Anti-Bribery and Corruption Policy
Apex Grove Distribution Ltd ("Apex Grove") takes a zero-tolerance approach to bribery and corruption. Much of our work is for county governments and government agencies, and our trading activities involve international counterparties, so integrity is essential. This policy reflects the Bribery Act 2016, the Anti-Corruption and Economic Crimes Act 2003, the Public Procurement and Asset Disposal Act 2015 of Kenya, and, as part of the Earthe group, the UK Bribery Act 2010.
Scope
This policy applies to the director, officers, employees, agents, consultants, subcontractors and anyone acting on our behalf.
Prohibited Conduct
- Offering, promising, giving, requesting or accepting a bribe, directly or through a third party.
- Facilitation payments to speed up routine actions such as permits, inspections, customs clearance or payment of invoices.
- Improperly influencing tender processes, evaluation or contract award, or colluding with other bidders.
- Falsifying records, invoices or certificates of work.
Public Officials
We do not offer anything of value to public officials, procurement officers or their relatives to obtain or retain business or any advantage. All dealings with officials must be transparent, documented and through proper channels. Any request for a payment must be refused and reported.
Gifts and Hospitality
Gifts and hospitality must be modest, infrequent, appropriate and never given or received to influence a decision. No gifts or hospitality may be offered to public officials involved in a current or pending procurement. Cash or cash equivalents are never permitted. Anything beyond token value must be approved in advance and recorded in the gifts register.
Political and Charitable Contributions
We do not make political contributions. Charitable or community contributions must be approved, transparent and not linked to any business decision.
Conflicts of Interest
Staff must declare any personal or family interest that may conflict with their duties, including links to public officials or suppliers.
Due Diligence on Third Parties
Before engaging agents, subcontractors, suppliers or trading counterparties, we carry out risk-based due diligence covering ownership, reputation, qualifications and any history of corruption. Contracts include anti-bribery obligations and termination rights. Payments are made only against genuine services, at fair value, to accounts in the counterparty's name.
Records
We keep accurate books and records of all transactions, and no off-book accounts are permitted.
Reporting and Consequences
Concerns must be reported to connect@apexgrove.ke under our Whistleblowing Policy. Breaches may lead to dismissal, termination of contracts and referral to the Ethics and Anti-Corruption Commission or other authorities.
Review
This policy is reviewed at least annually by senior leadership.
Last reviewed: November 2026
Signed:
Gruffald Salter, CEO
Apex Grove Distribution Ltd