Zero tolerance.
Nexus asserts its absolute opposition to any form of corruption, influence-peddling, favoritism, embezzlement, misuse of corporate assets, unlawful taking of interests or money laundering. This commitment is an integral part of our corporate culture and conditions every decision we take.
Corruption is a crime. It distorts competition, impoverishes economies, undermines citizens' trust in their institutions and slows Africa's development. As a Pan-African fintech actor, Nexus categorically refuses to participate in it, directly or indirectly.
International legal framework.
Our framework is aligned with the most demanding international standards:
- Sapin II Law (France, 2016) — Law n° 2016-1691 on transparency, combating corruption and modernizing economic life
- UK Bribery Act (United Kingdom, 2010) — extraterritorial reach
- FCPA — Foreign Corrupt Practices Act (United States, 1977) — extraterritorial reach
- Merida Convention — United Nations Convention against Corruption (2003)
- OECD Convention — Convention on Combating Bribery of Foreign Public Officials (1997)
- African Union Convention — Convention on Preventing and Combating Corruption (2003)
- Local laws — national anti-corruption legislation in the countries where Nexus operates
Scope.
This policy applies without exception to:
- All Nexus employees (staff, directors, board members, interns, temporary workers)
- All subsidiaries and investments of the Nexus group
- All subcontractors and consultants acting on behalf of Nexus
- All business partners — agents, distributors, business introducers, integrators
- Any third party engaged in a business relationship with Nexus, including on an occasional basis
Definitions.
Corruption
Offering, promising, granting, soliciting or accepting an undue advantage (financial or otherwise) in exchange for an act or omission.
Active corruption
A person offering an undue advantage.
Passive corruption
A person accepting or soliciting an undue advantage.
Influence-peddling
Trading on one's influence, real or supposed, with an authority or administration.
Facilitation payment
Small informal payments made to public officials to accelerate or secure a routine administrative procedure. Strictly prohibited at Nexus, even when tolerated by certain local laws.
Undue advantage
Any benefit (money, gift, service, opportunity, trip, meal, loan, employment, etc.) that is not legitimately owed to the beneficiary.
Areas of application.
Gifts and invitations.
Nexus acknowledges that some gifts or invitations may fall within normal professional practice. They are nonetheless strictly framed:
| Type | Threshold per year | Procedure |
|---|---|---|
| Courtesy gift (diary, promotional item) | ≤ 30,000 XAF (≈ €50) | No formality |
| Professional gift or meal | Between 30,000 and 150,000 XAF | Internal register |
| Event invitation | Between 150,000 and 500,000 XAF | Manager + Ethics Officer approval |
| Beyond | — | Prohibited without MLRO and executive validation |
Absolute rule: no gift, invitation or advantage may be offered or received in the context of an imminent or ongoing decision (contract signing, market award, regulatory decision). When in doubt, refuse.
Conflicts of interest.
A conflict of interest arises when an employee's personal interests conflict with those of Nexus. Everyone is required to:
- Declare without delay any situation that may constitute a conflict (family ties, shareholdings, parallel activities).
- Recuse from any relevant decision, delegating to an unaffected colleague.
- Document the situation in the conflict-of-interest register maintained by the Ethics Officer.
Third-party due diligence.
Any third party acting for or representing Nexus is subject to preliminary risk-based evaluation:
- Screening against sanctions lists, PEP databases, corruption convictions.
- Compliance questionnaire signed, with beneficial owners declared.
- Enhanced due diligence for agents, distributors and business introducers.
- Anti-corruption clause systematically included in all contracts.
- Periodic review of high-risk third parties (every 12 to 24 months).
- Contract termination upon serious indication of non-compliance.
Accounting and financial controls.
All payments made by Nexus are subject to rigorous controls to ensure traceability and justification:
- Segregation of duties — no payment can be initiated, approved and executed by the same person.
- Dual signature — mandatory above certain thresholds.
- Supporting documents — invoice, purchase order and contract attached to every payment.
- No slush funds — every transaction appears in official accounting.
- Annual review by independent statutory auditors.
- Internal audit — periodic thematic reviews on at-risk expense categories.
Whistleblowing system.
Nexus has set up a professional alert system enabling any employee or third party to report, in good faith, any behavior contrary to the law or to this policy.
Available channels
- Secure email: ethics@nexus.com
- Independent third-party platform: accessible via the intranet (anonymity guaranteed)
- Postal mail: Ethics Officer — Nexus SA, PO Box XXXX, Douala, Cameroon
- Escalation: possibility to refer sensitive cases directly to the Chairman of the Board
Protections for whistleblowers
- Absolute confidentiality of the whistleblower's identity and of persons mentioned.
- Protection against any form of retaliation: no disciplinary sanction, removal, discrimination or pressure may be applied to a good-faith whistleblower.
- Anonymity available via the third-party platform.
- Legal and psychological support if necessary.
- Acknowledgment within 7 days, case handling within 3 months.
Good-faith reporting. Any whistleblower acting in good faith benefits from the maximum protection offered by Sapin II, EU Directive 2019/1937 and equivalent local laws. Fraudulent or malicious reports may on the contrary be subject to sanctions.
Disciplinary sanctions.
Any violation of this policy, whether intentional or not, triggers an immediate and proportionate response:
- For employees: graduated disciplinary sanctions up to dismissal for gross misconduct, without prejudice to criminal proceedings.
- For partners and third parties: unilateral contract termination without notice, reporting to competent authorities, damages claims.
- For directors: identical sanctions, with dismissal procedure by the Board of Directors.
Nexus reserves the right to report to judicial authorities any fact that may constitute a criminal offense, in accordance with its legal obligations.
Anti-corruption training.
Awareness and training are essential pillars of our framework:
- Onboarding training — mandatory for every new hire, validated by assessment.
- Annual training — refresher for all staff, e-learning format + case studies.
- Targeted training — specific modules for exposed functions (sales, procurement, finance, compliance, executive).
- Partner training — awareness kit shared with distributors and integrators.
- Internal communication — quarterly briefings, real cases, feedback.
Governance of the framework.
The fight against corruption is championed at the highest level of the company:
- Ethics & Anti-Corruption Officer — reports to the CCO, operationally responsible for the framework.
- Ethics Committee — examines complex cases, rules on reports, decides on corrective measures.
- Board of Directors — approves the policy, receives quarterly reporting.
- Risk mapping — annual revision of the corruption risk map, by function and country.
- Internal control — periodic procedure testing by internal audit.
- External audit — biennial review by specialized independent firm.
Ethics contact and reporting.
Ethics & Anti-Corruption Officer — Nexus
Email: ethics@nexus.com
Reporting platform (anonymous): accessible from the intranet
Mail: Ethics Officer — Nexus SA, PO Box XXXX, Douala, Cameroon
Also see our AML/CFT Policy and our Personal Data Protection Policy for a complete view of our compliance framework.