Orthodynamic Limited’s Anti-Bribery Policy and Code of Conduct

Orthodynamic Limited is committed to upholding ethical standards, anti-corruption measures, and compliance with the Public Procurement and Disposal Act.

Anti-Bribery Policy

All employees of the company are required to adhere to Kenyan Anti-Bribery laws and comply with regulations prohibiting bribery, both in interactions with government officials and within the private sector. We strictly prohibit bribery in the following areas:

Government Bribery

Orthodynamic Limited and its employees are prohibited from offering, promising, providing, or authorizing payments of any kind to government officials for the purpose of obtaining or retaining business, securing an improper advantage, or influencing government officials improperly. It is essential to avoid creating any appearance of inappropriate interactions with government officials.

Commercial Bribery

In addition to government bribery restrictions, Orthodynamic Ltd. forbids employees from offering or accepting corrupt payments or advantages from private individuals and entities. Such payments are considered commercial bribery and are commonly referred to as “kickbacks.”

Facilitation Payments

The company’s anti-bribery policy applies to all improper payments, regardless of their size or purpose, including “facilitating” or expediting payments to government officials for non-discretionary actions or services.

Third-Party Management

Applicability to Third Parties

Third-party agents, consultants, distributors, and any other representatives acting on behalf of Orthodynamic Limited are prohibited from making corrupt payments on the company’s behalf. This prohibition also extends to subcontractors working on the company’s behalf.

Due Diligence

Third parties engaging with government officials on behalf of Orthodynamic Ltd. must undergo the company’s due diligence process before commencing work. Any concerns identified during a vendor’s due diligence review must be resolved to the satisfaction of the company’s Legal Counsel before establishing a relationship, with documented remediation measures.

Contractual Language

All agreements with third parties interacting with government entities or officials must be documented in writing and include appropriate anti-bribery language, as determined by the Company’s Legal Counsel.

Monitoring

Once retained, third-party agents or consultants must be actively monitored by relevant company employees to ensure ongoing compliance with anti-corruption laws and company policies.

Providing Items of Value to Government Officials

Gifts, Meals, Travel, and Entertainment (GME)

Providing assistance, meals, travel, or entertainment in exchange for improper favors or benefits is strictly prohibited. Cash or cash equivalents, such as gift cards, are never permissible as gifts.

Donations

Donations may be made directly to a government agency as part of a charitable effort but should never be used to improperly influence government officials.

Promotional Expenses

While it may be appropriate to direct promotional expenses to government officials or entities to demonstrate or explain the Company’s products and services, such expenses should never be used to improperly influence them.

Hiring Government Officials

Employing or engaging government officials or their immediate family members to improperly influence officials is strictly prohibited.

Political Contributions

Making political contributions to improperly influence government officials is not permissible.

Auditing

Company employees will conduct periodic internal audits to ensure ongoing compliance with anti-bribery laws and this policy. All employees must cooperate with and not interfere with or obstruct audit activities or company investigations.

By Management,
Orthodynamic Limited