Our Commitment

Ganbert Relocation (hereinafter “Ganbert”) has operated with integrity, transparency, and respect for the rule of law since our founding in Sudan in 1926. We have zero tolerance for bribery, corruption, or any form of unethical payment – whether involving government officials, private sector partners, employees, or third-party agents.

This Anti-Bribery Statement applies to all Ganbert directors, employees, contractors, agents, and representatives worldwide.

What Is Prohibited?

No Ganbert employee or associate may, directly or indirectly:

Prohibited Act	Explanation
Offer, promise, or give any financial or other advantage	To any person – whether a public official, private individual, or corporate representative
Request, agree to receive, or accept any financial or other advantage	As an inducement or reward for acting improperly
Use a third party (agent, supplier, intermediary)	To do any of the above on Ganbert’s behalf

This includes cash payments, gifts, entertainment, travel, favours, charitable contributions, employment offers, or any other item of value.

Key Principles

1. No Facilitation Payments

Ganbert prohibits “facilitation payments” – small unofficial payments made to secure or expedite routine government actions (e.g., customs clearance, visa processing, port releases). Even if such payments are customary or expected in a particular jurisdiction, they are illegal and forbidden.

2. Gifts & Hospitality

Modest, genuine gifts and reasonable hospitality (meals, refreshments) may be offered or accepted only if:

• They are infrequent and of nominal value (typically under $50 USD equivalent)
• They are not cash or cash equivalents (gift cards, vouchers)
• They are not given or received in connection with a tender, contract negotiation, or customs process
• They comply with local law and the recipient’s own employer rules
• They are properly recorded in Ganbert’s books

Never offer or accept gifts or hospitality to or from government officials without prior written approval from Ganbert management.

3. Political Contributions

Ganbert does not make political contributions – whether to candidates, parties, or political action committees – in any country where we operate.

4. Charitable Contributions

Charitable donations are permitted only through official Ganbert channels after due diligence to ensure the recipient is legitimate and not a conduit for bribery. Donations must never be made to secure business advantage.

5. Agents & Intermediaries

Any third party acting on Ganbert’s behalf (customs agents, freight partners, local representatives) must:

• Be subject to written contract including anti-bribery provisions
• Undergo due diligence before engagement
• Be monitored for compliance

Who Must Comply?

This policy applies to:

• All Ganbert employees (full-time, part-time, temporary)
• Directors and officers
• Contractors and consultants
• Agents and intermediaries
• Joint venture partners (where Ganbert has control or influence)

Third parties doing business with Ganbert are expected to adhere to equivalent standards.

Your Responsibility

All Ganbert personnel must:

• Read, understand, and comply with this Anti-Bribery Statement
• Report any suspected or actual bribery, corruption, or policy violation immediately
• Cooperate fully with any investigation

No one may:

• Ignore red flags or turn a blind eye to suspicious conduct
• Authorize or direct others to violate this policy
• Retaliate against anyone who reports a concern in good faith

Reporting a Concern

If you suspect or witness any violation of this Anti-Bribery Statement – whether by a Ganbert employee, agent, customer, or partner – you must report it immediately.

 

Consequences of Violation

Any violation of this Anti-Bribery Statement is a serious disciplinary matter and may also be a criminal offense under Sudanese law and the laws of other countries where Ganbert operates.

For employees: Violation may result in disciplinary action up to and including termination of employment and referral to law enforcement authorities.

For agents, contractors, and partners: Violation may result in immediate termination of the business relationship and legal action.

For Ganbert as a company: Violation could result in criminal prosecution, fines, debarment from government contracts, and irreparable reputational harm.

Training & Awareness

Ganbert provides regular anti-bribery training to all employees in roles exposed to bribery risk (including customs clearance, procurement, sales, and management). Training records are maintained.

Management Responsibility

All Ganbert managers are responsible for:

• Communicating this policy to their teams
• Modelling ethical behaviour
• Creating an environment where employees feel safe raising concerns
• Responding promptly and seriously to any report of misconduct

Statement Approval

This Anti-Bribery Statement was approved by the Board of Directors / Senior Management of Ganbert Relocation on 01/01/2026. It is reviewed annually and updated as necessary to reflect changes in law, business operations, or risk environment.

Contact us for Further Information

For questions about this Anti-Bribery Statement or compliance with anti-corruption laws