Anti-bribery and corruption policy

Who it applies to

The policy applies to everyone acting for Accenti, including employees, agents, intermediaries, subcontractors and suppliers, in every country where we work.

Key requirements

• Bribery prohibited

  No bribe in any form, whether money, gifts, hospitality, employment, contracts or donations, directly or through a third party.

• Facilitation payments

  Payments to speed up clearances, permits or checkpoints are prohibited regardless of local practice. Personal safety comes first under threat, and any such payment is reported.

• Gifts and hospitality

  Only modest, infrequent and transparent, never cash, never linked to a tender or pending decision, and always recorded in the register.

• Third parties and due diligence

  Agents, subcontractors and suppliers are screened before engagement. Contracts carry anti-bribery and audit clauses, and payments go only to the contracted party.

• Conflicts and procurement

  Conflicts of interest are declared in writing. Procurement is competitive and documented, and client procurement rules, including those of the United Nations, are observed.

• Accurate books and records

  Every transaction is recorded accurately. Off-book accounts, false invoices and disguised payments are prohibited, and cash use is minimized.

Reference framework

• Anti-corruption law of the Federal Republic of Somalia
• UAE Federal Decree-Law No. 31 of 2021 (Crimes and Penalties Law)
• UK Bribery Act 2010 and US Foreign Corrupt Practices Act, where they apply
• United Nations Convention against Corruption and the UN Supplier Code of Conduct