Anti-Bribery and Anti-Corruption Policy
1. Introduction
Prestige Bluestar Holdings Ltd is committed to conducting its business with the highest standards of integrity and transparency. This Anti-Bribery and Anti-Corruption Policy (the “Policy”) sets forth our commitment to preventing bribery and corruption in all aspects of our operations. This Policy applies to all employees, directors, officers, agents, and representatives of Prestige Bluestar Holdings Ltd and its subsidiaries.
2. Policy Statement
Bribery and corruption undermine the integrity of business practices and erode trust. Prestige Bluestar Holdings Ltd prohibits all forms of bribery and corruption and will not tolerate any attempt to offer, give, receive, or solicit anything of value that could influence or be perceived to influence business decisions or actions.
3. Definitions
- Bribery: Offering, giving, receiving, or soliciting anything of value to influence a person’s actions or decisions in relation to their role in the company or in business dealings.
- Corruption: Abuse of power or authority for personal gain, including bribery, kickbacks, and other unethical practices.
4. Prohibited Conduct
- Bribes: Employees and representatives must not offer, give, receive, or request bribes in any form, whether directly or indirectly.
- Kickbacks: Any form of kickbacks or secret commissions in relation to company business is strictly prohibited.
- Facilitation Payments: Small payments made to expedite routine administrative actions are considered bribes and are prohibited.
- Gifts and Hospitality: While normal and appropriate hospitality or gifts may be acceptable, they must not be intended to influence business decisions or create a conflict of interest.
5. Guidelines for Gifts and Hospitality
- Gifts: Any gift or token of appreciation must be modest, transparent, and not intended to influence a business decision. Gifts should not exceed a value of KES 5,000 and must be reported to management.
- Hospitality: Business-related hospitality should be reasonable, proportionate, and necessary for the conduct of business. It should not be excessive or lavish, and must be reported to management.
6. Third-Party Relationships
- Due Diligence: We will conduct appropriate due diligence on third parties, including agents, consultants, and contractors, to ensure they adhere to anti-bribery and anti-corruption standards.
- Contracts: Contracts with third parties will include anti-bribery and anti-corruption clauses to ensure compliance with this Policy.
7. Reporting and Whistleblowing
- Reporting: Employees and representatives are encouraged to report any suspected or actual breaches of this Policy. Reports can be made confidentially through designated reporting channels or directly to management.
- Protection: Individuals who report in good faith are protected from retaliation. Any retaliation against whistleblowers will not be tolerated.
8. Compliance and Training
- Training: All employees and representatives will receive training on anti-bribery and anti-corruption practices to ensure understanding and compliance with this Policy.
- Monitoring: We will monitor compliance with this Policy and conduct regular audits to ensure adherence.
9. Enforcement
- Disciplinary Action: Violations of this Policy will result in disciplinary action, which may include termination of employment or contract, legal action, and reporting to relevant authorities.
- Investigation: All reports of potential breaches will be investigated thoroughly and impartially.
10. Review and Updates
This Policy will be reviewed periodically and updated as necessary to ensure its continued relevance and effectiveness. Employees and representatives will be informed of any changes to the Policy.
11. Acknowledgment
All employees, directors, officers, agents, and representatives are required to acknowledge their understanding and acceptance of this Anti-Bribery and Anti-Corruption Policy as a condition of their employment or engagement with Prestige Bluestar Holdings Ltd.
