1. Gifts, Entertainment and Hospitality
Gifts, entertainment and hospitality are acceptable if they are of a nominal, reasonable, proportionate, and made in good faith and in compliance with our company policies. Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business. These activities are acceptable provided they fall within reasonable bounds of value and occurrence.

Value for the gift to be acceptable can be Ksh .500.00 or less, any value above this shall need management approval.
How do you know if an offered gift, entertainment, or hospitality is acceptable? First, take a step back and ask yourself the following:
• What is the intent – is it to build a relationship or is it something else?
• How would it look if these details were on the front of a newspaper?
• What if the situation were reversed – would there be a double standard?

If you find it difficult to provide a comfortable answer to one of the above questions, ASK your manager.

What to do when you doubt if you can accept? If you are unsure if you should accept something of value – ASK. Ask your manager. If your manager is participating, seek a higher-level manager.

As a general rule, employees and business partners should not provide gifts or hospitality to, or receive them from, a government or other public official (or their close families and business associates).

2. Facilitation Payments
Facilitation payments are not allowed. If you are unsure whether certain payments represent facilitation payments, please contact your manager.

3. Procurement Process
Supplier selection should never be based on receipt of a gift, hospitality or payment. When supplier selection is a formal, structured invitation for the supply of products or services (often called a ‘tender’), it is most important we maintain documentation supporting our internal controls. In the public sector, such a tender process may be required and determined in detail by law to ensure that such competition for the use of public money is open, fair and free from corruption.

A tender process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the tender, no parties having the unfair advantage of separate, prior, closed-door negotiations for the contract where a bidding process is open to all qualified bidders and where the sealed bids are in the open for scrutiny and are chosen on the basis of price and quality.

4. Political Community and Charitable Contributions
Contributions made by Harleys to community projects or charities need to be made in good faith and in compliance with this Anti-Corruption Policy and all relevant Harleys Limited policies and procedures.

5. Books, Records and Internal Control Requirements
All business units must maintain an effective system of internal control and monitoring of our transactions. Certain monitoring controls are identified in our policies, specifically regarding approval of travel and entertainment expenses. It is your responsibility to be knowledgeable of control procedures and ensure compliance.

6. Creating awareness and communication of malpractices observed.
To assist individuals who believe they have discovered malpractice or impropriety, Harley's has a documented and implemented a Whistle blowing policy. Employees of Harley’s and other key stakeholders (public, private, and non-governmental organizations) raise concerns internally and at a high level to disclose information which the individual believes shows malpractice or impropriety. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g., disciplinary.

7. You Are Responsible
Harley's Limited takes corruption and bribery very seriously. Any violation of this policy will be regarded as a serious matter by the Company and is likely to result in disciplinary action, including termination, consistent with local law. Bribery is a criminal offense.

As an employee you will be accountable whether you pay a bribe yourself or whether you authorize, assist, or conspire with someone else to violate an anti-corruption or anti-bribery law. Punishment for violating the law are against you as an individual and may include imprisonment, probation, mandated community service and significant monetary fines which will not be paid by Harley's Limited.

• Harleys Limited will conduct its business honestly and ethically wherever we operate in the world. We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the company’s best interest. Harleys Limited will not compromise its principles for short-term advantage. The ethical performance of this company is the sum of the ethics of the men and women who work here. Thus, we are all expected to adhere to high standards of personal integrity.

• Officers, directors, and employees of the company must never permit their personal interests to conflict, or appear to conflict, with the interests of the company, its clients or affiliates. Officers, directors and employees must be particularly careful to avoid representing Harleys Limited in any transaction with others with whom there is any outside business affiliation or relationship. Officers, directors, and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

• No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity. Officers, directors and employees shall avoid gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity.

• Officers, directors and employees of Harleys Limited will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. This information—whether it is on behalf of our company or any of our clients or affiliates—could include strategic business plans, operating results, marketing strategies, customer lists, personnel records, upcoming acquisitions and divestitures, new investments, and manufacturing costs, processes and methods. Proprietary, confidential, and sensitive business information about this company, other companies, individuals and entities should be treated with sensitivity and discretion and only be disseminated on a need-to-know basis.

• Misuse of material inside information in connection with trading in the company’s securities can expose an individual to civil liability and penalties. Directors, officers, and employees in possession of material information not available to the public are “insiders.” Spouses, friends, suppliers, brokers, and others outside the company who may have acquired the information directly or indirectly from a director, officer or employee are also “insiders.” The Act prohibits insiders from trading in, or recommending the sale or purchase of, the company’s securities, while such inside information is regarded as “material”, or if it is important enough to influence you or any other person in the purchase or sale of securities of any company with which we do business, which could be affected by the inside information.

• Officers, directors and employees will seek to report all information accurately and honestly, and as otherwise required by applicable reporting requirements.

• Officers, directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The officers, directors and employees of Harleys Limited will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

• Officers, directors and employees will obey all Equal Employment Opportunity laws and act with respect and responsibility towards others in all of their dealings.

• Officers, directors and employees will remain personally balanced so that their personal life will not interfere with their ability to deliver quality products or services to the company and its clients.Officers, directors and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management.

• Violation of this Code of Ethics can result in discipline, including possible termination. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether the violator cooperated in any subsequent investigation.



This Policy is Approved By :
NISHIL HARIA
OPERATIONS DIRECTOR.