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Anti-Corruption Policy

Anti-Corruption Policy

Last Updated: June 16, 2024

Introduction​

CENO TRANSPORT LTD is committed to conducting business with integrity and in compliance with all applicable laws and regulations, including anti-corruption and anti-bribery laws. This Anti-Corruption Policy outlines our zero-tolerance approach to bribery and corruption and our commitment to acting professionally, fairly, and with integrity in all our business dealings and relationships.

Scope​

This Policy applies to:

  • All employees, directors, and officers of CENO TRANSPORT LTD
  • Contractors, consultants, and temporary workers
  • Business partners, agents, and representatives acting on our behalf
  • Suppliers, vendors, and service providers
  • Any other person or entity associated with CENO TRANSPORT LTD

CENO TRANSPORT LTD complies with all anti-corruption laws applicable to our operations, including but not limited to:

  • The Nigerian Corrupt Practices and Other Related Offences Act
  • The Economic and Financial Crimes Commission Act
  • The Money Laundering (Prohibition) Act
  • The Foreign Corrupt Practices Act (FCPA) when dealing with U.S. entities
  • The UK Bribery Act when dealing with UK entities
  • Other applicable international anti-corruption conventions and laws

Prohibited Conduct​

Bribery​

We strictly prohibit offering, promising, giving, requesting, agreeing to receive, or accepting a bribe, which includes:

  • Cash or cash equivalents (gift cards, loans, etc.)
  • Gifts and entertainment that are lavish or inappropriate
  • Payment of travel expenses when there is no clear business purpose
  • Charitable or political donations made to influence a business decision
  • Kickbacks or channeling improper payments through third parties
  • Facilitation payments (except in limited circumstances discussed below)

Facilitation Payments​

Facilitation payments are small payments made to secure or expedite a routine governmental action by a government official. These payments are prohibited except in extraordinary circumstances where there is an imminent threat to health or safety. Any facilitation payment must be:

  • Immediately reported to the Compliance Officer
  • Accurately recorded in our financial records
  • Exceptional and not repeated

Dealing with Government Officials​

Particular care must be taken when dealing with government officials. For the purpose of this Policy, "government officials" include:

  • Officials or employees of any government or government-controlled entity
  • Political parties and party officials
  • Candidates for political office
  • Officials of public international organizations
  • Anyone acting on behalf of the above

Interactions with government officials must be transparent, honest, and in compliance with all applicable laws and regulations.

Due Diligence​

Third-Party Due Diligence​

Before engaging third parties who may interact with government officials on our behalf, appropriate due diligence must be conducted, including:

  • Background checks and reference verification
  • Review of qualifications and reputation
  • Assessment of relationships with government officials
  • Verification of compliance with anti-corruption laws
  • Documentation of the due diligence process

Red Flags​

Be alert to potential red flags that may indicate corruption risks:

  • Unusual payment patterns or financial arrangements
  • Lack of transparency in expenses and accounting records
  • Refusal to certify compliance with anti-corruption laws
  • Unusually high commissions or fees
  • Lack of qualifications or resources to perform services
  • Recommendations from government officials
  • Requests for payments to offshore accounts or third parties

Books and Records​

CENO TRANSPORT LTD maintains detailed and accurate books and records that fairly reflect all transactions and disposition of assets. All payments, gifts, entertainment, and expenses must be accurately recorded with appropriate supporting documentation.

False, misleading, incomplete, inaccurate, or artificial entries in the company's books and records are strictly prohibited.

Training and Communication​

All employees will receive regular training on this Policy and anti-corruption laws. The training will be tailored to specific roles, responsibilities, and corruption risks.

This Policy will be communicated to all employees, business partners, and relevant third parties at the outset of our business relationship and as appropriate thereafter.

Reporting Violations​

Any employee or third party who becomes aware of a potential violation of this Policy or anti-corruption laws must immediately report it through one of the following channels:

Non-Retaliation​

CENO TRANSPORT LTD prohibits retaliation against anyone who, in good faith, reports a concern about potential violations of this Policy or anti-corruption laws, or who assists in an investigation of suspected wrongdoing.

Any act of retaliation should be reported immediately and will be subject to disciplinary action.

Consequences of Violations​

Violations of this Policy or anti-corruption laws may result in:

  • Disciplinary action, up to and including termination of employment
  • Termination of business relationships with third parties
  • Criminal penalties, including fines and imprisonment
  • Civil liability and damages
  • Significant reputational harm

Responsibilities​

Board of Directors and Senior Management​

  • Set the "tone at the top" emphasizing ethical conduct
  • Oversee the implementation and effectiveness of this Policy
  • Allocate adequate resources for compliance programs

Compliance Officer​

  • Administer and monitor this Policy
  • Provide guidance and training on anti-corruption matters
  • Investigate potential violations
  • Report to the Board on compliance matters

All Employees​

  • Read, understand, and comply with this Policy
  • Complete required anti-corruption training
  • Report potential violations
  • Seek guidance when uncertain about proper conduct

Policy Review​

This Policy will be reviewed annually by the Compliance Officer and updated as necessary to reflect changes in applicable laws, regulations, or business operations.

Contact Information​

For questions or concerns regarding this Policy, please contact:

CENO TRANSPORT LTD
Headquarters: 30 Park Avenue (Suite 5), Enugu State, Nigeria
Email: legal@ceno.ng
Phone: +234 707 239 4683