Mangochip – Business Conduct and Ethics Policy

  1. INTRODUCTION
    1. Mangochip Limited (the “Company”, “we”, “us”, “our”) owns the rights to the website of the Hylo application whose domain is [link] (“Website”) and to its related mobile application (“App”) (together the “Platform”).
    2. The Company is committed to upholding the highest professional and ethical standard. The Company stands for core values, synergy and integrity and as such, we expect all users of the Platform to be directed by the same values in their judgement and behaviour.
    3. Through this Business Conduct and Ethics Policy (the “Policy”) the Company aims to put their values into practice. This Policy applies to all the Company’s customers, suppliers, couriers, partners and/or any other parties who have a direct and/or indirect relationship with the Company (together “Users”).
  2. DEFINITIONS AND INTERPRETATION
    1. The following definitions and rules of interpretation shall apply in this Policy:
      1. Applicable Law” means, from time to time, any law (including statutory, common or customary law), statute, constitution, decree, judgement, treaty, regulation, directive, by-law, order, other legislative measure, or any directive, requirement, request or guideline (whether or not having the force of law but, if not having the force of law, is generally complied with by the persons to whom it is addressed or applied) of any government, supranational, local government, statutory, regulatory, self-regulatory or similar body, authority or court, as amended, replaced, re-enacted, restated or reinterpreted;
      2. Cookie Policy” means the Company’s cookie policy available at [link];
      3. Data Protection Law” means all applicable Kenyan laws and regulations imposing an obligation in relation to the collection, use, disclosure, storage, publication or transmission of Personal Data, including the Data Protection Act No. 24 of 2019, Laws of Kenya;
      4. Mandatory Policies” means the Company’s Terms and Conditions, Privacy Policy, Cookie Policy, Refund Policy and this Policy;
      5. Parties” means all parties to this Policy and “Party” shall mean any one of them as the context may require;
      6. Personal Data” means any information provided by you to the Company (a) relating to an identified or identifiable natural person; (b) that can reasonably be used to identify or authenticate an individual, including name, contact information, precise location information, persistent identifiers; and (c) that may otherwise be considered “personal data” under applicable Kenyan law;
      7. Privacy Policy” means the Company’s privacy policy available at [link];
      8. Refund Policy” means the Company’s refund policy available at [link]; and
      9. Terms and Conditions” means the Company’s terms and conditions available at [link].
  3. COMPLIANCE WITH THE LAW
    1. Users are obligated to be aware of and comply with all Applicable Laws and Mandatory Policies relating to their access and use of the Platform.
  4. ANTI-CORRUPTION AND BRIBERY
    1. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
    2. A User shall not:
      1. give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
      2. accept any offer from a third party that they know or suspect is made with the expectation that a business advantage will be provided;
      3. give or offer any payment (sometimes referred to as a facilitation payment) to a government official to facilitate or speed up a routine or necessary procedure; or
      4. give or receive any payment, gift, hospitality or other benefit for any unlawful reason whatsoever.
    3. This Policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining the Company’s image or reputation or marketing of our products and services.
    4. If you are offered a bribe, or asked to make one, or if you suspect that any bribery, corruption or other breach of this Policy has occurred or may occur, you must contact us at [insert contact details] as soon as reasonably practicable.
  5. DISCRIMINATION
    1. The Company does not tolerate discrimination of any kind between Users. Such discrimination includes but is not limited to discrimination based on religion, race, sexual orientation, gender, sex, marital status, disabilities or any other characteristic protected under Applicable Law.
  6. ANTI-HARASSMENT AND BULLYING
    1. The Company is committed to providing a healthy Platform free from harassment and bullying and ensuring all Users are treated, and treat others, with dignity and respect.
    2. The Company does not tolerate any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment.
    3. Any offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened is strictly prohibited. Power does not only mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation.
  7. PRIVACY AND DATA PROTECTION
    1. The Company takes reasonable steps to protect your Personal Data. The terms and conditions of the Company’s Privacy Policy [link] will apply to the collection, use and processing of Users’ Personal Data.
    2. Users shall comply with all applicable Data Protection Laws in connection with their access and use of the Platform.
    3. Users recognise that any use, sharing or retention of Personal Data must be supported by, or based on, consent and strictly in accordance with the contractual terms and conditions entered into with the Company.
  8. ENFORCEMENT OF POLICY
    1. The Company may at any time request for documentation to confirm compliance with Mandatory Policies and Applicable Laws. Users must at all times maintain such documentation that demonstrates compliance with Mandatory Policies and Applicable Laws.
    2. If the Company believes that you are in breach of any of the terms of the Mandatory Policies or Applicable Laws, the Company may immediately, automatically and without notice to you, terminate your access to our Platform, and/or prohibit your future access to the Platform, and/or take appropriate legal action against you (including without limitation, applying for urgent and/or interim relief or claiming damages), without incurring any liability of any nature whatsoever and howsoever arising, and all of our rights in this regard are expressly reserved,
    3. The Company may temporarily restrict your access to the Platform if the Company is investigating any alleged breach of this Policy.
  9. CONTACT US
    1. The Company treats all allegations, concerns and complaints very seriously. Please contact us on [insert contact details] to report your issue.
    2. All reports must be made in good faith.