Sanctions policy.

01. Policy overview.
  1. Afrihost is committed to conducting business in compliance with all legal and regulatory requirements. We strive to operate with integrity and uphold the highest ethical standards.
02. Afrihost commitment.
  1. Afrihost commits to:
    1. Zero tolerance against fraud, theft, corruption, or any similar illegal behaviour.
    2. Compliance with all applicable anti-bribery, anti-corruption, and sanctions laws and regulations.
    3. Conducting business transparently, honestly, and ethically.
03. Applicability.
  1. This policy applies to all Clients and End-Users of Afrihost. Clients agree to inform respective End-Users of their obligations under this policy, where applicable. By engaging with Afrihost, you agree to abide by this policy.
04. Obligations of clients and end-users.
  1. Clients and End-Users of Afrihost are obligated to:
    1. Not engage in any bribery, corruption, or actions that violate applicable sanctions laws.
    2. Conduct their business transparently and ethically.
    3. Report any suspected bribery, corruption, or sanctions violations to Afrihost immediately.
    4. Ensure compliance with all applicable sanctions laws and regulations in their business dealings.
    5. Not use Afrihost’s products or services in any manner that would result in a breach of sanctions laws.
05. Definitions.
  1. Bribery” or “Bribe” means offering, giving, receiving, or soliciting something of value to influence the actions of an individual holding a public or legal duty.
  2. Corruption” or “Corrupt Activities” means the abuse of entrusted power for private or personal gain.
  3. End-User” means any individual or entity that ultimately uses or is intended to use the products or services provided by Afrihost.
  4. Facilitation Payments” means usually small payments made to expedite or secure the performance of a routine governmental action.
  5. Red Flags” means indicators that suggest the possibility of bribery, corruption, or sanctions violations. Examples include unusually high commissions, lack of transparency in expenses, and business with entities in high-risk jurisdictions.
  6. Politically Exposed Persons” or “PEPs” means individuals who are or have been entrusted with prominent public functions, such as heads of state, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, and important political party officials.
  7. Sanctions” or “Sanctions Laws” means restrictions or prohibitions imposed by governments or international bodies on dealings with certain countries, governments, groups, entities, individuals, or controlled goods/services due to breaches of international law or human rights violations. Sanctions can include trade embargoes, asset freezes, and travel bans.
06. Bribery and corruption.
  1. Afrihost does not permit Bribery and Corruption regardless of the form or manner.
  2. Afrihost does not permit facilitation payments, regardless of value.
  3. Clients and End-Users must not offer or accept Bribes or Facilitation Payments or engage in Corrupt Activities in dealings with Afrihost.
07. Donations and sponsorships.
  1. Donations may only be made only in accordance with Afrihost’s policies.
  2. Sponsorships may only be granted to entities or events that enhance Afrihost’s reputation or promote business development, following specific rules and procedures.
08. Dealing with third parties and cross-border dealings.
  1. Clients and End-Users must exercise diligence when conducting business with third parties, especially those from foreign countries.
  2. Clients and End-Users must ensure their third-party or cross-border dealings do not involve bribery, corruption, or sanctioned entities.
09. Politically Exposed Persons (PEPs).
  1. Clients and End-Users acknowledge that enhanced due diligence or background checks are required when dealing with PEPs due to their high-risk nature.
10. Sanctions compliance.
  1. Afrihost complies with all relevant sanctions laws in the countries where we operate.
  2. Sanctions place restrictions on dealings with certain countries, governments, groups, entities, individuals, or controlled goods/services.
  3. Afrihost complies with all economic and trade sanctions applicable to our business activities.
  4. Client and End-User Obligations:
    1. Clients and End-Users must not engage in transactions or dealings with sanctioned countries, entities, or individuals.
    2. Immediately disclose to Afrihost any knowledge or suspicion of transactions involving a sanctioned person, group, or country.
    3. Ensure that no goods or services are procured from suppliers on a country sanctions list.
    4. Seek advice and guidance from Afrihost on the impact of sanctions on their business or if there are concerns about a particular transaction or supplier.
    5. Not engage in any action that would cause Afrihost to violate any sanctions laws.
11. Due diligence.
  1. Clients and End-Users must conduct appropriate due diligence or background checks on their customers, suppliers, and third parties to ensure compliance with sanctions laws.
  2. Clients and End-Users must immediately report any Red Flags or suspicions that may indicate the involvement of a restricted territory or party.
12. Non-adherence to policy.
  1. Non-compliance with this policy can result in termination of services, business relationships and reporting to external regulators. Afrihost may take civil and/or criminal action against non-compliant Clients or End-Users.
13. Indemnification.
  1. The Client and End-User agree to indemnify, defend, and hold harmless Afrihost, its affiliates, officers, directors, employees, agents, and representatives from and against any and all claims, liabilities, damages, losses, costs, and expenses, including reasonable attorneys' fees and expenses, arising out of or related to:
    1. The Client’s or End-User’s use of Afrihost’s products or services.
    2. Any breach of this Policy by the Client or End-User.
    3. Any violation of applicable laws, regulations, or third-party rights by the Client or End-User.
14. Incident reporting.
  1. Clients and End-Users must report any suspected Bribery, Corruption or violations of Sanctions Laws immediately. Reports can be made directly to reportcorruption@afrihost.com.
15. Policy update.
  1. This policy is reviewed and updated annually.
16. Policy queries.
  1. For any queries regarding this policy, please contact Afrihost at reportcorruption@afrihost.com.