Corporate Responsibility

Legba INC provides equal employment opportunities to all employees and applicants for employment and prohibits discrimination and harassment of any type without regard to race, color, religion, age, sex, national origin, disability status, genetics, protected veteran status, sexual orientation, gender identity or expression, or any other characteristic protected by federal, state or local laws.

This policy applies to all terms and conditions of employment, including recruiting, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, compensation and training.

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Legba INC, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking.

Our supply chains

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Introduction

Legba INC values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The actions and conduct of the organisation’s staff as well as others acting on the organisation’s behalf are key to maintaining these standards.

The purpose of this document is to set out the organisation’s policy in relation to bribery and corruption. The policy applies strictly to all employees, partners, agents, consultants, contractors and to any other people or bodies associated with Legba INC within all offices, areas and functions.

Understanding and recognising bribery and corruption

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest under the circumstances.

Bribery can be defined as offering, promising or giving a financial (or other) advantage to another person with the intention of inducing that person to act or to reward them for having acted in a way which a reasonable person would consider improper under the circumstances. Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery.

Bribes are not always a matter of handing over cash. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision. For high risk areas, consider some of the following points:

• How do other international companies in the same area operate? Can they recommend particular individuals or groups to work with?
• The relationship with the local or national government. Do you have direct lines of communication with trustworthy officials, and do your operations comply with your company’s anti-money laundering and anti-bribery policies?
• Engage with local labour groups and NGOs. Establish relationships with groups on the ground who can advise on good practices and provide local knowledge.

Penalties

The Bribery Act 2010 came into force on 1^st July 2011. Under that Act, bribery by individuals is punishable by up to 10 years imprisonment and/ or an unlimited fine. If the organization is found to have taken part in bribery or is found to lack adequate procedures to prevent bribery, it too could face an unlimited fine.

A conviction for a bribery or corruption related offence would have severe reputation and/or financial consequences for the organisation.

Policy

Legba INC will not tolerate bribery or corruption in any form.

The organization prohibits the offering, giving, solicitation or acceptance of any bribe or corrupt inducement, whether in cash or in any other form:

• To or from any person or company wherever located, whether a public official or public body, or a private person or company
• By any individual employee, partner, agent, consultant, contractor or other person or body acting on the organisation’s behalf
• In order to gain any commercial, contractual or regulatory advantage for the practice in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded:

• Normal hospitality
• Fast tracking a process which is available to all on the payment of a fee; and/or
• Providing resources to assist a person or body to make a decision more efficiently, provided that it is for this purpose only

The organisation will investigate thoroughly any actual or suspected breach of this policy, or the spirit of this policy. Employees found to be in breach of this policy may be subject to disciplinary action which may ultimately result in their dismissal.

Key risk areas

Bribery can be a risk in many areas of the organization. Below are the key areas you should be aware of in particular:

• Excessive gifts, entertainment and hospitality can be used to exert improper influence on decision makers. Gifts, entertainment and hospitality are acceptable provided they are within reasonable limits and are authorised by a partner. Any gift or hospitality, either given or received, over the value of £50 per person should be reported to the COLP.
• Facilitation payments are used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right. The practice will not tolerate or excuse such payments being made.
• Reciprocal agreements or any other form of ‘quid pro quo’ are never acceptable unless they are legitimate business arrangements which are properly documented and approved by a partner. Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.
• Actions by third parties for which the practice may be held responsible can include actions by a range of people, e.g. agents, contractors and consultants, acting on the practice’s behalf. Appropriate due diligence should be undertaken before a third party is engaged. Third parties should only be engaged where there is a clear business rationale for doing so, with an appropriate contract. Any payments to third parties should be properly authorised and recorded.
• Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that we have robust controls in place so that our records are accurate and transparent. The COLP is responsible for all record keeping.

Employee responsibility and how to raise a concern

The prevention, detection and reporting of bribery or corruption are the responsibility of all partners and employees of the practice. If you become aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt, then you have a duty to report this to the COLP without delay.

Purpose

Legba INC acknowledges a responsibility to the environment, and we express our commitment towards implementing practices which will promote environmental sustainability. The following policy governs the management of the environmental aspects of our company, with specific focus on the conservation of resources and the reduction of waste.

This policy relates to how all operations in our company will be continually reviewed and improved, so that we will truly be able to integrate environmental and social considerations into our everyday practices.

The company will consistently strive to raise awareness in the community, encourage participation and train employees in environmental matters.

Principles

• Comply with any laws governing the environment, and actively look for ways to improve on these guidelines.
• Work towards the conservation of energy, water and resources in all our operations.
• Strive to better understand both the direct and indirect impact that our practices may have on the environment.
• Promote environmental awareness throughout all operations of the company.
• Provide training/newsletters/posters to staff on implementing our sustainable policies.
• Dispose of waste thoughtfully, and develop an attitude of “reducing, recycling and reusing.”
• Lessen our environmental impact by purchasing environmentally-friendly products and services.
• Work with our entire supply chain in order to gain mutual benefits of incorporating environmentally sustainable goals into everyday business.
• Regularly review our business practices, and determine whether each practice is suitable in an environmental context.
• Independently audit our practices, and determine whether our goals have been reached.