01
Anti-Bribery & Corruption
Top Notch maintains an absolute prohibition on bribery and corruption in any form, whether direct or indirect, domestic or international.
No payment, gift, loan, or benefit of any kind may be offered, promised, or given to any public official, client representative, or third party for the purpose of obtaining or retaining business or a procurement advantage.
Note
Any staff member or agent found to have breached this policy will face immediate termination and referral to the relevant law enforcement authorities.
Gifts and hospitality above KES 5,000 (approximately $38 USD) in value must be declared to the Ethics Officer and recorded in the gifts register regardless of whether they are given or received.
- Gifts of cash or cash equivalents are prohibited in all circumstances
- Hospitality must be proportionate, transparent, and directly connected to a legitimate business activity
- Gifts to or from public officials require prior written approval from the Compliance Officer
- All declared gifts are reviewed quarterly by the Ethics Sub-Committee
All advisory staff, board members, and agents must declare any actual, potential, or perceived conflict of interest before accepting an engagement and whenever a new conflict arises during an ongoing engagement.
You are responsible for safeguarding your password and for activities that occur under your account.
Mandatory
Failure to declare a known conflict of interest constitutes a serious disciplinary offence and may result in termination and restitution of fees earned.
Top Notch staff may not share confidential bid information between competing tenderers, advise a bidder on another bidder's pricing, or influence evaluation criteria in favour of a preferred contractor.
Evaluation reports are prepared independently by designated staff who have signed recusal declarations confirming no conflict with any shortlisted contractor.
Note
Evaluation committee members are rotated per procurement to prevent familiarity bias.
Attempting unauthorized access or interference
Publishing harmful, unlawful, or misleading content
Systematic extraction or scraping of data
Using the service in a way that violates law or policy
All contractors, agents, and significant subcontractors introduced via the Top Notch platform are screened before engagement against OFAC, EU, and UN sanctions lists, PEP registers, and international adverse media databases.
Screening databases used:
- OFAC SDN List (US Treasury)
- EU Consolidated Sanctions List
- UN Security Council Sanctions
- World Bank Debarment List
- OECD Bribery Cases Database
- International adverse media (Refinitiv)
06
Whistleblower Protection
Any individual — staff, contractor, client, or third party — who reports an ethics concern in good faith is protected from retaliation in any form.
Reports may be made anonymously via the independent whistleblower portal. All reports are investigated within 21 days and a outcome summary provided to the reporter where identification has been provided.
Note
Retaliation against a whistleblower is itself a serious disciplinary offence under this policy.
You agree to defend, indemnify, and hold us harmless from claims and expenses arising from your use of the service or your breach of these terms.
We may suspend or terminate access at any time if we believe these terms have been violated or if continued access creates risk.
These terms are governed by the laws of the applicable jurisdiction and will be interpreted accordingly.
10
Changes to These Terms
We may update these terms from time to time. The revised version will replace the prior version once posted.
Your continued use of the service means you accept the updated terms.
Note
Please review this page regularly to stay informed about revisions.
