Mpishi Energy
Mpishi Energy / Policies / Anti-Corruption

Anti-Corruption, AML and KYC Policy

Mpishi Energy is committed to preventing, detecting and responding to corruption, bribery, fraud, conflicts of interest, procurement irregularities, retaliation and misuse of funds. This page sets out the anti-corruption part of our Anti-Corruption and Whistleblowing Policy, together with the anti-money-laundering and know-your-counterparty controls our lenders and development-finance partners expect.

Last approved 14 May 2025

  • Zero tolerance

    No bribes, kickbacks, collusion, coercion or facilitation payments, ever.

  • Know your counterparty

    Verified identity and beneficial ownership for every partner, agent and major supplier.

  • Clean funds

    Funds only from verified sources through regulated banks; grant and donor money used as agreed.

  • Controls

    Accurate books, segregation of duties and dual authorisation of payments.

How a report is handled
  1. 1Report

    Concern submitted through report@mpishienergy.net, the Managing Director or a Board-designated contact.

  2. 2Log and screen

    Recorded and assessed for urgency, credibility and impact.

  3. 3Review

    Assigned to management, the Board or an external adviser, independent of the matter.

  4. 4Action

    Investigation, corrective action, recovery, funder notice or referral where required.

Scope

  • This Policy applies to directors, employees, consultants, advisers, contractors, suppliers, partners and anyone acting for or on behalf of Mpishi Energy.
  • It covers project development, procurement, contracting, financial management, stakeholder engagement, and the use of company, grant, donor and investor funds.

What is prohibited

  • Bribery in any form: offering, promising, giving, requesting or accepting anything of value to improperly influence an act or decision, whether of a public official or a private person.
  • Kickbacks, collusion, coercion, and obstruction of an audit or investigation.
  • Facilitation payments to speed up routine government actions, even where they are small or customary.
  • Falsification of records, fraud, theft and deliberate misuse of funds or assets.
  • Undisclosed conflicts of interest and procurement misconduct, including bid rigging and splitting contracts to avoid approvals.
  • Political contributions made on behalf of the company.

Gifts, hospitality, donations and sponsorship

  • Gifts and hospitality must be modest, infrequent, lawful, recorded and never in cash. Anything involving a public official requires prior written approval.
  • Charitable donations and community investments are made only to verified organisations, documented in writing and never linked to a pending decision, permit or contract.

Know your counterparty

  • Before entering into agreements we identify and verify investors, lenders, joint-venture partners, contractors, agents and major suppliers, including their ultimate beneficial owners.
  • Counterparties are screened against applicable sanctions and debarment lists and for politically exposed persons. Higher-risk relationships receive enhanced due diligence and senior approval.
  • Agents and intermediaries are appointed only under written contracts with anti-corruption undertakings, a clear scope, fees proportionate to services and audit rights.

Anti-money laundering

  • We accept funds only from verified sources through regulated financial institutions and do not accept material cash payments.
  • The source of funds for equity and shareholder loans is documented.
  • Unusual or suspicious transactions are escalated to the Managing Director and reported to the Financial Intelligence Centre as the law requires.

Grant, donor and investor funds

  • Funds received for a specific purpose are tracked separately, used only for that purpose and reported to the provider as agreed.
  • Any suspected misuse of such funds is notified to the provider promptly, in line with the funding agreement.

Responsibilities

  • Management promotes an ethical culture, maintains proportionate internal controls, reviews reports and ensures corrective action.
  • All personnel and representatives comply with this Policy, keep truthful records, avoid prohibited conduct and report concerns in good faith.
  • The Board, or designated oversight authority, reviews serious allegations, especially those involving senior management, material financial exposure, funder risk or reputational risk.

Investigation, corrective action and records

  • Reported matters are reviewed promptly and fairly, with a proportionate inquiry or investigation where warranted.
  • Action may include disciplinary measures, contract termination, recovery of funds, strengthening of controls, notification to funders and referral to the authorities.
  • Records of reports, actions, outcomes and follow-up are kept securely with restricted access.

Training and monitoring

  • Directors, employees and key contractors receive anti-corruption training at induction and at least annually.
  • Controls are reviewed annually and after any significant incident, and summarised to lenders as our financing agreements require.

Contact

Mpishi Energy Limited, 31 Peri Peri Street, Salama Park, Lusaka, Zambia. Confidential reports: report@mpishienergy.net. General enquiries and grievances: info@mpishienergy.net.

This is the public version of an approved Mpishi Energy policy. It applies to Mpishi Energy Limited and its project companies and is reviewed at least annually.