Vedanta - Code of Conduct and UK Bribery Act

The objective of the course is to familiarize KCM employees with the Code of Business Conduct and Ethics and also to introduce the salient features of the UK Bribery Act

Session on Code of Conduction and UK Bribery Act

Vedanta Group Philosophy

Vedanta Group Philosophy

“Uncompromising business ethics are an integral part of the Company‘s values and of our way of doing business. The manner in which we conduct ourselves day to day with our colleagues, our customers, our shareholders, our competitors, our neighbouring communities and our suppliers forms the basis of our reputation as an ethical group. Our customers and other stakeholders expect us to maintain the highest ethical standards, to fulfill our commitments and to act with complete integrity towards all our commitments. We must endeavor to live up to our reputation and stakeholder expectations by making sure that our actions and policies are not only legal, but also in line with the highest level of business ethics and personal integrity.”

Code of Business Conduct & Ethics


  • Honest & ethical conduct.
  • Conduct of employees in accordance with the policies governing the Group’s business dealings.
  • Ethical handling of conflict of personal & professional interest.
  • Compliance with applicable laws, rules, regulation – “ Zero tolerance “.
  • Full, fair, accurate, timely and understandable disclosures.
  • Prompt internal reporting of exception to laws, regulation, policies & procedures to appropriate person..


Code of Business Conduct & Ethics

  • General guidelines for conducting the business of the Company in accordance with the highest standards of Business Ethics.
  • The way we conduct with all stakeholders – Basis of our reputation
  • Intended to assist all employees in achieving highest standards of professional & personal integrity, required of them.
  • Vedanta expects all its employees to uphold the highest standards of ethical behavior & integrity.
  • Strict adherence – a condition of employment.


  • Applies to all directors, officers & employees of the Company.


Code of Business Conduct & Ethics - Reporting



  • Each employee is responsible for ensuring his & his subordinate’s conduct is in line with the code.
  • Duty of employee – to report any known or suspected violation of this code, including any other applicable laws, rules & regulations.


  • Reporting authority – Concerned supervisor / Legal Department/HCM Manager/Group Audit services and Security.
  • Any whistle blowing incident can be reported through the Chief Executive Officer’s office for investigation.


  • Email ID:
  • Confidentiality & anonymity of the employee reporting the violation will be protected.


  • Retaliation against the employee is completely prohibited.

Code of Business Conduct & Ethics - Guidelines




With Customers:


  • Deal with customers fairly, honestly & with integrity.
  • Exercise due care & diligence in establishing business relations.

With Suppliers:


  • Deal honestly & fairly.
  • Relationship should be based on price, quality, service & reputation.
  • Two core areas of focus for procurement:


1. Ethics.

2. Health, safety & environment.


With Competitors:


  • Not to engage in any anti-competitive practices like illegal fixation of prices, sharing of markets or others which distort competition.


Code of Business Conduct & Ethics

Conflicts of Interest:
  • Company expects employees to perform their duties conscientiously, honestly and in accordance with the best interests of the Company.
  • Employees must not use their positions or knowledge gained through their employment with the company, for private or personal advantage or in such a manner that a conflict or an appearance of conflict arises between the company’s interest and their personal interest.
  • If employees feel that a course of action which they have pursued, are pursuing or are contemplating pursuing, may involve them in a conflict of interest situation, they should immediately make all the facts known to the person to whom they report or to the Vice President – Human Capital Management or the Company Secretary.

Identifying potential conflicts of interests may not always be clear-cut. The following situations are examples of conflicts of interest:

 Directors and Senior Officers: Directors and senior officers must disclose to the Company’s Board of Directors any material transaction or relationship that is or may be a potential conflict of interest in line the Company’s policy on conflicts of interest and UK law.

Outside Employment: Any outside activity must be strictly separated from employment by the Group and should not harm the Group’s interest, the business of the Group or job performance at the Group.


Code of Business Conduct & Ethics

Conflicts of Interest:

Family Members and Close Personal Relationships: Employees may not seek to obtain special treatment from any member of the Group for family members or friends.

Financial Interests: No employee should have a significant financial interest (ownership or otherwise) in any company that is a material customer, supplier or competitor of the Company.

Loans or Other Financial Transactions: No employee should obtain loans or guarantees of personal obligations from, or enter into any other personal financial transaction with, any company that is a material customer, supplier or competitor of the Group.

This guideline does not prohibit arms-length transactions with banks, brokerage firms or other financial institutions.


Code of Business Conduct & Ethics

General Guidelines:


  • Gifts: Business gifts of insignificant commercial value are allowed unless the same construe as bribes or improper payments that you compromise your objectivity & fair dealing.
  • Where gifts are to be accepted, then the same should be reported to the immediate superior and deposited with the Company Secretary.


  • Entertainment: As a general rule, you may give or receive entertainment to or from customers or suppliers only if the entertainment would not be viewed as inducement to or reward for any particular business decision.


  • Personal Investments: The Company respects the right of all employees to make personal investment decisions. Employees should not permit their personal investment transactions to have priority over transactions for the Company and its clients.
  • Employee’s should ensure efficient use of company’s asset for legitimate business purposes only & to take care to prevent theft / damage.

Code of Business Conduct & Ethics

General Guidelines:


  • Gifts: Business gifts of insignificant commercial value are allowed unless the same construe as bribes or improper payments that you compromise your objectivity & fair dealing.
  • Where gifts are to be accepted, then the same should be reported to the immediate superior and deposited with the Company Secretary.


  • Entertainment: As a general rule, you may give or receive entertainment to or from customers or suppliers only if the entertainment would not be viewed as inducement to or reward for any particular business decision.


  • Personal Investments: The Company respects the right of all employees to make personal investment decisions. Employees should not permit their personal investment transactions to have priority over transactions for the Company and its clients.
  • Competition and fair dealing: All employees are obligated to deal fairly with fellow employees and with the Company’s customers, suppliers, competitors and other third parties. Employees should not take unfair advantage of anyone.
  • Company Funds and Property: Employee’s should ensure efficient use of company’s asset for legitimate business purposes only & to take care to prevent theft / damage.
  • Company Records: Accurate and reliable records should be maintained to meet the the Company’s legal and financial obligation and to manage affairs of the Company.
  • Employees are prohibited from (a) Falsifying Records (b) providing material misstatement.


Code of Business Conduct & Ethics

Privacy and Confidentiality:


  • Employees should keep the confidentiality of material information.
  • To comply with all the terms of all confidentiality agreements unless otherwise required by Statute.


Indicative list of confidential information:


  • Financial results & sales results of the company.
  • Trade secrets including any business or technical information.
  • Any invention or process developed by an employee using the group’s facilities.
  • Proprietary information like customer sales list, vendor database etc.
  • Employee’s obligation continues even after he leaves the company.
  • Adequate care to be taken to safeguard confidential information viz. confidential information should be securely stored & should not be discussed within hearing range of visitors.

Code of Business Conduct & Ethics

Dealing with Outside Persons/ Organisations and Selective Disclosure
  • The Company strives to achieve complete, accurate and timely communications with all parties as well as government authorities and the public with whom it conducts business.
  • The Company will on occasion be asked to express its views to the media on certain issues. As a general rule, the Company's position on public policy or industry issues will be dealt with by senior management of the Company.
  • Employees approached by the media should immediately contact the Head Corporate Affairs or the Corporate Department.

“Selective disclosure‘ occurs when any person provides potentially market-moving information to selected persons before the news is available to the investing public generally. Guidelines to avoid improper selective disclosures:

  • Contacts with investment analsyts, press media shall be made through the Corporate Affairs Department
  • Presentation to investment community will be made under direction of Senior Management of the Company
  • Please contact the Corporate Affairs / Legal Department if you have any questions about the scope or application of the Company‘s policies regarding selective disclosure

Code of Business Conduct & Ethics

Bribery & Corruption
  • Company and employees shall not offer any undue monetary advantage to any person in violation of laws


  • Company is committed to elimination of fraud and ensure wrongdoers are appropriately dealt with
  • Intermediaries shall not be used to channel payments, and thereby circumvent the company’s policies


  • No funds or assets may be contributed to any political party/public office except otherwise permitted bylaws and authorised by Chairman/Board
  • The UK Bribery Act (UKBA) prohibits the Company and its associated persons from offering, promising or giving any financial or other inducements to influence foreign public officials with an intention to obtain or retain business or an advantage in the conduct of the business.

Code of Business Conduct & Ethics - Insider Trading

Insider Trading
  • According to the Listing Rules of the United Kingdom Listing Authority, no employee of the company or any member of his/her immediate family living in the same household as the employee shall directly or indirectly purchase or sell any securities of the group while he/she is in possession of material non-public information affecting the Group


  • Employees may not “tip off "others about important information regarding the Group, and should keep any information pertaining to the Group confidential.


  • Any trading you have in the Company’s shares needs to be brought to the attention of the Legal Department


  • Failure to comply with these provisions could result in disciplinary action and severe criminal and civil penalties.



Code of Business Conduct & Ethics - Whistle Blower Policy

Whistle Blower Policy


  • To govern the receipt, retention, and treatment of complaints and to protect the confidential, anonymous reporting of the same, employees and other stakeholders may submit complaints pertaining to;
    • Provision of information to management which leads to the prevention of theft and recovery of stolen assets
    • Violations of rules and regulations applicable to the Company and related accounting, internal accounting controls and auditing matters
    • Intentional error or fraud in the preparation, review or audit of any financial statement of the Company
    • Any violations to the Company’s ethical business practices as specified in this code of conduct
    • Any other event which would affect the interests of the business.
  • The policy is applicable to and is available to all employees of the Company and all external stakeholders
  • All the ‘Complaints’ under this policy should be reported to
  • Email:
  • Postal Address: The Chief Executive Officer

KCM whistle Blower

Konkola Copper Mines Plc

P.O Box 11271

Chingola :

Code of Business Conduct & Ethics - Whistle Blower Policy

Whistle Blower Policy – Treatment Procedure


  • The CEO is the primary owner for receipt of all Whistle-Blower incidents.
  • Complaints received will be dealt with by the CEO, his nominee or any wing as designated by the CEO.
  • The person/persons against or in relation to whom the ‘complaint is made shall cooperate with the Investigator and have the right to provide their inputs during the investigation.
  • Where relevant, the CEO may nominate an internal or external official to investigate the Whistle blower incident.
  • A permanent committee shall be appointed to review or investigate any reported incidences.
  • Where such a Committee is constituted it shall meet on a regular basis to review complaints and make recommendations of the investigation.
  • Access to Reports and Records and Disclosure of Investigation Results : all reports and records associated with complaints are considered confidential information and access shall be restricted to the CEO and any constituted Committee.
  • Retention of Records: All documents relating to such Complaint‘s made through the procedures outlined above shall be retained for at least five years from the date of the Complaint.
  • Contravention of the Code is a serious matter and may result in disciplinary action including termination of employment and civil or criminal proceedings.



Salient features of the UK Bribery Act 2010

  • Passed in the parliament during April 2010. Comes to force from 1st July 2011
  • It is to replace the existing, fragmented and complex offenses listed under the common law and in the Prevention of Corruption Acts 1889-1916
  • It applies to companies incorporated or doing business in the UK and individuals who are ordinary residents of UK



Why Bribery Act Compliance is critical for Vedanta

Bribery and Corruption Risk Radar

Vedanta has operations in Australia , Africa, India, Zambia and United Kingdom. The CPI ranking of India and Zambia are 87 and 101 respectively indicating increased corruption

Mining/ minerals industry involving complex business processes, huge investment and risky operations is exposed to bribery risks

Industry by its nature has complicated regulations and high levels of government control for exploitation and export requiring significant interactions with government

With its expansion of operation in new territories, transactions with third parties gains utmost importance as potential inadequate due diligence can cost compliance

The level of compliance maturity in varied geographical operations assumes significance as Bribery Act requires organizations to establish measures taken to prevent bribery to avoid penalty incase of violations


Anti-Bribery and Corruption Landscape

  • The Serious Fraud Office, UK and Financial Services Authority (FSA) have recently taken numerous actions against UK corporates and see bribery and corruption as a focus area for future enforcement.

The US has prosecuted well over 100 foreign bribery cases since 1999. German prosecutors have brought over 40 cases since then, of which 39 were launched in the last few years.

  • There is an increasing number of investigations around the world, including higher penalties, disgorgement of profits, and more multilateral cooperation
    • Cases are likely to continue through to and after the implementation of the Bribery Act

  • 38 countries have signed onto the Organisation for Economic Cooperation and Development (OECD) Convention and over 100 have adopted statutes regarding bribery and corruption
    • UK Bribery Act passed in April 2010 and implemented on 1 July 2011, including a new corporate offence of failing to prevent bribery.
    • SFO keen to show itself to be an effective anti-bribery and corruption law enforcer and has made clear in public and private statements that it intends to enforce the Bribery Act as broadly as possible.


UK Bribery Act 2010

The Act creates following offences, specifically:

  • Giving or receiving a bribe to induce a person to improperly perform a relevant function
  • Bribery of a foreign public official with the intention of obtaining a business advantage and
  • As a new strict liability corporate offence, failing to prevent bribery (Section 7).

The Act is extra territorial in nature which covers bribery in the UK and overseas. It covers a non-UK commercial organization which carries on business in the UK is capable of being prosecuted under this Act even if the bribe is paid outside the UK. It also applies to UK commercial organizations (UK companies and partnerships, or other companies and partnerships which carry on their business or part of their business in UK) even if the bribe is paid outside the UK.

The Act also covers “an associated person” being a third party who performs services on behalf of a commercial organization. The Act gives examples of employees, agents and subsidiaries. The definition in the Act is sufficiently broad however that the possibility of other third party representatives and business partners satisfying the definition is potentially high.


UK Bribery Act – Jurisdiction & Consequences

  • The Act applies to:
    • UK citizens and those normally resident in the UK
    • Commercial organisations headquartered, organised, or “carrying out all or part of a business” in the UK
  • Consequences of violations
    • Unlimited corporate fines; maximum 10 years imprisonment
    • Disgorgement of profits
    • Extradition of individuals
    • Independent monitorships
    • Disqualification from public sector work in the EU, USA
  • The prohibitive scope of the Bribery Act is thus much wider than that of the Foreign Corrupt Practices Act (“FCPA”), in that it is an offence to receive as well as to give a bribe
    • UK AB&C Act or Local Laws – whichever is more stringent will apply

Applicability of UK AB&C Act

Applicability of UK AB&C Act

  • Yes, “Vedanta Resources Plc” is incorporated in UK
    • FCPA covers bribery in public sector and UK Bribery Act extends to private sector as well. It is wider in scope
    • To implement ‘adequate procedures’ to prevent bribery.
  • Does UK Bribery Act 2010 apply to Vedanta Group ?
  • How is it different from FCPA?
  • What’s the next step


Recent bribery related prosecutions

Details of some of the recent bribery related prosecutions are given below (source – Website / Big 4 firms)


Brief Details of Case



Prosecution on individuals


(December 2014 )




ALSTOM’s UK operations alleged to have paid more than $75 M in bribes to government officials around the world and agreed.


ALSTOM pleaded guilty to falsifying books and records, and failing to implement adequate controls over bribes paid to officials in Indonesia, Saudi Arabia, Egypt Taiwan and the Bahamas.


ALSTOM also tried to hide the scheme by hiring consultants, who acted as the conduits to pay the bribes to government officials, the DOJ said. Code names for some of the consultants included “Mr Geneva”, “Mr Paris”, “London”, “Quiet Man” and “Old Friend”, according to internal company documents.


This was subject to dual investigations by UK and Swiss authorities.

$772.30M fine, the largest penalty by the US Department of Justice for foreign bribery.


DOJ charged five people in the ALSTOM case, including four company employees. Three of them have pleaded guilty and the fourth is awaiting trial.


Recent bribery related prosecutions

Details of some of the recent bribery related prosecutions are given below (source – Website / Big 4 firms)


Brief Details of Case



Prosecution on individuals

Bhushan Steel

(August 2014 )



The Central Bureau of Investigation (CBI), India arrested Bhushan Steel's Vice Chairman and Managing Director for allegedly offering a bribe of Rs 50 lakh to Syndicate Bank Chairman and Managing Director for extending its credit limit in violation of laid-down procedures.


Bhushan Steel is already neck deep in debt and owes around Rs 40,000 crore to 51 banks, including State Bank of India (SBI), Punjab National Bank and others.


Vice Chairman and Managing Director of the company has been arrested by CBI along with CMD of Syndicate Bank.

AVON Products

(May 2014 )



Avon is the world's largest direct seller of cosmetics has pleaded guilty to conspiring to violate the Foreign Corrupt Practices Act by bribing officials in its China unit.


It admitted that disguised gifts its employees gave Chinese government officials from at least 2004 through late 2008. It said it concealed and disguised cash, non-business meals, travel and entertainment it provided to obtain business benefits.

Avon Products will pay $135 million to settle criminal and civil charges for violating Foreign Corrupt Practices Act.

The Company suspended the four officials including a General Manager and a Finance Chief.


Recent bribery related prosecutions

Details of some of the recent bribery related prosecutions are given below (source – Website / Big 4 firms)


Brief Details of Case



Prosecution on individuals

Rolls Royce

(March 2014 )



The Rolls Royce bribery scam came to the force after a preliminary investigation by the chief vigilance official of Hindustan Aeronautical Limited (HAL), which had received a letter from Rolls-Royce. The HAL official found prima facie evidence of violations of contractual provisions and obligations in the letter. The HAL board of directors then referred the case to the Ministry of Defense, with the recommendation that CBI should look into it.


The letter alleged that Rolls-Royce paid bribes to staff at HAL, the state-owned aircraft manufacturer based in Bangalore, to help the company win contracts to supply Hawk advanced jet trainers between 2007 and 2011. In the light of these serious allegations against the famed British company, it is now facing corruption inquiry over allegations that it paid bribes to win lucrative contracts to supply Hawk trainer jet engines to an aircraft manufacturer owned by the Indian government, HAL.

India's defence ministry had put on hold all "existing and future" contracts with Rolls-Royce until the results of an investigation by the country's Central Bureau of Investigation (CBI) into the purchase of jet fighter engines in a deal worth $1.6bn (£960m) came out. At stake, are Rolls-Royce contracts worth nearly Rs. 10,000 crore for the supply of aircraft engines to HAL for its trainer aircraft during 2007-2011. .



(December 2012 )



Walmart de Mexico, a highly successful business for Walmart (1/5th of Walmart's stores worldwide are in Mexico), systematically bribed Mexican government officials for years.


The bribes, which may have totaled more than $24 million, were paid to win permission to open new stories vastly more quickly than would have been possible had the company adhered to Mexican laws.


The bribes were initially hidden from Walmart's global headquarters in Bentonville, Arkansas, by disguising them as normal legal bills (a.k.a., accounting fraud).


One of the key executives in charge of the bribery payments quit the company in 2005 after being passed over for promotion. He then detailed his behavior to some of Walmart's lawyers, implicating many senior Walmart executives in the process.

May result in fine of ~$ 4.5 billion

Many senior officials including CEO, CFO and people from Legal Department were asked to quit.


Recent bribery related prosecutions

Details of some of the recent bribery related prosecutions are given below (source – Website / Big 4 firms)


Brief Details of Case



Prosecution on individuals

Siemens AG

(December 2008 )



Siemens AG, Europe's largest engineering company, pleaded guilty to violating U.S. anti-corruption laws.


Siemens was caught in a corruption scandal for bribing employees of other companies for contracts.


The companies rigged bids for procurement contracts, fixed prices, allocated projects to each other, shared markets and exchanged commercially important and confidential information.


Siemens chief executive Peter Loescher, was hired in July 2007 to clean up after the bribery scandal erupted, replaced half of the company's top executives and appointed division heads to eliminate decision-making by consensus on the Siemens board.

~ $814 million fine in Germany. The Company also will pay $800 million in criminal and civil penalties in the United States for falsely accounting for $1.36 billion in bribes and questionable payments.

Some of the executive board members have been charged in this scandal.


Kutschenreuter is the most senior Siemens executive found guilty of corruption so far. He was placed on probation for two years and fined 160,000 euro after admitting that he had covered up slush funds and bribes paid by his employees.


The other concerned person, Hans-Werner Hartmann, who was in charge of accounting at the company’s telecommunications arm, was placed on probation for 18 months and fined 40,000 euro.


AB & C

What are the concerns regarding AB&C

Impact of the UK Bribery Act on the business

Where are the risks?

How to comply?

Where to start?

How to leverage existing systems and processes to achieve an adequate but pragmatic and sensible response?

Third parties

Where do we use them and what do we know (or not know) about them?

What risks are they imposing on the organisation?

How to conduct effective but risk-based and cost-efficient due diligence?

High risk/emerging markets

How to increase turnover and geographic presence whilst managing AB&C risks?

What do we not know about new markets and companies we are buying?

How to conduct effective but cost-efficient AB&C M&A due diligence?

AB & C

UK Ministry of Justice has provide “Adequate procedure” –
What needs to be done?

  • Evaluate the bribery risks for business
  • Identify extent of government/ non governmental functions that are prone to bribery risk

Adequate Procedure Guidance and its application for Vedanta

Proportionate Procedures

Monitoring and Review

Top Level Commitment

  • Update code of conduct referring zero tolerance and compliance with bribery act
  • Include compliance as one of the key KRA’s for performance
  • Monitor controls addressing the bribery risk and assess the effectiveness
  • Implement additional controls for compliance

Adequate Procedures

Communication (including training)

Risk Assessment

  • Include bribery risk assessment as a part of routine audit
  • Plan to assess risk for all critical business processes prone to bribery risk periodically
  • Conduct trainings and awareness workshops
  • Incorporate act compliance as part of all agreements with employees and third parties

Due Diligence

Mandate due diligence specifically assessing bribery risks as one of the process for M&A and dealings with third parties

AB & C

Preliminary Planning and Scoping Regarding AB&C Risks

  • Country Risk
    • Industry Risk
    • Interactions with Government Officials
    • Agents and Third Parties
    • Compliance Programme Maturity
    • Past Practices

AB & C

Building an AB&C Compliance Programme

  • Identify areas or operations that may be susceptible to bribery and corruption risks via an AB&C risk assessment
  • Based on risk assessment findings, design appropriate programs and controls to help prevent, detect or respond to bribery and corruption risks
  • Implement programs and controls through the assignment of roles and responsibilities and deployment of resources
  • Evaluation of the design and operating effectiveness of Anti-Bribery Corruption programs and controls

AB & C

Illustrative preventive AB&C Controls

  • Code of Conduct and Related AB&C Standards
    • Executive and Line Management Responsibilities
    • Due Diligence Protocols for Employees and Third Parties
    • Due Diligence Protocols for M&A Transactions and Joint Ventures
    • Policies and Procedures pertaining to:
      • Gifts and Entertainment
      • Political and Charitable Donations
      • Payment to offshore accounts
    • Communication and Training
    • Audit / Compliance Committee Oversight
    • Whistleblower framework
    • Compliance Monitoring / Internal Audit

AB & C

Key aspects to be considered

The existence of a Code of Conduct that prohibits bribery is not enough

“Tone from the top” is essential but so is “tone from the middle”

There must be AB&C education and training to all officers, directors, employees and third parties

An effective AB&C Compliance programme must include protocols to prevent, detect, and respond to alleged misconduct

UK regulators will expect remediation and continuous monitoring

AB & C


If you have any queries about the Act, please contact your supervisor or the Secretarial / Legal Department.

All employees have a duty to report any known or suspected violation of this Act. If you know of or suspect a violation, immediately report the same to your supervisor. Your supervisor will contact the Secretarial / Legal Department, which will work with you and your supervisor to investigate your concern.

If you do not feel comfortable reporting the conduct to your supervisor or you do not get a satisfactory response, you may contact the ( and/or HCM / Legal Department directly. You may also report known or suspected violations at the whistleblower email address of your respective entity.

Declaration Form



Declaration Form- Non Violation of the Code/UKBA

Thank You

Thank You




UK Bribery Act 2010 – Guidance

Principles Based:

  • Proportionate Procedures
    • “A commercial organisation’s procedures to prevent bribery by persons associated with it are proportionate to the bribery risks it faces and to the nature, scale and complexity of the commercial organisation’s activities. They are also clear, practical, accessible, effectively implemented and enforced.”


  • Top-level commitment
    • “The top-level management of a commercial organisation (be it a board of directors, the owners or any other equivalent body or person) are committed to preventing bribery by persons associated with it. They foster a culture within the organisation in which bribery is never acceptable.”


UK Bribery Act 2010 – Guidance


  • Risk Assessment
    • “The commercial organisation assesses the nature and extent of its exposure to potential external and internal risks of bribery on its behalf by persons associated with it. The assessment is periodic, informed and documented.”


  • Due Diligence
    • “The commercial organisation applies due diligence procedures, taking a proportionate and risk based approach, in respect of persons who perform or will perform services for or on behalf of the organisation, in order to mitigate identified bribery risks.”


UK Bribery Act 2010 – Guidance


  • Communication (including training)
    • “The commercial organisation seeks to ensure that its bribery prevention policies and procedures are embedded and understood throughout the organisation through internal and external communication, including training, that is proportionate to the risks it faces.”


  • Monitoring and Review
    • “The commercial organisation monitors and reviews procedures designed to prevent bribery by persons associated with it and makes improvements where necessary.”


The Code of Ethics is only meant for politicians and non governmental organizations. Corporate entities can function without a clear Code of Ethics.

  • True
  • False
  • Don't Know

KCM has a Code of Ethics in place.

  • True
  • False
  • Maybe

Company records should be kept accurately and all transactions disclosed and transparent.

  • True
  • False

Read the statement below and provide your answer. 'Only collect personal information where necessary directly from the person in question or a reliable source and keep it safe'

  • Agree
  • Do Not Agree
  • Not Necessary

Provide your feedback: Confidential information on employees or company projects or transactions should not be disclosed

  • True
  • False

A supplier invited a group of 60% of members of the Contracts Technical Committee for dinner and freely offered them gifts. A decision was later made during dinner to award the contract to the supplier. What would you do in this situation?

  • There is no issue in accepting the gifts
  • No, We are not allowed to accept gifts. I would politely decline the gift and proceed to make a decision.
  • The gifts can be accepted as long as they are below 100 Kwatcha in value

Do not deal with suppliers who want to share information for money

  • We can deal with such suppliers
  • Strictly No Dealings
  • Can deal as long as my superior is aware

The KCM Code of Ethics applies only to the following employees:

  • KMC Members Only
  • KCM 6 and above
  • KCM 5 only
  • KCM 1 to 4
  • All employees

When you observe that your colleague at work has just received a gift of USD 10,000 from a supplier as a token for services provided, what should you do?

  • Keep Quite
  • Ask your colleague for information so that you can also get such a gift
  • Advise him to decline it and report the vendor to the commercial team.

.............................................. is a policy that governs the behavior of employees, contractors and management in alignment with the company's objective of attaining good governance and standards during its operations.