CEK-POL-002 · Version 1.0 · Issued October 2026 · Cekera Ltd
1. Purpose
Cekera has zero tolerance for bribery and corruption. This policy explains what is prohibited, the controls the Company applies and what Personnel must do.
2. Scope
This policy applies to all Personnel and to every third party acting for or on behalf of Cekera, including agents, distributors, consultants, freight forwarders and customs brokers, in every jurisdiction.
3. Legal framework
Cekera complies with the anti-corruption laws that apply to its business, including the Anti-Corruption Act 2016 of Seychelles, the laws of the countries in which it trades and, where applicable, laws with extraterritorial reach such as the United Kingdom Bribery Act 2010 and the United States Foreign Corrupt Practices Act. The Company also follows the principles of the United Nations Convention against Corruption and the OECD Anti-Bribery Convention.
4. Definitions
- Bribe: anything of value offered, promised, given, requested or received to improperly influence a decision or to obtain or retain business or an advantage. It includes cash, gifts, hospitality, travel, loans, discounts, employment, donations and favours.
- Public official: any person holding a legislative, administrative or judicial position, any officer or employee of a government body, state-owned enterprise or public international organisation, any political party official or candidate, and any person acting on their behalf.
- Facilitation payment: a small unofficial payment made to secure or speed up a routine action to which the payer is already entitled.
- Kickback: the return of part of a contract payment as a reward for awarding or favouring business.
5. Prohibited conduct
Personnel and third parties acting for Cekera must never:
- offer, promise, give or authorise a bribe to any person, whether in the public or private sector;
- request, agree to receive or accept a bribe;
- make facilitation payments, even where they are customary locally;
- pay or receive kickbacks;
- use a third party, relative or other channel to do anything prohibited by this policy;
- make a political contribution on behalf of Cekera;
- falsify or conceal any record to hide an improper payment.
6. Payments under duress
If a payment is demanded under a genuine and immediate threat to life, health or liberty, the payment may be made. It must be reported to the Compliance Officer as soon as it is safe to do so and recorded accurately.
7. Dealing with public officials
Dealings with public officials carry heightened risk. No gift, hospitality, travel or other benefit may be offered to a public official without the prior written approval of the Compliance Officer. Customs, tax, licensing and port procedures must be completed through official channels, against official receipts.
8. Third parties
Cekera may be held liable for bribes paid by those who act for it. Before appointing an agent, intermediary, consultant or other representative, the Company will:
- carry out risk-based due diligence on identity, ownership, reputation and connections to public officials;
- confirm that there is a genuine business need and that fees are reasonable for the services provided;
- put a written contract in place that includes anti-corruption obligations, audit rights and the right to terminate for breach;
- pay only against proper invoices, to a bank account in the name of the contracting party, in the country where it operates or provides the services.
9. Red flags
The following must be reported to the Compliance Officer before proceeding:
- requests for payment in cash, to a third party or to an account in an unrelated country;
- unusually high commissions or fees without clear justification;
- a third party recommended by a public official or reluctant to disclose its ownership;
- refusal to agree to anti-corruption contract terms;
- invoices that are vague, inflated or do not match the services provided;
- pressure to bypass normal procurement, contracting or payment procedures.
10. Charitable donations and sponsorship
Donations and sponsorships must be lawful, made to a legitimate organisation, approved in advance by the Director and accurately recorded. They must never be used to gain an improper advantage.
11. Books and records
All payments, gifts, hospitality and expenses must be recorded accurately and supported by documentation. Off-book accounts and false or misleading entries are prohibited.
12. Training and communication
All Personnel will be made aware of this policy when they join Cekera and at regular intervals afterwards. Third parties acting for the Company will be informed of this policy at the start of the relationship.
13. Responsibilities
The Director of Cekera has overall responsibility for this policy and for ensuring that it is applied.
The Compliance Officer is responsible for day-to-day implementation, for giving guidance, for maintaining the records this policy requires and for reporting to the Director. Until a separate appointment is made, the Director acts as Compliance Officer.
All Personnel are responsible for reading, understanding and complying with this policy.
14. Breaches of this policy
A breach of this policy is a serious matter. It may result in disciplinary action up to and including dismissal, or in the termination of a contract with a third party. Where a breach may also be a criminal offence, Cekera may report it to the competent authorities.
15. Questions and reporting concerns
Questions about this policy should be addressed to the Compliance Officer at compliance@cekera.com. Any suspected breach must be reported promptly, in accordance with the Whistleblowing (Speak Up) Policy. No person will suffer retaliation for reporting a concern in good faith.
16. Review
This policy is reviewed at least once a year, and whenever there is a material change in the law or in the business of Cekera. Changes are approved by the Director.