Policies

Introduction

The most important means by which Rango can avoid criminal exposure to third parties (service providers, suppliers, business partners, companies in consortium, representatives, temporary advisors or any other person or company that act on behalf of Rango, directly or indirectly) who use the resources of the company for illicit purposes is to have a clear and concise understanding of the third parties’s practices. The adoption of an effective “Know Your Customer” policy will enhance the company’s ability to detect suspicious activities by customers in a timely manner. It will also facilitate compliance with relevant regulatory requirements.

In formulating an effective KYC policy, it is important to note that appearances can be deceptive. Potential business partners of Rango may appear legitimate but in reality be conducting illicit activities through the company, while legitimate business partners may be turned away from the company because their activities are perceived to have a criminal tone. The policy must therefore, at a minimum, contain a clear statement of management’s overall objectives, expectations and establish specific line responsibilities.

Objectives

The objectives of Rango’s KYC policy are as follows:
• Ensure that Rango is in full compliance with all statutes and regulations and adheres to sound and recognized practices.
• Ensure that Rango will not become a victim of illegal activities perpetrated by its clients.
• Ensure an effective policy that protects the good name and reputation of Rango in accordance with the best corporate governance and Compliance practices, ensuring the complete and effective awareness of its clients and their activities, and establishing criteria of ethical, professional and good faith conduct.
• Ensure that the policy does not undermine the cordial relationship between Rango and its credible customers.

Scope

This policy is applicable to Rango Construction Company Ltd as well as Third Parties, who act for and/or represent Rango in its activities.

Content of the Policy

The following principles will be incorporated into the business practices of Rango:
• Rango will make a reasonable effort to determine the true identity of all third parties requesting the company’s services.
• Rango will take particular care to identify the ownership of all contract agreement. Rango will put in place a process for the identification of unusual transactions and activities that are inconsistent with the third party’s known business. In this regard, the company will establish a set of procedures that facilitates the collation of sufficient information for each customer. The primary objective of such procedures is to enable Rango predict with relative certainty the types of transactions in which a customer is likely to engage.
• Once identified, Rango will report suspicious transactions to appropriate personnel as directed by their businesses’ policies and procedures.
• Establish internal training programs.
• Rango shall not deal with ‘shell companies, i.e. companies incorporated in a jurisdiction in which it has no physical presence and is not affiliated with regulated sectors.

Staff Training

Every employee (interns, staff of all operational and managerial levels, advisors, directors and officers) of the company, shall be trained on AML at a minimum of once a year.

Anti-money Laundering Policies, Procedures and Regulatory Requirements

Definition of money laundering and terrorist financing
Money laundering is a process in which assets obtained or generated by criminal activity are moved or concealed to obscure their link with the crime. Perpetrators of the crime find ways to launder the funds in order to use them without drawing the attention of authorities.
Money laundering empowers corruption and organized crime where corrupt public officials and criminals are able to launder proceeds from crimes, bribes, kick-backs, public funds and on some occasion, even development loans from international financial institutions. Organized criminal groups want to be able to launder the proceeds of drug trafficking and commodity smuggling through the financial systems without a trace. In the modern day definition, money laundering now covers various offences including child trafficking, prostitution, etc. Generally, money laundering has three stages;

Placement

The physical disposal of cash/property derived from criminal activity. The purpose of this stage is to introduce proceeds into the traditional or non–traditional financial system without attracting attention e.g. purchase of artwork, cash deposits, casinos etc.

Layering

This involves separating source of proceeds from ownership by changing the form. It is designed to hamper audit trail e.g. complex wire transfers, resell of assets/properties, purchase of multiple investment-linked life policies to disguise origin of funds etc.

Integration

Re–channeling the laundered funds back to the financial system as legitimate funds.
The degree of sophistication and complexity in the money laundering scheme is infinite and is limited only by the creative imagination and expertise of criminals. Terrorist activities are sometimes funded from the proceeds of illegal activities.
Although often linked in legislation and regulation, terrorist financing and money laundering are conceptual opposites. Money laundering is the process where cash raised from criminal activities is made to look legitimate for re-integration into the financial system, whereas terrorist financing cares little about the source of the funds, but it is what the funds are to be used for that defines its scope.
In recent years, the international community has become more aware of the dangers that money laundering and terrorist financing poses in all these areas, and many governments and jurisdictions have committed themselves to taking action. The United Nations and other international organizations like Financial Action Task Force (FATF) are committed to helping governments in any way they can.

The Implication and Impact of Money Laundering on Rango

Where Anti-Money Laundering rules apply, compliance by the stakeholders of Rango Construction Company is mandatory. Four key principles apply:
• Staff and key stakeholders of Rango should not engage in money laundering activities knowingly.
• Staff and key stakeholders of Rango Construction Company should not assist others in engaging in money laundering activities.
• Rango and their personnel should not interfere with an authorized official investigation of money laundering.
• Personnel of Rango must implement appropriate processes, systems and controls to ensure compliance with local AML laws and regulations.

Failure of Rango and its staff to observe these principles damages the reputation, brand and goodwill of both Rango and the network of Rango Construction Company, and risk exposure to criminal prosecution and or regulatory action.

The Importance of Money Laundering To the Individual Employee and Rango Construction Company Ltd

In adhering to this Policy, as with every aspect of its business, Rango expects that its employees will conduct themselves in accordance with the highest ethical standards. Rango also expects its employees to conduct business in accordance with applicable money laundering laws. Rango employees shall not knowingly provide assistance to individuals who attempts to violate or avoid money laundering laws or this Policy.
Money Laundering laws apply not only to criminals who try to launder their ill-gotten gains, but also to institutions and their employees who participate in those transactions, if the employees know that the property is criminally derived.
“Knowledge” includes the concepts of “willful blindness” and “conscious avoidance of knowledge”. Thus, employees whose suspicions are aroused, but who then deliberately fail to make further inquiries, wishing to remain ignorant, may be considered under the law to have the requisite “knowledge”.

Rango Construction employees who suspect money laundering activities should refer the matter to appropriate personnel as directed by their businesses’ policies and procedures.
Failure to adhere to this Policy may subject Rango employees to disciplinary action up to and including termination of employment. Violations of money laundering laws also may subject Rango employees to imprisonment and, together with Rango Construction, to fines, forfeiture of assets, and other serious punishment.

As a company, the under-listed policies are put in place to guard against signing on persons and organizations involved in money laundering activities:

Principle of “Know Your Customer” (KYC)
• Customers are required to complete forms that captures information that will enable the Company to access the money laundering risk of the customer or the transaction.
• Relationship with the customer should not be established until we are convinced that the customer is not involved in money laundering activities.
• For all high risk businesses, site visitation of client’s address shall be carried out.
• The form shall capture enough KYC details to ensure that organizations or persons involved in money laundering activity are not signed on as customers.
• The company’s relationship managers and other officers of the company should be trained to be able to recognize suspicious transactions, such that timely return could be rendered to the regulatory authorities.
• Money laundering training should also be part of courses conducted for new staff members of the company.
• Suspicious transactions shall be reported to regulatory authorities as soon as such are detected.
• Appropriate measures shall be put in place to ensure that blacklisted terrorist organizations circularized by the FIC are not signed on as customers.

Regulatory Framework

Companies in Ghana are monitored for money laundering under the provisions of various regulations which are highlighted below:
List of Regulations
• AML Act 2008 – Act 749
• AML (Amendment) Act, 2014, Act 874
• AML Regulations 2011 L.I. 1987
• Anti-Terrorism Amendment Act, 2012 Act 842
• Anti-Terrorism Regulations L.I. 2181
• Criminal and Other Offences Act, 1960, Act 29
• Criminal Offences Amendment Act, 2012 – Act 849
• Economic and Organized Crime Act, 804
• Economic and Organized Crime Regulations, LI2183
• Gazette Notice with Regard to Terrorist Individuals Immigration Amendment Act 2012 (criminalized migrant smuggling in line with FATF standards)

Standard Principle of “Customer Identification” (KYC)

Rango shall have policies and procedures to determine and document at the time of the establishment of the business relationship, information that is commensurate with the assessment of the money laundering risks posed by the customer’s expected use services as shown below:
• The customer’s Name
• The customer’s form of ID
• The customer’s Proof or residence
• The customer’s source of funds
• The customer’s source of income and assets

Rango businesses shall have policies and procedures for obtaining and updating customers’ information obtained at the time of the establishment of a relationship i.e. “customer’s profile”. To achieve this, customers’ information shall be obtained and updated the on-boarding stage.

Information on customers of Rango Construction Limited

Rango shall establish policies and procedures under which the company can rely upon for information on the identification of a customer who maintains mutual relationship.

Watch list Check

Rango shall have policies and procedures that will ensure compliance with standard AML global requirement for maintenance of a data base for individuals/entities subject to sanction by the United Nations in its database.
The implication of this is that all processing units are required to check every single transaction for any individual/entity against this database and report any matching details to the MLRO and appropriate regulatory authority. The list will include Politically Exposed Person (PEP) List, Specially Designated Nationals (SDN) List, Office of Foreign Assets Control (OFAC) List, United Nations (UN) List, European Union (EU) List etc.

Compliance with Legislation

Rango will observe high ethical standards within the confines of the laws and regulations guiding its operations.

Cooperation with Law Enforcement Authorities

Rango will give full cooperation to law enforcement authorities within the limits of the rule governing confidentiality. For instance, where a company is aware of the facts that certain funds used in financing businesses was derived from criminal activity or intention, the company is expected to observe the stipulated procedures for disclosure of suspicious transactions by reporting to the Financial Intelligence Center (FIC) immediately.

Kyc Documentation Requirement

The Company is obliged to confirm and verify the identity of each person who enters into a business relationship with them. Hence, as part of the Company’s obligations to comply with applicable Anti-money laundering & Know Your Customer legislation, the Company requests its Clients and business partners to provide certain Verification Documents.

However, it is important that the Firm’s customers conform to the Firm’s principles and standards. Among other things, the following principles are considered as a part of the Know Your Customer procedure:
• The Company will not accept as Clients persons engaged in unethical behavior or in illegal activities;
• The Company will not accept as Clients or associates, parties that they cannot make a well informed and reasonable judgment as to the activities in which they are engaged;
• The Company will not accept as Clients, persons unwilling to provide sufficient documents/data and information.
• The Company will accept only those new Clients who complete the appropriate risk assessment forms and provide the Company with all necessary Verification Documents and information to the satisfaction of the Rango.
• The Company will accept a prospective or potential Client only when it becomes fully satisfied that the Client complies with Know Your Customer and due diligence procedures to ensure that a new relationship with the potential Client does not negatively affect the reputation of the Firm.

For the proper identification of the client and performing due diligence procedures, Rango will use the KYC Checklist as a tool being an integral part of the client/ third party acceptance or continuance procedures. The KYC Checklist is attached as Appendix I.
The information in the KYC form shall be maintained and constantly updated whenever relevant new information about the business partner surfaces.

If, during the business relationship, a Client or vendor fails or refuses to submit, within a reasonable timeframe set by the Company, the required documents, data and information requested by the Firm; the Company is entitled to terminate the business relationship. Moreover, during the business relationship additional documents may be requested by the Company and/or an update of the existing documents. If the Client or vendor denies providing these documents without any legitimate reason, the Company is entitled to terminate the business relationship The Client or vendor warrants that at all times all the information provided to the Company shall be true, accurate, up to date and complete and that the Client shall update the Company in writing via e-mail (send to the Company from the Client’s registered e-mail address) or letter upon any changes in regard to the information provided.

Client or vendors hereby agrees that the information collected and obtained from them may be used by the Company, and regulatory bodies to conduct identity, fraud, AML, credit and other checks and the Client or vendor hereby authorizes the above entities to conduct the said checks.

Risk Based Anti-money Laundering Programs

In order to make the company’s Anti-Money Laundering program more focused, a risk-based approach will be pursued. Controls will be put in place based on the risk posed by customers served and geographic jurisdiction as follows:

High-risk customers

Certain kinds of business will require enhanced customer due diligence and ongoing transactions review. The reviews will include their anti-money laundering systems, potential for being abused by money launderers, their level of risk and the company’s ability to control this risk. The high-risk entities include:
• Non- Bank financial institutions like Money lenders and Forex Bureau
• Non-Government Organizations like Nontraditional Churches
• Offshore Corporations
• Cash Intensive business like distributorship business

High-risk geographical Locations
Identifying high-risk geographic locations is essential to the Rango’s anti-money laundering program. Management will therefore gather information regarding high-risk geographic locations from several sources. Identifying customers and transactions from high-risk geographic locations will help develop, modify policies procedures and controls addressing the risks associated with those locations.
This document will be amended from time to time to meet with the changes put in place by government institutions to curb this AML/CFT.

Key Stakeholders Responsibilities

Board of Directors

• The Company’s Board of Directors has overall responsibility for ensuring this policy complies with the legal and ethical obligations, and that all those under the Company’s control comply with it.
• The Board shall approve AML/CFT policies that promote a culture of compliance.

Senior Management

The Senior Management of the company shall be responsible for managing the business effectively, in relation to AML/CFT systems. The senior management should;
• Be satisfied that the company’s AML/CFT systems are capable of addressing the ML/TF risks identified
• Appoint a director or senior manager as a compliance officer who has overall responsibility for the establishment and maintenance of the company’s AML/CFT systems
• Appoint a senior member of staff as the Money Laundering Reporting Officer (MLRO) who will be the central reference point for suspicious transaction reporting

Compliance Officer and Money Laundering Reporting Officer

The function of the Compliance Officer (CO) is to act as the focal point within the company for the oversight of all activities relating to the prevention and detection of ML/TF and providing support and guidance to the senior management to ensure that ML/TF risks are adequately managed. In particular, the CO assumes responsibility for:
• Developing and/or continuously review the company’s AML/CFT systems to ensure they remain up-to-date and meet current statutory and regulatory requirements.
• The oversight of all aspects of the AML/CFT systems, which include monitoring effectiveness and enhancing the controls and procedures where necessary.

Compliance and Audit Function

The independent compliance and audit function will have a direct line of communication to the senior management. The audit function either internal or outsourced shall;
• Regularly review the AML/CFT system to ensure effectiveness.
• Ensure important matters are escalated.
• Ensure proper compliance and implementation of AML/CFT policies.
• Shall have direct reporting line to the BOD.

Money Laundering Reporting Officer (MLRO)

The MLRO should play an active role in the identification and reporting of suspicious transactions. Principal functions performed are expected to include:
• Review all internal disclosures and exception reports and, in light of all available relevant information, determining whether or not it is necessary to make a report;
• Maintenance of all records related to such internal reviews;
• Act as the main point of contact with the fic, law enforcement, and any other competent authorities in relation to ml/tf prevention and detection, investigation or compliance.

Third Parties
Third Parties must ensure provision of timely, accurate and adequate information to enhance the due diligence checks performed.

Record Keeping

Employees are encouraged and mandated to immediately report all suspicious transactions to the MLRO for further investigation and report to the FIC. STRs must be filed when Customer:
• Presents fake documentation; or
• Is found to have been suspect in news publications egg. Wanted Persons etc.; or
• Is involved in identity theft, that is, presents fake Identity card to impersonate someone else in order to have access to a transaction; or
• Fails to complete the required Customer Relationship Form within the stipulated time.

Continuous Monitoring

Effective ongoing monitoring is vital for understanding of customers’ activities and an integral part of effective AML/CFT systems. It helps companies to know their customers and to detect unusual or suspicious activities.

Rango will continuously monitor its business relationship with customers by:
• Reviewing from time to time documents, data and information relating to the customer and obtained to ensure that they are up-to-date and relevant4;
• Monitoring the activities (including cash and non-cash transactions) of the customer to ensure that they are consistent with the nature of business, the risk profile and source of funds. An unusual transaction may be in the form of activity that is inconsistent with the expected pattern for that customer, or with the normal business activities for the type of product or service that is being delivered; and
• Identifying transactions that are complex, large or unusual or patterns of transactions that have no apparent economic or lawful purpose and which may indicate ML/TF.
Failure to conduct ongoing monitoring could expose Rango to potential abuse by criminals, and may call into question the adequacy of systems and controls, or the prudence and integrity or fitness and properness of Rango’s management.

How to Raise a Concern

• Employees, directors and all stakeholders are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage via designated whistle blowing channels.
• To guarantee the anonymity of employees and other persons who may want to report suspicious malpractices, management will from time to time deploy the services of an independent whistle blowing platform/firm.

Introduction

Rango Construction Company Ltd (herein “Rango”) adopts a zero tolerance approach to bribery and corruption. The Company conducts business affairs in a manner that shuns the use of corrupt practices or acts of bribery to obtain unfair advantage in our dealings within the markets and communities we operate.

This policy sets out the general rules and principles we adhere to, and also communicate to all employees, directors, agents, consultants, business associates as well as relevant partners, suppliers, and other stakeholders the need to maintain high ethical and professional conduct in the course of doing the Company’s business.

What is Bribery and Corruption?

Bribery and corruption can be regarded as but not limited to the following:
• The offer, promise, payment, transfer, request, agreement, to receive or the receipt of anything of value, whether directly or indirectly, to or from any person (whether a private person, corporate entity, or public official), in order to induce that person (or any other person through the aid of the recipient) to perform their roles improperly or, in the case of a public official, in order to influence them with the intention of obtaining or retaining business or an advantage in the conduct of business.
• The abuse or misuse of entrusted power or public officer for private gain.
• An inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage through “improper performance”.
• An “improper performance” happens when a person fails to act (1) in good faith, (2) impartially or (3) in accordance with a position of trust. Corruption is often associated with organized crime, money laundering and in some occasions the financing of terrorism. In addition, it affects the efficacy of investment and financing in the industrial and financial services sectors, particularly within economically disadvantaged societies. However, the mentioned categories of corrupt practices above are not closed but also include diverse acts amounting to bribery and breach of ethical rules and standards.

Scope of the Policy

This Anti-Bribery and Corruption Policy is designed to comply with, The 1992 Constitution of Ghana, The Criminal and Other Offence Act, 1960 (Act 29), Office of the Special Prosecutor Act, 2017 (959), The Government Contract Act 1979, Economic and Organised Crime Act 2010, United Nations Convention Against Corruption Treaty, The Africa Union Convention on Preventing and Combating Corruption, UK Bribery Act 2010, the US Legislation (Foreign Corrupt Practices Act), as well as compliance with all applicable anti-bribery laws covering both international and local jurisdictions.

Rango Construction Company Ltd.’s Anti-Bribery and Corruption Policy requires that employees, directors and business associates of Rango are:

• Prohibited from offering, promising, giving, requesting, accepting or agreeing to receive a bribe of any kind in any form, directly or indirectly.
• Prohibited from making facilitation or gratification payments, even if this represents local practice or custom.
• Prohibited from offering, promising or transferring anything of value to a public official in order to influence the public official and obtain or retain business or an advantage for the benefit of Rango (or to obtain or retain an advantage for any employee, any other entity or person). This includes offers, promises or transfers made to any third party (such as a public official’s family members or business associates) in order to influence a public official.
• To carry out appropriate due diligence on parties when Rango proposes to engage them to perform services for, or on behalf of the Company, and to include appropriate anti-bribery and anti-corruption clauses in contractual arrangements with such parties.
• Prohibited from offering/giving/accepting gifts from third parties.
• To undertake appropriate anti-bribery and anti-corruption training and awareness programs at least once every year.
• To audit donations and sponsorships from time to time and ensure that such donations/sponsorships are not disguised to obtain undue favours for the company.

The policy also contains procedures for employees, directors and business associates of RCCL on how to manage the risks of facilitation payments and contains provisions on charitable donations, sponsorship and record keeping.
Failure by any employee, director, agents or associates to comply with the policy requirements may lead to disciplinary action up to and including dismissal or termination of employment or appointment.

Purpose

The purpose of this policy is to:

• Set out Rango’s responsibilities and that of all staff, directors, or business associates, in observing and upholding the firm’s principles on bribery and corruption;
• Provide information and guidance to staff, directors, and business associates on how to recognize and deal with bribery and corruption issues.

Stakeholders

This policy will apply in Rango Construction Company Limited. It is important that it be read and adhered to at all time. The policy applies to all individuals working at all levels and grades, including managers, officers, directors, employees, consultants, contractors, or any other person associated with the Company or its employees, wherever located (collectively referred to as employees in this policy).

Risk Assessment

Effective risk assessment lies at the very core of the success or failure of this policy. Risk identification pinpoints the specific areas which the Company faces bribery and corruption risks and allows the Company to better evaluate and mitigate these risks and thereby protect the brand.

Business practices around the world can be deeply rooted in attitude, cultures and models which Management needs to assess the vulnerability of the Company to bribery and corruption risks. The risk assessment shall include assessment of external risks (country, sector, transactions, business opportunities, and business partner’s risks).

PERIODIC REVIEW AND MONITORING

Rango Construction Company Limited shall conduct assessment of the Anti-bribery and Corruption Policy on an annual basis and report this to the Board to provide reasonable assurance that the program has continued to function effectively.

Statement of Policy

It is an offence to:

• Bribe another person
• Be bribed
• Bribe a public official
• Fail to prevent bribery and corruption
• Fail to report any suspected infraction or wrongdoing relating to bribery and corruption
• Rango Construction employees, directors, business associates and stakeholders must never offer, promise, or give financial or other advantage to any person (including a foreign public official) with the intention of rewarding improper performance by them in the course of duty. • Rango Construction employees, directors, business associates, and other stakeholders must never directly or indirectly accept or agree to receive financial or other advantage as reward for the improper performance of their duties. It makes no difference whether the advantage is for them or a third party or the Company.
• In this policy “third party” means any individual or organization we come into contact with during the course of doing business and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, including their advisors, representatives, and officials, politicians and political parties.

This Policy should be read in conjunction with other related policies and regulations such as:

• Government Contracts (Protection) Act. 1979
• Office of the Special Prosecutor Act (Act 959)
• Economic and Organised Crime Act, 2010
• Criminal Code Act, 1960 (Act 29)
• Criminal Offences Act (Amendment), 2012
• Whistleblower Act, 2006 (Act 720)
• United Nations Convention Against Corruption
• African Union Convention on Preventing and Combating Corruption
• The US Foreign Corrupt Practices Act (FCPA)
• UK Anti-Bribery Act
• Our Principles
• It is Rango Construction Company Ltd.’s policy to conduct all its business in an honest and ethical manner. The Company adopts a zero tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all of its business dealings and relationships wherever it operates.
• It is the Company’s requirement that those it does business with takes a similar zero tolerance approach to bribery and corruption. • The Company is bound by the laws of Ghana, and all other international and local laws relevant to countering bribery and corruption in the jurisdictions in which it operates.
• Bribery and corruption are criminal offences and are punishable for individuals by up to ten years’ imprisonment and an unlimited fine which can also apply to the institution. The Company therefore takes its legal responsibilities in this regard seriously and expects all the stakeholders to do the same.

Kyc Documentation Requirement

The Company is obliged to confirm and verify the identity of each person who enters into a business relationship with them. Hence, as part of the Company’s obligations to comply with applicable Anti-money laundering & Know Your Customer legislation, the Company requests its Clients and business partners to provide certain Verification Documents.

However, it is important that the Firm’s customers conform to the Firm’s principles and standards. Among other things, the following principles are considered as a part of the Know Your Customer procedure:
• The Company will not accept as Clients persons engaged in unethical behavior or in illegal activities;
• The Company will not accept as Clients or associates, parties that they cannot make a well informed and reasonable judgment as to the activities in which they are engaged;
• The Company will not accept as Clients, persons unwilling to provide sufficient documents/data and information.
• The Company will accept only those new Clients who complete the appropriate risk assessment forms and provide the Company with all necessary Verification Documents and information to the satisfaction of the Rango.
• The Company will accept a prospective or potential Client only when it becomes fully satisfied that the Client complies with Know Your Customer and due diligence procedures to ensure that a new relationship with the potential Client does not negatively affect the reputation of the Firm.

For the proper identification of the client and performing due diligence procedures, Rango will use the KYC Checklist as a tool being an integral part of the client/ third party acceptance or continuance procedures. The KYC Checklist is attached as Appendix I.
The information in the KYC form shall be maintained and constantly updated whenever relevant new information about the business partner surfaces.

If, during the business relationship, a Client or vendor fails or refuses to submit, within a reasonable timeframe set by the Company, the required documents, data and information requested by the Firm; the Company is entitled to terminate the business relationship. Moreover, during the business relationship additional documents may be requested by the Company and/or an update of the existing documents. If the Client or vendor denies providing these documents without any legitimate reason, the Company is entitled to terminate the business relationship.
The Client or vendor warrants that at all times all the information provided to the Company shall be true, accurate, up to date and complete and that the Client shall update the Company in writing via e-mail (send to the Company from the Client’s registered e-mail address) or letter upon any changes in regard to the information provided.

Client or vendors hereby agrees that the information collected and obtained from them may be used by the Company, and regulatory bodies to conduct identity, fraud, AML, credit and other checks and the Client or vendor hereby authorizes the above entities to conduct the said checks.

Responsibility for the Policy

The Company’s Board of Directors has overall responsibility for ensuring this policy complies with the legal and ethical obligations, and that all those under the Company’s control comply with it.
• Management and senior staff at all levels are responsible for ensuring that staff reporting to them are made aware of and understand the policy.
• Responsibility of Key Officers
• Anti-bribery and Corruption Compliance Officer (ABCCO).

The firm shall appoint an ABCC officer who occupies senior management position or at least middle management role. The responsibilities of the ABCCO include:
• Develop and implement the Company’s Anti-bribery and Corruption Program.
• Conduct an annual risk assessment which identifies and assesses the internal and external risk of the Company relating to bribery and corruption practices.
• Ensure that all employees are required to confirm understanding and compliance with Anti-bribery and corruption policy of the Company on an annual basis.
• Ensure delivery of relevant training and awareness to employees throughout Rango to support them in meeting their responsibilities.
• Providing guidance and ongoing training opportunities for vendors, suppliers and business partners on anti-bribery and corruption.
• Establish and implement an effective Anti-bribery and Corruption monitoring program across all risk areas in the Company.
• Ensure that there are appropriate means to investigate and record instances or allegations of bribery/corruption in the Company.
• Chief Compliance Officer (CCO)
Either internal or outsourced, shall oversee the activity of the ABCCO and provide second level advise to management on the compliance posture of Rango to the firm’s ABC policy at all times. The compliance officer shall examine any form of non-compliance to the attention of senior management and the board.

Chief Internal Auditor

The Chief Internal Auditor audits the Anti-Bribery and Corruption programme periodically and the donations made during the period to ascertain the adequacy and adherence to internal controls.

Gifts and Hospitality

In consideration of services rendered, being rendered or to be rendered, employees shall not ask for, receive, consent or agree to receive, any gift, commission, employment, service, gratuity, money, property or anything of value for their personal benefit or advantage or for that of their spouses and dependents from a customer of, or a supplier to the Company.

A gift and hospitality register shall be maintained to record details of gifts received or given. All gifts and donations whose values exceed the cedi equivalent of $25.00 will have to be declared for approval by management.

• While it is recognized that exchange of gift is customary in festive seasons of Christmas/New Year, Id-el Fitri and Id-el-Kabir, as well as Easter, employees shall not during these seasons accept gift with excess value of $25.00 of any kind from any customer or supplier without declaration and approval
• Where the employees are in doubt as to the value of the gift, the affected employee should declare such gift to Management through the Head, Human Resources.
• If in any circumstance, the refusal of any gift referred to herein would adversely affect the relationship of the giver with the Company, the affected employee shall make a report of and deliver such gift to Management. • In every case and regardless of time or season, employees shall make every effort to discern whether any gift is truly a gift or an inducement and in the case of the latter, employees shall reject the gift regardless of the value, in its entirety.

The giving or receipt of gifts and hospitality is not prohibited, if the following requirements are met:
• Disclosure to the management in advance (where it is possible to do, or as soon as possible afterwards);
• It is not made with the intention of influencing, inducing or rewarding a third party in order to gain any advantage through improper performance, or in explicit or implicit exchange for favours or benefits.
• It complies with local laws
• It is given in the Company’s name
• It is appropriate in the circumstances
• Taking into account the reason for the gift, if it is an appropriate type and value and given at an appropriate time provided the Company is not participating in any tendering process with the recipient.
• It is given openly, not secretly
• Gifts and/or hospitality are not offered to, or accepted from, government officials or representatives or politicians or political parties, without the prior approval of management.

NOTE: Gifts in hampers and related form received by staff of the Company at any time will be submitted/disclosed to the head, Human Resources.

Facilitation Payments

Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
• Kickbacks are typically payments made in return for a business favour or advantage. All employees, directors, and business associates must avoid any activity that might lead to, or suggest that a facilitation payment or kickback will be made or accepted by the Company.
• If an employee or director or subcontractor is asked to make a payment on behalf of the Company, the purpose should be known and the amount should be proportionate to the goods or services provided.
• Whilst the law prohibits facilitation payments or kickbacks, no employee or director or business associate is required to place his/her professional integrity at risk.

Donations

Rango Construction Company Ltd will not make contributions to political parties for the pursuit of their objectives. The Company only makes charitable donations that are legal and ethical under local laws and practices. Requests for sponsorship and donations should be forwarded to the head of legal and compliance for advice.

Record-keeping

The Company shall keep financial records and have appropriate internal controls in place, which will evidence the business reason for making and/or receiving payments in respect of donations, hospitality, gifts, etc. to and from third parties.
• The Company shall ensure that all expense payments relating to donations, hospitality, gifts to third parties are submitted in accordance with the Expense Policy and specifically record the reason for the expenditure.
• All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as customers, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Communication and Training

All employees and directors of the Company shall undertake appropriate Anti-bribery and Corruption training at least once a year. All Rango internal and external communication shall emphasize the Company’s commitment to anti-bribery and corruption practices.

What Is Not Acceptable?

In addition to the above, it is not acceptable for employees or directors or business associates to:
• Give, promise to give or offer, a payment, gift or hospitality with the intention of influencing, inducing or rewarding improper performance
• Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate or expedite a routine procedure (where the payment is not a legitimate payment pursuant to local written law)
• Accept from a third party, payment that you know or suspect is offered with the expectation that it will obtain a business advantage for them which will be obtained through improper performance by the employee or directors
• Accept a gift or hospitality from a third party if it is known or suspected that it is offered or provided with the intention of influencing improper performance
• Threaten or retaliate against another employee/director who has refused to commit a bribery offence or who has raised concerns under this policy
• Engage in any activity that might lead to a breach of this policy in any respect.

How to Raise a Concern

• Employees, directors and all stakeholders are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage via designated whistle blowing channels
• To guarantee the anonymity of employees and other persons who may want to report suspicious malpractices, management will from time to time deploy the services of an independent whistle blowing platform/firm.

Protection

Employees, directors and all stakeholders that refuse to accept or offer a bribe or those who raise concerns or report another’s wrongdoing, are free from repercussions as they have acted in good faith.

Potential Risk Scenarios

Bribery and Corruption Indicators

The following is a list of possible scenarios that may arise during the course of an employee or director working for the Company and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only to help you in your compliance with this policy.

If an employee or director encounters any of these scenarios in the course of his/her work. He/she must report them promptly to management:
• He/she becomes aware that a third party engages in, or has been accused of engaging in, improper business practices
• He/she learns that a third party has a reputation for paying bribes, or requiring that bribes are paid to them or has a reputation for having a “special relationship” with foreign government officials
• A third party insists on receiving a commission or fee payment before committing to sign up to a contract with the Company or carrying out a government function or process for the Company.
• A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business
• A third party requests an unexpected additional fee or commission to “facilitate” a service
• A third party demands entertainment or gifts before commencing or continuing contractual negotiations or provision of services
• A third party requests that a payment is made to “overlook” potential legal violations
• An invoice from a third party that appears to be non-standard or customized
• A third party refuses to put contractual terms agreed in writing
• He/she is offered an unusually generous gift or offered a lavish hospitality by a third party
• He/she is asked to give hospitality to persons who are not associated with the organization (for example family members) or is offered hospitality which extends to persons beyond the Company’s business (for example family members).