ANTI-BRIBERY AND ANTI-CORRUPTION DEFINITION AND …

ANTI-BRIBERY AND ANTI-CORRUPTION DEFINITION AND INTERPRETATION "Bribery" ?the act or practice of giving or taking bribes; the act of influencing the official or political action of another by corrupt inducements

1) BACKGROUND Stuttafords Zambia Limited as a FIDI member subscribes against bribery and corruption of any form within the international moving industry. This is not only meant to protect its company but also to protect all its partners, stakeholders, affiliates and its customers.

2) CONTROL AND SECURITY POLICY In order to guarantee security within its supply chain, Stuttafords Zambia Limited is committed with safe and correct procedures and compliance with the law. This is achieved through the engagement of business partners, compliance with all legal requirements, identification and treatment of risks and continuous engagement of the FIDI systems.

Stuttafords Zambia Limited has zero tolerance for criminal activities such as; smuggling, piracy, theft, money laundering, drug related activities, terrorism and any other activities such as tax evasions that may affect the integrity of the business.

3) BRIBERY Bribery is the offering, promising, giving, accepting and or soliciting of an advantage as an inducement for action. It is illegal and breach of trust.

A bribe: is an inducement or reward offered, promised or provided in order to gain a commercial, contractual, regulatory or personal advantage.

4) ACTION AGAINST BRIBERY AND CORRUPTION Stuttafords Zambia Ltd has taken a stance against bribery and corruption of any sort. Management and staff are conscious of this and pledge to work with all stakeholders at all times in order to create a fair business environment free of the vice.

Directors: J.Murape (Managing Director), P.T.Makoni, T.R.Makoni, MK Achiume (SC)

Procedures to follow; Do not give any bribe for services or goods offered Do not accept any bribe that maybe in the form of a gift, money or offers for meals and

entertainment Report to Stuttafords Zambia Ltd management on +260 211 240412 Do not accept unreasonable discounts Job offers in order to influence decisions Political contributions Payment of travel expenses and paid holidays

5) COMMITMENTS Stuttafords (Z) Ltd makes firm commitment to ethical and legal behavior, which should be to refuse to participate in any action that will harm the interests of FIDI, other affiliates, customers and or the industry at large. Effective compliance will be verified by the policy and regulatory framework and action will be taken in case of non- compliance. LEGAL COMPLIANCE FIDI AFFLILIATES will ensure that they are aware of all applicable laws countering bribery and corruption in the entire jurisdiction in which they operate and that they will obey and uphold those laws

The laws that apply to particular international business activities include those of the countries in which the activities occur as well as others that ? like the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010 ? govern the international operations of national companies and citizens in respect of their conduct both at home and abroad

Directors: J.Murape (Managing Director), P.T.Makoni, T.R.Makoni, MK Achiume (SC)

ETHICAL BEHAVIOUR As a demonstration of its commitment, FIDI and its Affiliates pledge to take a zero-tolerance approach to bribery and corruption. At all times, FIDI and its Affiliates will act professionally, fairly and with the utmost integrity in all business dealings and relationships. This will apply wherever they operate.

6) CODE OF CONDUCT Stuttafords personnel undertakes to: 1. Never engage in any form of bribery, either directly or through any third party. 2. Never offer or take an improper payment, or authorize an improper payment (cash or otherwise) to any individual, including any local or foreign official anywhere in the world. 3. Never attempt to induce an individual or a local or foreign official to act illegally or improperly. 4. Never offer, or accept, money or anything of value, such as gifts, kickbacks or commissions, in connection with the procurement of business or the award of a contract. 5. Never offer or give any gift or token of hospitality to any public employee or government official or representative if there is any expectation or implication for return favor. 6. Never accept any gift from any business partner if there is any suggestion that a return favor will be expected or implied. 7. Never facilitate payments to obtain a level of service which one would not normally be entitled to. 8. Never disregard or fail to report any indication of improper payments to the appropriate authorities. 9. Never induce or assist another individual to break any applicable law or regulations.

This document is legal and is posted on our website for easy access to all Stuttafords Zambia Ltd' stakeholders.

Directors: J.Murape (Managing Director), P.T.Makoni, T.R.Makoni, MK Achiume (SC)

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