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Anti Bribery and Correlation Policy



This policy commits Unitrust into conducting its business ethically and with the utmost integrity in all its operations. This policy requires compliance with all applicable laws and regulation on bribery and corruption including but not limited to Independent Corrupt Practices and other related offences (ICPC) Act, The Economic and Financial Crimes Commission (EFCC) Act, Criminal Code, Money Laundering (Prohibition) Act, and the Constitution of the Federal Republic of Nigeria 1999 (as amended).


The purpose of the policy is to outline and explain the prohibitions against bribery and corruption in Unitrust, to highlight specific compliance requirement relating to these prohibitions and to reinforce Unitrust commitment to doing business ethically.

By endorsing this policy, Unitrust reiterates its strong commitment to adhering to relevant standards and laws against bribery and corruption.


A Bribe is: the offer, soliciting, promise or receipt of any gift, hospitality, loan, fee, reward or other advantage to induce or reward behaviour which is dishonest, illegal or a breach of trust, duty, good faith or impartiality in the performance of a person's functions or activities (including but not limited to, a person's public functions, activities in their employment or otherwise in connection with a business).

Corruption: is a form of dishonesty or criminal activity undertaken by a person or organization entrusted with a position of authority, often to acquire illicit benefit.
Third party: is any individual or organization you are in contact with during the course of your work, and includes actual and potential customers, suppliers, vendors, logistics providers, distributors, business contacts, agents, advisers, and government and public bodies.


This policy applies to all individuals working for Unitrust, directors, employees (whether regular, fixed term or temporary), trainees, seconded staff, interns, agents or any other person associated with Unitrust, wherever located.


Every incidence of bribery and corruption or attempts at promoting such, are recognized as illegal and internally abhorred as barriers to good business dealings and to sustainable development. Unitrust has zero tolerance and does not condone these practices hence the need to ensure the existence of measures and policies to detect and prevent bribery and corruption by its agents, employees, other stakeholders and 3rd parties which act on its behalf or involve in any business transaction with them. Unitrust recognizes that bribery and corruption attracts sanction and penalties and could cause severe damage to its reputation, it therefore commits to taking its legal responsibilities seriously and to uphold all national laws relating to bribery and corruption.


  1. No employee may offer, give, promise or receive money, or anything else of value, to or from an individual or entity in the private sector or government official in order to obtain an improper advantage.

  2. The above-mentioned payments are prohibited regardless of whether they are made directly or indirectly through third party intermediaries.

  3. This policy permits employees to provide modest gifts, hospitality or certain other things of value to private or public individuals that are legal and directly related to the promotion or demonstration of Unitrust's services.

  4. When deciding whether a gift is appropriate, employees must consider any past, pending or future business or administrative matters that are within the recipient's realm of influence. The timing and context of such gifting must be considered in order to assess whether any gifting could objectively be perceived as bribery.

  5. Unitrust may be held responsible for the actions of third parties in, for example, giving or accepting bribes, therefore, third parties must never be asked to engage in or condone any conduct that employees are prohibited from engaging in themselves under this policy.

  6. All third parties conducting business with, for or on behalf of Unitrust are required to act with the highest level of business, professional and legal integrity.


Unitrust supports the making of contributions to the communities in which it does business and permits reasonable donations to charities and sponsorships. In this respect, reasonable steps must be taken to verify that any such contribution does not constitute an illegal payment to a government body or official or any individual in violation of this policy.


A gift or favour that meets the following criteria may be generally permitted if:

  1. It is not intended to improperly influence or reward any person regarding any matter or transaction involving Unitrust or another party.

  2. It is unsolicited, given infrequently or given openly.

  3. It is given or received in Unitrust's name and not in the name of the individual member of staff.

  4. It is of an appropriate type and value, given at an appropriate time, considering the motive, relevant laws or rules or policies of the third party making or receiving the Gift/Favor.

  5. Where a cash gift or an item of value is given that falls within the above-mentioned category, such cash gift or item of value must not exceed N100,000 or its equivalent otherwise it should be reported.

  6. It does not breach any other law or Unitrust policy.


  1. It is the responsibility of all employees to ensure compliance with this policy.

  2. Any employee who witnesses a breach of this policy is encouraged to raise concerns at the earliest stage and to promptly the Legal and Compliance department or make use of whistle blowing procedure.

  3. Any employee who is in doubt, suspects that this policy has been breached or has concerns about past or proposed actions by anyone in Unitrust, or any third party working with Unitrust, is encouraged to contact the Legal and Compliance department.


Employees who refuse to accept or offer a Bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. Unitrust encourages openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. Unitrust is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in corruption, or because of reporting concerns under this Policy in good faith. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any detrimental treatment as a result of refusing to take part in corruption, or because of reporting concerns under this Policy in good faith, you should inform your Line Manager, Compliance department or a member of the Human Resources team immediately. If the matter is not remedied, and if you are a staff, you should raise the matter by following the procedure laid out in the Whistle Blower policy.


To promote this policy, Unitrust will ensure periodic training of all staff and may make available and provide appropriate educational and training programmes and resources.


Any employee found to be in violation of this policy will be subject to the company's disciplinary procedure.