Anti-Corruption Policy

Anti-Corruption Policy (Website Version)

DSKAY Technologies Zimbabwe (PVT) LTD (“DSKay”, “we”, “us”, “our”)

1. Purpose

DSKay is committed to operating with integrity, transparency, and zero tolerance for bribery and corruption. This Policy sets out the standards that govern how we prevent, detect, and respond to corruption risks in our operations and business relationships.

2. Scope

This Policy applies to all DSKay employees, directors, officers, contractors, consultants, agents, intermediaries, suppliers, and business partners acting for or on behalf of DSKay (collectively, “Representatives”), in Zimbabwe and internationally.

3. Definitions

• Corruption / Bribery: Offering, giving, requesting, or accepting anything of value to improperly influence a decision or secure an unfair advantage.
  
  

• Facilitation Payment: An unofficial payment made to expedite or secure routine government action.
  
  

• Gift / Hospitality: Anything of value offered or received, including cash equivalents, discounts, travel, meals, accommodation, entertainment, or services.
  
  

4. Policy Statement

DSKay prohibits all forms of bribery and corruption, including:

• bribes (direct or indirect);
  
  

• kickbacks and secret commissions;
  
  

• facilitation payments;
  
  

• fraudulent invoicing, false claims, or misrepresentation; and
  
  

• abuse of position for personal or third-party gain.
  
  

5. Compliance with Laws and Standards

All Representatives must comply with applicable anti-corruption laws and recognized international standards, including principles aligned with the United Nations Convention against Corruption (UNCAC). Where local practice conflicts with this Policy, this Policy prevails.

6. Gifts, Hospitality, and Business Courtesies

6.1 Gifts and hospitality must be:

• reasonable, infrequent, and proportionate;
  
  

• transparent and properly recorded; and
  
  

• never intended to influence business decisions.
  
  

6.2 Strict prohibitions:

• cash or cash equivalents (gift cards, vouchers, mobile money credits);
  
  

• gifts/hospitality offered during active tendering or procurement decisions; and
  
  

• anything offered to government officials without prior written approval and clear documentation.
  
  

6.3 DSKay maintains a Gifts & Hospitality Register. Any gift or hospitality above a nominal value must be disclosed and pre-approved in line with internal controls.

7. Conflicts of Interest

Representatives must avoid conflicts between personal interests and DSKay’s interests. Any actual or potential conflict (e.g., family relationships with suppliers, undisclosed financial interests, outside work affecting decisions) must be disclosed promptly.

8. Third-Party Due Diligence

DSKay applies a risk-based approach to due diligence on suppliers, agents, contractors, and partners. DSKay may refuse or terminate relationships where corruption risk is unacceptable or where cooperation with compliance controls is not provided.

9. Accurate Records and Controls

All transactions must be recorded accurately and supported by legitimate documentation. Off-book accounts, false invoices, misleading descriptions, or undocumented payments are prohibited. Payments must follow approved procurement and finance processes.

10. Reporting and Whistleblower Protection

DSKay encourages reporting of suspected bribery or corruption. Reports may be made confidentially through DSKay’s reporting channels. Retaliation against anyone who raises a concern in good faith is strictly prohibited.

11. Investigation and Enforcement

DSKay will investigate credible allegations promptly, fairly, and confidentially to the extent possible. Breaches of this Policy may result in disciplinary action, termination of contracts, and referral to law enforcement where appropriate.

12. Training and Awareness

DSKay provides periodic awareness and training proportionate to role and risk exposure, with a focus on procurement, finance, site operations, and third-party management.

13. Review and Updates

This Policy is reviewed periodically and may be updated to reflect changes in law, risk profile, or operational requirements. Updated versions will be published or communicated as appropriate.

14. Report Concerns

Report any suspected bribery, corruption, fraud, or unethical conduct confidentially to: info@dskay.co.zw (Subject: “Anti-Corruption Report”). Please include relevant dates, parties involved, and any supporting evidence where available. DSKay will handle reports discreetly and will not tolerate retaliation against anyone who raises a concern in good faith.