Anti-Bribery and Corruption Policy

Keystone Technologies Limited

Effective Date: 2025-08-16 | Approved by: Joseph Changala, Director

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1. Introduction

Keystone Technologies Limited (“the Company”) is committed to conducting business with integrity, transparency, and accountability. We strictly prohibit all forms of bribery and corruption in accordance with the laws of the Republic of Zambia, including the Anti-Corruption Act, No. 3 of 2012 and related legislation. This Policy sets out our responsibilities, and those of individuals working for or with us, to uphold these values and comply with all applicable anti-bribery laws.

2. Purpose

• Prevent bribery and corruption in all Company activities.
• Provide guidance to employees and business partners about our zero-tolerance approach.
• Ensure compliance with Zambian law and international best practices.

3. Scope

This Policy applies to:

• All employees, directors, and officers of Keystone Technologies Limited.
• Agents, consultants, contractors, suppliers, and third parties acting on behalf of the Company.

4. Definition of Bribery and Corruption

• Bribery: Offering, giving, receiving, or soliciting anything of value to influence a person’s actions or decisions in their official capacity.
• Corruption: Abuse of entrusted power for private gain, including bribery, extortion, fraud, collusion, nepotism, and other unethical practices.

5. Legal Framework

Keystone Technologies Limited complies with:

• The Anti-Corruption Act, No. 3 of 2012 (Zambia).
• The Penal Code Act, Cap 87 of the Laws of Zambia.
• Any other applicable anti-bribery and anti-corruption laws.

6. Policy Statement

• Bribery and corruption are strictly prohibited.
• Employees and associated persons must not offer, give, solicit, or accept bribes in any form, directly or indirectly.
• Facilitation payments are not permitted under any circumstances.
• Gifts and hospitality must be reasonable, proportionate, and not intended to influence decision-making.
• Any attempts to bribe or corrupt a public official are criminal offences and will be reported to relevant authorities.

7. Gifts and Hospitality

• Gifts or hospitality may only be given or received if they are modest, reasonable, and in line with customary business practices.
• Any gift or hospitality intended to secure an improper advantage is strictly forbidden.

8. Political and Charitable Contributions

• The Company does not make political donations or contributions intended to gain business advantage.
• Charitable donations must be transparent and not used as a vehicle for bribery.

9. Responsibilities

• The Director, Joseph Changala, is responsible for oversight and enforcement of this Policy.
• All employees and associated persons must report any suspected bribery or corruption immediately.
• Training will be provided to ensure awareness and compliance.

10. Reporting and Whistleblowing

• Employees are encouraged to report concerns confidentially to the Director
• No employee will suffer retaliation for reporting in good faith.

11. Consequences of Breach

• Breach of this Policy may result in disciplinary action, including dismissal.
• The Company will cooperate fully with law enforcement and regulatory authorities in investigations.
• Individuals may face prosecution under Zambian law, with penalties including imprisonment and fines.

12. Review of Policy

This Policy will be reviewed annually and updated as necessary to ensure ongoing compliance with Zambian laws and global best practices.

13. Declaration

By working for or with Keystone Technologies Limited, you acknowledge and accept the principles and requirements of this Anti-Bribery and Corruption Policy.