Prism Capital Partner (“the Firm”) is committed to conducting all business in accordance with the highest ethical standards. We have a zero-tolerance policy towards corruption, bribery, and any form of unethical conduct.

1. Purpose

This Policy establishes guidelines to prevent bribery and corruption in all business dealings, ensuring compliance with:

• The Anti-Corruption and Economic Crimes Act, 2003 (Kenya)

• The Bribery Act, 2016 (Kenya)

• Applicable international anti-bribery standards, including the UK Bribery Act and U.S. Foreign Corrupt Practices Act (FCPA) where relevant.

2. Prohibited Conduct

• Offering, giving, soliciting, or receiving bribes, kickbacks, or facilitation payments.

• Using company funds or assets for improper influence over business decisions.

• Engaging in corrupt practices with government officials, regulators, or third parties.

3. Gifts & Hospitality

• Modest and reasonable business courtesies may be permitted, provided they are transparent, proportionate, and lawful.

• All gifts and hospitality above a set threshold must be declared and approved in advance.

4. Third-Party Engagement

• All consultants, agents, and intermediaries engaged by the Firm must comply with this Policy.

• Prism Capital Partner will conduct due diligence on third parties to prevent association with corrupt practices.

5. Reporting & Whistleblowing

• Employees, clients, and partners are encouraged to report suspected corruption or bribery confidentially.

• Reports may be made via [Insert Contact/Whistleblowing Email or Hotline].

• Retaliation against whistleblowers is strictly prohibited.

6. Compliance & Enforcement

• All staff, contractors, and representatives of Prism Capital Partner must comply with this Policy.

• Violations may result in disciplinary action, termination of contracts, and referral to law enforcement authorities.