As a law firm based in Tanzania, Rollette and Co recognizes that bribery is a significant threat to the rule of law, economic growth, and social stability in the country. Bribery undermines the integrity of the legal system and the trust of the public in the institutions that meant to serve them. As Such we are committed to preventing and combating all forms of bribery, and we have developed the following anti-bribery policy:
Definition of bribery
For the purpose of this policy, bribery is defined as the offering, giving, receiving, or soliciting of anything of value in exchange for an improper advantage, whether for oneself or for someone else.

Zero-tolerance
Rollette and Co have a zero-tolerance policy for bribery, and we do not tolerate any form of corrupt or unethical behavior. This policy applies to all employees, clients, vendors, and partners, and any violation will result in disciplinary action.

Compliance with laws and regulations
We will comply with all applicable anti-bribery laws and regulations in Tanzania, including the Prevention and Combating of Corruption Bureau Act, Revised Edition of 2022, and the Anti-Money Laundering Act, Cap 423 Revised Edition of 2022.

Risk assessment
We will conduct regular risk assessments to identify and evaluate the risks of bribery in our operations, and we will take appropriate steps to mitigate those risks.

Due diligence
We will conduct due diligence on all employees, clients, vendors, and partners, including background checks and assessments of their compliance with anti-bribery laws and regulations.

Training and awareness
We will provide regular training to all employees on the risks and consequences of bribery and the importance of complying with anti-bribery laws and regulations. We will also raise awareness among clients, vendors, and partners of our anti-bribery policy and the consequences of violating it.

Gifts and entertainment
We will only offer or accept gifts or entertainment that are of nominal value and consistent with local business practices and ethical standards. Any gifts or entertainment offered or accepted must be recorded and reported to the appropriate supervisor.

Reporting and investigation
We encourage all employees to report any suspected or actual incidents of bribery, including attempts to bribe or solicit bribes. We will investigate all reported incidents promptly and thoroughly, and we will cooperate fully with law enforcement authorities in any investigations or prosecutions.

Record keeping
We will maintain accurate and complete records of all financial transactions and other activities that may be relevant to the prevention and detection of bribery.

Continuous improvement
We will regularly review and update our anti-bribery policy and procedures to ensure they remain effective and in line with the changing legal and business environment in Tanzania.

By implementing this anti-bribery policy, Rollette and Co will demonstrate its commitment to ethical behaviors and contribute to the broader efforts to combat bribery in Tanzania
CLEMENT E.A. KIIHOKO
MANAGING PARTNER

REPORTING A VIOLATION whistleblower@rollettelaw.co.tz