Governance and integrity
A development finance institution, sovereign fund or ministry integrity team asks the same questions of every intermediary before anyone takes a meeting. This page answers them, and each policy below can be downloaded and filed.
Policies
Each policy is reviewed annually; the version on this page is the current one.
Code of Conduct (PDF, v1.0, October 2026)
Values, lawful conduct, confidentiality, gifts and hospitality (none to public officials), no misrepresentation of regulatory status.
Anti-Bribery and Corruption Policy (PDF, v1.0, October 2026)
Zero tolerance; no facilitation payments; no payments, gifts or hospitality to public officials; third-party due diligence; Kenya Bribery Act 2016, UK Bribery Act 2010 and US FCPA where applicable.
AML, KYC and Sanctions-Screening Policy (PDF, v1.0, October 2026)
Identity, beneficial ownership and PEP screening of every counterparty; sanctions screening against UN, OFAC, UK, EU and Kenyan lists; seven-year record retention; FRC reporting.
Conflicts of Interest Policy (PDF, v1.0, October 2026)
How Ephesus’s own co-sponsor interests are disclosed before engagement; written engagement letters; no undisclosed commissions; conflicts register and recusal.
ESG and Environmental and Social Commitment (PDF, v1.0, October 2026)
Screening against the IFC Performance Standards and host-country law; exclusion list; community engagement; reporting to counterparties.
Whistleblowing Policy (PDF, v1.0, October 2026)
Who can report, how (including anonymously), confidentiality, no retaliation, acknowledgement within 5 working days, conclusion within 30.
Beneficial Ownership, PEP Declarations and Audit Rights: Statement of Availability (PDF, v1.0, October 2026)
What is available to counterparties on request under NDA, from whom, and within what time.
Compliance contact
compliance@ephesusinvestments.biz
49 Runda Ridge, Runda, Nairobi, Kenya
Beneficial-ownership extracts, PEP declarations for directors and shareholders, a certified certificate of incorporation and CR12, and audit rights over engagement records are available to counterparties on request under NDA, within ten working days and without charge.
Raise a concern
Anyone, including counterparties and members of the public, may report a concern about bribery, fraud, money laundering, conflicts, environmental or social harm, or breach of our policies.
Email compliance@ephesusinvestments.biz, or write to the Compliance Officer at the registered office, marked Private and Confidential. Anonymous reports are accepted. We acknowledge within five working days and do not tolerate retaliation.
Regulatory status
Ephesus Investments and Assets Ltd is a project-development, PPP advisory and investment-facilitation firm registered in Kenya. It does not act as an investment adviser, fund manager, broker-dealer or placement agent. Nothing on this website is investment, legal or tax advice, a recommendation, or an offer to sell or a solicitation of an offer to buy any security in any jurisdiction. Participation in any project is subject to independent due diligence and definitive agreements between the parties.
Remuneration is under written engagement letters; we receive no undisclosed commissions. We hold no client funds.
Fraud and impersonation warning. Ephesus communicates only from addresses ending in @ephesusinvestments.biz and never asks counterparties to transfer funds to it. If you receive a communication claiming to be from Ephesus that does not meet these conditions, contact compliance@ephesusinvestments.biz before acting on it.
Ready for your integrity review
Request the information pack or the beneficial-ownership and PEP declarations.
