Anti-Corruption Policy 

Bribery and corruption consist of three basic elements: (i) giver (ii) accepter and (iii) gratification.  It involves the payment or giving (giver) of a gift (gratification) to another (accepter).  The purpose of which is to induce the accepter to act in an improper manner, in the performance of their duties for the commercial or personal gain of the giver. Bribery is an act of corruption and therefore a criminal offence.

Purpose 

This policy states Cirtech’s commitment to conducting all its business dealings and relationships with integrity.  It outlines the measures to prevent bribery proportionate to the risks present due to the nature and complexity of the Cirtech business.

Policy 

The legislation governing bribery and corruption is contained in the Prevention and Combatting of Corrupt Activities Act, 12 of 2004. (PRECCA).  Cirtech subscribes to the statute.

Cirtech has a zero-tolerance approach to bribery. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements. We do not use or accept, third parties as a conduit to channel bribes.

Gratification is broadly defined and includes, but is not limited to, money, loans, donations and gifts, employment, avoidance of loss or liability and any other valuable consideration, or benefit.

This policy does not prohibit gifts, entertainment, hospitality or other promotional expenditures (given and received) to or from third parties which are proportionate, transparent, reasonable and for bona fide purposes related to the aims and objectives of the business.

Gifts and hospitality

We accept that the practice of giving business gifts varies between countries and cultures. The test to be applied in all circumstances is whether the gift or hospitality is reasonable, proportionate and most importantly; the intention behind the gift should always be considered.

The following criteria must be met for the giving or receipting of gifts or hospitality:

1. It is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
2. It complies with local law;
3. It is given or received in the company’s name and not in the name of an individual;
4. It does not include cash or a cash equivalent (such as gift certificates or vouchers);
5. It is appropriate in the circumstances and it is given as a ceremonial gift at a special time e.g. Christmas;
6. Taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
7. It is given openly, not secretly;
8. Gifts may not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of a Company Director.
9. All gifts and hospitality per event/ per person, accepted or offered; may not exceed the maximum value (or comparable value in a different currency); as determined by the Company Directors from time to time.
10. Any deviation from the above must carry the pre-approval of a Company Director.

Due Diligence

Financial records must be kept detailing the business reason for making or receiving payments to third parties as follows:

1.  Employees must declare all hospitality or gifts on the gifts register, which will be subject to management review and appropriate distribution.
2. Expenses claims relating to hospitality, gifts or expenses incurred to third parties must be recorded and submitted in accordance with the company’s expenses policy.
3. All accounts, invoices and other relevant documents and records relating to third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts may be kept “off-book” to facilitate or conceal improper payments.
4. It is the responsibility of all employees to raise issues of concerns or suspicion of malpractice at the earliest possible stage. If there is uncertainty as to whether a particular act constitutes bribery or corruption, these should be raised with any of the management or Company Director confidentially.

Employees who refuse to accept or offer a bribe, or those who raise genuine concerns in good faith under this policy can be assured of Cirtech’s commitment to:

• Supporting and protecting such employees against unfavourable treatment;
• Honouring the confidentiality and often sensitivity of such reports;
• Investigating all reports and taking decisive corrective action as appropriate.

Non-Compliance

The act of directly or indirectly offering, promising, giving, requesting, agreeing, receiving or accepting bribes are considered gross misconduct.

The giving or accepting of excessive or lavish gifts, hospitality, travel or entertainment is also considered gross misconduct if such expense is not proportionate and reasonable to the business, work performed, event or occasion.  

Consistent with the company’s code of conduct, employees found guilty of gross misconduct may be sanctioned up to and including dismissal.