The Company undertakes to adhere at all times to sound Corporate Governance Policies, including but not limited to:

Clear Strategy

Good corporate governance starts with a clear strategy for the organization. At each stage, knowing the overall strategy helps the company’s workforce stay focused on the organizational mission: meeting the needs of the consumers in that target market.

Effective Risk Management

The Consortium shall implement effective strategic risk management plans and policies and shall have a committee dedicated to this aspect of the Consortium’s governance.

Discipline

Corporate policies are only as effective as their implementation. Good corporate governance requires having the discipline and commitment to implement policies, resolutions and strategies and not only that but to continually monitor the implementation and performance of these matters.

Fairness

Fairness must always be a high priority for management. Too heavy a heavy workload can have negative long-term effects, such as low morale and high turnover. Companies also must be fair to their contractors and transparent in their dealings with contractors, employees, consulants, local communities and governmental regulators for ethical and public-relations reasons as well as increasing efficiencies.

Transparency

Corporate transparency helps unify an organization: When employees understand management’s strategies and are allowed to monitor and play an active role in the company’s performance, they understand their roles within the company. Transparency is also important to the public, who tend not to trust secretive corporations.

Social Responsibility

Social responsibility at the corporate level is increasingly a topic of concern. Communities expect companies to be good corporate citizens, for example, by initiating recycling efforts and reducing waste and pollution. Good corporate governance identifies ways to improve Company practices and also promotes social good by reinvesting in the local community.

Self-Evaluation

Self-evaluation is a key part of the Consortium’s corporate governance policy. Mistakes will be made, no matter how well you a company is managed. Regular self-evaluations to identify and mitigate brewing problems will be encouraged and enforced. Hiring outside independent consultants to analyse operations will be employed to allow focus on problem areas, be they of a financial, HSE, regulatory, operational or production and sales nature.

Anti-bribery and Corruption Policy

Corruption is a symptom of numerous difficulties within contemporary societies. Corruption is a problem of routine deviation from established standards and norms by public officials and parties with whom they interact. These include bribery, private gain,and other benefits to non-existent workers and pensioners (called ghost workers). The dishonest and illegal behavior exhibited for their personal gain is corruption. According to the ICPC Act of Nigeria, corruption includes vices like bribery, fraud, and other related offences. Corruption is the abuse or misuse of power or position of trust for personal or group benefit (monetary or otherwise).

Within Nigeria there is a comprehensive system of Acts, agencies and commissions designed to combat corruption at many different levels including the Independent Corrupt Practices Commission (ICPC) and the Economic and Financial Crimes Commission (EFCC).

External to Nigeria there are a number of similar systems in place, for example covering corrupt practices that may apply to the citizens of the United Kingdom, Australia and the United States of America operating either domestically or within Nigeria and or other foreign jurisdictions.

The Consortium members undertake that they (including its Officers, Directors, Employees and Agents) shall:

  1. conduct business in accordance with high ethical standards, and in compliance with all applicable laws and regulations (local or international) prohibiting bribery and any and all other forms of corruption and/or bad faith (including without limitation the Criminal Code Act 1995 (Cth. Australia), the Bribery Act UK 2010, the Corrupt Practices and other Related Offences Act 2000 of Nigeria, the Foreign Corrupt Practices Act (U.S. 1977) and or any updated related relevant legislation and shall not do anything that might prejudice the other party from complying with the same;
  2. not directly or indirectly, through any third party, pay, give, offer, promise or authorise payment of any money or anything of value to any person, including without limitation any agency or entity issuing a solicitation for bids, for the purpose of improperly incentivising or rewarding favourable treatment or advantage in connection with the Services, proposal or projects underlying the Consortium’s business affairs;
  3. appoint a specific Officer who shall be responsible for comprehensive introductory and continuing training and awareness programmes throughout all Consortium members;
  4. immediately investigate any reports of corruption or bribery and take action to report it to the relevant authorities.