FLEX FINANCE ANTIBRIBERY AND CORRUPTION (ABC) POLICY

1. Policy Statement

Flex Finance maintains a zero-tolerance approach to bribery and corruption. We are committed to conducting business with integrity, transparency, and in compliance with all applicable antibribery and anticorruption laws, including but not limited to:

• Nigeria’s Corrupt Practices and Other Related Offences Act (2000)
• UK Bribery Act (2010)
• U.S. Foreign Corrupt Practices Act (FCPA) (1977)
• Any local anticorruption laws in countries where Flex operates

2. Scope

This policy applies to:

• All employees, officers, and directors of Flex Finance
• Contractors, agents, consultants, and third parties acting on behalf of Flex
• Subsidiaries, affiliates, and joint venture partners

3. What is Bribery?

Bribery is offering, giving, receiving, or soliciting anything of value to improperly influence the actions of another party. Bribes can take many forms, including:

• Cash or cash equivalents (e.g. gift cards, crypto)
• Gifts, entertainment, or hospitality beyond reasonable limits
• Kickbacks or facilitation payments
• Political or charitable donations tied to favourable treatment

4. Prohibited Conduct

Under this policy, it is strictly prohibited to:

• Offer or accept bribes in any form
• Make facilitation payments (small payments to expedite routine actions)
• Use intermediaries to make improper payments
• Offer anything of value to public officials to gain a business advantage
• Falsify records to conceal corrupt activity

5. Gifts and Hospitality

Gifts and hospitality must be:

• Modest in value
• Infrequent and appropriate
• Not intended to influence a business decision

All gifts or hospitality above ₦150,000 or local equivalent must be pre-approved by the Head of Compliance.

6. Third-Party Risk Management

All third parties must undergo risk-based due diligence prior to engagement. High-risk partners (e.g., agents interacting with government officials) require enhanced screening and written contractual undertakings on ABC compliance.

7. Record Keeping

All payments, expenses, and approvals must be accurately recorded in our books and systems. No off-book accounts are permitted.

8. Reporting and Whistleblowing

Employees and third parties must report suspected or actual bribery or corruption via:
Email: [email protected]

Reports are treated confidentially and without fear of retaliation.

9. Consequences of Violation

Violations may lead to:

• Disciplinary action, including dismissal
• Civil or criminal liability for individuals and Flex
• Termination of business relationships

10. Training and Awareness

All employees will receive regular training on this policy. Key roles (sales, procurement, compliance) will receive additional, role-specific training.

11. Oversight and Review

The Head of Compliance is responsible for policy implementation and review.
This policy will be reviewed annually and updated as necessary.

12. Acknowledgement

All employees and relevant third parties must acknowledge that they have read, understood, and agree to comply with this policy.