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Anti Bribery and Anti Corruption Policy Statement of D-Vine Partners Commercial Solicitors

Our Declaration

D-Vine Partners Commercial Solicitors (DPCS) is founded on showcasing transparency , integrity and fairness as hallmarks of exhibiting its professionalism in all its conducts. And to do this , we are committed to the highest global ethical values and standards in all our transactions both locally and internationally.

It is our further commitment to ensure that all our staff (permanent or temporary), partners, managers, fees earners, trainees/interns, volunteers, agents , clients, consultants , advisers, contractors and any person(s) or organization(s) associated with the firm strictly adhere to these standards in the conduct of the firm's affairs/business.

This is in view of the fact that the firm may be liable under Anti graft Acts if it fails to prevent bribery and corruption by an associated person who acted for the firm's benefit.

It is therefore the purpose of this declaration to outline the firms position on bribery and corruption in so far as it relates to the conduct of its affairs both locally and internationally not only to as evidence of its zero tolerance for bribery and corruption but to also outline the firm's counter measures against the twin evil of bribery and corruption.

Our Covenant

It is thus our covenant to adhere to and sustain all anti bribery and anti corruption laws, policies and practices in Nigeria such as EFCC Act , ICPC Act etc., and in all the countries where we operate including the US's Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act;

We prohibit bribery and corruption in all its meaning and ramification, this include giving , offering , solicitation and or receipt of any bribe or corrupt inducement in any form whatsoever whether

The firm prohibits the offering, giving, solicitation or the acceptance of any bribe or corrupt inducement for whatsoever reason(s) or cause, whether in cash or in any other form to and from any person(s) and or organisation(s), private or public both locally and internationally.

What constitute bribery and corruption ?

It is an act which is targeted at influencing, inducing and or rewarding an individual or an organization either private or public in the performance of their duty in such a way and manner that a reasonable person would consider to be inappropriate under the given circumstances.

Such inducement, reward or promise which often constitute an offence under the law are sometimes meant to confer contractual , commercial , personal or regulatory gains, benefits or advantage on the firm.

Corruption which is generic encompasses bribery and it manifests in offering, promising or giving a financial and or other advantage to another person or organisation with the intention of influencing or rewarding that person to act or for having acted in a way which a reasonable person would consider inappropriate in the circumstances. In other words it is an abuse of trust or power for the purpose of private gain which may include bribery.

So many times it involves the giving or promising of money but at some other times it can be in kinds such as gifts.

Bribery and Corruption are severely punished by series of legislations both locally and internationally. For instance ICPC Act punishes corrupt act with not less than 7 years imprisonment and or with fine. This portends serious reputational damage for the firm.

Caveat on Gifts and hospitality

It is imperative to note that it is not the intention of this Policy to prohibit the giving and receiving of gifts when appropriate, provided it is properly documented and disclosed in line with the firm's practice and procedure which is encompassed as follows;

Such gifts and or hospitality;

a. Must not be with the purpose of inducing or influencing any person(s) or organization(s) to obtain , gain and or retain benefits , favour or advantage ;

b. Must be disclosed, recorded and transparently given in the corporate name of the firm without any conflict with the laws, code of corporate, ethical practice and conducts ;

c. Must be proportionate, appropriate in a given circumstance and the reason for such gift must be disclosed

While it is without doubt that what constitutes an acceptable gift and or hospitality varies from one country to the other , the test of reasonableness and motive or intention for such gift and or hospitality should always be applied and whenever in doubt on the appropriate course of action particularly with regards to whether a possible cause of action is in conflict with this policy or any extant law, such circumstances should be referred to the firm's Regulatory and Compliance Partner.

Further to the above No gift or hospitality must be offered to or accepted from government officials or representatives, politicians or political parties without express approval in writing of the firm's Regulatory and Compliance Partner.

Default from this policy will not be tolerated from any employee or anybody or organization acting on behalf of the firm. Such default or suspected default will be strictly treated as misconduct which may lead to dismissal.

Red Flag!

The firm shall not tolerate the following act(s) under any circumstances from any of its staff or anyone or organization(s) acting for or on behalf of the firm;

a. A payment, gift, hospitality or promise of gift , payment or offer hospitality to a government official, representative or agent for the purposes of " facilitating" or expedite an otherwise routine activit(ies);

b. A payment, promise to pay ,give or promise to give, hospitality or promise of hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

c. Acceptance of payment from any person or organization where it is known or suspected that it is offered with the expectation that it will obtain a business advantage for them;

d. Acceptance of a gift or hospitality from any person or any organization where it is known or suspected that it is offered or provided with an expectation that a business advantage will be provided by the Firm in return;

e. Engaging or encouraging the breach of this policy .

Payment of facilitation fees and or "kickbacks"

The firm will not under any circumstance make or accept facilitation payment and or make any kickbacks in order to expedite government officials' duties and obligations.

Charitable Donations

The Firm will make charitable donations subject to respective laws and code of ethics of its different countries of operation.

In order to show accountability and transparency, the firm shall maintain adequate records and internal control for all such payments or donation to charitable organization or to any third party parties.

Further to the above, records will also be kept of all accepted and or offered hospitality or gifts in accordance with the firm's practice and procedures.

Raising concerns and employees responsibilities

It shall be the responsibility of all the firm's employees and those working for the firm to prevent not only to detect and report any incident of bribery and corruption but to also avoid any activity that might lead to or suggest a breach of any law or this policy.

The firm employees' have the onerous duty and responsibility to immediately inform the firm if they suspect or believe there is any conflict or likelihood of conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe or bribe demanded from them , suspect that this may happen in the future.

The staff are enjoined to report any infraction or suspicious infraction by a member of staff or any third party to their line manager or directly to the firm's Regulatory and Compliance Partner in strictest confidence.

If any member of public is aware of any activity of any member of staff which suggest or might lead to the breach of this policy or any law , such member of public is enjoined to immediately contact the firm's Partner in charge of regulatory and compliance at or

Periodic Review of the Policy

The policy shall be subject to periodic review on bi annual basis in order to appraise its effectiveness and suitability as well as to consider the employees' performance under the policy. This is also coupled with the appraisal of internal control system in order to gauge its effectiveness in countering bribery and corruption.

Training and communication

All the staff are given updated training on the policy on a regular basis while all the third parties that work with and for the firm are informed of the firm's strict position on anti bribery and corruption.


Managing Partner

K.O. Balogun BL, L.MM , MBA