Company Policies

CORPORATE, SOCIAL AND ENVIRONMENTAL RESPONSIBILITY (CSR)

HFV has developed a close relationship between with local villagers with tangible results of HFV delivering on its CSR obligations, even this early in its engagement with the local community. HFV’s corporate policy is to help improve the lives of the community by building and developing infrastructure such as schools, crèche, shops, sports amenities, clinics and hospitals. In addition, training will be provided to those employed in the project to become future workers and staff of the project. HFV has committed to a benefit sharing agreement for the Revenues derived from the project for the community.

HFV has already initiated its CSR activities by constructing a deep water well and recently completed the construction of a primary school at the project site, for the children of the Maserie village in Sierra Leone.

STATEMENT OF BUSINESS ETHICS and ANTI-CORRUPTION POLICY

HFV is committed to the promotion of high standards of ethical conduct in its business activities. We ensure that our partners are fully informed of the rules, regulations and compliance issues that apply to the work we undertake. In particular, we apply this knowledge to the conduct of our business within the framework of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (1999) and the Bribery Act 2010. All staff, Partners and anyone else working on behalf of HFV are required to comply with our ethical policies and procedures. We expect our partner organisations to share our values and ethical standards. HFV will aim to ensure that all statements, communications and representations made to prospective clients in project proposals and bid preparations are accurate and truthful.

HFV will not pay bribes or try to influence improperly decisions about awards of projects, nor will HFV condone such behaviour in others. We will avoid any conflicts of interest and will inform partners/stakeholders/investors beforehand of any potential conflict of interest that could arise during the work we perform.

HFV will only undertake opportunities in our areas of expertise, where we can deliver efficient, effective and high quality services to our clients. We will act with loyalty to our clients, and respect the confidentiality of proprietary information that we acquire from partners and clients during the course of our normal business activities. We will also carry out due diligence on partner organisations.

Brochures and other formal documents will reflect HFV’s experience and track record accurately. We will maintain accurate and complete company records. All transactions between HFV and outside individuals and organisations will be promptly and accurately entered in our books in accordancewith generally accepted accounting practices and principles.We will not take part in any activities that could damage HFV’s reputation or that of partner organisations.

Policy

In order to comply with the provisions of the Bribery Act 2010, HFV prohibits all staff and anyone else working on behalf of HFV from:

Offering, giving, soliciting or accepting any bribe, whether cash or other inducement, to or from any person or company, in order to gain any commercial, contractual or regulatory advantage for HFV or anyone connected to HFV in a way which is unethical or in order to gain any personal advantage.

Any such payment or inducement may result in immediate dismissal for those involved in their payment or receipt.

This policy allows the following practices providing they are customary in a particular market, or are proportionate and are properly recorded:

Normal and appropriate hospitality (given or received);

The giving of an appropriate gift at a festival, ceremony or at another special time;

The use of any recognised fast-track process which is available to all on payment of a fee. HFV recognises that market practice varies across those countries in which we do business and what is normal and acceptable in one place may not be in another.

HFV also appreciates that to refuse a gift in certain circumstances and/or countries would cause offence to our partners. The test to be applied in all circumstances is whether the gift or entertainment is reasonable and justifiable. What is the intention of the gift? Special care must be taken in accepting or giving gifts and/or entertainment, particularly from or to a public official and these are not permitted if it would create a real or perceived conflict of interest.

HFV will keep financial records and have appropriate internal controls in place which will provide evidence of the business reason for making any payments to third parties. The prevention, detection and reporting of bribery and corruption is the responsibility of all staff and anyone else working on behalf of HFV. Any suspicion of bribery can be reported confidentially to one of the Directors of HFV. If anyone is in doubt as to whether a potential act constitutes bribery/corruption, the matter should be referred to one of HFV’s Directors.

Training will be given to all members of staff on how to recognise and avoid bribery.

The Directors are responsible for carrying out regular risk assessments and for implementing and monitoring this policy which will be reviewed annually.