Anti-Bribery &
Corruption (ABC) Policy

Proxi NVE Limited (Kenya)

Ref: PROX-GOV-001

Effective Date: January 1, 2026 | Applicability: Global Operations

1. Policy Statement (Zero Tolerance)

Proxico operates with a Zero Tolerance approach to bribery and corruption. We would rather lose a business opportunity than secure it through unethical or illegal means.

It is the policy of Proxico to conduct all business in an honest and ethical manner. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate, and to implementing and enforcing effective systems to counter bribery.

2. Scope

This policy applies to all individuals working at all levels and grades, including:

Directors, senior managers, and officers.
Employees (permanent, fixed-term, or temporary).
Consultants, contractors, trainees, seconded staff, casual workers and agency staff.
Volunteers, interns, agents, sponsors, or any other person associated with us.

This policy covers our operations in East Africa (Proxi NVE Limited), as well as any joint ventures or sourcing partnerships globally.

3. Legal Framework

Our operations are cross-jurisdictional. Therefore, we adhere strictly to the following laws:

The Bribery Act 2016 (Kenya): Governing our local operations and interactions with Kenyan public officials.
The UK Bribery Act 2010: Acknowledged as the global "gold standard" for anti-bribery compliance.
The Foreign Corrupt Practices Act (FCPA) of 1977 (USA): Relevant for our dealings with international supply chains and USD transactions.

4. Prohibited Conduct

4.1 Bribes

Give, promise to give, or offer a payment, gift, or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.

4.2 Facilitation Payments ("Grease Payments")

Make "facilitation payments" or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action (e.g., clearing customs, obtaining a permit).

Proxico Position: We do not make facilitation payments. If a demand is made, it must be refused and reported immediately.

4.3 Kickbacks

Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.

4.4 Political Contributions

We do not make donations, support any political parties or candidates, as this can be perceived as an attempt to gain an improper advantage.

5. Gifts and Hospitality

Gifts and hospitality are only permitted if they are reasonable, proportionate, and transparent.

Acceptable

Modest business lunch

Promotional items (branded stationery)

Moderate seasonal hospitality

Prohibited

Cash gifts of any amount

Lavish dinners or entertainment

Gifts given during tender processes

Reporting Threshold

Any gift or hospitality offered or received with a value exceeding €100 (or KES equivalent) must be declared to the Compliance Officer and recorded in the Gift Register.

6. Third-Party Due Diligence

As a master distributor and sourcing agent, we are responsible for our supply chain.

We must ensure that our suppliers, freight forwarders, and clearing agents adhere to these same standards.
We will not engage with any third party that has a history of corruption or refuses to commit to our anti-bribery standards.

7. Record Keeping

We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

All accounts, invoices, memoranda, and other documents and records relating to dealings with third parties, such as customers, suppliers, and business contacts, should be prepared and maintained with strict accuracy and completeness.

"Off-the-books" accounts are strictly prohibited.

8. Your Responsibilities & How to Raise a Concern

The prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control.

Whistleblowing (Non-Retaliation)

If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption, or other wrongdoing has occurred or may occur, you must notify your manager or the Compliance Officer immediately.

Protection: We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We guarantee a policy of non-retaliation.

9. Consequences of Breach

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

Master Policy Control Document // Proxico Compliance Framework

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Anti-Bribery & Corruption (ABC) Policy