Anti Corruption and Bribery Policy
ITSA prohibits bribery and corruption in public and private business. No sales target, tender opportunity, permit delay or instruction from a senior person justifies an improper benefit. This policy applies to ITSA personnel and people acting on its behalf and supports compliance with Namibia's Anti-Corruption Act 8 of 2003 and other applicable laws.
1 Prohibited benefits and conduct
Do not offer, promise, give, request, agree to receive or accept an improper advantage to influence a decision, reward improper conduct or conceal a conflict. A benefit can include money, a gift, hospitality, a job, travel, a loan, an inflated rebate, confidential information, a donation or something given to a relative or connected organisation. Attempted and indirect arrangements are also prohibited.
Prohibited conduct includes kickbacks, secret commissions, false invoices, bid manipulation, undisclosed conflicts, misuse of confidential procurement information and facilitation payments for routine official action. A payment does not become lawful because it is small, common locally or routed through a consultant. A properly receipted lawful fee paid to the authorised institution is different from an unofficial personal payment.
2 Gifts hospitality and expenses
Cash and cash-equivalent gifts, including vouchers used as money, are prohibited. Decline gifts or hospitality during a live tender, contract evaluation, licence approval or payment decision where they could influence or appear to influence the outcome. Do not provide a personal benefit to a public official to obtain or retain business.
Other modest business hospitality or a low-value promotional item is permitted only if lawful, infrequent, proportionate, transparent and unrelated to an improper decision. Obtain prior written approval from an unconflicted Managing Member for hospitality or gifts beyond ordinary refreshments, and record the recipient, organisation, purpose, value and approval. If the Managing Member is involved, another unconflicted member must approve; where none is available, decline the benefit. There is no safe-harbour monetary limit that makes an improper gift acceptable.
Travel and accommodation for a legitimate business event must have a documented business purpose, reasonable costs and approval. Pay the provider directly where practicable and do not fund private holidays, cash allowances without evidence or unnecessary companions. Public-official participation requires particular care and compliance with the recipient institution's rules.
3 Conflicts and procurement
Declare actual, potential and reasonably perceived conflicts before selection, pricing, recruitment, payment or contract decisions. This includes family, ownership, financial and close personal connections. Record the conflict, recusal and approved safeguards. Do not evaluate or approve your own connected transaction without independent review.
Use clear specifications, fair evaluation and documented approval. Public-sector work must comply with applicable procurement rules and tender conditions, including the Public Procurement Act 15 of 2015 where relevant. Do not collude, offer inducements to evaluators, misuse bid information or make false local-content, qualification or ownership declarations. Do not disguise a personal commission as marketing or technical support.
4 Agents suppliers and donations
Before appointing an intermediary, establish its identity, owners where relevant, competence, genuine services, reputation and connection to decision-makers. Use a written agreement, reasonable compensation, verified payment account and anti-corruption obligations. Refuse unexplained success fees, payment to an unrelated party or an insistence on secrecy. Check delivery before approving payment and monitor material red flags.
Charitable donations, sponsorship and CSR projects require a legitimate purpose, recipient checks, written approval and a record of benefit delivered. They must not be used to secure a tender, reward an official or benefit a connected person improperly. ITSA funds or resources must not be used for political contributions without a lawful expressly authorised decision by the members following appropriate independent review. This policy does not restrict lawful personal political activity at personal expense.
5 Records payments and coercion
Keep complete accurate books, supporting invoices, approvals and descriptions of the real transaction. Do not maintain off-book accounts, split transactions to evade approval or conceal a recipient. Verify bank-detail changes using an independently known contact and separate preparation and approval of significant payments where practicable. Finance must challenge unsupported or unusual payments.
If a person faces an immediate credible threat to life or physical safety, protect the person and seek assistance; do not risk injury to resist a demand. Report any payment made under such coercion to an unconflicted responsible member as soon as safe, record it accurately and obtain advice on external reporting. This is an emergency response provision, not an advance authorisation of facilitation payments.
6 Reporting investigation and consequences
Report demands, offers, suspected misconduct and retaliation promptly under the Whistleblower Policy. You may approach the Anti-Corruption Commission or another competent authority directly without internal permission. Preserve evidence lawfully, avoid tipping off suspects where prohibited and do not conduct unauthorised surveillance or retaliation.
The Managing Member, or an unconflicted member where necessary, must arrange impartial assessment, immediate safeguards and appropriate investigation. A personal legal duty to report must not await management approval. Proven violations may lead to fair discipline, termination of an engagement, recovery action or referral to authorities. Train relevant personnel at induction and periodically, and review gifts, conflicts, intermediaries and this policy at least annually.