Anti-Corruption Policy

Purpose

At Elba Afrika, we are dedicated to conducting business with integrity, transparency, and in full compliance with international anti-corruption laws. This policy reflects our commitment to preventing corruption and bribery and ensuring compliance with legislation in all jurisdictions where we operate, including Australian and U.S. laws, as well as the laws of the Democratic Republic of Congo (DRC) and Zambia.

2. Who We Are

Elba Afrika operates across multiple countries, including the DRC, Zambia, and other regions, upholding the highest ethical standards. We expect our employees, contractors, and business partners to maintain these standards in all locations where we do business.

3. What We Prohibit
4. Bribery: No employee, contractor, or partner may offer, give, or accept anything of value with the intent to improperly influence a decision or gain an unfair advantage.
5. Facilitation Payments: Elba Afrika strictly prohibits any small, unofficial payments made to expedite routine government actions. These payments are illegal under most international anti-corruption laws, including those in Australia, the U.S., DRC, and Zambia.
6. Improper Gifts and Entertainment: Only modest and transparent gifts, entertainment, or hospitality are permitted, provided they are not intended to influence business decisions.
7. Global Compliance

Elba Afrika adheres to a range of anti-corruption laws, including:

1. The U.S. Foreign Corrupt Practices Act (FCPA)
2. The Australian Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024
3. Local anti-corruption laws in the Democratic Republic of Congo, Zambia, and any other countries in which we operate

Our operations in foreign jurisdictions are subject to extra scrutiny, and we require strict compliance with local and international regulations when dealing with government officials and third parties.

5. Commitment to Due Diligence

Elba Afrika ensures that all employees, contractors, and third parties undergo due diligence checks to prevent any involvement in corrupt practices. Contracts with external parties must include anti-corruption clauses in line with international and local laws.

6. Reporting Corruption

We strongly encourage employees, contractors, and business partners to report any suspicion or evidence of corruption. Elba Afrika maintains a confidential and secure whistleblowing system, and all reports are handled with discretion, ensuring there is no retaliation against whistleblowers.

7. Consequences of Violations

Any violations of this policy, whether under international or local law, will result in disciplinary action, including possible termination of employment or contracts. Elba Afrika reserves the right to pursue legal action if necessary.

8. Record Keeping and Accountability

All financial transactions must be accurately recorded to reflect the true nature of business activities. We do not permit false or misleading entries in any of our records, in compliance with international and local laws.

9. Training and Awareness

Elba Afrika provides anti-corruption training to ensure that employees, contractors, and partners understand the legal requirements and ethical standards they must follow, with additional training focused on specific regional compliance in the Democratic Republic of Congo and Zambia.

10. Contact Us

If you have any questions regarding this policy, or to report potential violations, please contact our Compliance Officer at compliance@elbaafrika.com

This policy will be reviewed regularly and updated as necessary to reflect any changes in local or international law, or company practices.