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McRollin Anti-Corruption Policies

1. Purpose and Commitment

McRollin & Company Ltd is committed to operating with the highest standards of integrity, transparency, and accountability. Our Anti-Corruption Policies establish a zero‑tolerance stance toward bribery, fraud, collusion, extortion, money laundering, influence peddling, and all forms of corrupt conduct across all jurisdictions where we operate.

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2. Scope

These policies apply to:

  • All McRollin employees, partners, executives, and consultants.

  • All third parties acting on behalf of McRollin, including suppliers, subcontractors, agents, intermediaries, and strategic partners.

  • All client engagements, internal operations, and cross-border activities

3. Definitions

  • Bribery: Offering, giving, receiving, or soliciting anything of value to influence an action.

  • Facilitation Payments: Small, unofficial payments to expedite routine government actions—strictly prohibited.

  • Conflict of Interest: A situation where personal interests may improperly influence professional judgment.

  • Kickbacks: Payments made in return for business advantages.

4. Prohibited Conduct

McRollin prohibits:

  • Direct or indirect bribery of any public or private official.

  • Facilitation payments of any kind.

  • Manipulation of procurement, bidding, or evaluation processes.

  • Improper gifts, hospitality, travel, or entertainment.

  • Use of third parties to conceal corrupt actions.

  • Misrepresentation, falsification of records, or concealment of information.

  • Financial misconduct including embezzlement or money laundering.

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5. Gifts, Hospitality, and Entertainment

Gifts and hospitality are allowed only if they are:

  • Modest, infrequent, and compliant with local laws.

  • Not intended to influence a business decision.

  • Fully declared and approved through McRollin’s Integrity Compliance System.

Any gift or hospitality exceeding approved limits must be declined and reported.

6. Due Diligence and Third-Party Integrity

McRollin conducts mandatory integrity due diligence on:

  • All suppliers and subcontractors.

  • Strategic partners.

  • High-risk clients and jurisdictions.

Third parties must commit in writing to adhere to McRollin’s Anti-Corruption Policies.

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7. Record Keeping & Transparency

  • All financial transactions must be accurately recorded.

  • No off-the-record accounts or undisclosed transactions are permitted.

  • Contracting and procurement decisions must be fully documented

8. Reporting & Whistleblowing

McRollin provides safe, confidential reporting channels for raising concerns about corruption. Retaliation against whistleblowers is strictly prohibited.

9. Training & Capacity Building

All employees undergo mandatory annual anti-corruption training. High-risk roles receive enhanced training.

10. Enforcement & Disciplinary Measures

Violations of this policy may result in:

  • Termination of employment or contracts.

  • Legal action in relevant jurisdictions.

  • Reporting to authorities and regulatory bodies.

Contact us

Head Office:
McRollin & Company Ltd
21673 – 00505, Ngong Road, Nairobi, Kenya

Tel: (+254) 791 752 938 / 756 599 371
Email: info@mcrollin.com

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