Anti Bribery and Corruption Policy and Commitment Statement

Last updated: September 2026

ARUSi prohibits bribery and corruption in every form. We will win work, obtain approvals, select participants and suppliers, manage public and partner funds, and make programme decisions fairly and transparently.

1. Who and what this covers

This policy applies to directors, employees, instructors, volunteers, consultants, agents, contractors and any person acting for ARUSi. It covers dealings with learners, licensing and regulatory bodies, national and county governments, schools, police and road authorities, donors, sponsors, partners, fleet operators, suppliers and communities.

2. Prohibited conduct

No person may directly or indirectly offer, promise, give, request, agree to receive or accept money, a gift, favour, job, donation, hospitality, discount, confidential advantage or anything else of value to influence a decision improperly or reward improper performance.
Facilitation payments are prohibited, including unofficial payments intended to speed up licensing, inspection, registration, procurement, payment or another routine action. An immediate payment made under a credible threat to health or safety must be reported as soon as it is safe to do so and accurately recorded.
Kickbacks, secret commissions, false invoices, inflated claims, diversion of programme resources, bid manipulation, favouritism in return for a benefit, and the use of third parties to do what ARUSi prohibits are forbidden.
Political or charitable contributions may not be used to obtain an improper advantage. Corporate political contributions require lawful authority and governing-body approval; ARUSi personnel must not use ARUSi resources for personal political activity.

3. Gifts hospitality and conflicts

Gifts and hospitality must be lawful, modest, infrequent, transparent and connected to a legitimate business purpose. Cash and cash equivalents are never acceptable. A benefit must be declined where it could influence, or appear reasonably likely to influence, a tender, licensing decision, assessment, recruitment, sponsorship or other official action. Actual, potential and perceived conflicts of interest must be disclosed before the person participates in the decision. Management will record and manage material disclosures.

4. Risk controls

ARUSi will assess bribery risks in higher-risk activities such as permits and licensing, public-sector engagement, procurement, cash collections, sponsorship, learner assessment, selection of beneficiaries, use of agents and delivery in new locations.
Risk-based checks will confirm the identity, ownership, competence, reputation, conflicts and intended role of relevant partners, agents and suppliers before appointment. Contracts will define services, reasonable payment, record-keeping, audit and termination rights, and compliance expectations.
Payments must match approved work and reliable supporting evidence, pass the required approval steps and be recorded accurately. No undisclosed account, misleading description or false record is permitted.

5. Speak up and response

Anyone may report a concern in good faith to a supervisor, a member of management or legal@arusi.ke with the subject Confidential integrity concern. Reports may also be made to the Ethics and Anti-Corruption Commission or another competent authority. ARUSi will protect confidentiality as far as law and a fair investigation permit and prohibits retaliation. Concerns will be assessed promptly, evidence preserved, conflicts managed and findings escalated. Confirmed misconduct may lead to discipline, termination, recovery, contract action and referral to authorities.

6. Governance

The governing body oversees the anti-bribery programme. Management must implement proportionate procedures, communicate them, train relevant personnel, review gifts and conflicts, investigate concerns and improve controls. Every person within scope must refuse improper requests and report suspected breaches. This policy supports ARUSi's obligations under the Anti-Bribery Act and related Kenyan anti-corruption law.

7. Applicable Kenyan Law

This policy is governed by the laws of the Republic of Kenya and will be interpreted consistently with all mandatory legal and regulatory requirements that apply to ARUSi. Relevant references include:

If this policy conflicts with a mandatory legal requirement, that requirement will prevail and ARUSi will update the policy as necessary.

8. Contact Us

If you have questions about this policy or wish to report a concern, please contact us:

Email: legal@arusi.ke
Address: P.O. Box 64469-00620, Nairobi, Kenya
Phone: +254 709 700 500