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ANTI-CORRUPTION POLICY

1. RATIONAL

Tantine Group Ltd anti-corruption policy aims to help the organization conduct its daily activities in an honest and ethical manner. We have set up some core values to guide throughout our work including a zero-tolerance approach to any corruption or bribery and we are committed to put forward professionalism and integrity in all our work.

2. WHO IS COVERED BY THE POLICY? 

This anti-corruption policy applies to all Tantine Group Ltd employees, whether temporary volunteers, fixed-term, or permanent staffs, sponsors, or any other person or persons associated with us. Any other individual or organization that can meets and work with us shall be communicated with this Ant-corruption policy at the outset of our partnership and collaboration.

Any arrangements Tantine Group Ltd makes with other organization is subject to clear contractual terms, including specific provisions that require the collaborating organization to comply with minimum standards and procedures relating to our anti-corruption policy. In the context of this policy, Third-party refers to any individual or organization Tantine Group Ltd may meet and work with.

3. WHAT IS AND WHAT IS NOT ACCEPTABLE  

This section of the anti-corruption policy refers to four areas:

3.1.GIFTS, INVITATIONS & HOSPITALITY

This Anti-corruption policy accepts appropriate gestures of hospitality and gift given to or received from third parties so long as it meets the following requirements:

  1. If the gift or hospitality is not made with the intention to influence the party to whom it is being given to or obtained from;
  2. If it is not made with the suggestion that a return favor is expected;
  3. If it is in compliance with local governing laws;
  4. If it is given in the name of the organization, not in an individual’s name;
  5. If it is not given or received secretly, but openly.

Tantine Group Ltd Anti-corruption policy does not allow accepting or giving a gift to a third party in the following situations:

  1. If it is made with the intention of influencing a Third Party to obtain or preserve advantage, favor or benefit of any kind;
  2. If it is given in someone’s name and not in the name of the organization;
  3. If it is given secretly and not openly.

Despite the fact that giving and receiving gifts varies between countries, regions, cultures, and religions, a good practice our organization adopted is that in all the circumstances the gift or hospitality should always be reasonable, justifiable and disclosed. Additionally, the intention behind the gift should always be considered.

3.2.FACILITATION PAYMENTS

Tantine Group Ltd does not make, and will not accept, facilitation Payments or Payoffs of any kind in its daily activities.  Tantine Group Ltd recognizes that facilitation payments are a form of bribery paid by someone who is in need of a given service for the intention of speeding up the performance of a certain duty or action.

Even though our anti-corruption policy is very strict on facilitation payments, there are some situation our employees may find avoiding a facilitation payment may put them at risk and under these circumstances, any facilitation payment made must be reported as soon as possible. If such payment is made to any of our employee, these steps must be taken:

  1. Keep any facilitation payment amount to the minimum.
  2. Ask for a receipt, detailing the amount paid and reason for the payment.
  3. Create a record concerning the payment.
  4. Report this incident to your line manager immediately.
3.3.POLITICAL CONTRIBUTIONS

Tantine Group Ltd will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognize this may be perceived as an attempt to gain an improper business advantage.

3.4. CHARITABLE CONTRIBUTIONS

Tantine Group Ltd accepts, and indeed encourages, the act of donating to the neediest community members whether through services, knowledge and time. We agree to disclose all charitable activities we are making to the community.

All charitable activities made must legal and ethical under local governing laws and culture norms of the community we are working in.

4. EMPLOYEES AND VOLUNTEERS RESPONSIBILITIES

As an employee or volunteer of Tantine Group Ltd, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given. All employees and volunteers must be responsible for the prevention, detection, and reporting any form of corruption or bribery. In addition, our employees are required to avoid any activities that could lead to, or imply, a breach of this Anti-corruption policy.

If any employee or volunteer breaks this policy, they will face disciplinary action and could face dismissal for gross misconduct. Tantine Group Ltd] has the right to terminate a contractual relationship with an employee or volunteer if they breach this Anti-corruption policy.

5. WHAT HAPPENS IF I NEED TO RAISE A CONCERN?  

This section of our Anti-corruption policy covers 3 areas:

  1. Whistleblowing procedure.
  2. What to do if you are a victim of bribery or corruption.
  3. Protection. 
5.1. WHISTLEBLOWING PROCEDURE 

If anyone is the organization is suspecting that there is an instance of corruption or bribery activities occurring, they are encouraged to raise their concerns to the Tantine Group Ltd Program Manager as early stage as possible.

Tantine Group Ltd acquaint all employees with its whistleblowing procedures so employees can report their concerns quickly.

5.2. WHAT TO DO IF YOU ARE A VICTIM OF BRIBERY OR CORRUPTION

If any of our employee or volunteer are offered with a bribe by anyone, they must tell to our Program Manager immediately.

5.3. PROTECTION 

If any of our employee or volunteer refuse to accept or offer a corruption or you report a concern relating to potential act(s) of corruption or kickbacks, Tantine Group Ltd will support and protect anyone who reported any corruption concern.

Tantine Group Ltd will ensure that no one suffers any detrimental treatment like dismissal, disciplinary action, treats, because of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act of corruption. 

6. TRAINING AND COMMUNICATION 

Tantine Group Ltd will provide training on this policy as part of the induction process for all employees and volunteers. Even the new recruited employees and volunteers will be provided with such training on this policy and sign to comply with it.

7. MONITORING AND REVIEW 

Tantine Group Ltd Program Manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. Program Manager will assess its suitability, adequacy, and effectiveness.

Both employees and volunteers are encouraged to provide their feedback on this policy if they have any suggestions on how it may be improved. The feedback should be submitted to our Program Manager and any need for improvements will be applied as soon as possible.

Done in Kigali, Rwanda

November 2017

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