Introduction and Purpose

Melcom is committed to maintaining the highest standards of ethical conduct, legality, and integrity in all aspects of its operations. This Zero Tolerance Policy is designed to ensure that employees, suppliers, partners, and stakeholders adhere to the principles of honesty, transparency, and responsibility in their actions while representing Melcom Ltd.

This document will be referenced in our agreements (where applicable) and can be found online at:
https://Melcomgroup.com/zero-tolerance-for-unethical-illegal-and-fraudulent-acts-policy/.

 

Zero Tolerance

Melcom strictly prohibits any form of unethical, illegal, or fraudulent behavior. Violations of this policy will result in immediate disciplinary action, up to and including termination of employment or business relationships.

Examples of Prohibited Conduct

• Fraudulent Activities:
  • Any form of misrepresentation, falsification, or manipulation of information
  • Intentional deception in financial transactions, reporting, or communications
• Unethical Behavior:
  • Conflict of interest without proper disclosure
  • Harassment, discrimination, verbal abuse, or any form of unfair treatment
  • Corruption in any form, such as bribery, extortion, and abuse of power
• Illegal Activities:
  • Violation of local, national, or international laws
  • Any practice inconsistent with the rights outlined in the Convention on the Rights of the Child or the six core principles for Protection from Sexual Exploitation and Abuse in Humanitarian Crises
  • Participation in activities that undermine public trust

Prevention: To achieve the prevention of fraudulent activity, unethical behavior, and illegal activity within the organization, the following preventive measures shall be implemented:

Screening: Melcom follows procedures when engaging with different types of stakeholders. The social enterprise follows the following guidelines when it enters into any kind of service agreement -

• Screening and Hiring of Employment Procedure for employees
• Screening and Onboarding of Agencies and 3rd Party Servicers
• Procedure for engagement of Purchasing and Evaluation of Supplier

Code of Conduct: All individuals associated with Melcom, including employees, contractors, partners, and board members, are required to adhere to its Code of Conduct. This code outlines the principles of honesty, integrity, and ethical behavior expected from each member.

Training and Awareness Programs: Melcom will conduct regular training sessions and awareness programs to educate employees on recognizing, preventing, and reporting fraudulent, unethical, and illegal activities. These programs will ensure that all members of the organization are well-informed about the policies and ethical standards.

Conflict of Interest Policy: A Conflict of Interest Policy will be maintained to identify and manage situations where personal interests may conflict with the interests of the organization. Transparency and proper disclosure of potential conflicts of interest are vital to maintaining ethical standards.

Reporting Violations: Melcom encourages a culture of accountability and transparency, and individuals who become aware of potential violations are urged to report such incidents promptly. Melcom has an open-door policy where reporting can be channeled in any corridors that the affected persons feel comfortable with, and also through the following channels:

• Channels of Communications:
  • Direct Supervisor or Manager
  • HR Manager
  • Legal Officer
  • Union Representative
  • Grievance Redress Service Form
    • Can be done anonymously
  • Dedicated whistleblowing email address
    • grievance@melcomgroup.com.
  • Whistleblower Service
    • You can contact the external Whistleblower Service via +233 596 91 0545, or grievance@melcomgroup.com

Adherence: All individuals associated with Melcom are required to read, understand, and strictly adhere to this Zero Tolerance Policy. Failure to comply may result in serious consequences, reflecting Melcom’s unwavering commitment to maintaining the highest ethical standards in its operations.

Regular Review, Assessment, and Revision: The organization will conduct regular reviews and assessments of its policies and procedures to identify and address potential vulnerabilities to fraudulent, unethical, and illegal activities. Any necessary updates or improvements will be implemented to enhance the effectiveness of prevention measures. This policy will be updated as needed to ensure its effectiveness and alignment with best practices.

Adoption: The Zero Tolerance for Unethical, Illegal, and Fraudulent Acts Policy is effective as of 1st. January 2024, and has been adopted by Melcom’s Executive Board.

 

Prepared By: Legal	Reviewed By: Director	Annual Review Date:
(Legal Officer)	Francis Sam (General Manager)	January 1th, 2024