Fraud Policy

Purpose

This Anti-Bribery and Corruption Policy sets out the responsibilities of Kartoza and its employees, contractors, and upholds our zero-tolerance stance on bribery, kickbacks, and corrupt activities. The purpose of this policy is to ensure that everyone connected with Kartoza understands and complies with our legal and ethical obligations regarding bribery and corruption, and to prevent any form of unethical behaviour in our operations.

Policy Statement

  • Kartoza is committed to operating in an ethical and honest manner and enforcing systems that ensure bribery is prevented.
  • We maintain a zero-tolerance approach to bribery, kickbacks, and facilitation payments — whether offered or accepted directly or indirectly.
  • We comply with all anti-bribery and corruption laws applicable in South Africa, Australia, and in every country where we operate.
  • Bribery and corruption are criminal offences that can result in imprisonment, fines, and severe reputational damage. Kartoza takes its legal and ethical responsibilities seriously.

Scope

This policy applies to:

  • All Kartoza employees (permanent, temporary, part-time, or casual),
  • Contractors, consultants, interns, secondees, volunteers, and agency workers,
  • Board members, officers, or trustees,
  • Third parties acting on behalf of Kartoza, including agents, sponsors, suppliers, and partners.

Third parties include all individuals and organisations that Kartoza interacts with:

  • clients,
  • vendors,
  • service providers,
  • government officials.
  • And regulators.

All third-party contracts must include provisions requiring compliance with anti-bribery standards.

Definitions

Bribery

The offering, promising, giving, accepting, or soliciting of an undue advantage (financial or otherwise) to influence a decision or gain improper advantage. Bribes may include:

  • Money, loans, or fees
  • Gifts or entertainment
  • Favourable contracts
  • Personal favours
  • Donations with hidden agendas

Kickbacks

A form of bribery where a payment or advantage is returned (or “kicked back”) in exchange for preferential treatment in business dealings.

Facilitation Payments

Small, unofficial payments to expedite routine actions by public officials (e.g. issuing permits or releasing goods). These are strictly prohibited by Kartoza.

What is Acceptable and What Is Not

A. Gifts and Hospitality

Acceptable gifts or hospitality must:

  • Be of nominal value (typically under R1,000)
  • Be offered openly and transparently.
  • Be given in a company name, not a personal one.
  • Not include cash or equivalents.
  • Be culturally appropriate and lawful.
  • Not be linked to any expected return favour

Prohibited Gifts or Hospitality:

  • Cash or cash equivalents
  • Gifts to influence a business decision
  • Secret or lavish entertainment
  • Offers to or from government officials without approval

Note: All gifts must be reported to the compliance manager.

B. Facilitation Payments and Kickbacks

  • Kartoza prohibits all facilitation payments regardless of the amount or country.
  • No kickbacks will be offered or accepted under any circumstances.
  • If you are coerced into making a payment to protect personal safety:
  • Keep the payment minimal.
  • Request a receipt
  • Record the incident
  • Report immediately to your manager or compliance officer

C.Political Contributions

  • Kartoza does not support any political parties or candidates, whether through financial, in-kind, or service-based contributions.

D.Charitable Contributions

  • Kartoza supports charitable donations that are transparent, legal, and ethical.
  • Contributions must not be used to bypass anti-bribery rules or to secure business advantage.
  • All donations require approval from the compliance manager.

Responsibilities

A. All employees and representatives must:

  • Read and understand this policy.
  • Refuse to offer or accept bribes or facilitation payments.
  • Immediately report any concerns or incidents to the compliance manager.
  • Avoid any activity that could be interpreted as bribery or corruption.

B. Breaches of this policy may result in:

  • Disciplinary action,
  • Dismissal for gross misconduct and/or
  • Legal consequences under local and international law.

Reporting Concerns and Protection

A. Raising a Concern

Report concerns early to:

  • Line Manager or Compliance Manager
  • Director or Head of Governance and Legal

B. If You Are a Victim of Bribery

Report concerns early to:

  • Report any bribe offered or solicited to you.
  • Record the event and notify the compliance manager immediately.

C. Protection

Report concerns early to:

  • Kartoza supports anyone reporting concerns in good faith.
  • No employee will suffer retaliation, discrimination, or adverse treatment for refusing a bribe or raising a concern.

Record Keeping

Kartoza will:

  • Maintain accurate financial records.
  • Keep a register of all gifts and hospitality.
  • Ensure controls are in place to detect improper payments.

Monitoring and Review

The relevant staff members will:

  • Regularly assess the effectiveness of this policy.
  • Monitor internal controls
  • Audit financial records and procedures
  • Employees are encouraged to provide feedback to improve this policy.
  • This policy may be updated at any time to reflect best practices or legal changes. It does not form part of any employment contract.

Conclusion

Kartoza is fully committed to acting with integrity, fairness, and professionalism. Bribery and corruption are not tolerated in any form. This policy is an essential part of ensuring that we maintain our ethical standards and legal compliance in all areas of operation.