Anti-bribery & Anti-corruption Policy



Bribery undermines democracy and the rule of law and poses very serious threats to sustained economic progress in developing and emerging economies and to the proper operation of free markets more generally.

Caracal Gold (together with its subsidiaries, “The Company”) is therefore committed to upholding the UK Anti Bribery Act (2010) and any local anti-bribery or anti-corruption laws that may be applicable. The Company is committed to doing business ethically, even if this means not gaining new business, not using the services of particular agents or business partners or incurring delays in carrying on existing business.

The Company adopts a zero-tolerance approach to bribery and corruption and demands the same from all of our employees, officers, directors, contractors and agents, as well as our subsidiaries and affiliates.


The objective of this Policy is to provide guidance and procedures to ensure that the Company conducts business in an honest and ethical manner when dealing with government officials and all other parties, and in compliance with all applicable laws and regulations pertaining to bribery and corruption.


This Policy is applicable to our entire workforce, including senior executives, financial officers, as well as consultants, contractors and members of the Board of Directors and reflects the standards to which the Company expects its business associates, partners, agents, and consultants to adhere to when acting on the Company’s behalf.


A copy of this Policy will be made available to all directors, officers, employees, consultants, contractors, and agents of the Company as well its auditors, legal counsel, and other advisors.

All agreements with consultants, contractors and agents shall include a provision that the consultant, contractor, agent, or intermediary must abide by this Policy at all times.

It is also posted on the Company’s website at  and additionally, a copy of the policy will be posted at any site operated by the Company.


In dealings with domestic and foreign public officials and government employees, directors, employees, contractors and representatives must, at all times maintain and enhance the reputation and integrity of the Company. All directors, employees, contractors and representatives shall conduct their dealings with government officials and employees in compliance with UK Anti Bribery Act (2010).

Bribery and corruption

A “bribe” is any financial or other advantage which is offered, provided, authorised, requested or received as an inducement or reward for the improper performance of a person’s relevant function or the receipt of which its itself improper. “Corruption” is the misuse of power by government officials or other parties for illegitimate private gain.

Facilitation Payments

Facilitation payments, which are payments to government officials or employees to expedite routine services, are prohibited.

Political Contributions

Under no circumstances shall Company funds be used to make political contributions to political parties or candidates even if such contributions are permitted by local laws.

Books and Records

Prior to paying or authorizing a payment to a domestic or foreign official or government employee, directors, employees, contractors and representatives must ensure that no part of such payment is to be made for any purpose other than that to be fully and accurately described in the Company’s books and records. All payments to a domestic or foreign official or government employee must be recorded and reported as such. Misrepresentative entries are not to be made in the books and records of the Company.

Gifts and Entertainment

As the Company expects employees, contractors and representatives to conduct business in a way that avoids even the perception of illegal or unethical conduct, when offering or receiving entertainment, gifts, or favours, the following standards should be followed:

  • The entertainment, gift or favour should be incidental or customary hospitality and of nominal value; it cannot be meant or perceived to influence the recipient’s judgment or to secure preferential treatment for the giver.
  • The entertainment, gift or favour should justify a definite business purpose and be appropriate to the person’s responsibilities.
  • Public disclosure of the receipt of any entertainment, gift or favour, or the potential for public disclosure to occur, must not embarrass the Company or the recipient.
  • In general, the receipt by any director, employee, contractor or representative of entertainment, gift or favour valued at more than US$100 may carry the presumption of a conflict of interest and should be disclosed to the individual’s immediate supervisor.

Charitable contributions and social benefits

No charitable or community contributions on behalf of the Company should be done without first obtaining formal internal approval for such contribution in accordance with prescribed procedures.


  • There should be no kickback of any portion of a contract payment to any third party (including employees of another contracting party) or utilise other techniques, such as subcontracts, purchase orders or consulting agreements, or commissions to channel bribes to any third party (including public officials, employees of another contracting party, their relatives or associates);
  • Any employee, contractor or representative whose position allows him or her to select, contribute to, or otherwise influence the selection of a supplier or service provider, will inform their immediate supervisor of any situation where a supplier or service provider is related to or has an affiliation with himself or herself. In such circumstances, it is not appropriate for the employee, contractor or representative to participate in the tender process and/or selection of the supplier or service provider.
  • Furthermore, any employee, contractor or representative involved in purchase award decisions, who has or whose relative (spouse, immediate family, etc.) has a substantial interest in any contract with a supplier, sale to a supplier, purchase from a supplier or service provided by a supplier, must make that interest known to their immediate supervisor and must not participate in any manner in the relevant contract or provision of goods or services.


The Company will maintain a system of internal accounting controls and keep books and records that, in reasonable detail, accurately and fairly reflect transactions and dispositions of assets.

Should a director, employee, contractor or representative be solicited for or offered a bribe or incentive of any type, or suspect that a bribe or incentive will be solicited for, directors, employees, contractors and representative are required to advise the ESG committee.


Any breach of this Policy will result in disciplinary action (possibly including, but not limited to, termination of employment, contractor, consulting, or agency relationships) and may also result in conviction for a criminal offence in many jurisdictions, including severe financial penalties and imprisonment. The Company treats the risk of bribery extremely seriously, not least because of the potential for reputational damage if the Company or an employee were found guilty of a bribery offence.

Approval date: 12th June 2023.