Anti-Bribery & Anti-Corruption Policy

1       Introduction

West Blue Consulting Limited (hereinafter referred to as WBC or the Company) takes an uncompromising stance on bribery and corruption. The Company seeks to conduct all its businesses in an honest, lawful, and ethical manner, devoid of bribery and corruption. The Company has zero-tolerance for bribery and corruption and is committed to acting professionally, fairly and with integrity in all its relationships and business dealings wherever it operates. In addition, the Company is committed to implementing and enforcing effective systems to counter bribery and corruption.

This Anti-Bribery and Anti-Corruption Policy (the Policy) sets out the Company’s policies and procedures aimed at preventing acts of bribery and corruption and has been designed in compliance with international standards and domestic legislation governing bribery and corruption,  including:

  1. The Whistle-blower Act, 2006 (Act 720).
  2. Anti-Money laundering Act, 2008 (Act 749) as amended
  3. Public Procurement Act, 2003 (Act 663); and
  4. Income Tax Act, 2015 (Act 896) as amended
  5. ISO 37001:2016 ABMS

This Policy provides guidance on the standards of behaviour to which all Employees must adhere, which standards also reflect common sense and good business practices that must be adopted. It is also designed to help Employees identify prohibited practices so that bribery and corruption is avoided. The Policy also provides the needed guidance whenever Employees are in doubt as to whether an act constitutes bribery and/or corruption.

1.1      What does the Policy Cover?

  • This anti-bribery policy exists to set out the responsibilities of West Blue Consulting and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption.
  • It also exists to act as a source of information and guidance for those working for West Blue Consulting. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
  • This Policy applies to all Managers, Officers, Employees (permanent, temporary and Contract), Directors, Intermediaries (Corporate Agents), family members, third party service providers/consultants and contractors, outsourced staff working for and on behalf of the Company, irrespective of where they are located. Compliance with this Policy constitutes terms of service for each director, conditions of employment for each manager, officer and employee, and conditions of providing services to WBC for each consultant and contractor. Each such person agrees to be bound by the provisions of this Policy upon notification of the most recent copy being given to them or upon notification that an updated version has been placed on WBC’s website for review.
  • This Policy extends across all the Company’s business dealings and in all countries and territories in which the Company operates. All persons covered by this Policy, in discharging their duties on behalf of WBC, are required to comply with the laws, rules and regulations applicable in the location in which WBC is performing business activities, and in particular with respect to anti-bribery and anti-corruption laws, rules and regulations. Where uncertainty or ambiguity exists, please contact the Compliance Officer who may seek further legal advice.
  • The Policy further applies to dealings with both the public and private sectors.

1.2      Responsibilities Under the Policy

All directors, officers, Employees, consultants, and contractors are expected to understand and comply with the Policy and applicable laws in all business dealings throughout the Company’s operational jurisdiction. They must always act with the utmost level of work ethics and integrity and avoid any impression of misconduct.

All directors, officers, employees, consultants, and contractors of WBC must participate in all training provided by the Company.

The prevention, detection and reporting of bribery offences and other forms of corruption are the responsibility of all those working for WBC or under its control. All such persons are required to avoid any activity that might lead to, or suggest, a breach of this Policy.

If you are asked to make a payment on the Company’s behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Compliance Officer, wherever possible, prior to taking any action.

All directors, officers, employees, consultants and contractors of WBC must notify the Compliance Officer or make a disclosure under WBC’s Whistle Blower Policy (see Section 11 below) as soon as possible if they believe or suspect that an action in conflict with this Policy has occurred, or may occur in the future, or has been solicited by any person.

When in doubt about a particular action or conduct, you must consider the following questions:

  • Is the action or conduct legal?
  • Is the action or conduct ethical?
  • Is the action or conduct consistent with this Policy?
  • Will the action or conduct reflect positively on the Company and the individual personally?

If the answer to any of these questions is no, the action or conduct should not be carried out. The Company has a variety of resources available to assist them to be aware of their obligations under this Policy. One should seek guidance from any of the under listed units if need be:

  • Human Resource
  • Audit, Risk, Legal & Compliance

Failure to comply with this Policy may lead to disciplinary action (up to and including dismissal), and criminal liability for the individuals involved. Employees will be required to confirm that they have read and understood the Policy and that they will comply with the terms therein.

2        Policy Statement

  • West Blue is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. West Blue Consulting has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
  • West Blue will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of Ghana & Nigeria, including the Bribery Act, and all applicable ABC laws regarding our conduct both at home and abroad.
  • West Blue recognizes that bribery and corruption are punishable by imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.
  • The basic tenets of the Policy are:
    • The Company does not pay bribes to government officials, private company executives or to any other individual or entity to obtain or maintain business, induce improper performance, or gain an unfair advantage.
    • The Company does not pay bribes directly or indirectly through brokers, agents, consultants, or other associated persons or third parties.
    • The Company avoids the appearance of paying bribes through other means such excessive entertainment or gift giving or making facilitation payments.
    • The Company maintains detailed and accurate books and records and internal controls.
    • The Company does not conceal bribes or other improper payments by “off books” arrangements or by falsifying its books and records.
  • All Employees, Contractors and Consultants are responsible for using their best endeavours to understand what their partners, agents, consultants and other third party representatives are doing on behalf of the Company and ensuring that such entities are not paying bribes on the Company’s behalf. Wilful ignorance is no excuse, and all Employees, Contractors and Consultants are expected to follow both the spirit and letter of this Policy.
  • A copy of this Policy document will be provided to all Employees, Contractors and Consultants. A copy of the document will also be posted on the Company’s website for viewing by Employees, Contractors and Consultants and all other stakeholders in the Company.
  • Employees who fail to comply with this Policy will be subject to the Company’s disciplinary procedures as set out in the HR Employee Handbook – Disciplinary Policy and Procedures and as such could be subject to Summary Dismissal. Contractors or Consultants who fail to comply with this Policy will be in breach of contract which will provide grounds for the termination of their Contractor or Consulting Agreement, as the case may be.
  • Strict compliance with this Policy is especially important because all Employees, Contractors and Consultants worldwide are potentially criminally liable under the law for violating ABC laws. Criminal violations could result in fines for individuals and imprisonment for each violation. Individuals could also be subject to additional criminal fines and penalties under local laws. The Company could face numerous sanctions, including criminal indictment and fines, disgorgement of any ill-gotten gains, the prohibition on doing business with government entities, and the appointment of a compliance monitor to oversee its business operations
  • This Anti-bribery and Anti-Corruption Policy was approved for use by Top management of West Blue Consulting Limited on 13-AUG-2020 and will be reviewed for accuracy and relevance every two years.

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