and promoting, so far as is reasonably practicable, health & safety and suitable environment for its stakeholders. The company aims to prevent accidents & cases of work-related ill health. UCCL acknowledges that health and safety in the workplace is the responsibility of all staff.

ARRANGEMENTS
UCCL requires the field staff to wear the provided protective gear whenever out on the field. This includes but not limited to reflectors, raincoats, safety boots, helmets & dust masks. Appropriate sanitization and surgical masks to be utilized when & where necessary by UCCL staff.

UCCL stakeholders are urged to maintain the working premises as a NO-SMOKING zone. First aid kit has been provided to ensure that staff get immediate help if taken ill or injured at work. The first aid kit is in the custody of the health and safety lead who will ensure it is suitably stocked

UCCL staff should be aware of their duties and responsibilities. If unaware they are urged to inquire from their supervisors for clear instructions and information regarding their duties & responsibilities.

All UCCL employees are requested to observe the below office timings as per their respective departments for the working days of Monday-Saturday:

Day Shift Timings Monday-Friday | 8:00am-12:30pm & 2:00pm-5:30pm
Day Shift Timings Saturday | 8:00am-1:00pm
Night Shift Timings Monday-Friday | 5:30pm-8:00am (Depending on workload)
Night Shift Timings Saturday | 1:00pm-8:00am (Depending on workload)

Employees are encouraged to ensure smooth flow of information and data during handing over in-between shifts and having prioritized any urgencies to their supervisors.

Employees will be granted 21 Days paid leave accrued at the end of every year. Absence from work by staff due to illness or emergencies should be communicated to their supervisors or HOD as soon as possible and written form/letter submitted within 24hrs of reporting back for record keeping.

UCCL premises are adequately equipped with fire equipment. Guidance on how to use them will be provided to staff to ensure they are well acquainted with safety measures. Emergency plans have been put in place, which includes evacuation and assembly procedures, posted evacuation maps, reporting and communication practices, training, and drills. Appointed fire marshals as led by the Health and Safety lead shall oversee the implementation of the emergency plans.

ROLES & RESPONSIBILITIES
All staff have a responsibility to read, understand and fully comply with the requirements of this policy and any other health and safety guidelines. All staff have a mandatory duty to report health and safety concerns and potential hazards they come across and observe all safety rules and instructions. Staff must also ensure their health and safety and that of other persons who may be affected by their actions or omissions.

Line managers are responsible for the health and safety of all employees under their supervision. This includes responsibility for appropriate training and instruction, proper follow up on reported health and safety concerns, and implementation of recommended corrective action.

RISK ASSESSMENT
To minimize risks in the work environment and optimize the working capacity of the staff assessment will be under-taken on a regular basis to monitor and rectify if needed the level of condition and health & safety in the company. UCCL request their stakeholders to co-operate with the policy to enable utmost efficiency.

Whistleblower Policy

OVERVIEW

At United Clearing Company Ltd we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with each other, our clients, members, suppliers, shareholders and other stakeholders. The Company is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty and integrity in our business activities.

PURPOSE
The policy has been put in place to ensure any concerns raised regarding any misconduct or improper state of aﬀairs or circumstances in relation to the Company’s business are dealt with eﬀectively, securely, appropriately, and in accordance with the Kenyan Law.

The Company encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the Company’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal.

This policy will be provided to all employees and oﬃcers of the Company upon commencement of their employment or engagement.

The Company may invite oﬃcers, senior management and employees to attend training sessions to ensure ongoing education regarding the application of the policy.

SCOPE

This policy applies to any person who is or has been any of the following with respect to the company:

Employee
Supervising Officer
Director
Contactor (including sub-contractors & employees of contractors)
Suppliers (including employees of suppliers)
Consultant
Auditor
Associate
Relative, dependent, spouse or dependent of spouse of any of the above.

REPORTABLE CONDUCT

You may make a report or disclosure under this policy if you have reasonable grounds to believe that a Company director, oﬃcer, employee, contractor, supplier, consultant or other person who has business dealings with the Company has engaged in conduct (Reportable Conduct) which is:

Dishonest, fraudulent or corrupt.

Illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property).

Unethical including any breach of the Company’s policies such as the Code of Conduct; Oppressive or grossly negligent.

Potentially damaging to the Company, its employees or a third party; Misconduct or an improper state of aﬀairs.

A danger or represents a danger to the public or ﬁnancial system, Harassment, discrimination, victimization or bullying.

Any disclosures that do not fall within the deﬁnition of Reportable Conduct, will not qualify for protection under the Act. It will be at the Company’s discretion whether it considers there is a reasonable suspicion that the Reportable Conduct is occurring and/or whether the conduct constitutes “misconduct or improper state of aﬀairs” under the Act.

For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staﬀ member’s current or former employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for the Company. Examples of personal work-related grievances are as follows:

An interpersonal conﬂict between the staﬀ member and another employee.

A decision relating to the engagement, transfer or promotion of the staﬀ member; A decision relating to the terms and conditions of engagement of the staﬀ member.

A decision to suspend or terminate the engagement of the staﬀ member, or otherwise to discipline the staﬀ member.

Personal work-related grievances should be reported to your manager or supervisor.

MAKING A DISCLOSURE

The Company relies on its employees maintaining a culture of honest and ethical behavior. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy.

There are several ways in which you may report or disclose any issue or behavior which you consider to be Reportable Conduct.

INTERNAL REPORTING

You may disclose any Reportable Conduct to the Whistleblower Protection Oﬃcer whom can be your supervisor or the Directors depending on the nature of the issue. You can make a disclosure outside of business hours by contacting the above Whistleblower Protection Oﬃcers via email.

You are also encouraged to contact the above Whistleblower Protection Oﬃcers to obtain any additional information you may require before making a disclosure or for any clariﬁcation regarding this policy.

If you are unable to use any of the above reporting channels, a disclosure can be made to an “eligible recipient” within the Company. Eligible recipients include:

Director
Supervising Officer
Senior Manager
Auditor/ Member of Audit team

The Whistleblower Protection Oﬃcer or eligible recipient will safeguard your interests and will ensure the integrity of the reporting mechanism.

ANONYMITY

When making a disclosure, you may do so anonymously. It may be diﬃcult for the Company to properly investigate the matters disclosed if a report is submitted anonymously and therefore the Company encourages you to share your identity when making a disclosure, however you are not required to do so.

INVESTIGATION

The Company will investigate all matters reported under this policy as soon as practicable after the matter has been reported. The Whistleblower Protection Oﬃcer will investigate the matter and where necessary, appoint an external investigator to assist in conducting the investigation. All investigations will be conducted in a fair, independent and timely manner and all reasonable eﬀorts will be made to preserve conﬁdentiality during the investigation.

If the report is not anonymous, the Whistleblower Protection Oﬃcer or external investigator will contact you, by your preferred method of communication to discuss the investigation process and any other matters that are relevant to the investigation.

Where you have chosen to remain anonymous, your identity will not be disclosed to the investigator or to any other person and the Company will conduct the investigation based on the information provided to it.

Where possible, the Whistleblower Protection Oﬃcer will provide you with feedback on the progress and expected timeframes of the investigation. The person against whom any allegations have been made will also be informed of the concerns and will be provided with an opportunity to respond (unless there are any restrictions or other reasonable bases for not doing so).

To the extent permitted by law, the Whistleblower Protection Oﬃcer may inform you and/or a person against whom allegations have been made of the ﬁndings. The Company will document the ﬁndings in a report however any report will remain the property of the Company and will only be shared with you or any person against whom the allegations have been made if the Company deems it appropriate.

PROTECTION OF WHISTLEBLOWERS

The Company is committed to ensuring that any person who makes a disclosure is treated fairly and does not suﬀer detriment and that conﬁdentiality is preserved in respect of all matters raised under this policy.

PROTECTION FROM LEGAL ACTION

You will not be subject to any civil, criminal or administrative legal action (including disciplinary action) for making a disclosure under this policy or participating in any investigation.

Any information you provide will not be admissible in any criminal or civil proceedings other than for proceedings in respect of the falsity of the information.

PROTECTION AGAINST DETRIMENTAL CONDUCT

The Company (or any person engaged by the Company) will not engage in ‘Detrimental Conduct’ against you if you have made a disclosure under this policy.

Detrimental Conduct includes actual or threatened conduct such as the following (without limitation): Termination of employment.

Injury to employment including demotion, disciplinary action; Alternation of position or duties.

Discrimination.

Harassment, bullying or intimidation; Victimization.

Harm or injury including psychological harm; Damage to a person’s property.

Damage to a person’s reputation.

Damage to a person’s business or ﬁnancial position; or any other damage to a person.

The Company also strictly prohibits all forms of Detrimental Conduct against any person who is involved in an investigation of a matter disclosed under the policy in response to their involvement in that investigation.

The Company will take all reasonable steps to protect you from Detrimental Conduct and will take necessary action where such conduct is identiﬁed. If appropriate, the Company may allow you to perform your duties from another location or reassign you to another role (at the same level) or make other modiﬁcations to your workplace or your duties to protect you from the risk of detriment.

If you are subjected to Detrimental Conduct as a result of making a disclosure under this policy or participating in an investigation, you should inform a Whistleblower Protection Oﬃcer or eligible recipient in accordance with the reporting guidelines outlined above.

You may also seek remedies including compensation, civil penalties or reinstatement if: You suﬀer loss, damage or injury because of a disclosure; and

The Company failed to take reasonable precautions and exercise due diligence to prevent any Detrimental Conduct.

PROTECTION OF CONFEIDENTIALITY

All information received from you will be treated conﬁdentially and sensitively.

You will not be required to provide your name when making a disclosure. To make a disclosure on an anonymous basis, it is recommended that you use a pseudonym and contact the Whistleblowing Protection Oﬃcers in the manner outlined above.

If you report on an anonymous basis, you will still qualify for the protections in this policy.

If you make a disclosure under this policy, your identity (or any information which would likely to identify you) will only be shared if:

You give your consent to share that information; or

The disclosure is allowed or required by law (for example where the concern is raised with a lawyer for the purposes of obtaining legal advice); or

Where it is necessary to disclose information for the eﬀective investigation of the matter, and this is likely to lead to your identiﬁcation, all reasonable steps will be taken to reduce the risk that you will be identiﬁed. For example, all personal information or reference to you witnessing an event will be redacted from any report, you will be referred to in a gender-neutral context, where possible you will be contacted to help identify certain aspects of your disclosure that could inadvertently identify you. Any disclosure under this policy will also be handled and investigated by qualiﬁed staﬀ.

The Company will also take the following measures for protecting your identity:

All paper and electronic documents and other materials relating to disclosures will be stored securely.

Access to all information relating to a disclosure will be limited to those directly involved in managing and investigating the disclosure.

Only a restricted number of people who are directly involved in handling and investigating a disclosure will be made aware of your identity (subject to your consent) or information that is likely to lead to your identiﬁcation.

Communications and documents relating to the investigation of a disclosure will not be sent to an email address or to a printer that can be accessed by other staﬀ; and

Each person who is involved in handling and investigating a disclosure will be reminded about the conﬁdentiality requirements, including that an unauthorized disclosure of your identity may be a criminal oﬀence.

If you are concerned that your identity has been disclosed in relation to a disclosure, and without your consent, you should inform a Whistleblower Protections Oﬃcer or eligible recipient immediately.

OTHER MATTERS

Any breach of this policy will be taken seriously and may result in disciplinary action, up to and including termination of employment.

In so far as this policy imposes any obligations on the Company, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes beneﬁts and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual are set out in an employee’s written employment contract.

The Company may unilaterally introduce, vary, remove or replace this policy at any time.

Our Policies

Business Ethics & Information Security Policy

Respect for others

Integrity and honesty

Conflict of interest

Justice

Lawfulness

Competence and accountability

Teamwork

Anti-Bribery & Anti-Corruption Policy

Waste Management & Recycling Policy

Career Management & Diversity Policy

Career Management & Diversity Policy

Health Safety & Working Conditions Policy

Whistleblower Policy

SCOPE

REPORTABLE CONDUCT

MAKING A DISCLOSURE

INTERNAL REPORTING

ANONYMITY

INVESTIGATION

PROTECTION OF WHISTLEBLOWERS

PROTECTION FROM LEGAL ACTION

PROTECTION AGAINST DETRIMENTAL CONDUCT

PROTECTION OF CONFEIDENTIALITY

OTHER MATTERS

Mombasa Branch

Phone:

Email:

Location:

Nairobi Branch

Phone:

Email:

Location: