1. Introduction
Carmedis Limited is committed to maintaining the highest standards of integrity, ethics, and lawful conduct in all business activities.
This Anti-Corruption and Anti-Bribery Manual establishes a zero-tolerance approach to bribery, corruption, fraud, facilitation payments, kickbacks, and other unethical practices.
2. Scope
This manual applies to:
- Directors
- Employees
- Contractors
- Consultants
- Agents
- Suppliers
- Business partners
- Any person acting on behalf of Carmedis
3. Zero-Tolerance Policy
Carmedis prohibits all forms of bribery and corruption, whether involving public officials, private individuals, suppliers, customers, or other third parties.
No employee or representative may directly or indirectly offer, promise, authorize, request, receive, or accept any improper benefit intended to influence a business decision.
4. Definition of Bribery
Bribery includes:
- Offering money to secure business advantages.
- Providing gifts or hospitality to improperly influence decisions.
- Paying kickbacks to obtain contracts.
- Offering favors in exchange for preferential treatment.
- Concealing improper payments through false records.
5. Prohibited Conduct
The following activities are strictly prohibited:
Bribes and Kickbacks
- Giving or receiving bribes.
- Offering kickbacks or secret commissions.
- Providing payments to influence procurement decisions.
Facilitation Payments
- Small unofficial payments intended to expedite government or administrative processes.
Fraudulent Transactions
- False invoicing.
- Misrepresentation of expenses.
- Manipulation of company records.
Improper Gifts and Hospitality
- Gifts intended to secure unfair business advantages.
- Excessive entertainment or hospitality.
6. Third-Party Relationships
Before engaging suppliers, contractors, consultants, or agents, Carmedis shall take reasonable steps to ensure that such parties:
- Operate lawfully and ethically.
- Have no known history of corruption.
- Agree to comply with Carmedis ethical standards.
Contracts may be terminated where corruption concerns arise.
7. Books and Records
All transactions must be:
- Accurately recorded.
- Supported by appropriate documentation.
- Approved according to company procedures.
No undisclosed accounts, off-book transactions, or false records shall be maintained.
8. Reporting Concerns
Employees and stakeholders are encouraged to report:
- Suspected bribery.
- Fraudulent activities.
- Ethical misconduct.
- Violations of company policies.
Reports may be made confidentially without fear of retaliation.
9. Investigation Process
All reported concerns shall be:
- Reviewed promptly.
- Investigated objectively.
- Documented appropriately.
- Escalated to management where necessary.
- Addressed through corrective actions.
10. Protection Against Retaliation
No employee shall suffer retaliation, discrimination, harassment, or adverse treatment for reporting concerns in good faith.
11. Training and Awareness
Carmedis shall periodically provide awareness and training on:
- Ethics and compliance.
- Anti-bribery obligations.
- Reporting mechanisms.
- Conflict of interest management.
12. Disciplinary Measures
Violations of this manual may result in:
- Verbal or written warnings.
- Suspension.
- Termination of employment.
- Termination of contracts.
- Referral to law enforcement authorities.
13. Compliance Contact
Compliance Officer:
Operations & Administration Manager
Email:
hello@carmedis.com
Telephone:
+234 803 898 5410
Website:
www.carmedis.com
14. Policy Review
This manual shall be reviewed annually by management to ensure continued effectiveness and compliance with applicable laws and industry best practices.
Effective Date: January 1, 2026
Approved By: Management, Carmedis Limited