Last Updated: 01/11/2025

At Wondernut International EPZ Ltd, we uphold the highest standards of integrity, fairness, and accountability.
We are committed to conducting all business honestly, transparently, and in full compliance with local and international anti-corruption and ethical conduct laws.

This policy establishes our zero-tolerance approach toward bribery, fraud, and any form of unethical behavior in our operations or partnerships.

1. Purpose

The purpose of this policy is to ensure that Wondernut operates ethically and transparently — preventing corruption, promoting fair business practices, and safeguarding our reputation as a responsible global company.

2. Scope

This policy applies to:

• All directors, officers, employees, and contract staff.

• Third-party agents, suppliers, distributors, and joint venture partners acting on behalf of Wondernut.

• All domestic and international business operations.

3. Core Principles

a. Zero Tolerance for Bribery & Corruption
Wondernut strictly prohibits offering, giving, soliciting, or accepting any form of bribe or undue advantage — whether directly or indirectly — to gain or retain business or influence decisions.

b. Gifts & Hospitality
Reasonable, occasional hospitality may be acceptable if it is transparent, lawful, and not intended to influence business outcomes.
All gifts and entertainment exceeding company thresholds must be declared to management and recorded.

c. Conflicts of Interest
Employees must avoid situations where personal interests conflict with company interests.
Any potential conflict must be disclosed immediately to the Compliance Officer.

d. Facilitation Payments
No employee or representative shall make facilitation payments (“speed payments”) to secure routine approvals or services.

e. Financial Transparency
All transactions must be accurately recorded in the company’s books and subject to audit. False accounting, concealment, or misrepresentation of financial data is strictly prohibited.

f. Due Diligence & Third-Party Compliance
All suppliers, partners, and intermediaries must undergo ethical and compliance screening.
Contracts include anti-corruption clauses requiring adherence to this policy.

4. Reporting & Whistleblowing

Wondernut encourages employees and partners to report suspected misconduct or breaches of this policy.
Reports can be made confidentially to the Compliance & Ethics Committee via secure communication channels.
All reports will be investigated promptly and fairly, with strict protection against retaliation.

5. Roles & Responsibilities

• Board of Directors: Oversees implementation and enforcement of the policy.

• Compliance Officer: Ensures training, monitoring, and reporting of compliance risks.

• Employees: Must adhere to the policy and complete mandatory ethics training annually.

6. Training & Awareness

All employees receive anti-corruption and compliance training during onboarding and refresher sessions thereafter.
Regular communication reinforces awareness of evolving legal requirements and company expectations.

7. Enforcement & Disciplinary Action

Violations of this policy are treated seriously.
Disciplinary measures may include termination of employment, termination of contracts, and legal action under applicable anti-bribery and corruption laws.

8. Policy Review

This policy is reviewed annually to ensure ongoing relevance, legal compliance, and effectiveness. Updates are communicated to all staff and partners.

9. Contact Information

For questions or to report concerns confidentially, please contact:

Wondernut International EPZ Ltd
Athi River EPZ, Machakos County, Kenya
📧 Email: [Insert compliance or ethics email]
🌐 Website: www.wondernutint.com

At Wondernut, integrity is non-negotiable.
We believe that ethical conduct is not just good practice — it is the foundation of trust, credibility, and sustainable success.