Business without improper influence.
Pintop prohibits bribery, corruption, kickbacks and improper payments in every part of its business. This policy explains the standards expected from employees, directors, contractors, consultants, agents and business partners acting on Pintop’s behalf.
Zero tolerance for bribery and corruption.
Pintop Technologies Limited is committed to conducting its business with integrity, transparency and respect for applicable law. Bribery and corruption are prohibited whether they involve a public official, a private individual, a commercial organisation or an intermediary acting for another party.
This policy applies to employees, directors, contractors, consultants, agents and business partners acting for or representing Pintop, wherever they are located.
What constitutes bribery?
Bribery includes offering, promising, giving, requesting or accepting a financial or other advantage to induce or reward improper performance.
Gifts and hospitality must remain modest and transparent.
Reasonable and occasional hospitality may be accepted or provided only when it cannot influence a decision, create an obligation or undermine the integrity of a transaction.
One transaction must not become a pattern.
Multiple gifts to the same person or organisation are considered together. Splitting gifts or hospitality to avoid the threshold is not permitted.
Permitted only when
- It is modest in value and occasional.
- It is given openly in Pintop’s name.
- It is not intended to influence a decision.
- It complies with the recipient’s own rules.
- It is culturally appropriate and proportionate.
- It is recorded in the Gifts and Hospitality Register.
Never permitted
- Cash, prepaid cards, vouchers or personal loans.
- Gifts during a tender or contract negotiation.
- Lavish travel, accommodation or event tickets.
- Anything offered in exchange for preferential treatment.
- Anything concealed from the organisation involved.
- Anything that would embarrass Pintop if disclosed publicly.
Dealings with public officials require extra caution.
A public official includes a person holding a legislative, executive, administrative or judicial position, a person exercising a public function, and an official or agent of a public international organisation.
Facilitation payments are prohibited.
Pintop does not permit small unofficial payments intended to speed up or secure a routine governmental action such as processing, clearance or permit issuance.
No unofficial payment is routine.
A payment does not become acceptable because it is customary, small or described as an administrative convenience. Requests must be refused and reported.
Explain
State that Pintop policy prohibits facilitation payments.
Refuse
Politely decline the request without creating further risk.
Report
Notify Pintop management as soon as possible.
Record
Ensure any payment made under an immediate physical safety threat is reported and accurately recorded.
Contributions must never disguise improper influence.
Political and charitable activities are treated differently, but neither may be used to obtain an improper commercial or regulatory advantage.
Political contributions
Pintop does not make contributions to political parties, candidates or political organisations. This includes money, company facilities, resources or paid staff time.
Charitable donations
Donations must go to legitimate organisations, remain transparent, receive prior management approval and be recorded accurately. A donation must not be requested by someone positioned to influence a business decision.
Third parties must meet the same standard.
Pintop expects agents, intermediaries, contractors, consultants and business partners to act with integrity and avoid improper payments.
Due diligence
Assess the third party and the risks connected to the proposed relationship.
Contractual controls
Include appropriate anti-bribery obligations and termination rights.
Monitoring
Monitor the relationship and investigate suspected breaches promptly.
Termination
End a relationship where bribery or corruption has occurred.
Raise concerns without delay.
Employees and representatives must report requests, offers, suspected bribery and possible violations of this policy. Everyone is expected to cooperate with a resulting investigation.
Breaches have serious consequences.
A breach may affect employment, commercial relationships and personal legal exposure.
Employees
A breach may constitute gross misconduct and may result in disciplinary action, including dismissal.
Business partners
A contractor, agent or business relationship may be terminated and may give rise to claims for loss.
Legal referral
Suspected criminal conduct may be referred to the appropriate authorities.
The policy is supported by operating controls.
Prevention depends on accurate records, staff awareness and regular review—not policy wording alone.
Record-keeping
Gifts, hospitality, donations and sponsorships must be recorded with the date, value, recipient, purpose, business context and approving authority.
Training
Staff receive the policy during induction and as part of Pintop’s continuing compliance awareness programme.
Policy review
Management reviews the policy periodically and may update it following legal, organisational or operational changes.
Nigerian legal framework.
This policy should be read alongside the anti-corruption, criminal, public conduct and anti-money-laundering laws applicable to Pintop’s activities and relationships.
Connected policies and reporting routes.
Speak up before an issue becomes a breach.
Contact Pintop for clarification about gifts, hospitality, third-party conduct, public officials, payment requests or a suspected violation of this policy.