77 Legacy Africa Ventures

Compliance

Foreign Corrupt Practices Act (FCPA)

Our zero-tolerance stance on bribery, corruption, and improper payments in all business dealings.

Our Anti-Corruption Commitment

77 Legacy Africa Ventures Limited is committed to conducting business with the highest standards of integrity and in full compliance with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all applicable anti-corruption laws in the jurisdictions where we operate.

We maintain a zero-tolerance policy toward bribery and corruption in any form — whether involving government officials, private parties, or third-party intermediaries acting on our behalf.

What the FCPA Requires

The FCPA prohibits U.S. persons and entities, as well as foreign companies listed on U.S. stock exchanges, from bribing foreign government officials to obtain or retain business. It also requires accurate books and records and adequate internal accounting controls.

  • No payments — direct or indirect — to foreign officials to influence official acts.
  • Accurate and transparent financial records reflecting all transactions.
  • Robust internal controls to prevent and detect improper payments.
  • Due diligence on all third-party agents, consultants, and business partners.

Our Programme

  • Mandatory FCPA and anti-bribery training for all employees and management.
  • Comprehensive due diligence procedures for all third-party intermediaries.
  • Clear policies on gifts, hospitality, and political contributions.
  • Confidential reporting channels for suspected violations.
  • Non-retaliation protections for good-faith reporters.
  • Regular audits and monitoring of high-risk transactions and relationships.

Reporting Concerns

Any employee, contractor, or third party who becomes aware of a potential FCPA violation or suspicious conduct is encouraged to report it immediately. Reports may be made directly to management or via our confidential reporting channel at [email protected]. All reports will be treated with strict confidentiality.

This policy is reviewed annually and updated to reflect changes in applicable law and best practice. For enquiries contact [email protected].

77 Legacy Africa Ventures

77 Legacy Africa Ventures Limited

P.O BOX 14827, Westlands, Nairobi

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Business Hours

Mon – Fri: 09:00 – 17:00
Sat – Sun: Closed
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