At Walblue we comply with the following standards:

Bribery and Improper Payments

Walblue does not tolerate any form of bribery or corruption in the course of its business. We must never — directly or indirectly — give, offer, or promise Anything of Value for the purpose of improperly obtaining or retaining business, securing a business advantage, or influencing any other decision or action by the recipient. Walblue does not tolerate corruption regardless of local customs or traditions.

Walblue’s zero tolerance for corruption applies to our relations with all business clients we do businesses (everyone).

Our prohibition on improper payments covers interactions with Business Professionals and other members of the Government Officials, and Customers, including private sector business partners.

Walblue also prohibits facilitation payments. This is the giving of a small payment of cash or Anything of Value to a Government Official to secure or speed up a routine government action, such as clearing our products through customs or expediting the processing of a visa. Facilitation payments violate most anti-corruption laws, and Walblue strictly prohibits them even if a payment may be permissible or not expressly prohibited under our company law.

Ethical Business Practices

Walblue is committed to doing business the right way. We comply with all Applicable Laws and Codes, and avoid situations that are contrary to Walblue’s values or that may damage Walblue reputation.

Our commitment to integrity means that we would rather lose an opportunity or

Business contract or clients than obtain benefits through unethical or improper means.

In order to prevent improper payments or even the appearance of impropriety, we make sure that all of our activities and payments:

—Have a legitimate purpose and are not intended to gain an Improper Advantage;

  • Are appropriate and reasonable;
  • Are provided at Fair Market Value;

Comply with Applicable Laws and Codes

Donations must not be provided for a promotional purpose or to gain an Improper


Donations may only be awarded to reputable not-for-profit institutions and organizations for genuine medical, scientific, educational or charitable purposes, and in an amount corresponding to the legitimate need. Donations may not be provided to individuals. All donations must be approved under the proper procedure.

Unfair Business Practices

Walblue complies with all applicable antitrust and competition laws.

These laws are intended to promote the preservation of a competitive free market by prohibiting unreasonable restraints on competition and acts of monopolization.

Certain interactions with competitors (including potential competitors) could be deemed unlawful.

In order to ensure reasonable and appropriate competitive business practices:

We never communicate with actual or potential competitors about commercially sensitive information, unless we receive express approval from Legal. Such commercially sensitive information includes, but is not limited to market strategies, tenders, business opportunities, and any aspect of pricing or costs. If we are at a meeting (including a trade association meeting) and competitors start discussing commercially sensitive information, we must leave immediately, making sure that everyone present in the meeting would recall that we left upon refusing to exchange such information and preferably have this recorded in the minutes of the meeting, if any. Legal must be promptly notified of any such event.

We never agree or cooperate in any way with competitors to fix any price related conditions and terms of trade; share or allocate markets in respect to specific territories, products, customers, or sources of supply; fix production, sale, or purchase volume; or boycott our customers or suppliers.

For additional behaviors that are prohibited under antitrust and competition laws, please refer to Walblue Antitrust and Competition Compliance Guidelines.

Third Party Representatives:

Walblue cannot take actions indirectly through a third party that we may not take directly. We may be held responsible for the actions of Third Party Representatives and expect them to abide by all Applicable Laws and Codes.

Third Party Representatives may only be engaged if they have been approved under the Global Compliance Due Diligence Policy and associated Procedure.

Third Party Representatives must meet our standards for ethical business conduct, and must be engaged through written contracts with appropriate anti-corruption provisions.

Political Contributions:

Political contributions must never be given for the purpose of obtaining an Improper Advantage. All contributions to political parties or politicians must be for a legitimate purpose and must comply with Applicable Laws and Codes.

Political contributions may only be given following appropriate approvals.

The Global Government Affairs and HR Department must review and approve all proposed political contributions. The Legal department, may require additional approvals for political contributions in a particular region in Ghana or any country we do business in.

Accurate Books and Records and Internal Controls:

We are accurate and transparent in our books and records. Walblue must create and maintain books and records that reflect financial transactions and dispositions of assets fairly, accurately, and in reasonable detail. Walblue employees must always adhere to applicable local finance and accounting policies and procedures. False or misleading entries in Walblue’s books and records, “slush funds,” or other “off-the books” accounts are strictly prohibited.

We maintain effective internal controls. Walblue must maintain a system of internal accounting controls sufficient to provide reasonable assurance that Walblue’s transactions are accurately recorded in its books and records in accordance with local finance and accounting policies and procedures, all Walblue assets are accounted for, and access to Walblue assets is controlled

Exceptions: Any exceptions to this Policy may only be granted, in writing, by Walblue Global Chief Compliance Officer (The overall Chairman or Presidents of the company). No exception will be granted that would violate an applicable law or regulation.


Any breach of this Policy, including failure to report actual or potential violations of this Policy or applicable law, may result in disciplinary measures, up to and including termination of employment.

Walblue personnel are required to promptly report any known or suspected improper activity in violation of this Policy. Walblue’s Code of Conduct, or Applicable Laws and Codes. Such reports can be made to any manager, Legal, or HR.

Walblue will not tolerate any form of retaliation against anyone for making a good faith report of a potential violation.