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ANTI-CORRUPTION POLICY

BUILT ON INTEGRITY. COMMITTED TO AFRICA’S INDUSTRIAL FUTURE.

At the Dickinson Group of Companies (DGC), our legacy of over 115 years is built on trust, ethical leadership, and a deep commitment to doing what is right. As a fifth-generation family-owned business operating across the African continent, we maintain a zero-tolerance approach to bribery, blackmail, extortion, fraud, and all other forms of corruption.

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Integrity is not a principle we reference occasionally - it defines who we are. It is embedded in every decision we make, every service we deliver, and every relationship we build.

  WHO THIS POLICY  

  APPLIES TO  

This policy applies to all individuals associated with DGC, including:

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  • Employees (permanent, temporary, or contract-based)

  • Directors, executives, and consultants

  • Third-party agents, representatives, and service providers acting on behalf of DGC

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All are expected to uphold DGC’s core values: People, Integrity, Trust, Service, and Innovation.

  WHAT WE STAND    AGAINST  

We define corruption as the abuse of entrusted power for personal or organisational gain. This includes:

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  • Bribery – offering, receiving, or requesting anything of value to improperly influence decisions

  • Blackmail – using threats or information to coerce or manipulate others

  • Extortion – obtaining something of value through pressure, intimidation, or abuse of position

  • Fraud – deliberate deception for unlawful advantage

  • Conflicts of Interest – allowing personal interests to compromise professional duties

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At DGC, we hold ourselves to the highest standards and do not excuse unethical conduct under the guise of pressure, custom, or convenience.

  RECOGNISING   RED FLAGS  

Corruption is not always overt. DGC encourages vigilance in identifying the warning signs, which may include:

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  • Unclear or excessive consultancy fees

  • Payments requested in personal or offshore accounts

  • Lack of documentation or unusual urgency in transactions

  • Gifts or hospitality during tenders, negotiations, or audits

  • Attempts to bypass internal processes or controls

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For more detail, see Annex A – Red Flags and How to Respond.

  GIFTS, HOSPITALITY  

  & ENGAGEMENTS  

While professional courtesy and cultural respect are important, all gifts and hospitality must:

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  • Be modest, occasional, and culturally appropriate

  • Serve a legitimate business purpose

  • Never be offered or accepted to gain improper influence

  • Be disclosed when required and never concealed

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For more detail, see Annex B – Guidance on Gifts, Hospitality and External Interactions.

  RECOGNISING   RED FLAGS  

Corruption is not always overt. DGC encourages vigilance in identifying the warning signs, which may include:

​

  • Unclear or excessive consultancy fees

  • Payments requested in personal or offshore accounts

  • Lack of documentation or unusual urgency in transactions

  • Gifts or hospitality during tenders, negotiations, or audits

  • Attempts to bypass internal processes or controls

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For more detail, see Annex A – Red Flags and How to Respond.

  GUIDANCE    FOR EMPLOYEES  

Our employees frequently seek clarity on how to navigate ethical challenges in practical settings. We provide clear, supportive answers to common questions, such as:

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  • What to do if a client offers a gift

  • How to handle invitations to events or travel

  • How to report concerns without fear of retaliation

  • What constitutes a conflict of interest

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For more detail, see Annex C – Frequently Asked Questions for further guidance.

  GLOBAL STANDARDS 

  & LEGAL COMPLIANCE 

DGC aligns its anti-corruption efforts with both international frameworks and local laws, including:

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  • United Nations Global Compact – Principle 10

  • UN Convention Against Corruption (UNCAC)

  • OECD Convention on Combating Bribery

  • African Union Convention on Preventing and Combating Corruption

  • National laws such as:

  1. South Africa’s PRECCA

  2. Zambia’s Anti-Corruption Commission Act

  3. DRC’s Anti-Corruption Law

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Our approach is detailed in Annex D – Ethical Standards and Commitments.

  REPORTING    MISCONDUCT  

Speaking up protects our business, our people, and our values. DGC encourages everyone - employees, clients, and partners - to report misconduct confidentially and in good faith.

 

Contact the DGC Fraud Hotline:

·        Email: fraudhotline@dgc-africa.com

·        Compliance Officer: ria@dgc-africa.com

·        Phone: +27 82 376 2457

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Reports can be made anonymously and will be treated with the utmost professionalism and discretion. Retaliation of any kind is strictly prohibited.

  OUR    COMMITMENT  

We do not compromise. We do not turn a blind eye. We are a business built on integrity - driven by purpose, guided by principle, and committed to shaping a responsible, transparent, and ethical industrial future across Africa.

 

Trevor Dickinson

Chairman, Dickinson Group of Companies

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