ANTI-CORRUPTION POLICY

The OIL AND GAS ASSOCIATION OF TANZANIA (OGAT) is a company limited by guarantee registered under the Companies Act, 2002, in the United Republic of Tanzania. OGAT’s main objects are interalia:

  1. The holding of regular meetings for the purposes of exchanging information and facilitating discussions relevant to the hydrocarbon industry in the United Republic of Tanzania;
  2. Making representations on behalf of the hydrocarbon industry in the United Republic of Tanzania.

The main law governing anti-corruption in Tanzania is the Prevention and Combating of Corruption Act, 2007, (“PCCA”) which applies in conjunction with other laws, subsidiary legislation and any guidelines published from time to time. The competent authority established to deal with anti- corruption investigations where corruption is alleged or suspected is the Prevention and Combatting of Corruption Bureau. This Policy supplements all applicable laws and provides guidelines for compliance with the said laws.


GENERAL PRINCIPLES

OGAT does not tolerate bribery or corruption in any form and this anti-bribery and anti-corruption policy (hereinafter the “Policy”) extends to all its activities in the United Republic of Tanzania.

The purpose of this Policy is to reiterate OGAT’s commitment to full compliance by its representatives and members with Tanzanian anti-bribery and anti-corruption laws.

It is OGAT’s policy to apply international standards designed to counter corruption and bribery when engaging in its practices and to conduct all of its activities in compliance with these standards.

 The following principles provide the framework within which OGAT conducts its activities:

1. OGAT expects the highest standards of integrity and professionalism from its representatives, its members and representatives of its members and has a zero tolerance policy to any failure to meet such standards. This means that the giving or receiving of bribes in any form whether directly or by those who work on behalf of OGAT is prohibited and will not be tolerated. Any OGAT representative, member or representative of any member failing to comply with the PCCA will be reported by OGAT to the relevant authorities and shall be subject to investigation and, if found guilty, punishment as envisaged by Tanzanian law.
3.OGAT, its representatives, members or representatives of any member shall not request, agree to receive or accept anything of value including money, inappropriate gifts, hospitality or services for improper performance of an activity or for any other improper purpose.
2. OGAT, its representatives, members or representatives of any member shall not promise, offer or make any payment or transfer anything of value, including inappropriate gifts, hospitality, services or any other advantage to anybody for improper performance of an activity or for the purpose of obtaining or retaining business or for any other improper purpose. (i.e. ensuring that any gifts, hospitality or services are not intended or perceived as intended, to influence the recipient).
4. OGAT recognises that facilitation payments are bribes and does not pay them
5. The Policy applies to contributions to charitable causes and any funds donated are not to be used as a cover for bribery or to gain undue advantage.
6. OGAT requires service providers engaged by it to abide with the Policy.
7. Any OGAT representative, member or representative of any member or service provider failing to comply with the Policy shall be banned from all future association of any kind with OGAT.


INTERNAL CONTROLS AND REPORTING

OGAT has put into place internal controls to counter bribery and corruption. These measures include. proper record keeping, a register of attempted or actual corrupt approaches to OGAT or its representatives and financial checks.

OGAT has adopted formal reporting channels by virtue of the appointment of an anti-corruption reporting officer (“ACRO”)to whom representatives,/ members or representatives of any member 2 shall report suspected activity for investigation by the ACRO. All offers of bribes, requests for bribes or facilitation or any other payments shall be reported to the ACRO as soon as possible.

OGAT’s ACRO shall review all reports of corruptive practice or incidents on a monthly basis and shall provide a summary report to the Board of Directors of OGAT detailing the number and nature of such incidents. The Board of Directors of OGAT shall then determine whether any action is required and the ACRO shall document any such action taken.


This Policy has been adopted by the Members of OGAT and is signed by the Chairman of the Board of Directors Meeting as evidence of this.