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Compliance with applicable laws and regulations is part of Fankama Mining & Construction's corporate identity, which is ultimately reflected in its Code of Conduct.

Prevention and fight against corruption are of particular importance, as any violation of laws can lead to high fines, to obligation to pay damages and even to criminal prosecution. In addition, this could significantly damage the public reputation of Fankama Mining & Construction.

This policy explains the standards for cooperation with business partners and public authorities. It also contains rules to ensure compliance with applicable anti-bribery laws in relation to customers and others.

In the course of their professional activities, Fankama Mining & Construction’s employees shall not, directly or indirectly, offer, promise or give an unjustified benefit in the form of money or other services, nor request or cause any other to promise this advantage. Employees are therefore obliged to do everything possible to avoid even the appearance of any act of corruption.

Obviously, this policy cannot cover every possible scenario. If you have questions or need more information, contact the Fankama Mining & Construction Senior Compliance Officer.

ANTI-BRIBERY POLICY: GOALS AND SCOPE

1. This policy includes standards of conduct for the prevention of corruption and therefore applies to officers, employees and agents of Fankama Mining & Construction (hereinafter referred to as "employee" or " Fankama Mining & Construction’s employee”). It aims to help employees behave properly in certain situations in order to avoid harming themselves and the company.

2. In addition, this policy sets standards for cooperation with business partners, including the possibility of providing benefits to partners in business.

3. With respect to business transactions and decisions made by our employees, applicable laws and other essential regulations must be respected at all times.

4. It is based on the laws in force in Guinea at the time of its publication.

5. It applies worldwide to all executives, employees and agents of Fankama Mining & Construction. In addition, the principles of this policy are also valid for representatives, consultants and other third parties acting on behalf of Fankama Mining & Construction.

6. If the actions of an employee, because of the laws in force in the country where he works, are governed by stricter rules, the latter must replace this policy.

The norms and principles set out in this policy cannot cover all imaginable possible situations that may be considered problematic by the anti-corruption laws. Therefore, every employee is required to use his prudent judgment to assess whether or not a certain mode of conduct violates the rules of the anti-corruption policy. If the behaviour may violate applicable anti-corruption laws, it is up to the employee to consult the respective superior.

BRIBERY: DEFINITION

In general, corruption is defined as accepting or granting benefits in order to illegally influence the course of administrative decisions or private sector decision.

Relations with civil servants are generally subject to stricter anti-corruption regulations. However, corruption is also prohibited in the private sector.

Corruption is a punishable offense in many countries. The party that agrees to be bribed is as likely to be sued as the party willing to bribe.

Corruption goes far beyond accepting or conferring benefits in order to illegally influence the course of administrative decisions or the private sector. Even the offer, the promise, the demand and the promise of a benefit is a punishable offense with all the associated consequences.

CONSEQUENCES FOR EMPLOYEES AND THE COMPANY

Corruption can have significant consequences for employees as well as for the company.
  1. Consequences for employees

    1. Anyone who is guilty of bribery - whether conferring or accepting benefits-would normally commit an offense. Anyone found guilty of corruption may be sentenced or sentenced to pay a high fine.
    2. Corruption can be harmful to business partners and competitors who can personally claim damages from the perpetrator.
    3. By acting corruptly, the employee commits a breach of duty towards his employer. Generally speaking, corrupt behavior justifies the immediate dismissal of the employer.
  2. Consequences for the management

    1. If the employees of Fankama Mining & Construction are guilty of acts of corruption that could have been prevented or made much more difficult by proper local supervision, local managers may have to pay the fines and, in individual cases, even be liable to prosecution.
    2. Therefore, the local management of a company has a legal obligation to thwart corrupt conduct, to carry out regular checks, to investigate suspicious cases and to punish the perpetrators accordingly.
  3. Consequences for the company

    If Fankama Mining & Construction employees are found guilty of corruption, it may be ordered to pay a high fine. If business partners or competitors have been harmed by the corrupt action of an employee, the company may be subject to civil law claims for damages.

THE POSITION OF FANKAMA MINING & CONSTRUCTION

1. Fankama Mining & Construction is determined not to tolerate the use of corrupt practices by its employees or partners. Violation of the rules set out in this policy must have legal consequences and may result in dismissal outright in any particular case.

2. Fankama Mining & Construction prohibits any involvement in or tolerance to corruption or any other form of corruption.

3. The principles addressed in the Fankama Mining & Construction Code of Conduct require that, within the framework of the company, every effort be made to avoid even the appearance of corruption.

4. Fankama Mining & Construction expects all employees to engage in the prevention and detection of corruption in the FMC business environment and thereby enhance the reputation of Fankama Mining & Construction. and in doing so, enhance the reputation of Fankama Mining & Construction.

STANDARDS FOR PREVENTING CORRUPTION

The purpose of the following driving instructions is to avoid even the appearance of behaviors that may lead to corruption.
  1. Relationship with customers and suppliers

    1. The choice of a supplier must be made exclusively in accordance with the principles of competition, according to the price, quality and adequacy of its services to the needs of Fankama Mining & Construction.
    2. Fankama Mining & Construction employees should immediately reject any attempts by suppliers to illegally influence the placement of an order by offering, promising or conferring a personal benefit.
    3. Fankama Mining & Construction employees are strictly prohibited to attempt to illegally influence customer decisions by offering, promising or conferring a personal benefit.
  2. Gifts to Government Officials

    It is strictly forbidden for Fankama Mining & Construction employees to offer, promise or pay any kind of cash or in-kind gifts to employees. This is due to particularly strict rules that prohibit giving gifts to officials.
    Strict rules for civil servants apply to all working people or public service institutions such as government, ministries, government departments. The same is true for foreign public officials. They are also addressed to managers, agents and employees of organized institutions who, because of their status or for other reasons, are treated as civil servants.

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