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Anti-Corruption Policies & Procedures

GBI Energy Limited is committed to maintaining the highest standards of integrity and ethical conduct in all business operations.

Policies
Conflict of Interest Policy Public Officials Engagement Policy Facilitation Payments Ban Due Diligence and KYC Approval Authority Matrix

In addition to the Anti-Corruption and Compliance Policy, GBI Energy Limited has adopted and implemented the following procedures and measures to further prevent any form of corruption, particularly corruption involving Public Officials.

Conflict of Interest Policy

  • Employees must disclose any personal, financial, or family relationship with Public Officials or other business partners that may create, or appear to create, a conflict of interest.
  • A Conflict of Interest Register shall be maintained and reviewed periodically.

Public Officials Engagement Policy

Any engagement with Public Officials must:

  • Be pre-approved by the Compliance Officer/Managing Director.
  • Be conducted transparently and documented in writing.
  • Have at least two representatives from GBI Energy present to prevent undue influence.
  • No cash, gifts, or benefits may be provided to Public Officials unless expressly permitted by law and properly documented.

Facilitation Payments Ban

  • Even small "grease payments" to speed up administrative processes are strictly prohibited.
  • Employees encountering demands for such payments must report immediately to the Compliance Officer.

Due Diligence and KYC (Know Your Counterparties)

  • Mandatory due diligence checks on suppliers, agents, contractors, and potential partners, including checks for connections to Public Officials.
  • All third parties must sign an Anti-Corruption Declaration confirming adherence to the Company's standards.

Approval Authority Matrix

  • A clear delegation of authority must be established for approvals involving payments, donations, sponsorships, and contracts with government-linked entities.
  • Dual sign-off (two levels of approval) shall be required for high-risk transactions involving Public Officials.

Our Commitment to Compliance

GBI Energy Limited is dedicated to conducting business with the highest ethical standards and in full compliance with all applicable laws and regulations. We maintain a zero-tolerance policy toward corruption in any form.

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