1. Introduction

At Benson Eusebio Sanga Company Limited, we uphold the highest standards of ethical behaviour and integrity in all our business dealings. The Business Code of Conduct outlines the fundamental principles and guidelines that govern the conduct of our employees, officers, directors, and representatives in their interactions with colleagues, customers, partners, suppliers, and other stakeholders.

2. Ethical Principles

• Honesty and Integrity: We conduct ourselves with honesty, integrity, and fairness in all aspects of our work and relationships. We do not engage in deceptive, misleading, or unethical practices.
• Compliance with Laws and Regulations: We comply with all applicable laws, regulations, and legal requirements in the countries and jurisdictions where we operate.

3. Conflicts of Interest

• Disclosure: We disclose and manage conflicts of interest transparently and responsibly. Employees are required to avoid situations where their personal interests conflict with the interests of Benson Eusebio Sanga Company Limited.
• Gifts and Entertainment: We do not offer, accept, or solicit gifts, favours, or entertainment that could compromise our objectivity, impartiality, or integrity in business transactions.

4. Confidentiality and Data Protection

• Confidential Information: We protect confidential and proprietary information belonging to Benson Eusebio Sanga Company Limited, our customers, partners, and other stakeholders. Employees are required to safeguard confidential information and use it only for legitimate business purposes.
• Data Privacy: We respect the privacy rights of individuals and comply with applicable data protection laws and regulations when collecting, processing, and storing personal information.

5. Fair Competition

• Antitrust and Competition Laws: We compete fairly and ethically in the marketplace, adhering to antitrust and competition laws that prohibit anti competitive behaviour, collusion, price-fixing, and other unfair trade practices.
• Intellectual Property Rights: We respect the intellectual property rights of others and do not engage in unauthorised use, reproduction, or distribution of copyrighted materials, trademarks, or trade secrets.

6. Respectful Workplace

• Diversity and Inclusion: We foster a workplace culture that promotes diversity, equity, and inclusion. Discrimination, harassment, and retaliation of any kind are strictly prohibited.
• Health and Safety: We prioritise the health, safety, and well-being of our employees and strive to maintain a safe and healthy work environment free from hazards and risks.

7. Reporting and Compliance

• Reporting Violations: Employees are encouraged to report any suspected violations of the Business Code of Conduct to their supervisor, HR department, or through Benson Eusebio Sanga Company Limited’s confidential reporting mechanism.
• Non-Retaliation: We prohibit retaliation against individuals who report suspected violations of the Business Code of Conduct in good faith. Any form of retaliation is subject to disciplinary action.

8. Training and Awareness

• Training: Benson Eusebio Sanga Company Limited provides training and educational programs to employees to ensure they understand their obligations under the Business Code of Conduct and know how to apply ethical principles in their work.
• Communication: This Business Code of Conduct will be communicated to all employees, officers, directors, and representatives of Benson Eusebio Sanga Company Limited and made accessible through Benson Eusebio Sanga Company Limited’s intranet or other appropriate channels.

9. Enforcement and Consequences

• Enforcement: Violations of the Business Code of Conduct may result in disciplinary action, up to and including warnings, fines, suspension, termination of employment or contract, and legal action as appropriate.
• Compliance Monitoring: Benson Eusebio Sanga Company Limited will monitor compliance with the Business Code of Conduct through regular audits, reviews, and investigations as necessary.

10. Conclusion

By adhering to the principles outlined in this Business Code of Conduct, Benson Eusebio Sanga Company Limited demonstrates its commitment to ethical business conduct, integrity, and accountability. We believe that upholding these principles is essential to maintaining the trust and confidence of our stakeholders and sustaining long-term success.