Anti-Bribery & Corruption Policy

Policy Statement

SERPA Africa is committed to conducting business ethically and in compliance with all applicable anti-bribery and corruption laws. We maintain a zero-tolerance policy toward bribery and corruption in all our business dealings and relationships.

Scope

This policy applies to:

• All employees, directors, and officers of SERPA Africa
• Contractors, consultants, and temporary workers
• Business partners, agents, and representatives
• Any person or organization acting on our behalf

Prohibited Conduct

The following conduct is strictly prohibited:

Bribery

• Offering, promising, or giving any financial or other advantage to obtain or retain business
• Requesting, agreeing to receive, or accepting any bribe
• Bribing foreign public officials

Facilitation Payments

We do not make facilitation payments or "grease payments" to expedite routine government actions, even where such payments may be customary or legal locally.

Gifts and Hospitality

Gifts and hospitality must be:

• Reasonable and proportionate
• Not given with the intention of influencing business decisions
• Properly recorded and approved
• In compliance with local laws and recipient's policies

Due Diligence

We conduct appropriate due diligence on:

• Business partners and third-party intermediaries
• Agents and distributors
• Suppliers and vendors
• Joint venture partners

Record Keeping

We maintain accurate books and records that:

• Reflect all transactions and asset dispositions
• Are kept in reasonable detail
• Provide an adequate system of internal controls
• Are retained in accordance with legal requirements

Training and Communication

We provide regular training to ensure all personnel understand:

• Their obligations under this policy
• How to recognize and report concerns
• The consequences of policy violations

Reporting Concerns

If you suspect or witness any bribery or corruption, you must report it immediately. Reports can be made:

• To your direct supervisor or manager
• To the Compliance Officer
• Via our confidential ethics hotline

Whistleblower Protection

We will not tolerate retaliation against anyone who reports concerns in good faith. All reports will be investigated promptly and confidentially.

Consequences of Violations

Violations of this policy may result in:

• Disciplinary action, up to and including termination
• Civil and criminal penalties
• Reputational damage
• Termination of business relationships

Legal Framework

This policy is designed to comply with:

• Zimbabwe Prevention of Corruption Act
• South Africa Prevention and Combating of Corrupt Activities Act
• UK Bribery Act 2010
• US Foreign Corrupt Practices Act
• Other applicable local and international anti-corruption laws

Contact

For questions about this policy or to report concerns:

Compliance Officer
SERPA Africa
Email: compliance@serpa.africa
Phone: +263 718 592 096