Anti-Bribery & Anti-Corruption Policy
Mtengwa Strategic Advisory enforces a zero-tolerance policy against all forms of bribery, corruption, kickbacks, and vendor commissions in strict adherence to the UK Bribery Act 2010.
1. Absolute Vendor Independence & Zero-Kickback Guarantee
The foundation of Mtengwa Strategic Advisory's reputation is uncompromised, objective strategic counsel. Fiduciary advisory cannot co-exist with commercial hardware or software sales quotas.
Our architectural recommendations, RFP evaluations, and vendor scorings are formulated solely in the client's commercial and risk interests.
2. Legal Scope: UK Bribery Act 2010
Mtengwa Strategic Advisory strictly complies with all provisions of the UK Bribery Act 2010 across all jurisdictions where we operate or advise clients:
- Section 1 (Bribing Another Person): Absolute prohibition on offering, promising, or giving financial or other advantage to induce or reward improper performance.
- Section 2 (Being Bribed): Absolute prohibition on requesting, agreeing to receive, or accepting any bribe or improper incentive.
- Section 6 (Bribery of Foreign Public Officials): Absolute prohibition on influencing foreign public officials to obtain or retain business advantage in international mandates.
- Section 7 (Failure of Commercial Organisations to Prevent Bribery): Enforcing proportionate prevention procedures, risk assessments, top-level commitment, and ongoing monitoring.
3. Gifts, Hospitality & Entertainment Rules
To prevent actual or perceived conflicts of interest or improper influence, Mtengwa Strategic Advisory enforces rigorous hospitality thresholds:
Modest corporate stationery, calendars, or industry books of nominal value. Must be recorded in the firm’s Hospitality Register within 5 business days.
Cash, cash equivalents, personal loans, paid travel/lodging, lavish hospitality, or sporting tickets from technology vendors are strictly barred.
4. Facilitation Payments & Subcontractor Due Diligence
Zero Facilitation Payments: Facilitation payments (unofficial payments made to secure or expedite routine government or administrative action) are illegal under UK law. Mtengwa Strategic Advisory strictly prohibits facilitation payments anywhere in the world, regardless of local custom.
Third-Party Vetting: Any associated parties—including forensic accounting specialists, expert legal partners (such as Abba Zanzibar Attorneys), or technical testing subcontractors—must undergo anti-bribery due diligence and sign contractual commitments adhering to this Policy before commencing work.
5. Reporting Suspected Bribery & Whistleblower Protections
Any partner, contractor, client, or external party who suspects bribery or corruption must report it immediately to our Compliance Lead:
