Mpishi Energy
Mpishi Energy / Policies / Code of Conduct

Ethical Guidelines and Code of Conduct

These Ethical Guidelines set the standards of conduct expected of everyone who acts for or on behalf of Mpishi Energy. They promote integrity, accountability, fairness, transparency, professionalism and responsible decision-making across project development, stakeholder engagement, procurement, financial management, partnerships and the use of funds.

Last approved 20 May 2025

  • Integrity

    Act in good faith, comply with the law and never offer or accept improper advantage.

  • Respect

    Treat colleagues, communities and counterparties with dignity and fairness.

  • Accurate records

    Keep complete, supportable and timely records, approvals and communications.

  • Speak up

    Report concerns promptly; retaliation against good-faith reporters is prohibited.

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

  • These Guidelines apply to directors, officers, employees, consultants, advisers, contractors, suppliers and other representatives of Mpishi Energy and its project companies.
  • They apply in all internal and external dealings, including with communities, regulators, public officials, lenders, grant providers, investors, partners and counterparties, and in every country where we operate.

Core principles

  • Act with integrity and in good faith in all business dealings.
  • Comply with applicable laws, contractual obligations, permits, licences and internal policies.
  • Avoid bribery, kickbacks, facilitation payments, fraud, misuse of funds and any other improper conduct.
  • Treat colleagues, counterparties and stakeholders with dignity, fairness and respect.
  • Exercise professional care, stay within delegated authority and escalate when in doubt.
  • Maintain accurate, supportable and timely records, approvals and communications.
  • Protect confidential, commercially sensitive and personal information.
  • Use company, donor, investor and project resources only for authorised purposes.

Conflicts of interest

  • Disclose any actual, potential or perceived conflict of interest promptly to management or another designated authority, including family, financial and outside business interests.
  • Anyone with a conflict must not take part in the related review, recommendation, negotiation, approval or decision unless expressly authorised with appropriate mitigation, including recusal where necessary.
  • Declarations are recorded in a conflicts register reviewed at least annually and whenever circumstances change.

Gifts, hospitality and benefits

  • Never offer, request or accept gifts, hospitality, travel, entertainment or other benefits that could improperly influence a decision, create a sense of obligation or give rise to a perception of impropriety.
  • Cash and cash-equivalent gifts are not permitted in any circumstances.
  • Permissible hospitality must be reasonable, infrequent, lawful, transparent, recorded and consistent with funder requirements. Anything involving a public official requires prior approval from the Managing Director.

Financial integrity, procurement and partner conduct

  • All financial and operational records must be complete, accurate, timely and supported by documentation. False, misleading or off-record entries are prohibited.
  • Procurement and partner engagement must be fair, transparent and proportionate, with documented selection criteria.
  • Undisclosed personal interests, collusion, bid manipulation, favouritism and splitting purchases to avoid approval thresholds are prohibited.
  • Contractors and suppliers are expected to meet equivalent standards, and contracts include integrity, labour, environmental and audit clauses.

People, health, safety and environment

  • Provide safe workplaces; anyone may stop work that is unsafe.
  • Never use forced, bonded or child labour, directly or in the supply chain, and respect freedom of association.
  • Follow the project Environmental and Social Management System, report incidents immediately and respect community health and safety, land rights and cultural heritage.
  • Discrimination, harassment and sexual exploitation, abuse and harassment are prohibited, as set out in our Gender Equality Policy and SEAH Guidelines.

Speak-up and non-retaliation

  • Anyone who becomes aware of suspected misconduct, unethical behaviour, conflicts of interest, corruption, fraud, retaliation or other serious concerns is expected to report it promptly.
  • Primary channel: report@mpishienergy.net. Alternative channel: the Managing Director or a Board-designated contact.
  • Reports made in good faith are handled as confidentially as reasonably possible. Retaliation, intimidation, discrimination or disadvantage against a reporter or anyone assisting a review is prohibited.

Responsibilities

  • Management promotes an ethical culture, leads by example, implements these Guidelines and addresses breaches appropriately.
  • All personnel and representatives understand and comply with these Guidelines, exercise sound judgment, keep truthful records and raise concerns.
  • The Board, or the designated oversight authority, oversees serious or material ethical concerns.

Training and awareness

  • New personnel receive these Guidelines at induction and confirm in writing that they have read them.
  • Refresher training is provided at least annually and before high-risk activities such as procurement rounds, land processes or community consultations.

Breaches and corrective action

  • Breaches may result in disciplinary action, termination of employment, contract or engagement, recovery action, funder notification, referral to the relevant authorities or other proportionate measures.
  • These Guidelines are reviewed periodically to reflect organisational growth, project complexity, legal developments and funder expectations.

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.