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ANTI-BRIBERY AND CORRUPTION POLICY
Our ANTI-BRIBERY AND CORRUPTION POLICY
Last updated: June 22, 2023
Compliance Communication on APPL Anti-bribery and Corruption Policy
At Alternative Petroleum and Power Limited (APPL), It is our policy that all officers, employees, contractors, service providers, consultants, public officers, business partners, agents, and any persons representing the Company or its subsidiaries in any capacity shall comply fully with all the applicable provisions of Nigeria’s Anti-Bribery and Corruption Laws such as; the Corrupt Practices and Other Related Offences Act 2000, the Economic and Financial Crimes Commission (Establishment) Act 2003, The Criminal Code (Cap C38) Laws of the Federation of Nigeria 2004, UK Bribery Act of 2010 (“UKBA”), the United States Foreign Corruption Practices Act of 1977 as amended (“FCPA”) and all other equivalent anti-corruption and/or anti-bribery legislation applicable to the Company (whether by virtue of its jurisdiction of incorporation or the conduct of its business operations).
Business Conduct and Ethics Policy
It is the policy of APPL to conduct its business in accordance with applicable laws, rules, and regulations, with honesty, in a manner that demonstrates respect for local cultural and ethnic customs, and with a strong commitment to the highest standards of ethics. Hence, we demand high standards of integrity and sound ethical judgement from our personnel at all times. Strict adherence to the provisions of the Company’s Code of Business Ethics and Conduct as well as the Anti-bribery and Corruption (ABAC) policy of the Company. It is therefore essential that all personnel of the Company and stakeholders (customers, public officers, service providers, contractors, etc.) familiarize themselves with the Policy.
Any other individual or organization such as a joint venture partner, service provider, supplier or family member can also rely on this Policy to report concerns regarding the conduct of APPL or anyone acting on our behalf. Such openness can help information reach us, which may otherwise go unnoticed, for example, fraud, bribery or exploitation of gifts and hospitality.
As contains detailed provisions on bribery and corruption of the Company, We Prohibit the following unethical conduct and corruption practices:
Speak Up & Whistleblowing Hotline
Speaking Up is the disclosure of any information which, in the reasonable belief of the person making the disclosure, relates to suspected acts of misconduct, fraud, unethical behaviour or dangers at, and in the course of work for APPL. These include:
Fraud
- any type of fraud or mismanagement
- any activities that may constitute bribery or corruption in breach of any relevant laws or of APPL’s Code of Business Conduct (“COBC”)
- misuse or theft of APPL’s assets and property
- forgery (use of fake certificates, false declaration of age, etc.)
- product theft
- override of controls
- Unreceipted or unaccounted products purchased
Misconduct
- failure to comply with any legal, professional obligations or regulatory requirements
- breach of the COBC or any other APPL internal policies and procedures
- conduct that is likely to damage APPL’s reputation
- sexual or physical abuse i.e., Harassment
- abuse of office on the part of any member of staff or director
- unauthorised disclosure of confidential information
- conflicts of interest
- unethical activities
- contract kickbacks
- misuse of APPL’s information systems, computer databases and stored information assets
- the deliberate concealment of any malpractice
- miscarriage of justice
Health and Safety
- incidents or risks of pollution or environmental hazard
- any conduct capable of damaging APPL’s reputation
- Health and safety risks including risks to employees in the workplace and the public
Do not keep any of the above-mentioned unethical practices to yourself; discuss it with the appropriate supervisor or manager or the Compliance department of APPL in person or through the compliance communication desk at compliance@altpetroleum.com for reporting and escalation.
The Company’s whistleblowing communication channels are as follows:
Give us a call: (234) 908 770 6704
Send us an email: whistleblowing@altpetroleum.com
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