INTRODUCTION 

Corruption and influence peddling are serious offences that can harm Gruvi Ltd, all the companies in the group and its reputation. They are illegal and can lead to financial penalties and even jail time. This Anti-Corruption Code outlines Gruvi Ltd’s commitment to ethical business practices and helps employees avoid these risks.

WHAT IS CORRUPTION AND INFLUENCE PEDDLING?

Corruption: Offering or accepting bribes (undue gifts or advantages) to influence a decision. This includes:

Active corruption: Offering a bribe.

Passive corruption: Accepting a bribe.

Facilitating payments: Small bribes to speed up routine tasks. (These are illegal in most countries.)

Influence peddling: Using your connections with someone in power to get an unfair advantage.

AVOIDING CORRUPTION

Here’s how Gruvi Ltd employees can avoid corruption:

Gifts and Invitations: Refuse gifts or invitations that could influence your decisions or create an obligation.

Conflicts of Interest: Avoid situations where your personal interests conflict with Gruvi Ltd’s interests.

Hiring: Don’t hire someone based on unfair advantages gained from a third party.

Commercial Partners: Conduct proper due diligence on potential partners and avoid those with suspicious practices.

Lobbying: Be transparent and ethical when influencing government decisions.

Donations, Patronage, and Sponsorships: Ensure these activities are legal and not intended to gain an unfair advantage.

Political Donations: Gruvi Ltd does not make political donations.
Acquisitions and Joint Ventures: Ensure partners comply with anti-corruption laws.
Ledgers and Registers: Maintain accurate and complete financial records.

IF YOU SEE SOMETHING SAY SOMETHING

If you suspect corruption, report it to your manager or the Group CEO. Gruvi Ltd encourages employees to report concerns without fear of retaliation.

NON-RETALIATION ASSURANCE

Gruvi Ltd is committed to protecting employees who report suspected corruption or unethical behaviour. We assure employees that they will not face retaliation for reporting concerns in good faith. Any form of retaliation, including threats, intimidation, or adverse employment actions, will not be tolerated.

WHAT HAPPENS IF YOU VIOLATE THIS CODE?

Violating this code can lead to disciplinary action, including termination of employment.

REMEMBER

Gruvi Ltd has a zero-tolerance policy for corruption.
By following this code, you help Gruvi Ltd maintain its reputation and operate ethically.
If you have any questions, ask your manager or the Group CEO.

PERIODIC REVIEW

This Anti-Corruption Code will be reviewed annually in October to ensure its continued effectiveness and relevance. Any necessary updates or modifications will be implemented to address evolving risks and legal requirements.