Corporate Governance
& Code of Ethics

This Code of Ethics (“The Code”) establishes the non-negotiable standards of conduct for Proxico and its regional operating entity, Proxi NVE Limited.

This framework applies universally to all directors, officers, employees, and third-party contractors. We require that our supply chain partners extend the principles of this Code to their own subcontractors and suppliers to maintain an uncompromised chain of custody.

The Company enforces a Zero Tolerance policy toward bribery and corruption in all jurisdictions of operation.

• Regulatory Adherence: Our operations are conducted in strict alignment with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, and applicable local anti-corruption laws including the Bribery Act 2016 (Kenya).
• Prohibited Payments: No employee or agent shall offer, promise, give, or accept any financial advantage—direct or indirect—to induce improper performance or influence a Government Official.
• Facilitation Payments: We strictly prohibit "facilitation payments" (unofficial payments to secure or expedite routine government actions).
• Audit Trail: All financial transactions must be recorded accurately in the Company’s books and records. Off-the-books accounts are strictly prohibited.

To ensure the integrity of the international supply chain, the Company mandates strict adherence to global trade controls.

• Restricted Parties: We screen all suppliers, clients, and intermediaries against restricted party lists maintained by OFAC (US), the European Union, the United Nations, and the UK Treasury.
• Sourcing Restrictions: The Company will not source materials, seek financing, or engage in trade with sanctioned jurisdictions or denied entities.

We are committed to a respectful working environment compliant with International Labour Organization (ILO) conventions.

• Forced Labor: We strictly prohibit the use of forced, bonded, or involuntary labor (ILO Conventions 29 & 105).
• Child Labor: We prohibit the hiring of individuals under the age of 15, or under 18 for hazardous work (ILO Conventions 138 & 182).
• Non-Discrimination: Employment decisions are based solely on merit, qualifications, and performance, without regard to race, religion, gender, or nationality.

Our operations prioritize the physical safety of our workforce and environmental stewardship.

• Operational Safety: We adhere to the Occupational Safety and Health Act (OSHA) standards and enforce strict PPE utilization in all logistical and technical operations.
• Environmental Impact: Our logistical planning aims to align with ISO 14001 principles and IFC Performance Standards (PS3) regarding resource efficiency and pollution prevention.

We recognize the importance of data security in a digital procurement environment.

• Compliance: We comply with the General Data Protection Regulation (GDPR) for European operations and the Data Protection Act (2019) for Kenyan operations.
• Confidentiality: We implement robust technical measures to protect the proprietary data and intellectual property of our clients and OEM partners.

• Duty to Report: Any stakeholder who suspects a violation of this Code is encouraged to report it immediately to the Compliance Office.
• Whistleblower Protection: We guarantee a policy of non-retaliation against any individual reporting a concern in good faith.
• Right to Audit: The Company reserves the right to audit employees and supply chain partners to verify compliance with this Code.