Code of Ethics

Introduction

At Global Investments for Africa (GIA), we are committed to conducting our business with the highest standards of integrity, professionalism, and ethical behavior. This Code of Ethics (the “Code”) establishes the principles, standards, and expectations that guide our employees, executives, consultants, and partners in making ethical decisions and fostering a culture of trust, accountability, and respect.

Our commitment to ethics is central to our mission of providing exceptional investment services, innovative solutions, and sustainable value to our clients, partners, employees, and communities. Every individual associated with GIA is expected to uphold this Code and contribute to a culture of ethical excellence.

1. Core Principles

1.1 Integrity and Honesty

  • Act with honesty, transparency, and fairness in all dealings.
  • Avoid misrepresentation, exaggeration, or withholding critical information in business communications or reporting.
  • Ensure accuracy in financial reporting, disclosures, and any public statements.

1.2 Respect and Dignity

  • Treat colleagues, clients, partners, and communities with respect, dignity, and fairness.
  • Promote a workplace free from harassment, discrimination, or intimidation.
  • Recognize and value diverse perspectives, experiences, and contributions.

1.3 Accountability

  • Take responsibility for decisions, actions, and their consequences.
  • Report any unethical behavior, violations of law, or breaches of this Code promptly and through appropriate channels.
  • Cooperate fully in investigations related to ethics, compliance, or misconduct.

1.4 Compliance with Laws and Regulations

  • Comply with all applicable national and international laws, regulations, and industry standards.
  • Ensure adherence to anti-corruption, anti-bribery, anti-money laundering, and fair competition laws.
  • Respect trade sanctions, embargoes, and restrictions in international business operations.

1.5 Professionalism

  • Conduct business with competence, diligence, and professionalism.
  • Avoid conflicts of interest that may compromise independent judgment or impartiality.
  • Maintain confidentiality of sensitive information obtained in the course of work.

2. Ethical Business Practices

2.1 Anti-Corruption and Anti-Bribery

  • Prohibit offering, giving, receiving, or soliciting bribes, kickbacks, or other improper payments.
  • Maintain accurate books and records to reflect all transactions transparently.
  • Avoid facilitating payments intended to influence decisions unfairly.

2.2 Conflicts of Interest

  • Disclose any personal or financial interests that may conflict with professional responsibilities.
  • Refrain from using GIA resources, information, or influence for personal gain.
  • Avoid business relationships or investments that compromise impartiality or integrity.

2.3 Fair Competition and Antitrust

  • Conduct business fairly, ethically, and in compliance with competition laws.
  • Avoid agreements, understandings, or practices that may restrain trade or create unfair advantages.
  • Compete on the basis of merit, innovation, and quality of services.

2.4 Accurate Reporting and Record-Keeping

  • Ensure financial, operational, and client records are complete, accurate, and timely.
  • Prohibit falsification, concealment, or manipulation of data for any reason.
  • Protect the integrity of internal and external reporting mechanisms.

3. Workplace Ethics

3.1 Diversity, Equity & Inclusion

  • Foster a workplace that values diversity, equity, and inclusion in all aspects.
  • Promote equal opportunity in hiring, development, promotion, and recognition.
  • Create an environment where all employees feel valued, empowered, and supported.

3.2 Health, Safety, and Environment

  • Ensure a safe and healthy work environment for all employees, contractors, and visitors.
  • Comply with occupational health and safety regulations and environmental standards.
  • Promote sustainability, energy efficiency, and responsible resource management.

3.3 Professional Development

  • Encourage continuous learning, skills development, and ethical decision-making.
  • Support mentoring, coaching, and knowledge-sharing within the organization.
  • Recognize and reward ethical behavior and professional excellence.

4. Confidentiality and Data Protection

4.1 Confidential Information

  • Protect proprietary, sensitive, and client information from unauthorized disclosure.
  • Use confidential information only for legitimate business purposes.
  • Respect intellectual property rights of GIA and third parties.

4.2 Data Privacy and Security

  • Adhere to applicable data protection laws and internal privacy policies.
  • Implement robust measures to secure personal, financial, and operational data.
  • Immediately report any suspected data breaches or unauthorized access.

5. Social Responsibility

5.1 Community Engagement

  • Support initiatives that benefit local communities, education, and social development.
  • Ensure that all philanthropic or social projects align with GIA’s mission and ethical standards.

5.2 Anti-Forced Labor and Human Rights

  • Prohibit forced labor, child labor, and human trafficking in any aspect of operations.
  • Respect the human rights and dignity of all employees, clients, and stakeholders.
  • Conduct supplier and partner due diligence to ensure compliance with human rights standards.

5.3 Environmental Stewardship

  • Minimize environmental impact through sustainable practices.
  • Promote recycling, resource efficiency, and environmentally responsible procurement.

6. Reporting, Compliance, and Enforcement

6.1 Reporting Misconduct

  • Employees and stakeholders are encouraged to report violations of this Code or any unethical behavior.
  • Reports can be made through designated channels, including anonymous reporting mechanisms.
  • GIA prohibits retaliation against anyone reporting concerns in good faith.

6.2 Investigations and Accountability

  • All reported violations will be investigated promptly, fairly, and confidentially.
  • Appropriate disciplinary action will be taken for confirmed violations, up to and including termination.
  • Compliance with this Code is a condition of employment and engagement with GIA.

6.3 Training and Awareness

  • Employees will receive regular training on ethics, compliance, and responsible business practices.
  • Leadership is responsible for reinforcing ethical behavior and modeling integrity.

7. Implementation and Oversight

  • The Board of Directors and senior management oversee adherence to this Code.
  • Ethics and compliance officers are responsible for monitoring, guidance, and enforcement.
  • The Code will be reviewed periodically to ensure relevance, effectiveness, and alignment with best practices.

Acknowledgment

All employees, contractors, consultants, and partners of GIA are required to read, understand, and acknowledge this Code of Ethics. By doing so, they commit to uphold its principles and promote an ethical, responsible, and inclusive culture within the organization.