EBC Anti-Corruption and Bribery Policy
1. Purpose
EBC is committed to conducting its business ethically and in compliance with all applicable laws and regulations related to anti-corruption and bribery. This policy outlines our stance on corruption and bribery and provides guidance to all employees, partners, and stakeholders to ensure integrity in all business dealings.
2. Scope
This policy applies to all employees, contractors, consultants, and any third parties acting on behalf of EBC. It covers all activities related to EBC’s operations, regardless of the country in which they occur.
3. Definition of Corruption and Bribery
Corruption: The abuse of entrusted power for personal gain.
Bribery: Offering, promising, giving, or receiving any financial or other advantage to influence a decision or gain improper advantage.
4. Policy Statements
4.1. Prohibition of Bribery
EBC strictly prohibits the offering, giving, soliciting, or receiving of bribes or any other improper advantages, whether directly or indirectly, as part of any business activities. This includes:
- Payments to expedite routine tasks (facilitation payments).
- Gifts or hospitality that are intended to influence decision-making.
4.2. Gifts and Hospitality
While reasonable gifts and hospitality can be part of legitimate business relationships, any such exchanges must be transparent and not intended to influence a business outcome. EBC employees must avoid accepting or offering gifts or hospitality that could create a conflict of interest or the appearance of impropriety.
4.3. Facilitation Payments
EBC does not permit the use of facilitation payments. Employees must avoid making payments to secure or expedite any action by a public official or government employee.
4.4. Third Parties
EBC expects all third parties, including agents, suppliers, and business partners, to adhere to the same anti-bribery and anti-corruption standards. All third-party relationships must be subjected to appropriate due diligence to ensure compliance with this policy.
4.5. Charitable Donations and Sponsorships
All charitable donations or sponsorships made by EBC must be transparent and not used as a way to gain undue influence or favor. Any donations must be approved by senior management.
5. Responsibilities
Employees: All employees are required to read, understand, and comply with this policy. Employees are responsible for reporting any suspicion of bribery or corruption in connection with EBC’s operations.
Management: Senior management is responsible for enforcing and monitoring compliance with this policy, providing training, and ensuring that anti-bribery measures are integrated into business processes.
6. Reporting Violations
Any employee who becomes aware of an act of bribery or corruption is required to report it immediately. Reports can be made to a line manager or anonymously through the company’s whistleblowing policy. Retaliation against whistleblowers is strictly prohibited.
7. Compliance and Consequences
Violations of this policy will be treated as serious misconduct and may lead to disciplinary action, including termination of employment or contract. EBC will fully cooperate with authorities in any investigation related to bribery or corruption.
8. Monitoring and Review
EBC will regularly review and update this policy to ensure it continues to meet legal requirements and reflects best practices. Internal audits will be conducted to assess compliance.
9. Legal Framework
This policy aligns with Ugandan anti-corruption laws and international standards, such as the UK Bribery Act and the U.S. Foreign Corrupt Practices Act (FCPA), to ensure global compliance where applicable.