Policies

How we govern and safeguard our practices

How we govern and safeguard our practices

Our policies set out the principles and standards that guide how we operate, make decisions and engage with our employees, partners and wider stakeholders. They help us maintain a culture of integrity, accountability and responsible business practice.

Our policies set out the principles and standards that guide how we operate, make decisions and engage with our employees, partners and wider stakeholders. They help us maintain a culture of integrity, accountability and responsible business practice.

Code of Conduct Policy

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Our Commitment

At Dhamana Guarantee, we conduct business with integrity, transparency, and respect for people and the planet. Our decisions are guided by our I-SPIC values — Integrity, Sustainability, People-Centricity, Innovation, and Courage.

We expect all employees, board members, contractors, suppliers, and any third parties representing or working with us to uphold this Code and comply with applicable laws. Together, we protect the trust that clients, partners, and communities place in us.


Our Values in Action (I-SPIC)

  • Integrity — We do the right thing, even when no one is watching.

  • Sustainability — We manage resources responsibly and support long-term value creation.

  • People-Centric — We treat everyone with dignity and foster inclusion.

  • Innovation — We seek better ways to solve problems.

  • Courage — We take principled stands and challenge the status quo.


Our Standards (Elements of the Code)

  1. Compliance with the Law (5.1)

We follow all applicable laws, regulations, and internal policies wherever we operate. When rules differ, we apply the stricter standard.

  1. Zero-Tolerance for Corruption & Bribery (5.2)

We prohibit bribery, kickbacks, facilitation payments, and any improper advantage — directly or through third parties. We only do business transparently and on merit.

  1. Gifts, Hospitality & Entertainment (5.3)

We avoid anything that could create undue influence or the appearance of impropriety. Modest, proportionate courtesies may be acceptable where lawful and properly recorded.

  1. Accurate Books, Records & Internal Controls (5.4)

We keep complete, timely, and accurate records in line with applicable standards. No undisclosed funds, off-book accounts, or misleading entries.

  1. Conflicts of Interest (5.5)

We act in Dhamana’s best interests and disclose any personal, financial, or relational interests that could affect objectivity — in advance and in writing.

  1. Economic Crimes & AML/Sanctions (5.6)

We prevent money laundering, fraud, and other economic crimes, and comply with sanctions and trade controls. We conduct due diligence and refuse suspicious transactions.

  1. Privacy & Data Protection (5.7)

We lawfully collect, use, and protect personal data with appropriate technical and organisational safeguards, and only for legitimate purposes.

  1. Human Rights (5.8)

We respect and promote human rights, equal opportunity, and non-discrimination. Harassment, bullying, or abuse of any kind is not tolerated.

  1. Stewardship of Company Assets (5.9)

We safeguard company property, funds, information, and intellectual property; use them for legitimate business purposes; and prevent loss, misuse, or theft.

  1. ESG Commitment (5.10)

We integrate environmental, social, and governance considerations into decisions. We aim to minimise environmental impact and uphold robust governance.

  1. Health & Safety (5.11)

We provide and maintain a safe and healthy workplace, follow safety procedures, and act promptly on hazards or incidents.


Fair Partner & Supplier Relationships

We choose partners who share our commitment to ethical conduct, human rights, safety, and sustainability.
All suppliers, contractors, agents, and service providers are expected to uphold this Code (or equivalent standards) and comply with the law. We review concerns and may take corrective action, up to and including ending the relationship.

Speaking Up (Whistleblowing & Non-Retaliation)

We encourage employees and external stakeholders to report suspected violations in good faith through our confidential channels as set out in our Whistleblowing Policy. We investigate concerns fairly and prohibit retaliation against anyone who speaks up.

Dhamana Guarantee Company Limited
6th Floor Sanlam Tower
Waiyaki Way
Nairobi
Kenya

© 2026 Dhamana Guarantee Company Limited.

All rights reserved.

Dhamana Guarantee Company Limited
6th Floor Sanlam Tower
Waiyaki Way
Nairobi
Kenya

© 2026 Dhamana Guarantee Company Limited.

All rights reserved.

Dhamana Guarantee Company Limited
6th Floor Sanlam Tower
Waiyaki Way
Nairobi
Kenya

© 2026 Dhamana Guarantee Company Limited.

All rights reserved.