• Bisunzu Mining Company

Anti-corruption policy

Anti-corruption policy



As a mining company, SMB Sarl champions sustainable economic activities and fair business practices

The company requires its employees to strive to maintain the highest level of excellence and integrity in all their business relationships. The company’s Code of Conduct, to be read in conjunction with this policy, sets out the company’s core values, including professionalism, fairness, sustainability and adherence to all applicable ethical and legal standards. In addition to economic indicators, society also views public perception as a key indicator of its success.

The Company expects its employees to know that bribery is a serious crime that can have a serious  impact on the Corporation’s reputation and economic state. Offering, paying or accepting bribes, gifts or gifts for the purpose of gaining business or gaining a commercial advantage is illegal under Congolese law, the International Penal Code and the OECD Guide to Countering Corruption. Violation of these laws can result in significant monetary fines, imprisonment, and other socially detrimental consequences for the company or employees who violate these rules.

With this policy, SMB Sarl provides its employees with common guidelines and information to raise awareness of corruption and empower employees to deal with corruption.

Each employee is personally responsible for complying with this policy at all times. As such, each employee is required to refrain from any activity that would constitute or could be perceived as a bribe, and to report any alleged or potential violation of this policy to the Executive Committee.


The purpose of this policy is to provide employees with practical guidelines for handling situations involving corruption. Although this policy is intended to address the situations most likely to be encountered by employees, it is not intended to answer any questions that may arise. Therefore, in the event of circumstances not covered by this policy or in case of doubt, employees should seek guidance from the management or traceability department and act accordingly. This policy should be read in conjunction with the supply chain policy and the security protocol.

This policy applies to all employees, security departments, directors and officers of the company at all levels of the chain. This policy applies regardless of local customs that may permit behaviors prohibited under this policy.

A violation of this policy may result in disciplinary action against the employee concerned, up to and including termination of employment, as well as additional legal actions that may be brought by the company. To the extent that Congolese legislation requires the Company to report cases of corruption to local authorities, it will do so without delay.

All principles listed in this policy must be implemented by all entities within the SMB Mining Group, regardless of their location or role. The company expects its leaders to lead by example. Managers must perform their duties in accordance with this policy and ensure that the contents of this document are communicated and respected by all reporting employees.


All employees are required to:

  • Understand this policy and its implications;
  • Adhere to this policy at all times; and
  • Report any alleged violations of applicable law or this policy to the Executive Committee as soon as possible. The steering committee will protect those who report violations in good  faith.

1. CORRUPTION (General definition)

Corruption is generally understood as the misuse of power entrusted to one’s personal ends. This can take many forms and is not limited to interactions with the government. As a result, any action to benefit an individual in exchange for an abuse of professional power is bribery. This includes offering, giving, demanding or accepting contributions as an incentive to influence normal business activities and to promote ore fraud on the perimeter of operations. In this context, these abuses of power are generally referred to as corruption offenses. Giving contributions or granting benefits in order to influence the decision of a tier is prohibited worldwide. Although each country has its own anti-corruption laws, the above-mentioned principle is respected throughout the world and embodied by statutory provisions. In addition, it is forbidden to offer or accept a contribution if its intention is to influence the behavior of an individuals or partner.


According to the OECD Code, a “bribe” is any direct or indirect financial benefit or a free or reduced rate facility, designed to increase the comfort and enjoyment of the person to whom it is provided.

Typical examples of bribe contributions include:

  • Financial benefits, including:
  • Cash payments and bank transfers;
  • Granting interest-free loans;
  • Granting equivalent cash benefits;
  • Employees must not accept gifts or other personal benefits or privileges that would harm the business.


All employees, as well as security agents working for the account of the company, must comply with this charter, as well as all anti-corruption laws and regulations applicable in the Democratic Republic of Congo. All supervisors are responsible for enforcing and complying with this policy, including communication with lower-level employees and third parties.

Ignorance of the law or charter will not excuse conduct that violates the law or policy. Failure to comply with this policy may result in prosecution by the authorities, in addition to disciplinary action by the company. In order to protect the company and its employees from such consequences, it is not enough to avoid real acts of corruption, but even to avoid suspicions of corruption. As a result, employees are expected to adhere strictly to the provisions of this policy, including the obligation to report suspected or potential violations as described in Section 4 below.


Employees are required to follow this policy at all times. The Company will take all reasonable steps to ensure that complainants will not feel intimidated when reporting contraventions. The traceability department will ensure the confidentiality and fair protection of the complainants.

Alleged or potential violations of this policy should be reported immediately to the Executive Committee. Complaints can be submitted confidentially and anonymously.

The traceability department will investigate all complaints, if necessary with the assistance of external entities. The identity of the whistleblowers, the parties involved and all documentation will be kept confidential within the maximum limits permitted by law. No form of retaliation against the plaintiffs will be tolerated.

All complaints must be made in good faith. Abuse of this procedure may constitute dishonesty punishable under the code of the company.


This policy sets out the minimum requirements expected of employees facing corruption cases.

If you have any doubt as to whether an action violates this policy, you should seek the advice of management and act accordingly.

The Ethics Committee can be contacted by e-mail (nzonga@smb-sarl.com) for advice or questions or complaints regarding this policy.