Anti-Corruption and Bribery

Policy
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Anti-Corruption and Bribery Admin March 5, 2025
  1. Purpose

Africa Transcribe Enterprises (hereinafter “ATE”) is committed to conducting its operations with integrity, transparency, and accountability. This Anti-Corruption and Bribery Policy (the “Policy”) establishes our zero-tolerance stance on bribery and corruption in all forms. It ensures compliance with Tanzanian laws, including the Prevention and Combating of Corruption Act, 2007 (PCCA), as well as international anti-corruption standards, while aligning with our mission to empower communities and foster sustainable development across Africa.

This Policy applies to all ATE employees, directors, consultants, contractors, agents, partners, and any third parties acting on behalf of ATE. It supplements all applicable national and international anti-corruption laws and provides guidelines to ensure ethical business practices.

  1. Scope

This Policy governs ATE’s activities across all regions of operation, with a particular focus on compliance with Tanzanian laws where we are registered, and international standards applicable to our cross-border engagements. It extends to our interactions with small-scale miners, communities, non-governmental organizations (NGOs), government agencies, and private sector partners.

  1. Policy Statement

ATE prohibits all forms of bribery and corruption, whether involving public officials, private individuals, or entities. We are dedicated to upholding the highest standards of ethical conduct and fostering a culture of integrity in all our dealings. Any violation of this Policy will result in disciplinary action, including potential termination, and may be reported to the relevant authorities for investigation and prosecution under applicable laws.

  1. Legal Framework

This Policy is informed by:

  • Tanzanian Laws: The Prevention and Combating of Corruption Act, 2007 (PCCA), alongside related legislation such as the Anti-Money Laundering Act, 2006, and the Public Procurement Act, 2011.
  • International Standards: The United Nations Convention Against Corruption (UNCAC), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and other relevant frameworks.
  1. Definitions
  • Bribery: Offering, promising, giving, accepting, or soliciting any advantage (financial or otherwise) to improperly influence actions or decisions, without lawful consideration or for inadequate consideration.
  • Corruption: The abuse of entrusted power for private gain, including bribery, extortion, fraud, and embezzlement.
  • Public Official: Any person holding a legislative, administrative, or judicial office, or acting in an official capacity for a government or public institution, as defined under the PCCA.
  • Facilitation Payments: Small payments made to expedite routine governmental actions. These are considered bribes under this Policy and are strictly prohibited.
  1. Key Principles

ATE adheres to the following principles:

  • Zero Tolerance: ATE does not tolerate bribery or corruption in any form, whether direct or through intermediaries.
  • Prohibited Activities: Employees and representatives shall not:
    • Offer, promise, or provide any payment, gift, or advantage to influence a decision or secure improper benefits.
    • Solicit or accept any advantage that compromises integrity or impartiality.
    • Make facilitation payments, regardless of local customs or practices.
  • Gifts and Hospitality: Reasonable and proportionate gifts or hospitality intended to build relationships or promote ATE’s mission are permitted, provided they:
    • Are not intended to improperly influence the recipient.
    • Comply with local laws and this Policy.
    • Are recorded transparently in ATE’s records.
  • Charitable Contributions: Donations must align with ATE’s mission, be transparent, and not serve as a disguise for bribery or undue influence.
  • Third Parties: All partners, contractors, and agents acting on behalf of ATE must comply with this Policy. ATE will conduct due diligence to ensure third-party integrity
  1. Responsibilities
  • Management: The leadership team is responsible for promoting a culture of compliance, providing training, and ensuring resources for Policy enforcement.
  • Employees and Representatives: All individuals must read, understand, and comply with this Policy, reporting any suspected violations promptly.
  • The Administrative and Operations Lead (AOL): A designated AOL will oversee compliance, investigate reports, and provide quarterly summaries to ATE’s leadership.
  1. Reporting and Whistleblowing
  • ATE encourages reporting of any known or suspected violations of this Policy. Reports should be made to the CEO via: complaints@africatranscribe.co.tz or call the +255 765 531 39.
  • ATE guarantees protection against retaliation for individuals reporting in good faith. Allegations of retaliation will be investigated, and appropriate action taken.

All reports will be confidentially reviewed, documented, and investigated as necessary.

  1. Record-Keeping and Internal Controls
  • ATE will maintain accurate records of all transactions, gifts, hospitality, and charitable contributions.
  • A register of attempted or actual corrupt approaches will be maintained and reviewed by the AOL.
  • Financial checks and audits will be conducted regularly to detect and prevent corrupt practices.
  1. Training and Awareness
  • ATE will provide mandatory anti-corruption training to all employees and representatives annually, with additional tailored sessions for high-risk roles (e.g., those engaging with government agencies).
  • Cultural competency training will include modules on ethical conduct and anti-corruption practices in African contexts.
  1. Consequences of Non-Compliance
  • Violations of this Policy by ATE employees may result in disciplinary action, up to and including termination, and referral to authorities under the PCCA or other applicable laws.
  • Third parties found in breach may face termination of contracts and exclusion from future collaboration with ATE.
  • Under the PCCA, individuals convicted of bribery may face imprisonment (3-7 years), fines, or forfeiture of proceeds of crime.
  1. Monitoring and Review
  • The AOL will monitor compliance and report findings to ATE’s leadership quarterly.
  • This Policy will be reviewed annually or as needed to reflect changes in laws, organizational priorities, or operational contexts.
  1. Commitment to Stakeholders

ATE’s dedication to anti-corruption aligns with our vision of a thriving Africa built on sustainable practices and empowered communities. By adhering to this Policy, we strengthen trust with our partners – small-scale miners, NGOs, government agencies, and private sector entities – and contribute to a transparent and equitable future.

 

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