Anti-Corruption Policy
KPpay Platform
Message from Management
Dear Colleagues and Partners,
KPpay is firmly committed to conducting its business activities with integrity and transparency in all markets where we operate. As an innovative digital financial services platform, KPpay aspires to be a leader in transaction digitization, adhering strictly to ethical and regulatory standards. We adopt a zero-tolerance policy towards all forms of corruption and expect every member of our organization to uphold this commitment.
Objective and Scope
This policy provides a framework for all employees, partners, suppliers, consultants, and stakeholders of KPpay. It defines the principles and expected behaviors to prevent and combat corruption in all its forms, including influence peddling, bribery, and facilitation payments. This policy applies to all KPpay entities in every country where it operates.
Our anti-corruption policy aligns with international anti-corruption conventions, including those of the African Union and the United Nations, as well as national laws in the countries where KPpay operates.
1. Definition of Corruption and Influence Peddling
Corruption
Corruption is any act of offering, promising, giving, or soliciting, directly or indirectly, an undue advantage to influence an act in the course of professional duties or to reward such an act.
Influence Peddling
Influence peddling involves soliciting or accepting, directly or indirectly, an advantage to use one's real or supposed influence to obtain favorable decisions from a public or private authority.
2. Zero-Tolerance Principle
KPpay enforces a zero-tolerance policy on corruption and influence peddling. Under no circumstances should an employee or a third party acting on behalf of KPpay:
- •Offer or accept payments, gifts, commissions, travel, invitations, or any form of gratification in exchange for an undue advantage or as a reward for such an advantage.
- •Make facilitation payments to a public official or intermediary to expedite a routine process.
- •Yield to extortion demands under pressure, unless life, health, or freedom is threatened. In such cases, the incident should be reported as soon as possible.
3. Gifts and Hospitality Policy
To prevent corruption risks or conflicts of interest, KPpay strictly regulates gifts and hospitality:
- •Gifts and Invitations: Giving or receiving gifts and hospitality should be reasonable, professional, and not intended to influence a transaction or business decision. Cash gifts are strictly prohibited.
- •Thresholds and Declaration: Any gift or invitation exceeding a defined threshold must be reported to the Compliance Officer. A gift registry will be maintained to ensure complete traceability of benefits received or offered.
4. Awareness and Training
KPpay is committed to regularly training its employees on corruption risks and the procedures to follow:
- •Mandatory Training: All employees, especially those exposed to corruption risks, must attend training sessions to identify, prevent, and report any suspicious activities.
- •Partner Awareness: KPpay also educates its partners, subcontractors, and consultants on this policy to ensure they adhere to the same standards of conduct.
5. Reporting and Alert System
KPpay encourages employees to report any suspicion of corruption or influence peddling through a secure alert system:
- •Reporting Channel: Any suspicion of corruption should be reported via the dedicated email alert.compliance@kppay.co. The anonymity and confidentiality of the whistleblower's identity are guaranteed.
- •Whistleblower Protection: No employee will face discrimination or punishment for reporting an alert in good faith. However, any misuse of the alert system will be subject to disciplinary action.
6. Conflicts of Interest
Conflicts of interest must be avoided to maintain the integrity of decisions made by KPpay:
- •Identification and Prevention: Every employee is required to declare any real or potential conflicts of interest to the Compliance Officer.
- •Conflict Management: A conflict-of-interest management system is in place to ensure impartial decision-making and protect KPpay's interests.
7. Sponsorships, Donations, and Lobbying
- •Sponsorships and Donations: Sponsorship and donation initiatives adhere to ethical standards and aim to contribute to community development without expecting any undue reciprocation.
- •Lobbying: All lobbying activities are conducted transparently, in compliance with regulations, and without any behavior that could be perceived as corruption.
8. Risk Mapping and Third-Party Assessment
- •Risk Mapping: KPpay maintains a risk map of corruption, which is updated periodically to identify risk areas in its operations.
- •Third-Party Due Diligence: Thorough due diligence procedures are conducted to evaluate the compliance of partners and suppliers with anti-corruption standards.
9. Internal Controls and Accounting
Strict internal controls are in place to detect and prevent any act of corruption:
- •Compliance Controls: Enhanced control processes are implemented to ensure all activities comply with anti-corruption standards.
- •Accounting Transparency: All accounts, invoices, and transaction-related documents are maintained accurately and comprehensively to avoid fraudulent manipulation.
10. Archiving and Document Management
Data and documents demonstrating the application of the anti-corruption policy are archived to ensure full traceability and demonstrate KPpay's compliance.
11. Management of the Anti-Corruption Policy
The Ethics and Compliance Committee of KPpay is responsible for ensuring the implementation and effectiveness of this policy:
- •Chief Compliance Officer's Responsibility: The Chief Compliance Officer, in collaboration with compliance teams, oversees the deployment and monitoring of the policy's effectiveness.
- •Continuous Improvement: This policy is reviewed periodically to incorporate best practices and adapt to regulatory changes.