Zero tolerance.
On paper and on site.
A sound structure rests on healthy foundations. So does our reputation. This charter binds our directors, our staff, our subcontractors, our suppliers and our consortium partners.
Version 1.0 · adopted on 8 November 2026
Our frame of reference
We apply Malagasy law and the rules of the international funders we work with. Where two rules differ, we apply the stricter one.
- Law No. 2016-020 of 22 August 2016 on the fight against corruption
- Law No. 2016-021 of 22 August 2016 on the Anti-Corruption Courts (Pôles anti-corruption)
- Law No. 2016-055 on the Public Procurement Code, including its title on ethics
- United Nations Convention against Corruption
- African Union Convention on Preventing and Combating Corruption
- Anti-corruption guidelines and integrity policies of the World Bank, AFD, AfDB, EIB and the European Union
What we refuse, without exception
These practices are prohibited for anyone acting on behalf of FANAMBINANTSOA, whatever the amount, the country or the counterpart, and even when presented as “customary”.
Offering, promising, giving, soliciting or accepting, directly or through an intermediary, an undue advantage to influence a decision: award of a contract, issue of a permit, acceptance of works, payment of an invoice.
Deliberately misleading a client, a funder or an administration: false statements, forged documents, inflated references or CVs, over-invoiced quantities or prices, tests not carried out presented as done.
Colluding with other bidders or with an agent of the buyer to distort competition: market sharing, cover bids, price fixing.
Threatening or harming, directly or indirectly, a person or their property in order to influence their decisions or conduct.
Destroying, falsifying or concealing evidence, or obstructing an investigation or audit by a funder, a client or an authority.
Trading on real or supposed influence with an authority, or making “small payments” to speed up an administrative procedure, including a building permit. We follow official procedures and timescales.
Our everyday rules
Practical rules for the situations a construction company and engineering consultancy actually face.
Only occasional, transparent gifts and hospitality of token value are allowed. No gift is offered or accepted during a tender procedure, an evaluation or the acceptance of works. Any gift received is declared to management and recorded in a register.
Any situation where a personal, family or financial interest could influence a decision is declared in writing, and the person concerned withdraws from the decision. We never inspect works we carry out ourselves, and we never combine advising the buyer with bidding on the same contract.
We comply with the procurement and ethics rules of the Public Procurement Code and of funders. No contact with members of an evaluation committee outside official channels, and no attempt to obtain confidential information on competing bids.
Our bids, references, CVs, certificates, test reports, progress statements and invoices are truthful and verifiable. Company references and the individual experience of our directors are always presented separately.
Before any partnership, consortium or use of an agent, we check the partner's identity, reputation and competence. Any remuneration is in writing, justified by a real service and proportionate. This charter is appended to contracts.
We select them on objective criteria of price, quality and lead time. They undertake to comply with this charter, and we reserve the right to check their practices on our sites.
Donations and sponsorship are transparent, documented and never linked to an expected decision. The company does not fund any political party, candidate or campaign.
Payments go through traceable banking channels; cash is limited and justified. Our books, contracts and procurement files are kept and may be audited by our clients and funders, as provided for in the contract.
Beyond corruption
Integrity also covers the way we treat people and the environment.
Protective equipment, safety plan, safety induction for everyone on site, works stopped in the event of serious danger.
Compliance with the MECIE decree and environmental and social management plans; management of waste, water and quarries.
No child labour or forced labour; written contracts, wages declared and paid on time, equal treatment.
Zero tolerance for harassment, sexual exploitation and abuse, on our sites and in our offices; respect for neighbouring communities.
Report a breach
Employee, client, partner or local resident: if you witness or suffer a practice contrary to this charter, write to us. Every report is handled confidentially by management.
No sanction or retaliation may be taken against anyone who reports in good faith. You may also contact Madagascar's Independent Anti-Corruption Bureau (BIANCO) directly.
fanambinantsoasarl@proton.me · subject “Ethics report”
Implementation and sanctions
A charter is only worth something if it is applied.
The co-managing directors are responsible for applying this charter and appoint an ethics officer.
Every employee receives the charter on joining, signs it and attends an annual awareness session.
The charter is appended to our subcontracting, supply and consortium agreements.
Any breach leads to disciplinary action up to and including dismissal, termination of a partner's contract and, where appropriate, referral to the competent authorities.
We cooperate fully with investigations and audits by our clients, funders and the authorities.
The charter is reviewed every year and whenever the law or our partners' requirements change.
We personally commit to complying with this charter, ensuring it is complied with, and appending it to each of our contracts.
The full signed version is available as a PDF on request, for your tender and partnership files.