Effective Date: January 23, 2026

1. Policy Statement

Mtengwa Strategic Advisory is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. We have zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us.

2. Our Commitments

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts, and face damage to our reputation. We therefore take our legal responsibilities very seriously.

3. What is Bribery?

A bribe is an inducement or reward offered, promised, or provided in order to gain any commercial, contractual, regulatory, or personal advantage.

3.1 Gifts and Hospitality

This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. However, gifts and hospitality are only acceptable if they are reasonable, proportionate, and made in good faith.

We do not accept or give gifts or hospitality if the intention is to influence a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favors or benefits.

3.2 Facilitation Payments and Kickbacks

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

4. Your Responsibilities

You must ensure that you read, understand, and comply with this policy. The prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control.

You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify the Principal Consultant or Compliance Officer as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

5. Record-Keeping

We keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

6. Reporting Suspicions

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with the Principal Consultant.

7. Contact

For questions regarding this policy, please contact:

Principal Consultant: Burhani Mtengwa, MBCS
Email: contact@mtengwa.co.uk