Anti-Bribery & Anti-Corruption Policy

A-flow has zero tolerance for bribery and corruption. This policy applies to A-flow Mining Supply Solutions, of 10 Miles, Chibombo, Lusaka Province, Zambia and to all employees, agents, carriers, suppliers, and intermediaries acting on its behalf.

We comply with the Anti-Corruption Act No. 3 of 2012 of Zambia and, because A-flow is a U.S.-based company, the U.S. Foreign Corrupt Practices Act (FCPA).

• Offering, promising, giving, requesting, or accepting anything of value to improperly influence any person, including public officials.
• Facilitation payments to speed up routine actions, including at border posts, weighbridges, checkpoints, and depots.
• Using carriers, clearing agents, or other intermediaries to make payments that A-flow could not make directly.

Fuel transport requires frequent contact with customs, police, and regulatory officials, including the Energy Regulation Board (ERB), the Zambia Environmental Management Agency (ZEMA), the Road Transport and Safety Agency (RTSA), and the Zambia Revenue Authority (ZRA). Drivers and agents must pay only official fees against an official receipt.

Any request for an unofficial payment must be refused and reported to A-flow immediately. The only exception is where a person faces an imminent threat to their safety; any such payment must be reported to A-flow the same day and recorded accurately.

• Gifts and hospitality must be modest, infrequent, transparent, and never intended to influence a decision.
• No gifts or hospitality may be given to public officials without prior written approval from A-flow management.
• A-flow does not make political contributions. Charitable and community contributions require written approval and are recorded.

Before engaging a carrier, supplier, or agent, A-flow verifies its registration, ownership, reputation, and licences, and requires contractual anti-corruption commitments.

Red flags — such as requests for cash, unusual commissions, or payments to unrelated third parties — are investigated before any engagement proceeds.

All payments must be recorded accurately with supporting documents. Off-book accounts and undocumented cash payments are prohibited.

Report concerns to compliance@aflowsolutions.com. Breaches may result in disciplinary action, termination of contracts, and referral to the competent authorities.