Anti-Corruption Policy

Onyeisi Group Ltd (RC: 1994390) is committed to conducting all of its business activities with the highest standards of integrity, honesty, and transparency. We have a zero-tolerance approach to bribery and corruption in all its forms. This policy applies to all directors, employees, consultants, contractors, agents, and any other persons who act on behalf of Onyeisi Group Ltd in any capacity. Compliance with this Policy is mandatory.

• This Policy applies to Onyeisi Group Ltd and all of its subsidiary companies, affiliated businesses, and joint ventures.
• It applies to all business activities conducted in Nigeria and in any other jurisdiction where the Group operates or seeks to operate.
• It covers all transactions, regardless of value, with public officials, private sector counterparts, government agencies, and regulatory bodies.
• The Policy applies equally to direct and indirect acts of corruption, including acts carried out through third-party intermediaries.

• Offering, promising, giving, requesting, agreeing to receive, or accepting any bribe, kickback, or improper payment in any form.
• Providing or accepting gifts, hospitality, or entertainment that could reasonably be perceived as influencing a business decision or creating a conflict of interest.
• Making or approving payments to government officials, regulatory authorities, or their family members to obtain or retain business or any improper advantage.
• Using third parties (agents, consultants, or distributors) to route improper payments that we ourselves would not be permitted to make.
• Creating false or misleading records, invoices, or financial documents to disguise corrupt transactions.
• Retaliating against any person who raises a concern or makes a report in good faith under this Policy.

Facilitation payments are small unofficial payments made to public officials to speed up routine government actions. Onyeisi Group Ltd strictly prohibits all facilitation payments, regardless of their size, local custom, or business impact. If any person is asked to make a facilitation payment, they must refuse and report the incident immediately through our reporting channels.

• Gifts and hospitality can be legitimate tools for building business relationships, but they must never be used to improperly influence decisions.
• Gifts to or from business partners must be of nominal value, appropriate to the occasion, transparent, and not given or received during sensitive periods (such as contract negotiations or procurement processes).
• Cash gifts, loans, or gifts of significant monetary value are prohibited.
• All gifts above a reasonable threshold (as defined by management guidelines) must be declared and approved by a director.
• When in doubt about whether a gift or act of hospitality is appropriate, seek guidance from a director before proceeding.

We recognize that our reputation can be affected by the conduct of those who act on our behalf. Before engaging any agent, consultant, joint venture partner, distributor, or other third-party representative, we conduct appropriate due diligence to assess their integrity and compliance standards. All third-party contracts must include anti-corruption clauses, and we reserve the right to terminate any agreement where a third party engages in corrupt conduct.

Onyeisi Group Ltd does not make political donations or contributions of any kind on behalf of the company. Individual employees may make lawful personal political donations but must ensure these are entirely separate from their activities on behalf of the Group and do not give rise to any conflict of interest.

We maintain accurate and complete books, records, and accounts that fairly reflect all transactions and disposals of assets. No false, misleading, or incomplete entries may be made for any reason. All expense claims, invoices, and financial records must be documented honestly, accurately, and in sufficient detail to allow proper audit and review.

• Any person who suspects or becomes aware of a violation of this Policy must report it promptly.
• Reports can be made to a director, a member of senior management, or via email to [email protected].
• All reports will be treated as confidential to the greatest extent possible consistent with the need to investigate the matter.
• Onyeisi Group Ltd strictly prohibits retaliation against anyone who raises a concern in good faith, even if the concern turns out to be unfounded after investigation.
• Anonymous reports will be accepted and investigated to the extent possible given the information provided.

Any breach of this Policy is a serious matter and may result in disciplinary action up to and including termination of employment or contract, recovery of losses, and referral to law enforcement authorities. Corruption is a criminal offense under Nigerian law and in many other jurisdictions. Individuals found guilty of bribery or corruption may face criminal prosecution, significant fines, and imprisonment.

• This Policy is designed to ensure compliance with applicable anti-corruption laws, including the Corrupt Practices and Other Related Offences Act (ICPC Act), Nigeria.
• The Economic and Financial Crimes Commission (Establishment) Act (EFCC Act), Nigeria.
• The Money Laundering (Prohibition) Act, Nigeria.
• Where the Group conducts business internationally, we also observe the principles of the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act (FCPA) to the extent applicable.

All directors, employees, and relevant third parties will receive appropriate training on this Policy. The Policy will be communicated clearly across the Group and made available on our website. We will review and update this Policy periodically to reflect changes in law and best practice.

The Board of Directors of Onyeisi Group Ltd holds overall responsibility for this Policy and for ensuring that appropriate systems are in place to prevent bribery and corruption. Questions about this Policy or any ethics concern should be addressed to the Board at: [email protected], or by post to 4 Meru Close, by FADAMA House, Off Aminu Kano Crescent, Wuse 2, Abuja, Nigeria.