Energyshelf Limited is committed to conducting its business with integrity, transparency, and in full compliance with all applicable anti-bribery and anti-corruption laws. We maintain a zero-tolerance policy towards bribery and corruption in all forms.

1. Zero Tolerance for Bribery and Corruption

We prohibit any form of bribery, kickbacks, or facilitation payments in all business transactions:

• No Bribery: Offering, giving, receiving, or soliciting anything of value to influence business outcomes or gain an unfair advantage is strictly prohibited.

• Facilitation Payments: Energyshelf Limited does not tolerate facilitation payments or "grease payments" intended to expedite routine government actions or processes.

2. Compliance with Anti-Bribery Laws

We comply with all applicable national and international anti-bribery and anti-corruption laws, including but not limited to:

• Nigerian Anti-Corruption Laws: Adherence to the laws and regulations enforced by the Economic and Financial Crimes Commission (EFCC).

• International Regulations: Compliance with global anti-bribery frameworks, such as the UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA).

3. Responsibility and Accountability

All employees, managers, and directors at Energyshelf Limited are responsible for upholding our anti-bribery policy:

• Employee Responsibility: Every employee must report any suspected bribery or corruption to their supervisor or compliance officer.

• Leadership Accountability: Senior management is responsible for ensuring that anti-bribery procedures are implemented, communicated, and enforced across all business units.

4. Due Diligence and Risk Management

We implement strict due diligence processes to mitigate risks related to bribery and corruption:

• Business Partner Due Diligence: Conduct rigorous background checks on all partners, suppliers, contractors, and agents to ensure they comply with our anti-bribery policy.

• Risk Assessments: Regularly assess bribery and corruption risks in our operations and supply chains, taking corrective actions where necessary.

5. Gifts and Hospitality

The giving or receiving of gifts and hospitality is subject to strict controls:

• Permitted Gifts: Modest, culturally appropriate gifts or hospitality that comply with local laws and company policy may be accepted, provided they do not influence decision-making.

• Reporting: Any gifts or hospitality received or offered must be reported and reviewed by the compliance department to ensure they align with our ethical standards.

6. Reporting and Whistleblowing

We encourage employees and third parties to report any instances of suspected bribery or corruption without fear of retaliation:

• Whistleblower Protection: All reports of suspected bribery or corruption are treated confidentially, and whistleblowers are protected from retaliation.

• Reporting Channels: We provide multiple channels for reporting concerns, including anonymous whistleblowing mechanisms.

7. Training and Awareness

We ensure all employees are well-informed about our anti-bribery policies through:

• Regular Training: All employees undergo mandatory training on the company’s anti-bribery and corruption policies.

• Ongoing Awareness: Communication programs to keep staff updated on any changes in anti-bribery regulations and policies.