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Anti-Bribery and Corruption Policy

Aligned with South African legislation and international standards including the UK Bribery Act and OECD guidelines.

Anti-Bribery and Corruption Policy

Aligned with South African legislation (such as the Prevention and Combating of Corrupt Activities Act), as well as international standards like the UK Bribery Act and OECD guidelines.

Layer7 Networking - Anti-Bribery and Corruption Policy

1. Purpose

Layer7 Networking is committed to conducting its business fairly, honestly, and transparently. This policy sets out our zero-tolerance stance toward all forms of bribery and corruption and provides guidance for recognising, preventing, and reporting corrupt conduct.

2. Scope

This policy applies to:

  • All Layer7 Networking employees (permanent, contract, and temporary)

  • Directors, officers, and consultants

  • Suppliers, partners, and third-party representatives acting on behalf of Layer7 Networking

  • All business conducted in South Africa and internationally

3. Legal Framework

This policy complies with:

  • The Prevention and Combating of Corrupt Activities Act (PCCAA) No. 12 of 2004 – South Africa’s primary anti-corruption legislation

  • The UK Bribery Act 2010 – particularly where international clients or partners are involved

  • The OECD Anti-Bribery Convention

  • Other applicable anti-corruption laws where Layer7 Networking operates

4. Definitions

Bribery involves offering, giving, receiving, or soliciting something of value to influence a business or official decision.

Corruption is the abuse of entrusted power for private gain.

Examples include:

  • Cash payments or “kickbacks”

  • Lavish hospitality or gifts that create a conflict of interest

  • Political or charitable contributions intended to influence decisions

  • Hiring or awarding contracts in exchange for business advantages

5. Our Commitment

Layer7 Networking will:

  • Prohibit all forms of bribery and corruption

  • Act with integrity and transparency in all our business dealings

  • Promote ethical behaviour across our business and value chain

  • Investigate all reported incidents and take appropriate action

6. Gifts, Hospitality, and Entertainment

  • Gifts and hospitality must be modest, infrequent, and not intended to influence decisions

  • Any gift or entertainment exceeding R1,500 must be pre-approved by management

  • Cash or cash equivalents (e.g., vouchers) must never be given or accepted

7. Political and Charitable Contributions

  • Any political donations must be authorised by the board and be transparent and lawful

  • Charitable donations must be genuine, for socially responsible purposes, and not a means of securing business advantage

8. Third Parties and Due Diligence

  • We will conduct appropriate due diligence before engaging with third parties

  • Contracts will include anti-bribery clauses requiring compliance with this policy

  • Agents, consultants, and intermediaries must not act in ways that would violate this policy

9. Responsibilities

  • Management is responsible for promoting this policy and ensuring it is understood

  • Employees and stakeholders must report any suspicions of bribery or corruption

  • The Compliance Officer will oversee implementation, training, monitoring, and investigations

10. Reporting and Whistleblowing

Suspected violations can be reported confidentially to:

  • info@layer7.co.za

  • Anonymous reports are permitted and protected

Layer7 Networking will not tolerate retaliation against anyone who raises concerns in good faith.

11. Breach of Policy

  • Violations will be treated as gross misconduct and may lead to disciplinary action, including dismissal

  • Legal action may be taken against individuals or entities found guilty of bribery or corruption

12. Training and Communication

  • All employees will receive training on anti-bribery and corruption practices

  • Policy awareness will form part of the induction for new employees

  • Regular refresher training and reminders will be issued

13. Monitoring and Review

  • This policy will be reviewed annually or after any significant legal or regulatory change

  • Internal audits and risk assessments will be conducted periodically to ensure compliance