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HomePolicy on Anti Bribery Corruption

Policy on Anti Bribery Corruption

ANTI-BRIBERY AND CORRUPTION POLICY STATEMENT

1. POLICY STATEMENT


1.1. Consumer Feedback Consultancy (CFC) is committed to applying the highest standards of
ethical conduct and integrity in its business activities in Zimbabwe and in the Region. Every
employee and individual acting on CFC’s behalf is responsible for maintaining our
reputation and for conducting company business honestly and professionally.
1.2. We take a zero-tolerance approach to bribery and corruption and are committed to acting
professionally, fairly and with integrity in all our business dealings and relationships
wherever we operate.
1.3. The purpose of this policy statement is to:
a. set out our responsibilities, and of those working or providing services for us, in
observing and upholding our position on bribery and corruption;
b. provide information and guidance as to how we expect those working for us to
conduct themselves and how to recognise and deal with bribery and corruption issues;
and
c. how to raise concerns with us including any breaches of this policy statement
1.4. CFC’s Board and Executive Committee are committed to implementing and enforcing
effective systems throughout CFC.


2. WHAT IS BRIBERY?
A bribe, broadly, is an inducement or reward offered, requested, promised or provided in order to
gain any commercial, contractual, regulatory or personal advantage. This can be in the context of
giving or receiving.


3. RESPONSIBILITIES
The prevention, detection and reporting of bribery and other forms of corruption is the
responsibility of all those working for us, or supplying services to us, or under our control.
ANTI-BRIBERY AND CORRUPTION POLICY STATEMENT
Anti-Bribery and Corruption Policy Statement of 25 July 2019


4. GIFTS AND HOSPITALITY
4.1. CFC permits normal and appropriate corporate entertainment, gifts, hospitality and
promotional expenditure (given and received) to or from third parties that is undertaken:
a. for the purpose of establishing and maintaining good business relationships
b. to improve the image and reputation of CFC
c. to present CFC’s services effectively
Provided that it is:
a. in good faith
b. not offered, promised or accepted to secure an advantage for its employees or
associated persons or to influence the impartiality of the recipient
4.2. The giving of gifts by CFC employees with an approximate value of US$50 or higher (or the
local equivalent outside Zimbabwe) is prohibited unless they have been given prior
approval by their Head of Department. With regard to our employees receiving gifts, unless
approval has been provided by the appropriate Head of Department, gifts that exceed a
US$50 threshold must be declined and will be recorded. Gifts in the form of cash must
never be accepted by our employees or service providers and therefore must not be
offered and any offers of cash must be immediately reported to the relevant CFC Executive
Committee member. The giving or receiving of promotional material is not considered a
gift.
4.3. The giving and receiving of corporate entertainment and hospitality for our employees
should not exceed an approximate value of US$50 per head (or the local equivalent outside
the Zimbabwe) without prior approval by a CFC Executive Committee member where
possible and reasonable to do so in the circumstances.
4.4. The test to be applied is whether in all the circumstances, the gift, entertainment or
hospitality is reasonable and justifiable. We expect the intention behind the gift to always
be considered.


5. WHAT IS NOT ACCEPTABLE
Below are some non-exhaustive scenarios we think are not acceptable for employees or service
providers of CFC to do, namely:
a. give, promise to give, or offer, a payment, gift or hospitality to a third party with the
expectation or hope that a business advantage will be received, or to reward a business
advantage already given;
Anti-Bribery and Corruption Policy Statement of 25 July 2019
b. give, promise to give, or offer, a payment, gift or hospitality to a government official,
agent or representative to “facilitate” or expedite a routine procedure;
c. give, offer or promise to a foreign public official to induce that public official to obtain or
retain business or an advantage in the conduct of business (and that is not permitted by
local laws), request, agrees to receive or accept payment from a third party knowing or
suspecting it is offered with the expectation that it will obtain a business advantage for
them;
d. request, agrees to receive or accept payment from a third party knowing or suspecting it
is offered with the expectation that it will obtain a business advantage for them;
e. accept a gift or hospitality from a third party knowing or suspecting that it is offered or
provided with an expectation that a business advantage will be provided by CFC in
return
f. threaten or retaliate against another worker who has refused to commit a bribery
offence or who has raised concerns under this policy; and
g. engage in any activity that might lead to a breach of this policy


6. FACILITATION PAYMENTS AND KICKBACKS
6.1. We and our service providers should not make, and should not accept, facilitation
payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial
payments made to secure or expedite a routine government action by a government
official. Kickbacks are typically payments made in return for a business favour or advantage.
We expect all employees and service providers must avoid any activity that might lead to,
or suggest, that a facilitation payment or kickback will be made or accepted by us.
6.2. If you are asked to make a payment on behalf of the CFC, you should always be mindful of
what the payment is for and whether the amount requested is proportionate to the goods
or services provided. You should always ask for a receipt which details the reason for the
payment.
6.3. Any transactions in contracts and documentation must be recorded so that there is never
any attempt to hide the way a contract will work.


7. RECORD KEEPING
7.1. We and our service providers are expected to keep financial records and have appropriate
internal controls in place which will evidence the business reason forgiving and/or receiving
payments from/to third parties.
Anti-Bribery and Corruption Policy Statement of 25 July 2019


8. RAISING CONCERNS
8.1. If you believe this policy has been breached, or suspect it may have been breached, in any
way please contact Consumer Feedback Consultancy’s Finance & Admin Director, Thabani
Dhliwayo (farai@consumerfeedback.co.zw).

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