Anti-Bribery & Anti-Corruption Policy

Policy Statement

Woodcrest — Advocates, Tax & Advisory ("Woodcrest", "the Firm") is committed to conducting all of its professional and business activities with the highest standards of integrity, transparency, and ethical conduct. The Firm maintains a zero-tolerance policy towards bribery and corruption in any form.

This policy applies globally and without exception, regardless of local custom, competitive pressure, or business opportunity.

Scope

This policy applies to all partners, advocates, employees, consultants, agents, contractors, and any person acting on behalf of Woodcrest, whether in Uganda or elsewhere. It covers all forms of business activity undertaken on behalf of the Firm.

Prohibition

Woodcrest, its partners, advocates, employees, consultants, and agents are strictly prohibited from:

• Offering, promising, giving, or authorising any bribe, kickback, facilitation payment, or improper advantage to any person, including public officials, clients, or counterparties.
• Requesting, agreeing to receive, or accepting any bribe, kickback, or improper advantage from any person in connection with the Firm's business or any client matter.
• Taking any action, whether directly or through a third party, that would constitute bribery or corruption under applicable law.

Applicable Law

Woodcrest complies with all applicable anti-corruption laws, including:

• The Anti-Corruption Act, Cap. 154 (Laws of Uganda)
• The Penal Code Act, Cap. 120 (Laws of Uganda)
• The Leadership Code Act (Laws of Uganda)
• The United Nations Convention Against Corruption (UNCAC)
• All other applicable international anti-bribery standards and conventions

Gifts & Hospitality

No gift, entertainment, or hospitality shall be offered to or accepted from any client, counterparty, public official, or third party where it could reasonably be construed as an attempt to improperly influence a business relationship or professional decision.

Modest, proportionate, and transparent gifts or hospitality (such as branded stationery or modest professional lunches) given openly and in accordance with normal business courtesies may be acceptable, but must never be offered with the intention or expectation of receiving any business advantage in return.

Third Parties

Woodcrest requires that all third parties acting on its behalf — including agents, introducers, and subcontractors — comply with applicable anti-bribery laws. We conduct appropriate due diligence on third parties before engagement and include anti-bribery obligations in relevant contractual arrangements.

Reporting

Any person who suspects a breach of this policy, or who is offered or solicited for a bribe in connection with the Firm's affairs, is strongly encouraged to report the matter immediately to the Firm's managing partner or through the following contact:

All reports will be treated with strict confidentiality. Woodcrest does not tolerate retaliation against any person who makes a good-faith report under this policy.

Consequences

Violations of this policy will result in disciplinary action up to and including immediate termination of engagement or employment. Woodcrest reserves the right to report violations to the appropriate regulatory or law enforcement authorities, including the Inspectorate of Government (IGG) and the Uganda Police Force.

Contact