Anti-Bribery and Anti-Corruption Policy

Last updated: September 2025


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Table of Contents

  1. Background
  2. Bribery
  3. Facilitation Payments and Kickbacks
  4. Gifts, Entertainment, and Hospitality
  5. Reciprocal Agreements
  6. Actions by Third Parties
  7. Record Keeping
  8. Due Diligence
  9. Employee Responsibilities
  10. Disclosure Processes
  11. Audits
  12. Fraud
  13. Training and Communication
  14. Monitoring
  15. Review of Policy

  1. Background

The Institute of African Research and Innovation (iARAi) is a pan-African research and strategy institute dedicated to advancing sustainable development through thematic Sustainable Development Goals (SDGs), foresight, policy, and innovation. This Anti-Bribery and Anti-Corruption Policy sets out the responsibilities of iARAi and its stakeholders to uphold our zero-tolerance stance on bribery and corruption. It provides guidance to address these issues and ensures ethical conduct in all operations and partnerships.

This Policy aligns with applicable anti-bribery and anti-corruption laws, including the Nigerian Economic and Financial Crimes Commission Establishment Act 2004, the Independent Corrupt Practices and Other Related Offences Act 2000, the Advance Fee Fraud and Other Fraud Offences Related Act 2006, the Money Laundering (Prohibition) (Amendment) Act 2012, the United Nations Convention against Corruption 2003, and the African Union Anti-Corruption Convention 2003. It also draws on international standards such as the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act 2010 (UKBA).

This Policy applies to all iARAi directors, employees (temporary, fixed-term, or permanent), researchers, consultants, vendors, contractors, trainees, partners, or any other persons associated with iARAi, including third parties. It should be read alongside iARAi’s Code of Conduct, which addresses related issues such as gifts, transparency, and ethical partnerships.

iARAi has a zero-tolerance approach to bribery and corruption, recognising that such activities could undermine our mission, harm our reputation, and expose us to legal and reputational risks. The Board is fully committed to preventing bribery and corruption in all activities and takes these responsibilities seriously.

  1. Bribery

Bribery is defined as offering, giving, receiving, or soliciting any inducement, reward, or item of value to gain commercial, contractual, regulatory, or personal advantage. This includes, but is not limited to: 

  • Business opportunities. 
  • Favourable contracts or partnerships. 
  • Cash, cash equivalents (e.g., gift cards), or loans. 
  • Improper gifts, meals, travel, or entertainment. 
  • Favours, including offers of employment or internships for an individual or their relatives. 
  • Sponsorships or promises to pay/give.

Bribery is illegal, whether direct, passive, or through a third party (e.g., agent or partner). Employees and stakeholders must not engage in or accept bribes. If uncertain whether an action constitutes bribery, a gift, or an act of hospitality, individuals must seek guidance from the Organisation’s guidelines.

  1. Facilitation Payments and Kickbacks

Facilitation payments are bribes made to expedite routine administrative actions by public officials. Kickbacks are payments made in exchange for business favours or advantages. iARAi prohibits all facilitation payments and kickbacks, except in extraordinary circumstances where: 

  • The payment is approved in advance by the Managing Directors, or 
  • An employee’s safety or security is at risk.

In such cases, employees must:
a. Minimise the payment amount.
b. Request a receipt detailing the amount and reason, if possible.
c. Record the payment.
d. Report the incident to the Managing Directors via the email.

iARAi’s goal is to eliminate all facilitation payments and kickbacks.

  1. Gifts, Entertainment, and Hospitality

Gifts, entertainment, and hospitality are acceptable only if they comply with iARAi’s Code of Conduct provisions on gifts and gratuities. Excessive or improper gifts, entertainment, or hospitality intended to influence decision-makers are prohibited.

  1. Reciprocal Agreements

Reciprocal agreements are prohibited unless they are legitimate, documented business arrangements approved by management. Improper payments to secure partnerships, research opportunities, or other advantages are not permitted.

  1. Actions by Third Parties

iARAi may be held responsible for actions by third parties (e.g., agents, contractors, consultants) acting on its behalf. To mitigate risks: 

  • Conduct due diligence before engaging third parties. 
  • Engage third parties only with a clear business rationale and appropriate contracts. 
  • Authorise and record all payments to third parties.

  1. Record Keeping

Accurate and transparent record keeping is essential to prevent concealment of bribery or corrupt practices. iARAi maintains robust controls to ensure: 

  • All financial transactions, including payments to third parties, are documented. 
  • Records of research funding, partnerships, and operational expenses are transparent. 
  • Compliance with anti-corruption laws is verifiable.

  1. Due Diligence

To reduce the risk of bribery and corruption: 

  • The Procurement Unit must conduct due diligence on vendors, suppliers, partners, and consultants before initiating business relationships. 
  • Third parties must provide written commitments to comply with iARAi’s Anti-Bribery and Anti-Corruption Policy and Code of Conduct. 
  • Due diligence records must be documented and retained.

  1. Employee Responsibilities

All employees and stakeholders have a duty to act ethically and comply with this Policy. Failure to comply may result in disciplinary action, including dismissal, and potential legal proceedings under applicable laws. Responsibilities include: 

  • Reading, understanding, and adhering to this Policy and related training. 
  • Preventing, detecting, and reporting bribery or corruption. 
  • Notifying the Organisation promptly if bribery or corruption is suspected.

  1. Disclosure Processes

Disclosure is critical to the Policy’s effectiveness and covers three areas: 

  • Raising Concerns: Employees suspecting bribery or corruption must report concerns to the Company Secretary via HR@theiarai.org or whistleblowing channel: whistleblowing@theiarai.org. If unsure whether an action constitutes bribery, seek guidance from the Organisation’s guidelines. 
  • Victim of Bribery or Corruption: Employees must report immediately if offered a bribe, asked to make one, or suspect they may be involved in corrupt activities. 
  • Protection: iARAi ensures no detrimental treatment (e.g., dismissal, disciplinary action) for employees who refuse bribes or report concerns in good faith, even if investigations find no breach. Employees facing repercussions should contact the Organisation.

  1. Audits

Internal and external audits ensure compliance with this Policy, identifying weaknesses for prompt remediation. Employees must cooperate fully, providing accurate information during audits. Audits will assess: 

  • Financial transactions and third-party payments. 
  • Compliance with anti-corruption laws and iARAi policies. 
  • Effectiveness of training and disclosure processes.

  1. Fraud

Engaging in fraud, such as misusing iARAi assets, stealing, or falsifying expense reports, violates this Policy and applicable laws, carrying severe penalties. Employees, contractors, and directors must protect iARAi’s assets from damage, theft, or unauthorised use.

  1. Training and Communication

  • Training: All employees will receive anti-bribery and anti-corruption training during induction and annually. Training covers recognising and preventing bribery, reporting procedures, and policy compliance. 
  • Communication: iARAi’s zero-tolerance stance will be communicated to employees, partners, and third parties at the outset of relationships and regularly thereafter. 
  • Certification: Employees must annually confirm in writing their compliance with this Policy.

  1. Monitoring

The Board Committee is responsible for monitoring the Policy’s effectiveness, reviewing implementation regularly. Violations of this Policy or anti-corruption laws may result in disciplinary action, including dismissal, and legal consequences, including civil or criminal penalties.

  1. Review of Policy

This Policy will be reviewed every five years or as deemed necessary, in line with applicable laws and feedback from stakeholders. Updates will ensure alignment with iARAi’s mission and ethical standards.

Approved by the Managing Directors
2025