Corporate Procedure

Business Visits to Bassel® Africa

Compliance & Governance Framework

 

1. Purpose

 

This procedure establishes mandatory legal, compliance, and risk management requirements governing all business-related visits to Bassel® Africa operations. It ensures that visits are conducted in full compliance with applicable laws, corporate policies, and internal governance standards, with particular attention to jurisdictions that may require enhanced regulatory, compliance, or operational diligence and interactions with government authorities.

 

2. Scope

 

This procedure applies to:

All employees, consultants, contractors, and third parties representing the Company.

Requests, approvals, facilitation, or participation in business visits to Bassel® Africa.

Engagements with government officials or state-owned entities during such visits.

 

3. Preconditions for Visit

 

Visits to Bassel® Africa shall only proceed if all of the following are fully satisfied:

A detailed, documented business justification including scope, objectives, and expected outcomes.

Prior written approval from the relevant line manager and, where applicable, senior management and Compliance.

Comprehensive risk assessment, covering security, health, legal, regulatory, operational, and reputational risks.

Completion of all travel documentation, visas, permits, and insurance in compliance with local and international regulations.

 

Confirmation that the visiting personnel have completed mandatory compliance, anti-bribery, anti-corruption, and data protection training, and formally acknowledged corporate policies.

 

4. Approval and Coordination

 

All visit requests must be submitted through formal channels.

Legal, Compliance, and Risk Management functions shall review requests where necessary.

Enhanced Compliance Jurisdictions or interactions with government officials, additional approvals from senior management and Compliance are mandatory.

 

Documentation of all approvals, risk assessments, and supporting materials shall be retained for audit purposes.

 

5. Enhanced Compliance Jurisdiction Requirements

 

Certain jurisdictions may require enhanced regulatory and compliance attention due to factors such as evolving regulatory frameworks, operational conditions, or international compliance standards.

 

For visits to such jurisdictions:

 

Alternative engagement methods (e.g., virtual meetings) should be considered when appropriate.

Enhanced due diligence may be conducted on relevant third parties, intermediaries, or government-facing contacts.

 

All visits must comply with applicable anti-bribery, anti-corruption, sanctions, trade compliance, and corporate governance standards.

 

Where necessary, post-visit reporting summarizing business activities and compliance considerations may be required.

 

6. Government Officials Interaction Protocol

 

6.1 Scope

Applies to all engagements with government officials, public servants, or state-owned entity representatives during visits to Enhanced Compliance Jurisdictions.

 

6.2 Mandatory Approvals

Written pre-approval from Senior Management and Legal & Compliance is required.

 

Purpose, scope, participants, and outcomes must be clearly documented and aligned with legitimate business objectives.

 

A risk assessment covering anti-corruption and reputational risk must be completed and approved.

 

6.3 Conduct and Due Diligence

Enhanced due diligence for all parties, including conflicts of interest or sanctions exposure.

Gifts, hospitality, or entertainment require prior written approval per the Anti-Bribery and Anti-Corruption Policy.

Interactions must remain professional, transparent, and well-documented. Facilitation payments, bribes, or inducements are strictly prohibited.

 

6.4 Reporting and Escalation

Any unusual requests, policy breaches, or suspected violations must be reported immediately to Legal & Compliance.

Post-interaction reports summarizing the engagement and compliance considerations may be required.

 

6.5 Zero-Tolerance

Non-compliance may result in disciplinary action, up to termination, and potential legal consequences.

 

7. Compliance, Security, and Risk Management

 

All personnel must comply with company ethics, compliance, anti-corruption, and information security policies.

Local laws, cultural norms, and regulatory requirements must be followed at all times.

Emergency procedures and communication protocols must be adhered to, with contact information shared prior to departure.

 

7.1 Priority Request/Urgent Submission

In cases where a business visit to Bassel® Africa must be conducted on an urgent or priority basis due to critical operational, strategic, or regulatory requirements, the following procedure applies:

The requesting employee must submit a Priority Request in writing, clearly stating the business justification, urgency, and potential impact of delay.

The request must be routed directly to the Line Manager and Legal & Compliance functions for expedited review.

Enhanced risk assessment must be completed and documented, including security, compliance, and reputational considerations.

 

All required approvals (Line Manager, Senior Management if applicable, and Legal & Compliance) must be obtained prior to travel, even under expedited conditions.

Emergency communication protocols and contingency plans must be reviewed and confirmed before departure.

Post-visit reporting is mandatory, highlighting any deviations, risks, or urgent decisions made during the visit.

Failure to comply with the Priority Request process may result in disciplinary measures or compliance escalation, consistent with Section 9 of this procedure.

 

8. Incident Reporting

 

Any actual or suspected breach of law, corporate policy, or security incident must be reported immediately.

Escalation to senior management and Legal & Compliance is mandatory.

Documented investigation and follow-up actions are required.

 

9. Non-Compliance and Disciplinary Measures

 

Failure to comply with this procedure may result in:

Disciplinary action, up to termination of employment or contractual relationship.

Legal action and potential financial or reputational liability for the Company.

 

10. Effective Date

 

This procedure becomes effective upon approval by Senior Management and the Legal & Compliance function, and remains in effect until amended or revoked.

 

11. Expenses and Cost Allocation

 

All costs and expenses related to visits to Bassel® Africa, including but not limited to international and domestic travel, accommodation, meals, local transportation, visa fees, insurance, security arrangements, and any other incidental or personal expenses, shall be borne exclusively by the visiting party.

 

Bassel® shall not, directly or indirectly, cover, reimburse, advance, or subsidize any such expenses unless explicitly approved in writing in advance by the Bassel® Compliance Department and documented in accordance with applicable Anti-Bribery, Compliance, and Corporate Governance regulations.

Any exception to this rule must be justified on legitimate business grounds, fully transparent, proportionate, and compliant with international compliance standards, including but not limited to ISO, OECD, and applicable anti-corruption frameworks.

 

 

 

Approved by Management
Legal & Compliance Department

 

 ✉️law@basselgroup.com

 

 ✉️ethics@basselgroup.com