Anti-Bribery and Corruption Policy

Purpose

Aegir Consult Limited is committed to conducting business with integrity, transparency, and accountability. This policy outlines our zero-tolerance stance on bribery and corruption and establishes principles and responsibilities to ensure compliance with all applicable anti-bribery and anti-corruption laws.

Scope

This policy applies to all employees, directors, officers, consultants, contractors, agents, suppliers, and any third parties acting on behalf of Aegir Consult Limited.

Definitions

• Corruption - The abuse of entrusted power for private gain.
• Fraud - Any act or omission, including misrepresentation, that knowingly or recklessly misleads or attempts to mislead a party to obtain a financial or other benefit or to avoid an obligation.
• Collusion - An arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
• Coercion - Impairing or harming, or threatening to impair or harm, directly or indirectly, any party or their property to influence improperly the actions of a party.
• Obstruction - Deliberate interference with the investigation or resolution of allegations of corrupt practices.

Prohibited Conduct

Aegir Consult Limited strictly prohibits:

• Offering, promising, giving, or accepting bribes, kickbacks, or facilitation payments.
• Engaging in any form of fraud, corruption, collusion, coercion, or obstruction.
• Making or receiving improper donations, sponsorships, or gifts intended to influence business decisions.
• Using third parties to commit any act of bribery or corruption.
• Engaging in conflicts of interest that could lead to corrupt practices.

Gifts, Hospitality, and Donations

• All gifts and hospitality must be reasonable, lawful, and transparent.
• They must not be intended to influence business decisions or create a sense of obligation.
• Political and charitable donations require prior approval and must not be used to secure business advantages.

Responsibilities

• Employees and Representatives - Must adhere to this policy and report any concerns regarding potential violations.
• Management - Responsible for ensuring compliance, providing guidance, and facilitating training on anti-corruption measures.
• Third Parties - Expected to comply with this policy when conducting business on behalf of Aegir Consult Limited.

Reporting Violations

Employees and stakeholders are obligated to report any suspected bribery or corruption through the company's confidential reporting channels. Reports can be submitted via email at integrity@aegirconsult.systems or by calling +254-110-681-999. Retaliation against individuals who report concerns in good faith is strictly prohibited.

Compliance and Enforcement

• Non-compliance with this policy may result in disciplinary actions, including termination of employment or contracts.
• Aegir Consult Limited reserves the right to pursue legal action against individuals or entities that violate this policy.

Training and Awareness

All employees and relevant stakeholders will receive regular training to ensure a thorough understanding of this policy and the importance of anti-corruption measures.

Monitoring and Review

This policy will undergo periodic reviews to assess its effectiveness and ensure alignment with current legal and regulatory standards.

Approval and Effective Date

This policy has been reviewed and approved by the Board of Directors and is effective as of 6th January 2025.