Anti-Corruption & Anti-Bribery Policy

Jopetnah International Limited (the “Company”) is committed to conducting business with honesty, integrity, transparency and accountability. We maintain a zero-tolerance approach to bribery, corruption, fraud, kickbacks, facilitation payments and other improper influence in all Company activities.

This Policy applies to directors, officers, employees, consultants, contractors, agents, suppliers, intermediaries, business partners and other persons acting for or on behalf of the Company, across Uganda and in jurisdictions where we operate or maintain business relationships.

The Company expects compliance with applicable Ugandan law, including the Anti-Corruption Act, Cap. 116 (as amended), the Penal Code Act and other applicable requirements, together with relevant laws in other jurisdictions where business is conducted.

• Offering, authorising, promising or giving a bribe or improper advantage to any public or private-sector person.
• Requesting, soliciting, agreeing to receive or accepting a bribe, kickback or improper advantage.
• Making or receiving facilitation payments.
• Using gifts, hospitality, travel, entertainment, sponsorships, donations, employment or other benefits to improperly influence a decision.
• Creating false invoices, misleading records, off-book accounts or other arrangements intended to conceal improper conduct.
• Using a third party to do something the Company or its personnel are prohibited from doing directly.
• Retaliating against a person who refuses to participate in corruption or raises a concern in good faith.

Reasonable and modest gifts or hospitality may be acceptable only when lawful, proportionate, transparent, connected to a legitimate business purpose and not intended to influence a decision or create an obligation.

• Cash and cash-equivalent gifts are prohibited.
• Benefits offered during a tender, procurement decision, regulatory process or other sensitive decision require particular caution and, where appropriate, management approval.
• Gifts or hospitality involving public officials require heightened caution and appropriate approval.
• Personnel must not accept benefits that could reasonably create a conflict or appearance of improper influence.
• Material gifts, hospitality or benefits should be disclosed and recorded in accordance with Company procedures.

Agents, consultants, suppliers, intermediaries and partners can create corruption risks. The Company may conduct proportionate due diligence before engagement, including checks relating to identity, ownership, qualifications, reputation, conflicts and the purpose of the proposed relationship.

Contracts should contain appropriate anti-corruption, compliance, records, audit and termination provisions where relevant. The Company may suspend or terminate relationships where credible evidence of serious misconduct is identified, subject to applicable contractual and legal requirements.

All transactions must be supported by accurate documentation and recorded in the appropriate Company records. No person may create or maintain undisclosed funds, false entries, fictitious invoices or misleading descriptions to facilitate or conceal improper conduct.

Procurement, expenses, commissions, consultant payments, donations, sponsorships and other material transactions must follow applicable approval and documentation requirements.

Actual or suspected violations must be reported promptly through the Company’s Whistleblowing / Speak-Up Policy. Reports may be handled confidentially and, where permitted, anonymously. Retaliation, victimisation or adverse treatment for a good-faith report is prohibited.

Breaches may result in disciplinary action up to termination of employment or engagement, contract termination, recovery of losses and referral to competent authorities where appropriate.

Overall oversight rests with the Managing Director and the Company’s senior leadership and governance structures. Personnel are expected to understand this Policy and complete relevant training. The Policy will be reviewed periodically and updated as laws, risks and operations evolve.

Effective date: September 2026  |  Version: 1.0  |  Approved by: Managing Director