Ethics

AfroCentric Investment Corporation Limited (“ACT”) has implemented the Business Code of Ethics as part of its Corporate Governance policy that commits it to the highest standards of business conduct. The Code of Ethics is developed to ensure that all stakeholders are sensitized about AfroCentric Investment Corporation’s desired Corporate Culture.

All employees, directors and other officers and contractors (where they are under a relevant contractual obligation) are required to adhere to the Code. Controlled entities are also required to adopt and follow the Code. Non-controlled joint ventures, minority interests and suppliers are encouraged to adopt similar principles and policies.

The Code outlines the way we work at ACT. Much of the Code’s content comes from a range of policies and procedures that are mandatory across ACT. As an International business we are subject to the laws and regulations of countries in which we operate. We are also committed to upholding certain international standards and guidelines, such as the principles of the United Nations Global Compact, the United Nations Universal Declaration of Human Rights and the Voluntary Principles on Security and Human Rights.

The Code cannot describe every law, regulation or ACT requirement. Where differences exist as a result of local customs, norms, laws or regulations, the Code or local requirements are applied – whichever sets the higher standard of behaviour.

The Code is a common reference point for defining how each of our employees is expected to act when conducting ACT business. So whether they work on-site or in an office, deal only with fellow employees, liaise with third parties, community and government representatives or make decisions that are routine or high risk regarding the use of ACT assets, they will find clear guidance on expected business behaviour.

If employees and those to whom the Code applies have any queries about the interpretation of the Code or have concerns about how it is being applied, they are required to raise this with their supervisor or manager. Where this is not possible or it is inappropriate to do so, they can contact the Human Resources or LGRC representative or a member of senior management.

ACT prohibits any form of punishment, disciplinary or retaliatory action being taken against anyone for raising or helping to address a genuine business conduct concern.

In order to maintain ethical behaviour / conduct, and that all employees are clear and conscious about the code, all aspects are covered in detail in supplementary policies.

SUMMARY OF SUPPLEMENTARY POLICIES

IT Security: Computer hardware and software and all data on ACT information systems, as well as any ACT data on your home or non-Company digital systems, are the property of ACT. ACT information systems should always be used in a responsible manner.

Protecting ACT Assets: All ACT employees are responsible for safeguarding and appropriately using ACT assets under their control. ACT assets must not be used for personal benefit.

Harassment: ACT does not tolerate any form of harassment in any of our workplaces. People are the foundation of our success, and all our people must be treated fairly, respectfully and with dignity.

Accepting gifts, hospitality or entertainment can be a legitimate contribution to building good business relationships. It is important, however, that such things never unduly influence business decision-making or cause others to perceive that there has been an undue influence.

Conflict of Interest: ACT respects the privacy of its employees. However, on the job or in your personal time, nothing you do should conflict with your responsibilities to ACT or compromise, or appear to compromise, the quality of your work performance, and your commitment to your work or your ability to make impartial business decisions.

Working with Governments: ACT respects the authority of governments wherever we conduct business. We will maintain honest relationships with governments and their agencies, officials and personnel.

Corruption: ACT prohibits authorizing, offering, giving or promising anything of value directly or indirectly (via a business partner) to a government official to influence official action or to anyone to induce them to perform their work disloyally or otherwise improperly.

Community-based activities and programs are undertaken at various stages of our projects. These activities and programs are designed to improve the quality of life of the people in the communities where we operate in a sustainable way

Health and Safety: We believe that all accidents and occupational illnesses and injuries are preventable. At all times we will aim to meet or exceed applicable legal and ethical requirements.

Whistleblowing: It is the duty of all ACT employees to report unethical behaviour, including Theft, Fraud and any other corrupt activities. ACT management therefore encourages all ACT employees and its subsidiaries to report such conduct that in your view may be deemed unethical.

Insider Trading: Using Insider information for your financial or other personal benefit or conveying this information to others may be illegal.