Anti-Bribery and Corruption Policy

It is our policy to comply with all Nigerian laws, rules and regulations governing anti – bribery and corruption. This Policy applies to directors, employees, agents, intermediaries, consultants or other business partners and any other persons, organizations or bodies doing business with us. 

 The direct or indirect offer, payment, soliciting, authorization or acceptance of bribes in any form (including favors) is not allowed. No bribes of any sort may be solicited from, paid to or accepted from customers, suppliers, agents, consultants, intermediaries, joint ventures or other business partners, stakeholders, politicians, and/or government officials 

 It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions or decisions 

 CEJUL BROTHERS will promote its policy on bribery and corruption amongst its directors, employees, business partners, stakeholders, contactors, vendors and suppliers. 

 Recognizing that facilitation payments are bribes, CEJUL BROTHERS expressly prohibits such payments. Thus, directors, officers, employees, agents, customers, contractors, suppliers, vendors, joint venture or other business partners and stakeholders are not allowed to solicit, make or receive facilitation payments on behalf of the company.

 CEJUL BROTHERS prohibits the solicitation, offer or receipt of gifts and hospitality whenever they could affect or be perceived to affect the outcome of business transactions or decisions and are not reasonable and bona-fide 

 No expenditure of gifts, travel, lodging or entertainment for any Government Official or business partner or third party may be for the purpose of influencing any official action or to procure any improper advantage 

 Charitable donations and sponsorships shall not be provided to any organization upon the suggestion or request of a public (government) official or for the purpose of influencing a public official 

 CEJUL BROTHERS shall not make payments and/or donations to political parties, organizations or their representatives 

 When retaining, paying or working with an agent or intermediary, it is mandatory to: 

 Undertake properly documented due diligence. 

 Have a solid, documented basis for trusting the intermediary. 

 Take reasonable steps to monitor for and prevent misconduct 

 Ensure compliance with the Anti-Bribery Policy 

 We Make known the Anti-Bribery Policy to contractors, agents, intermediaries, suppliers, joint venture partners and other business partners and expect compliance from them 

 We take reasonable steps to monitor for and prevent misconduct 

 Breach of the provisions of the Anti-Bribery Policy constitutes serious misconduct and will be subject to appropriate disciplinary measures including, but not limited to, termination of employment or appointment of the affected officer or employee. 

 Breach of the Anti-Bribery Policy by agents, contractors, intermediaries, suppliers, vendors, consultants, joint venture or other business partners may lead to the termination of such business relationships. 

 Breach of the Anti-Bribery Policy may also result in civil or criminal proceedings against defaulters.