Anti-Bribery and Corruption Policy

1. Policy Statement

Keystone Technologies Limited prohibits bribery, corruption, facilitation payments, kickbacks, secret commissions and any improper benefit offered, requested, given or received to influence a business decision.

This policy is aligned with the Anti-Corruption Act No. 3 of 2012 and other applicable laws of the Republic of Zambia.

2. What Is Not Allowed

• Offering or accepting money, gifts, discounts, favours or benefits to win work unfairly.
• Paying a person to speed up, ignore or bypass an official process.
• Requesting a payment, gift or personal advantage before providing a service.
• Using a third party to do something Keystone would not be allowed to do directly.
• Submitting false invoices, inflated costs, hidden commissions or misleading records.

3. Gifts, Hospitality and Courtesy

Modest business courtesy may be acceptable only where it is lawful, reasonable, transparent, properly recorded and not intended to influence a decision.

Gifts, hospitality or benefits must never be used to influence tenders, inspections, approvals, procurement decisions, public officials or contract awards.

4. Public Officials and Regulated Work

Extra care is required when dealing with government offices, public bodies, regulators, utilities, public schools, hospitals, parastatals or anyone acting in an official capacity.

Keystone employees and representatives must not offer unofficial payments or benefits to obtain permits, speed up decisions, avoid inspections, secure contracts or influence any official duty.

5. Suppliers, Subcontractors and Agents

Suppliers, subcontractors, consultants and agents working with Keystone are expected to act with integrity and comply with this policy. We may refuse or terminate relationships where there is evidence of bribery, corruption, fraud or dishonest dealing.

6. Records and Conflicts of Interest

• Business records, invoices, delivery notes, receipts and project costs must be accurate.
• Any personal, family or financial interest that may affect a business decision should be disclosed.
• Company funds must not be used for unlawful political, charitable or personal payments.

7. Reporting Concerns

Anyone who suspects bribery, fraud, corruption, improper payment requests or unethical conduct involving Keystone should report it promptly. Reports can be made to management or through our contact channels.

Keystone does not support retaliation against a person who raises a genuine concern in good faith.

8. Consequences

Breaches of this policy may lead to disciplinary action, termination of contracts, cancellation of supplier relationships, reporting to relevant authorities or other lawful action depending on the seriousness of the matter.