Privacy Policy

Anti-Bribery and Anti-Fraud Policy

1. 1. 1. 1. 1. 1. Introduction

               MOBNNY TECHNICAL SERVICES strictly prohibit bribery, fraud and all other corrupt business practices. We expect our employees at all times to obey the law and maintain high ethical standards as stated in our Code of Business Conduct.

               We will uphold laws/regulations relevant to countering fraud, bribery and corruption in all of the Locations in which we operate, particularly laws that are directly relevant to specific business practices. Losses due to fraud, bribery and all other corrupt business practices can be more than just financial in nature: they can also cause damage to the company’s reputation. The reputation of MBONNY TECHNICAL for lawful and responsible business behaviour is of paramount importance.

         1. Policy objectives
            The purpose of this policy is to set out the responsibilities of the company employees and subcontractors in observing and upholding our position on bribery, fraud and other corrupt business practices.
         2. To achieve this commitment MBONNY TECHNICAL will:
            • Develop and maintain effective controls to prevent bribery, fraud and other corrupt business practices;
            • Ensure that any suspected, alleged, attempted or actual instances of bribery, fraud or other corrupt business practices are investigated appropriately, regardless of the position held or length of service of any individual implicated;
            • Take appropriate disciplinary action in all cases where investigation has proven attempted or actual instances of bribery, fraud or other corrupt practices. All significant cases shall be reported to the Group’s Legal function who will report them in the appropriate manner; and,
            • Operate a lessons learnt process to review incidents, systems and procedures to prevent similar instances occurring and embed responsible business behaviors within MBONNY TECHNICAL Services.
         3. 3. Delivering our objectives

            MBONNY TECHNICAL strictly prohibits:

            • The offering, solicitation or the acceptance of any bribe, whether cash or other inducement;
            • To or from any person or company, wherever they are located in the world, and whether they are a private person or company or a public official or body;
            • By any individual employee, agent or other person or body acting on the Group’s behalf;
            • To gain any commercial, contractual or regulatory advantage for the Group in a way which is unethical;
            • Or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.
            • MBONNY TECHNICAL recognizes that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Group or of the person or body employing them or whom they represent.

              Payments to public officials to carry out or speed up a process (“facilitation payments”) are prohibited – but MBONNY TECHNICAL understands that employees should not put their lives, liberty or property at risk. If employees are coerced or extorted into making a payment they must report the payment to their line manager and local Ethics and Compliance Officer as soon as possible.

              This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:

              • Normal and appropriate hospitality;
              • The giving of a ceremonial gift on a festival or at another special time;
              • The use of any recognised fast-track process which is available to all on payment of a fee; or
              • The offer of resources to assist the person or body to make the decision more efficiently provided that they are supplied for that purpose only.

              We do not make direct or indirect donations to political parties. Donations to charity on behalf of the group must be made following our internal processes.

              For practical purposes fraud may be described as the act of making false representation, or failure to disclose information, or abusing a position of trust, with the intent to make a gain or cause a loss or to expose another to the risk of loss.

              Examples of frauds that may be perpetrated against MBONNY TECHNICAL include the following:

              • Theft, misuse and misappropriation of MBONNY TECHNICAL  property, equipment, funds, materials, records or any other assets;
              • False accounting and/or making fraudulent statements financial or non-financial with a view to personal gain or gain of another (e.g. timesheets, expense claims, purchase orders, budgets, regulatory returns);
              • Any activity which involves the alteration, destruction, copying or manipulation of data for inappropriate purposes.

              Fraud may involve one individual or several people in collusion with each other who could be either from within or external to MBONNY TECHNICAL Services.

              Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery or fraud, the matter should be referred to your most senior local manager before proceeding. If necessary, guidance should also be sought from either your local Ethics and Compliance Manager or the Group Legal function. Hence our policy and business ethics are as stated below:

              1. Safety first.
              2. Customer is the King.
              3. Do not take bribe or give.
              4. Any gift to any of our officers must be declared and surrendered to the company for necessary action as deemed fit by the Management.

              Part of our anti-corruption strategy is embedded in our biz ethics include:

              1. Any staff involved in bribery will be summarily dismissed after investigation
              2. Quotations are invited from at least three bidders.
              3. Procurement and supplies are reviewed by project committee to select the best and competitive bidder.
              4. No single person can carry out negotiations for procurement and supplies
              5. Funds can only be released by at least two authorized signatories after recommendation from the project committee
              6. Goods or materials supplied must be according to specifications.
              7. Funds for a particular project is not allowed to be utilized on another project.
              8. Internal control department ensure that company policy and procedures are followed in all our processes and any infraction immediately reported.
         4. 4. Reporting and response

            Any employee who discovers or suspects bribery or fraudulent activity should normally raise any concerns through their line manager. Alternatively, you may raise your concerns with your local Ethics and Compliance Manager or the Group Legal function.

            However, it is recognised that individuals may feel inhibited in certain circumstances. In this case, employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage through our confidential and independent whistleblowing helpline.

            Please refer to the Whistleblowing Policy for further information.

         5. 5. Scope

            This policy applies to all legal entities which MBONNY TECHNICAL   wholly owns, has a majority stake in or overall operational control of. This policy is concerned with internal and external bribery, fraud and other corrupt business practices, committed by employees, temporary staff, agents, suppliers and contractors.

         6. 6. Governance

            The MBONNY TECHNICAL   MANAGING DIRECTOR and other Senior Management Staff of MBONNY TECHNICAL    provides oversight of this policy.

         7. Responsibilities

            This policy applies to all individuals who are employed by, or carry out work on behalf of MBONNY TECHNICAL    including contractors, temporary staff.

            All individuals identified above are responsible for:

            • Understanding and acting in accordance with MBONNY TECHNICAL ’s Code of Business Conduct in obeying the law and maintaining high ethical standards;
            • Reporting any known or suspected instances of attempted or actual bribery, fraud or instances of other corrupt practices in the company in line with this policy;
            • Notifying the Company at the earliest opportunity of the concern so that the issue can be investigated appropriately; and
            • Co-operating with any investigation into any concern.
         8. Supporting information
            • Code of Business Conduct
            • Whistleblowing Policy
            • Procurement Policy
            • MBONNY TECHNICAL  Anti-Bribery and Anti-Fraud Compliance Manual
         9. Document change history
            

            Policy status:	FINAL
            Issue date:	29.08.2023
            Version:	1.0
            Policy owner:	MBONNY TECHNICAL SERVICES LIMITED
            Review date:	28.09.2026