RAYMFIELD UGANDA LIMITED · REGISTERED IN UGANDA

RAYMFIELD UGANDA LIMITED

Anti-Bribery & Corruption Policy

The company’s standards of conduct.

1. Purpose and scope

Raymfield Uganda Limited does not tolerate bribery or corruption in any form, in any country. This policy applies to our directors, employees, consultants, agents and anyone else acting for us.

2. What is prohibited

  • Offering, promising, giving, asking for or accepting anything of value to influence a business or official decision improperly.
  • Kickbacks, secret commissions and payments to win or keep business.
  • Facilitation payments, meaning small payments to speed up routine official action.
  • Any benefit to a public official connected with a tender, licence, customs clearance or inspection.

3. Gifts, hospitality and donations

  • Gifts and hospitality must be modest, infrequent, open and never given or received during a tender or evaluation.
  • Cash or cash equivalents are never acceptable.
  • Gifts given or received must be recorded, and approval sought where required.
  • Political donations are not made. Charitable donations need the directors’ approval and must never be linked to a business decision.

4. Agents, intermediaries and suppliers

  • We check the background and reputation of any agent or intermediary before appointing one.
  • Agents work under a written contract that includes an anti-bribery clause and a right to audit.
  • No success fee is paid to an intermediary without the directors' approval.

5. Records and payments

  • Every payment is recorded accurately, with its purpose.
  • Payments go only to the bank account of the named contracting party, never to third parties or to cash.
  • There are no unrecorded accounts or payments.

6. Warning signs

Stop and raise a concern if you see: a request for cash or an unusual payment route, a supplier or agent recommended by an official, a commission that seems too high for the work, or a refusal to put terms in writing.

7. Reporting

Report suspected bribery through the Whistleblowing page. No one will be penalised for a report made in good faith, or for refusing to pay a bribe even if that costs us business.

8. Consequences

Breaches may lead to dismissal, ending of contracts and referral to the authorities.

9. Laws that apply

Among others, Uganda's Anti-Corruption Act, 2009 and Kenya's Bribery Act, 2016, together with the anti-bribery laws of any other country that applies to us or to our counterparties.