Code of Business Conduct and Ethics


M-Pesa is committed to high ethical standards in all our activities and in compliance with applicable laws and regulations. M-Pesa's integrity is one of our most important assets and M-Pesa expects all employees to safeguard and protect that integrity. All M-Pesa employees must conduct business in an ethical and legal manner whether dealing with customers, vendors, distributors, or each other. In order to promote an ethical culture and a commitment to compliance with the law, this Code of Business Conduct and Ethics (the "Code") is designed to help employees understand their responsibilities to uphold the highest standards of business.

All M-Pesa officers, managers, employees, and any other contractor, consultant or person acting in the name of M-Pesa and its sister companies are expected to comply with our ethical obligations. The following standards of conduct will be enforced at all organizational levels. Any employee who violates, or fails to report a violation of these standards will be subject to disciplinary action, up to and including separation. Acts constituting criminal conduct may also subject the perpetrator to fines and imprisonment.

This Code supplements other M-Pesa policies and procedures, including the M-Pesa Employee Handbook and core competencies. This Code does not replace existing policies and procedures.


M-Pesa encourages its employees to provide information that may assist M-Pesa in investigating and correcting any ethical or legal violations that may occur. M-Pesa also has a strict non-retaliation policy. No form of retaliation will be tolerated for reports made in good-faith.

If M-Pesa employees are aware of a possible violation of this Code or principles, policies, or any other legal or regulatory requirements they must notify their supervisor (if the supervisor is not involved), Human Resources, or Corporate Management. This notification may be done in person, by phone, via email (to or via the M-Pesa website (contact us section). All reports are confidential and information will be shared on a need to know basis. Reports can also be made anonymously in compliance with local law. M-Pesa may have an obligation to investigate and, in some situations, report to appropriate governmental authorities whenever M-Pesa has reasonable grounds to believe that there has been a 1) violation of criminal law involving fraud, conflict of interest, bribery, or gratuity violations; 2) violation of the civil False Claims Act (31 U.S.C. 3729-3733); or 3) a violation of U.S. export control regulations.

Employees are protected by law under whistleblower protection provisions if they report gross mismanagement, gross waste, public safety issues, abuse of authority, or violation of law in the implementation or use of stimulus funds pursuant to section 1553 of the American Recovery and Reinvestment Act of 2009 (Pub.L. 111-5). M-Pesa may not discharge, demote, or otherwise discriminate against employees as reprisal for making such reports.

M-Pesa's Human Resources Organization has been designated with responsibility for overseeing and monitoring compliance with this Code. The Human Resources Department will make periodic reports to M-Pesa's Corporate Management for this purpose regarding the implementation and effectiveness of this Code.


During employment with M-Pesa, employees may have access to intellectual property and confidential information relating to M-Pesa, M-Pesa's employees, and its customers. All employees must protect M-Pesa and its customers' proprietary and confidential information from improper disclosure. M-Pesa employees must never accept confidential information from another person or company, or sign a confidentiality agreement in favor of someone else, without proper internal authorization.

All M-Pesa employees sign a "Trade Secrets, Proprietary Information, and Inventions Agreement" which, along with various laws, gives M-Pesa ownership of work developed by employees in the scope of their employment. M-Pesa employees are obligated to cooperate with M-Pesa to obtain intellectual property rights as may be necessary to protect M-Pesa's rights in the work product.

M-Pesa requires all software, data, images, or other third party-owned materials installed on its computer equipment and mobile devices to be properly licensed. To ensure the compliance of all employees with M-Pesa's copyright policy, all obligations imposed by the vendors of software, data, images, or other third party-owned materials and by law must be adhered to at all times.


M-Pesa is committed to maintaining accurate and timely financial records. M-Pesa's record keeping procedures are essential to ensure that all costs are properly charged and allocated. It is critical to M-Pesa, that all financial and non- financial data be accurate, complete and valid in all material respects.

Every employee is expected to complete their electronic time card promptly and accurately, in accordance with the time charging guidelines. Similarly all check requests, travel expenses and other costs must be accurately coded to the proper expense accounts.


M-Pesa is committed to providing a safe and productive work environment that is free from all forms of sexual or other illegal harassment, violence, or illegal discrimination. All employees and non-employees in a business relationship with M-Pesa must comply with this policy. Further, M-Pesa employees may not perform work while impaired due to drugs or alcohol, and must comply with the M-Pesa drug free workplace policy. M-Pesa is a weapons-free work site. Please refer to the Employee Responsibilities section of the Employee Handbook for additional details.

M-Pesa prohibits the use of forced or involuntary labor, including all forms of child labor, human trafficking, and slavery. The Company is committed to preventing these practices in its supply chain and it expects suppliers to do the same.


M-Pesa complies with Equal Employment Opportunity laws and does not discriminate on the basis of race, color, national origin, sex, age, disability, creed, religion, sexual orientation, or veteran status in treatment or employment. M-Pesa also makes reasonable accommodations for people with disabilities. Please reference the Equal Employment Opportunity Policy.


M-Pesa discourages employees from engaging in any activity that is, or may appear to be, a conflict of interest with the employee's duties at M-Pesa. Every employee is expected to avoid circumstances where personal or family interests actually or potentially conflict with the interests of M-Pesa. Employees must declare in writing to Human Resources any hires of relatives or close associates, in addition to any financial interests employee or employee's relatives or close associates have in any competitors, customers, or suppliers to M-Pesa. Employees elected or appointed to public office, or to external boards with organizations related to or affiliated with M-Pesa competitors, customers, suppliers, or partners must also disclose these positions to Human Resources.


All dealings with customers and potential customers must be legal, fair, and open. M-Pesa does not tolerate bribery or corruption. M-Pesa employees may never accept or solicit bribes, improper payments, gifts or gratuities from or to any M-Pesa customer or supplier. M-Pesa employees may not on behalf of M-Pesa give or solicit a gift, entertainment, meals, political contributions, charitable donations, or other gratuity of any kind, nor may they accept a gift, entertainment, meals, or other gratuity from a customer, supplier, vendor representative or business partner greater than $20.00 market value without Corporate Management approval. M-Pesa employees may not give a public official anything of value: 1) with the intent to influence any official act; 2) to influence the official to commit or aid in fraud; nor 3) to induce the official to act in violation of their official duties.


Whenever M-Pesa employees are called upon to make statements about competitors and their products or about M-Pesa products and services, they should do their utmost to make sure these statements are current and accurate.


M-Pesa believes in fair and open competition and requires strict adherence to all applicable Antitrust or Competition laws worldwide. All employees must, at all times, comply with Antitrust or Competition laws and M-Pesa's antitrust and competition policies, including any regional policies that apply to particular businesses. Employees are not to seek proprietary competitor information either directly, or from others, which may have resulted from a breach of confidentiality or lapse of integrity. Business relationships with M-Pesa's customers, suppliers, and competitors must comply with all applicable laws, including U.S. antitrust laws. Any questions regarding Antitrust Laws may be directed to the Contracts and Legal Services department for clarification.

As a general rule, agreements and/or arrangements among competitors regarding (among other things) prices, trading conditions, projected sales for any specific products or services, revenues and expenses, production schedules, inventories or sharing markets violate antitrust laws. The exchange of competitive or proprietary information must also be avoided. These guidelines also apply to informal contacts with competitors, including those at trade shows or meetings of professional organizations.


M-Pesa is committed to promoting business while complying with all applicable U.S. export control laws and regulations that guide the transfer, export, sale, or release of any product including hardware, software, data, or technology from the United States. Guidance on compliance with U.S. export control regulations is available in the M-Pesa Export Compliance Manual. Any additional questions regarding export control may be directed to the Contracts and Legal Services department for clarification.