Anti-Corruption
& Anti-Bribery
Policy

This Anti-Corruption and Anti-Bribery Policy establishes Kilimora CLG's zero-tolerance approach to corruption, bribery, fraud, extortion, and all forms of unethical conduct. The policy demonstrates organisational commitment to conducting business with integrity, transparency, and in compliance with applicable anti-corruption laws — including the Kenyan Anti-Corruption and Economic Crimes Act, the Bribery Act 2016, the United States Foreign Corrupt Practices Act, and international standards including the United Nations Convention Against Corruption and OECD Anti-Bribery Convention.

This policy applies to all individuals and entities acting on behalf of or in association with Kilimora CLG — including employees at all levels and locations, board members, contractors, consultants, agents, intermediaries, joint venture partners, and suppliers. Geographic scope covers all countries where the organisation operates or conducts business, including Kenya, Rwanda, Burundi, and any future expansion markets.

The following terms carry specific meanings throughout this policy. Familiarity with all definitions is required of every person to whom this policy applies.

Government officials include elected representatives, appointed officials, civil servants, employees of state-owned enterprises, political party officials, candidates for public office, and individuals exercising public functions. Interactions with government officials require heightened scrutiny given corruption risks and strict liability under anti-bribery laws.

No employee may offer, promise, or provide anything of value to government officials with corrupt intent to influence official actions, secure improper advantage, or induce misuse of position. The prohibition applies equally to direct payments and indirect payments through intermediaries, family members, or third parties.

Agents, consultants, distributors, joint venture partners, and subcontractors may engage in corrupt practices creating legal liability and reputational damage even when senior management remains unaware. Due diligence processes mitigate these risks by screening third parties before engagement and monitoring ongoing relationships.

Modest gifts and reasonable hospitality supporting legitimate business relationship development are permitted when provided transparently without corrupt intent. The critical test is whether a reasonable observer would conclude the gift or hospitality was intended to influence a business or official decision.

Procurement processes incorporate anti-corruption controls ensuring vendor selection based on merit criteria — quality, price, capacity, and past performance — rather than personal relationships, kickbacks, or corrupt arrangements.

Accurate financial records provide the foundation for corruption detection, regulatory compliance, and stakeholder accountability. All transactions must be recorded promptly, accurately, and completely with sufficient detail enabling complete audit trails from source documents through financial statements.

Record Retention & Petty Cash Controls

Supporting documentation for all expenditures must be retained for a minimum of 7 years. Petty cash funds are capped at $300 with transaction logs, receipt requirements, and monthly verification by the Finance Manager. No employee may establish or maintain undisclosed bank accounts or cash funds on behalf of the organisation.

Internal audit functions test transactions periodically through sample testing of vendor payment legitimacy, expense report patterns, procurement file compliance, and gift register adherence. Findings are documented in reports to management and the board audit committee with corrective action plans.

Multiple reporting channels enable confidential disclosure of suspected corruption, providing employees safe avenues for raising concerns without fear of retaliation. All reports are taken seriously and investigated promptly regardless of reporter identity or seniority of the accused.

Anti-corruption training ensures all personnel understand policy requirements, recognise corruption risks in their specific roles, and know how to report concerns. New employees receive training during onboarding before assuming duties involving government interactions, procurement, or financial transactions.

Policy violations result in serious consequences proportionate to violation severity — considering misconduct intentionality, financial magnitude, position abuse, cooperation with investigations, and prior disciplinary history. Consequences range from written warnings for minor inadvertent violations to immediate termination for serious misconduct.

Criminal prosecution is pursued when evidence supports violations of anti-corruption laws. The organisation cooperates fully with law enforcement authorities providing documents, witness access, and other assistance. Civil litigation recovers damages when corruption causes financial losses, including fraudulent overbilling, asset misappropriation, or contracts secured through bribery.

Self-reporting of violations receives favourable consideration — employees who proactively disclose, cooperate fully, and demonstrate genuine remorse may receive reduced discipline. However, self-reporting does not guarantee immunity and serious violations may still warrant termination.

Anti-corruption programme effectiveness is assessed through monitoring activities including transaction testing, control reviews, and culture surveys. The Finance Manager conducts quarterly reviews of high-risk transactions — government-related expenses, third-party payments, and gifts provided or received.

Audit Framework

Annual audit plans include anti-corruption components targeting procurement processes, expense reimbursements, third-party due diligence, and gift registers. External financial statement audits include internal control testing for segregation of duties, authorization controls, and transaction documentation. Specialised anti-corruption audits are commissioned when heightened risks exist.

Culture Assessment

Anonymous surveys administered biennially gather staff feedback on ethical pressure, confidence in reporting mechanisms, and management responsiveness. Results inform training enhancements, communication campaigns, or control modifications addressing identified concerns.

Benchmarking

The organisation participates in anti-corruption networks including Transparency International Kenya Chapter and regional business integrity forums. Regulatory monitoring ensures compliance with evolving anti-corruption laws and enforcement priorities across all operating jurisdictions.

Ultimate responsibility for anti-corruption programme effectiveness rests with the board of directors. The board audit committee exercises specific oversight including policy review and approval, investigation oversight for matters involving senior management, and programme effectiveness assessment.

The CEO bears day-to-day responsibility for programme implementation and reports quarterly to the board audit committee on training completion rates, investigation summaries, policy violations, disciplinary actions, and monitoring results.