Dear employees and partners,
KPpay is firmly committed to conducting its business with integrity and transparency in all the markets in which it operates. As an innovative digital financial services platform, KPpay aspires to be a leader in digitizing transactions in compliance with ethical and regulatory standards. We adopt a zero-tolerance policy towards corruption in all its forms and expect every member of our organization to fully adhere to this commitment.
This policy aims to provide a frame of reference for all KPpay employees, partners, suppliers, consultants and other stakeholders. It defines the principles and behaviors expected to prevent and combat corruption in all its forms, including influence peddling, bribes and facilitation payments. This policy applies to all KPpay entities, in all countries where it operates.
This anti-corruption policy is in line with international anti-corruption conventions, notably those of the African Union, the United Nations, and national laws in force in the countries where KPpay operates.
Corruption : Any action aimed at offering, promising, giving or soliciting, directly or indirectly, an undue advantage to influence an act in the exercise of professional duties, or to reward such an act, constitutes an act of corruption.
Influence peddling : An act of influence peddling is any action aimed at soliciting or accepting, directly or indirectly, an advantage in order to use one's real or supposed influence to obtain a favorable decision from a public or private authority.
KPpay applies a zero-tolerance policy to corruption and influence peddling. Under no circumstances may an employee or third party acting on behalf of KPpay :
Offering or accepting a payment, gift, commission, trip, invitation or other gratuity in order to obtain an undue advantage or to reward an advantage already granted.
Make a facilitation payment to a public official or intermediary to speed up a routine procedure.
Give in to extortion demands under pressure , except in the event of a threat to life, health or liberty, in which case the incident must be reported as soon as possible.
To avoid any risk of corruption or conflict of interest, KPpay strictly limits gifts and invitations::
Gifts and Invitations : The giving or acceptance of gifts and invitations must be done in a reasonable manner, in a professional context, with no intention of influencing a business transaction or decision. Cash gifts are strictly forbidden.
Thresholds and Declaration : Any gift or invitation exceeding a defined threshold must be declared to the Compliance Officer. A gift register will be kept to ensure full traceability of benefits received or offered.
KPpay encourages its employees to report any suspicion of corruption or influence peddling through a secure alert system:
Reporting channel : Any suspicion of corruption should be reported via the dedicated alerte.compliance@kppay.co address. The whistleblower's anonymity and confidentiality are guaranteed.
Protection of whistle-blowers : No employee will be penalized or discriminated against for reporting a whistle-blowing incident in good faith. However, any misuse of the whistleblowing system is liable to disciplinary action.
Conflicts of interest must be avoided in order to preserve the integrity of decisions made by KPpay:
Identification and prevention : All employees are required to declare any actual or potential conflict of interest to the Compliance Officer.
Conflict management : A conflict of interest management system is in place to ensure impartial decision-making and protect KPpay's interests.
Patronage and sponsorship : Patronage and sponsorship initiatives comply with ethical standards and aim to contribute to community development without any undue consideration.
Representation of interests : All lobbying activities are carried out with transparency, in compliance with the regulations in force, and avoiding any behavior that could be perceived as corruption.
Risk mapping : KPpay maintains a corruption risk map which is periodically updated to identify areas of risk in its operations.
Evaluation of third parties : Due diligence procedures are carried out to assess the compliance of partners and suppliers with anti-corruption standards.
Rigorous internal controls are in place to detect and prevent any act of corruption:
Compliance controls : Control processes are strengthened to ensure compliance with anti-corruption standards.
Accounting traceability : All accounts, invoices and documents relating to transactions are kept accurately and exhaustively to prevent fraudulent manipulation.
Data and documents demonstrating the application of the anti-corruption policy are archived to ensure full traceability and demonstrate KPpay's compliance.
KPpay's Ethics and Compliance Committee is responsible for ensuring the application of this policy and its effectiveness:
Responsibility of the Chief Compliance Officer : The Chief Compliance Officer, in collaboration with the compliance teams, oversees the deployment of the policy and the monitoring of its effectiveness.
Continuous improvement : This policy is periodically reviewed to incorporate best practices and adapt to regulatory changes.
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