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Anti-Bribery Policy

1. Purpose

H&L Consulting is committed to conducting business with integrity, transparency, and in full compliance with all applicable laws, including the Prevention and Combating of Corrupt Activities Act (PRECCA), No. 12 of 2004, and other relevant South African anti-corruption legislation. This policy prohibits bribery, corruption, and unethical business practices in all forms.

2. Scope

This policy applies to:

  • All employees, directors, and contractors of H&L Consulting

  • Any third parties acting on behalf of the company (e.g., agents, consultants, suppliers, joint venture partners)

  • All business dealings, whether in South Africa or internationally

3. Definition of Bribery

Bribery involves offering, giving, receiving, or soliciting anything of value to improperly influence a business decision or gain an unfair advantage. This includes:

  • Cash payments, gifts, or hospitality intended to influence decisions

  • Facilitation payments (“grease payments”) to expedite routine services

  • Kickbacks, donations, or sponsorships used to secure business benefits

  • Any other improper inducement

4. Prohibited Conduct

Employees and associated persons must never:

  • Offer, promise, or give bribes to clients, government officials, or any other parties

  • Solicit or accept bribes in exchange for business favors

  • Use intermediaries or third parties to conceal corrupt payments

  • Falsify records to hide corrupt transactions

5. Gifts, Hospitality, and Expenses

  • Permitted: Modest, infrequent gifts or hospitality (e.g., meals, event tickets) that are transparent, proportionate, and not intended to influence decisions.

  • Prohibited: Excessive or frequent gifts, cash payments, or entertainment that could create a conflict of interest.

  • Approval Required: Any gift or hospitality  must be pre-approved by a Designated Compliance Officer.

6. Facilitation Payments

Facilitation payments (small payments to expedite routine government services) are strictly prohibited, even if customary in some regions.

7. Political and Charitable Contributions

  • No donations may be made to political parties or charities to secure business advantages.

  • All contributions must be transparent, properly recorded, and approved by management.

8. Record-Keeping & Financial Controls

  • All financial transactions must be accurately recorded in company books.

  • No “off-the-books” payments or slush funds are permitted.

  • Employees must retain receipts and approvals for all expenses.

9. Reporting Violations (Whistleblowing)

  • Employees must report suspected bribery to a Compliance Officer/Designated Email/Anonymous Hotline.

  • Reports will be treated confidentially, and whistleblowers will be protected from retaliation.

10. Consequences of Violations

  • Disciplinary Action: Up to and including termination of employment.

  • Legal Consequences: Criminal prosecution under South African law (PRECCA) and potential fines/imprisonment.

  • Reputational Damage: Loss of business partnerships and contracts.

11. Training & Compliance

  • All employees will receive regular anti-bribery training.

  • Compliance with this policy is a condition of employment.

12. Policy Review

This policy will be reviewed annually and updated as needed to reflect legal changes.

 

Approved by: [Managing Director Thelma Bucwa]