Ethics and Compliance

The standards we hold ourselves to are not a policy document. They are the foundation on which every client relationship, every engagement, and every decision is built.

ACAL operates in complex environments, governments, multilateral institutions, fragile regions, and communities where the stakes of poor practice are real and lasting. Our ethics and compliance framework reflects that responsibility. It applies to every member of our team, every associate consultant, and every partner who works alongside us.

The policies below are active commitments, not statements of intent.

Anti-Fraud Policy

ACAL takes a zero-tolerance approach to fraud in all its forms: the falsification of records, the misuse of assets, the abuse of position, and any conduct intended to deceive. Every member of our team, from directors to interns, carries personal responsibility for upholding financial honesty and reporting any breach they encounter. We maintain internal controls designed to prevent fraud before it occurs and to respond firmly when it is reported.

Anti-Bribery and Anti-Corruption Policy

ACAL conducts its business honestly and refuses to participate in bribery or corruption in any form - direct or indirect, facilitated through agents or third parties, or dressed as gifts, hospitality, or sponsorship. Our commitments are grounded in the Constitution of Kenya 2010, the Ethics and Anti-Corruption Commission Act 2011, and internationally recognised anti-bribery standards. No commercial outcome justifies a departure from these principles.

Child and Vulnerable Adults Safeguarding Policy

Many of ACAL's engagements bring us into contact with communities where children and vulnerable adults are present. We take our safeguarding obligations seriously. Physical, sexual, emotional, financial, and institutional abuse are never acceptable, and every member of our team is expected to recognise the indicators of harm and to report concerns immediately. We cooperate fully with statutory authorities whenever official investigations are required.

Duty of Care Policy

ACAL's work regularly takes consultants into fragile and conflict-affected environments. We treat the safety of our people as a non-negotiable obligation. Before any engagement begins in a high-risk context, we conduct a risk assessment and put in place the precautions, protocols, and support structures required to manage that risk to an acceptable level. This applies whether ACAL is leading an engagement or working as a sub-contractor, the duty of care does not transfer with the contract structure.

Modern Slavery and Human Trafficking Policy

Modern slavery is a crime. ACAL has zero tolerance for forced labour, servitude, or human trafficking in any part of our business or supply chain. We conduct due diligence on our value chains and take steps to identify and mitigate risk wherever it arises. Our commitments are grounded in Article 30 of the Constitution of Kenya 2010, which prohibits slavery, servitude, and forced labour without qualification.

Quality Policy Statement

ACAL is committed to delivering advisory services that consistently meet the requirements of our clients and the standards of our profession. Our Quality Management System is built around the requirements of ISO 9001 and reviewed annually by senior leadership. We invest in our people, maintain strong internal administration, and pursue continual improvement across every function of the firm. Quality is not a compliance requirement for ACAL, it is the measure by which we hold our own work to account.

Whistleblowing Policy

Any member of ACAL's team, or any external party dealing with us, who discovers evidence of wrongdoing should be able to report it without fear. ACAL provides multiple channels for raising concerns about fraud, corruption, bribery, criminal conduct, or health and safety risks. Reports are handled confidentially, fairly, and without reprisal. We do not tolerate harassment of any individual who raises a genuine concern, and we do not allow the confidentiality of any process to become a barrier to accountability.

ACAL's full policy documents are available on request. For compliance enquiries, contact: info@acalconsulting.co.ke