Code of conduct

Who it applies to

This code applies to directors, staff and everyone who acts for Bounty Industries, including agents, consultants and freight and customs intermediaries, and we expect suppliers and buyers to meet the same standard in their dealings with us.

Follow the law

We follow the laws of Nigeria, the Netherlands and every country we ship to or through, including export, customs, plant health and tax rules, and if you are not sure whether something is legal, ask before you act.

Be accurate about what we sell

• State grade, specification, origin, quantity and shipment date as they are.
• Never alter, backdate or create an inspection report, certificate, bill of lading or other document.
• Never misstate the origin, weight or value of a shipment.
• Tell the buyer promptly if a lot falls outside the contracted specification.

Bribery and corruption

We do not offer, pay, ask for or accept bribes in any form, to anyone, anywhere, which covers officials at ports, customs, inspection and certification bodies and employees of buyers and suppliers. We do not make facilitation payments, including small ones to speed up a routine service, and we do not use an agent or other third party to do what we may not do ourselves.

If someone demands a payment, refuse, write down what happened and report it, except that if you fear for your safety you may pay to protect yourself and must report it straight away.

Gifts and hospitality

Gifts and hospitality must be modest, infrequent, openly given and unable to influence a decision, so never give or accept cash, never give a gift to an official and do not give or accept a gift during a price negotiation or tender, and if you are unsure, ask management first.

Conflicts of interest

Tell management about any personal or family interest in a supplier, buyer, agent or competitor, and about any outside work that could affect your judgment, and do not take part in a decision where you have such an interest.

Sanctions, export controls and payments

We follow all export and import controls that apply, and we do not sell to or buy from sanctioned persons or ship to sanctioned destinations.

We take payment from buyers only by bank transfer from the contracting party, and we do not accept cash, and staff must report any request to pay a third party or to pay to a country other than the one agreed.

Fair competition

We set our prices and terms on our own, we do not agree with competitors on prices, bids, customers or markets, and we do not share non-public pricing with them.

Respect at work

We treat colleagues, suppliers, farmers and buyers with respect and do not accept discrimination, harassment, bullying or violence, and our expectations on labor and human rights in the supply chain are in the human rights policy.

Records and information

Keep accurate records of contracts, payments, inspections and shipments, do not keep accounts or make payments off the books, and treat buyer and supplier information as confidential and handle personal data as the privacy policy describes.

Reporting a concern

Anyone can report a breach of this code, of the law or of our human rights and environmental policies, including workers, farmers, community members, buyers and our own staff, by emailing contact@bounty.africa or calling +31 6 27361966 or +234 703 212 7274, and nobody has to give their name.

We acknowledge every report within 5 business days. Someone who is not involved in the matter looks into it, and we tell the person who reported it what we found and what we did, unless they asked to stay anonymous and we cannot reach them.

We keep the identity of the person reporting confidential as far as the law allows, and we do not retaliate against anyone who reports in good faith or allow anyone else to.

Consequences

Breaking this code can lead to disciplinary action, up to dismissal, or to ending a contract with an agent or supplier, and we report criminal conduct to the authorities.

Responsibility and review

The management of Bounty Industries is responsible for this policy, and we review it once a year and after any serious case.