Anti-corruption policy

Goal: This policy aims to establish standards of behavior that minimize the risk of corruption within Afcoms Sarl.
Anyone employed by, working for, or on behalf of Afcoms Sarl, anywhere in the world, is bound by this policy.
Intermediaries and other business partners must act ethically, and may be required to comply to this policy for all their transactions with Afcoms Sarl.

Compliance with this policy and all applicable anti-corruption laws is essential for both your protection and that of Afcoms Sarl. Here are the reasons why each of us must comply:

corporate culture: corruption is totally contrary to the culture of continuous improvement, irreproachable behavior and intellectual honesty. Complying with this policy is vital to maintaining this culture;

reputation: an image, a reputation and a position can be very easily tarnished or destroyed by any violation of the law or of this policy. It would also impact the trust and relationships that Afcoms Sarl has established in the market with its customers and other stakeholders since 2021;

legal obligations: according to law, Afcoms Sarl will be found guilty if the company does not take the necessary measures to prevent acts of corruption being caused by its employees or subcontractors;

criminal sanctions: in most countries’ corruption is a criminal act. Misconduct can occur even if the offense occurred abroad. Property resulting from an act of corruption can also be seized;

Civil sanctions: in many jurisdictions, those who have incurred damage or loss of contract because of an act corruption can claim compensation for such damage;

Investigations: Investigations of suspected crimes can be a waste of society's time and money and cause bad publicity;

Disciplinary Proceedings: Any failure to comply with this policy, or any procedure for enforcing this policy, will be treated as a serious matter by Afcoms Sarl and may result in disciplinary action and a report to the appropriate authorities. If a business partner does not comply with this policy, Afcoms Sarl will consider terminating their partnership.

Corruption: definitions
Corruption is the act of promising, offering, giving, demanding or accepting, directly or through a third party, any advantage aimed at inducing or rewarding inappropriate behavior (illegal, unethical or breach of an obligation).
Corruption is evident even if the corruption process fails or does not have the desired effect. The “benefits” may or may not be financial and include the following:

money, loans, donations (including to charities), contract award, employment contracts, consultancy contracts, preferential treatment, confidential information, gifts and hospitality, vacations;

any other advantage or benefit intended, or perceived, to be of value to the recipient or another close person.

The act of corruption can be committed by:

any Afcoms Sarl employee, regardless of seniority or rank, regardless of location in the world;

any other person performing services on behalf of Afcoms Sarl anywhere in the world (third parties such as agents, intermediaries, subcontractors and suppliers).

Corruption can occur in both the public and private sectors.
Alarm signals:

unusually high commissions or unusual payment methods;

third parties about which we have little information. Example: a murky transaction history, with information very limited or inaccessible or recently created;

third parties appearing to be underqualified or having insufficient human resources, specified or recommended by public officials;

repeated or excessive examples of gifts and hospitality;

requests to hide / cover unusually high expenses, or expenses of relationships or family members;

reception unrelated to a promotion or demonstration of products or services;

a history or perception of corruption in the country in question;

payments to or from officials or individuals who may be politically exposed.

Afcoms Sarl Policy
Afcoms Sarl has a zero tolerance policy regarding corruption, as follows:

employees, including contractors, should never promise, offer or pay any benefits;

they should never demand or accept a bribe;

no employee will be the victim of demotion, sanctions or other negative consequences for refusing to pay or receive bribes, even if the refusal may result in a loss of transaction for Afcoms Sarl;

Our Policy controls the giving and acceptance of gifts, hospitality / entertainment, charitable donations or sponsorship.

Conflicts of interest
Afcoms Sarl employees must act in such a way as to avoid any conflict of interest:

private arrangements for goods and services for personal use acquired through Afcoms Sarl purchasing services;

private arrangements regarding the use of discount conditions unless this has been formally negotiated by Afcoms Sarl as a benefit to staff and was advertised as available to all staff;

an employee or agent whose role involves negotiating or authorizing a contract with a third party must immediately declare any shareholding in this third-party company, its holding company, its subsidiaries or associated companies, unless the shareholding either in a listed company and that it represents less than 5% of the issued share capital;

employees cannot authorize payment of company funds to an external organization or charity of which they are shareholders, member of the board of directors, director or other employee;

business decisions, including appointments and contract awards, must not be influenced by a personal, family or other relationship, or by membership in any religious, social or political association.

Business transactions and contacts
Any transaction with companies or private individuals, officials, must remain clear and transparent and be conducted in a correct and adequate manner.
Afcoms Sarl can be held responsible for the actions of agents, intermediaries, and other business partners (including suppliers and subcontractors), therefore:

Afcoms Sarl works only with agents, intermediaries and other business partners who have been approved by the general management of the company;

any remuneration payable to agents or other business partners acting on behalf of Afcoms Sarl must correspond to the services performed as determined objectively;

payments must be made by legal means;

facilitation payments made to an official to ensure or accelerate the execution of a routine or necessary action to which the payer has a legal or other right, such as obtaining a permit, license, visa, are illegal payments and are in no way acceptable. It is Afcoms Sarl 's policy to keep transparent and accurate financial records, records and reports.

Important
If you know that an act of corruption has taken place, or suspect it has taken place, within (or in connection with) Afcoms Sarl, you should immediately notify Management.
Afcoms Sarl is committed to ensuring that employees can report their concerns in confidence. All reports are taken seriously and we will investigate accordingly; retaliation against an employee for reporting a problem is strictly prohibited.
You should also contact Management if you have general questions about this Policy, or how the rules apply in specific circumstances.