Anti Bribery & Corruption Policy

THE POLICY
This document sets out the long-standing policy of [Company] (“[Company]”/the “Company”) on combatting bribery and corruption. It was endorsed by the Board of Directors of the Company on (*) and applies to all subsidiaries in the group.

The policy consists of two Principles and a series of Practical Procedures to give effect to those Principles. The objective of the Policy is to clearly set out the Company’s ‘Zero Tolerance’ approach bribery and corruption.

The Principles

[Company] will not pay & will not accept bribes, either directly or via third parties, in any circumstances. Breaches or attempted breaches of this principle by an employee will be regarded as an act of gross misconduct.
[Company] will seek to encourage an equivalent policy in other business entities with which it has a significant business relationship.

Practical Procedures

Responsible Director
[Company] will at all times nominate a Director to be responsible for overseeing the application this anti-bribery and corruption policy and the Principles and Practical Procedures and for keeping a written risk assessment up to date.
The Director will be sufficiently senior to be fairly regarded as independently minded.
The first Director responsible for this role is l. In discharging this role he will report to l.
Training
Compulsory training will be provided to staff so that they are aware of this policy, relevant legislation and their obligations under the policy and their contract of employment.
Senior Management Information
Senior management will be kept informed of the steps to implement the Principles and the Practical Procedures, of the conclusions of any reviews and of any material findings arising out of the work of [Name].
Review
[Company] will monitor, review and at least annually report on the effectiveness of and adherence to its Principles, the Practical Procedures and the steps to implement them. The report will be submitted for approval by the Board of Directors.
Internal Record Keeping
[Company] will ensure that records are maintained of such reviews and the consequent reports to its senior management.
Communication
[Company] will communicate its Principles and Practical Procedures and its approach to their implementation to its employees and will publish this policy on its website and in its [Employee Handbook.] It will communicate it approach to their implementation to those that supply material goods & services to it both directly by correspondence but also by a clear statement on its website.
Employee Conduct
Employees are required to report any knowledge or suspicions of the offering, request for, receipt or payment of a bribe. A failure to do so may amount to gross misconduct.
No employee will suffer demotion, penalty or other adverse consequence for refusing to pay or accept a bribe even if such a refusal may result in [Company] losing business or failing to win a deal.
Whistleblowing
[Company] regards the reporting of any instance of bribery or attempted bribery as a legitimate example of ‘whistleblowing’ and affirms that no employee will suffer demotion, penalty, or other adverse consequences for reporting examples of or suspicions of the offer or request for or the receipt or payment of bribes.
Gifts Register
[Company] will continue to keep records of the gifts and corporate hospitality given and received by its staff. These records will be reviewed regularly.
Contractors and Associates
[Company] requires screening procedures to be carried out on those of its agents, advisers, contractors, intermediaries, and other representatives who supply material goods and services to it (“Associates”) to protect [Company] from the risk of it being associated with illegal or corrupt payments (or of payments purportedly being made on its behalf) and to ensure that the highest ethical standards are maintained.
[Company] requires that Associates are made aware of its Anti-Bribery Principles and Practical Procedures; to confirm that they will not make or receive any payment that put it in breach of those Principles and that such Associates have adequate procedures for preventing their own staff engaging in the receipt or payment of bribes, kickbacks etc.
Reporting
The report and accounts of [Company] and the Agenda for the Annual General Meeting will include a report on the workings and effectiveness of this policy including the number of reports of bribery and corruption received and a short summary of any investigations into them.

E&S Action Plan -– Statement to go on the [Company] website
Statement to go onto the [Company] Website

“Bribery and Corruption – our public statement
[Company] is committed to complying with all applicable laws and best corporate governance practices, wherever we operate. It is a core aspect of our mission to act with integrity in all of our operations. The Board of Directors of [Company] expects all employees to comply with both the letter and spirit of the law and governance codes.

[Company] affirms that will not pay or procure the payment of a bribe or unlawful fee to encourage the proper performance of a task or one which is intended or likely to compromise the integrity of another. We will not accept any payment, gift or inducement from a third party which is intended to compromise our own integrity.

[Company] has communicated this policy to all its employees, to ensure that its commitment to integrity and legal compliance is followed.

When contracting with a third party we will insist that they acknowledge our commitment to good governance and that they in turn require the same high standards of those they engage.

Any person who believes that [Company] or its staff are involved in bribery and corruption is encouraged to report their concerns to [Name to be agreed]”

Privacy Policy: Solarise Africa

By visiting Solarise Africa’s website, you are accepting the terms of this Privacy Policy.

This policy explains how we obtain, use and disclose your personal information, in accordance with the requirements of the Protection of Personal Information Act (“POPIA”).

At Solarise Africa (and including this website) we are committed to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully and transparently. Any questions regarding this policy should be directed by email to info@solariseafrica.com

Solarise Africa may be the Controller or Processor of your personal data provided to us by you or collected by us from you during your use of the website and/or applications, as outlined below. If you use the Solarise Africa service, you consent to this policy and the use/sharing of your personal data as described herein.  You have the choice to opt-out of sharing your data, as described below, and control how we use and share your data.

Links to other websites

Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.

Definition of personal information

According to the Act ‘‘personal information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person.  Further to the POPI Act, Solarise Africa also includes the following items as personal information:

- All addresses including residential, postal and email addresses.

- Change of name – for which we require copies of the marriage certificate or official change of name document issued by the state department.

The information we collect

We collect and process your personal information mainly to provide you with access to our services, to contact you for the purposes of understanding your requirements and to help us improve our offerings to you. We will only collect information that we need for the intended purpose.

We collect information directly from you where you provide us with your personal details.  Where possible, we will inform you what information you are required to provide to us and what information is optional.

Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

How we use your information

We will use your personal information only for the purposes for which it was collected and agreed with you.  In addition, where necessary your information may be retained for legal or research purposes. 

For example:

- To gather contact information;

- To confirm and verify your identity or to verify that you are an authorised user for security purposes;

- For the detection and prevention of fraud, crime, money laundering or other malpractice;

- To conduct market or customer satisfaction research or for statistical analysis;

- For audit and record keeping purposes;

- In connection with legal proceedings.

Personalised Content
We use personally identifiable information in order to give you a more enjoyable convenient shopping experience and to help us identify and/or provide information, products or services that may be off interest for you.

We may track your past purchases to provide you with a personalized profile of your shopping history. In addition, we may notify you about new services or special promotional programs, or send you offers or information.

Fulfilment of Services
We require this information to support and enhance your use of the Website and its features, including without limitation: fulfilling your order; providing customer service; tracking email invitations you send; billing clients and otherwise supporting your use of the Website. Solarise Africa is authorized to synthesize data provided by you, either on the Website or via the Facebook platform.

In connection with their performance of services to maintain and operate the Website and certain features on the Website, certain trusted third parties may be permitted to access your information. For example, we may use third parties to host the Website; operate various features available on the Website; send emails; analyse data; provide search results and links and assist in fulfilling your orders.

Mailing List
If you submit your email address to be added to our mailing list, we will use your email address for the sole purpose of sending you information, special offers and other partners along with website updates. Each email we send will contain information about how to unsubscribe from our mailing list. You can also unsubscribe by contacting us here.

Writing a Review
When you submit a review, you consent that Solarise Africa may post the said review on the Website. Should you wish to remove your review, please send an email to info@solariseafrica.com. If you elect to use our referral services for informing a friend about our website, we ask you for the friend’s name and email address. Solarise Africa will automatically send the friend a one-time email inviting them to visit the website. Solarise Africa stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. The friend may contact Solarise Africa at any time to request the removal of this information from our database.

Regular promotional offers and special discounts.
Our website’s registration form requires you to give us your contact information, financial information, and demographic information.

The contact information we collect will be used to contact you to query or complete a delivery where the recipient cannot be found, or if further information may be required. This information is also used to send you regular news about updates to our website, promotional offers, or special discounts. At any time, you may choose not to receive these notices; see the opt-out information.

Financial information that is collected is used to bill you for products and services. Demographic and profile data are also collected on our website and may be used to tailor your visitor’s experience at our website, we are also able to customise and display the content according to your preferences.

Your IP address is used to help identify you and your shopping cart. Our website also uses cookies to keep track of your shopping cart and use cookies to deliver content specific to your interests.

Online Surveys

We always strive to provide world-class customer service  and to ensure that our website and product range continues to meet your needs. In order to assist us with measuring how well we are achieving these goals we may from time to time ask for your feedback in the form of an online survey.

Our online surveys may ask for additional contact or demographic information as well as your preferences on certain topics/product categories.

Furthermore, we would ask for your thoughts and feelings about shopping with Solarise Africa. Data from our surveys may be used to tailor your visitor’s experience at our website, showing you content that we think you might be interested in, and displaying the content according to your preferences.

Contests

We occasionally run contests on our website in which we ask visitors for contact information and/or demographic. Such data will only be used to notify contest entrants of the winner and send further information about our products and services. You may opt-out of receiving future mailings at any time; see the opt-out section.

This website uses Google AdWords

This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our website. It could mean that we advertise to previous visitors who have not completed a task on our website, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a website in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Solarise Africa website. Of course, any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings.

Comments

When visitors leave comments on the site, we collect the data shown in the comments form, and the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Disclosure of information

We may disclose your personal information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with the privacy requirements as required by the Protection of Personal Information Act.

We may also disclose your information:

- Where we have a duty or a right to disclose in terms of law or industry codes.

- Where we believe it is necessary to protect our rights.

Information Security

We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure.

Our security policies and procedures cover:

- Physical security;

- Computer and network security;

- Access to personal information;

- Secure communications;

- Security in contracting out activities or functions;

- Retention and disposal of information;

- Acceptable usage of personal information;

- Governance and regulatory issues;

- Monitoring access and usage of private information;

- Investigating and reacting to security incidents.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.

We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

Your Rights: Access to information

You have the right to request a copy of the personal information we hold about you. To do this, simply contact us at info@solariseafrica.com and specify what information you require.  We will need a copy of your ID document to confirm your identity before providing details of your personal information.

Please note that any such access request may be subject to a payment of a legally allowable fee.   

Correction of your information

You have the right to ask us to update, correct or delete your personal information. We will require a copy of your ID document to confirm your identity before making changes to personal information we may hold about you. We would appreciate it if you would keep your personal information accurate.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights Solarise Africa have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

How to contact us

If you have any queries about this notice; you need further information about our privacy practices; wish to withdraw consent; exercise preferences or access or correct your personal information, please contact us at info@solariseafrica.com