Anti-Bribery Policy
Solutions Yarona Trading & Projects
1. Policy Statement
Solutions Yarona Trading & Projects (Pty) Ltd (“the Company”) is committed to conducting business with integrity, transparency, and in full compliance with all applicable anti-bribery and anti-corruption laws, including but not limited to the Prevention and Combating of Corrupt Activities Act (PRECCA) No. 12 of 2004 and the Companies Act No. 71 of 2008.
Bribery and corruption in any form are strictly prohibited. This policy applies to all employees, directors, contractors, suppliers, agents, and any other third parties acting on behalf of the Company.
2. Definition of Bribery
Bribery involves offering, giving, receiving, or soliciting any undue advantage (financial or non-financial) to influence a business decision or gain an improper benefit. This includes, but is not limited to:
Cash payments or kickbacks
Gifts, hospitality, or entertainment intended to influence decisions
Facilitation payments (“grease payments”) to expedite routine services
Political or charitable contributions used to conceal bribes
Unauthorized commissions or favors
3. Prohibited Conduct
All employees and associated persons must never:
Offer, promise, or give a bribe (directly or through a third party).
Request, agree to receive, or accept a bribe.
Engage in any activity that might lead to a breach of this policy.
Falsify records or misrepresent transactions to conceal bribery.
4. Gifts, Hospitality & Entertainment
The Company recognizes that reasonable and proportionate hospitality may be part of legitimate business relationships. However, such gestures must:
Be transparent, infrequent, and of modest value.
Not create an obligation or expectation of favoritism.
Be properly recorded in the Company’s books.
Comply with the recipient’s organization’s policies.
Any gift or hospitality exceeding ZAR 1,000 in value must be pre-approved by management.
5. Facilitation Payments
Facilitation payments (small bribes to expedite routine services) are strictly prohibited, even if customary in certain regions. Employees must report any demand for such payments to management immediately.
6. Donations & Sponsorships
The Company supports legitimate charitable and political activities, provided:
Donations are not used to influence business decisions.
They are transparent, properly documented, and comply with laws.
No donations are made to public officials without legal approval.
7. Third-Party Due Diligence
Before engaging agents, consultants, or subcontractors, the Company will:
Conduct risk-based due diligence.
Include anti-bribery clauses in contracts.
Monitor third-party relationships for compliance.
8. Reporting & Whistleblowing
Employees and stakeholders must report any suspected bribery via:
Direct Line Manager
Compliance Officer
Anonymous Whistleblowing Hotline:
The Company prohibits retaliation against good-faith whistleblowers.
9. Training & Awareness
All employees will receive regular anti-bribery training to ensure understanding of this policy and legal obligations.
10. Consequences of Violations
Breaches of this policy will result in disciplinary action, up to and including termination and legal prosecution.
11. Policy Review
This policy will be reviewed annually and updated as necessary to reflect legal changes and best practices.
Approved by:
Ms. DG Matekane
CEO
Solutions Yarona Trading & Projects (Pty) Ltd
REG NO.: 2019/605588/07
BRANCH ADDRESS:
NO. 2 PROTEA BUILDING,
PALLADIUM STREET,
CARLETONVILLE
2499
+27(0)73 949 4429
info@sytp.co.za