Member Code of Conduct

1 Introduction and Purpose

1.1 GATA's mission is to connect and empower trade and business across Africa. Achieving that mission depends on trust — trust between Members, trust in GATA's information and events, and trust in the association as a whole.

1.2 This Code of Conduct ("Code") establishes the minimum standards of conduct expected of all Members. It is not exhaustive; Members are expected to apply good judgement and act ethically even in situations not specifically addressed here.

1.3 By accepting GATA membership, each Member commits to upholding this Code and to ensuring that all persons who represent their organisation in GATA contexts do likewise.

2 Core Principles

3 Professional Standards

3.1 Members shall conduct themselves with professionalism in all GATA-related interactions, including at events, on the Member Portal, and in correspondence with GATA staff and other Members.

3.2 Members shall not engage in any conduct that is abusive, threatening, intimidating, or harassing towards any individual in the GATA community.

3.3 Members shall not make false, misleading, or defamatory statements about GATA, its officers, or other Members — whether in private communications, publicly, or on social media.

3.4 Members shall represent their organisation and its activities honestly and shall not misrepresent their membership status, tier, or the nature of their relationship with GATA.

4 Anti-Corruption and Ethical Business Practice

4.1 GATA has a zero-tolerance policy on bribery and corruption. Members shall not offer, pay, solicit, or accept any bribe, facilitation payment, or other improper advantage in connection with GATA membership, events, or any business conducted through GATA networks.

4.2 Members shall comply with all applicable anti-corruption legislation, including the Kenyan Anti-Corruption and Economic Crimes Act and, where relevant, the UK Bribery Act, the US Foreign Corrupt Practices Act, and equivalent national legislation.

4.3 Members shall not use GATA membership or the Member Directory to facilitate money laundering, sanctions evasion, tax fraud, or any other financial crime.

5 Non-Discrimination and Inclusion

5.1 GATA is committed to an inclusive, diverse, and equitable community. Members shall not discriminate against any person on the grounds of race, ethnicity, national origin, religion, gender, gender identity, sexual orientation, disability, age, or any other characteristic protected by law.

5.2 Discriminatory language, exclusionary behaviour, or conduct that creates a hostile environment for any individual in the GATA community will be treated as a serious breach of this Code.

5.3 Members are encouraged to foster inclusive business practices within their own organisations and to support GATA's broader mission of equitable trade development across Africa.

6 Conflict of Interest

6.1 A conflict of interest arises when a Member's personal, commercial, or financial interests could improperly influence — or be seen to influence — decisions made within GATA, including working group decisions, event programme selection, or the award of GATA-facilitated contracts.

6.2 Members who become aware of a conflict of interest shall disclose it promptly to the GATA Secretariat in writing. GATA will determine on a case-by-case basis whether the Member should recuse themselves from relevant decisions or activities.

6.3 Members who serve on GATA working groups, advisory committees, or governance bodies must disclose all material interests at the outset of their appointment and update that disclosure whenever circumstances change.

7 Confidentiality

7.1 Members acknowledge that they may, through GATA membership activities, gain access to commercially sensitive information about other Members' business strategies, operations, or financial positions. Such information must be treated as confidential and must not be disclosed to third parties or used for competitive advantage.

7.2 Information shared in GATA working groups, restricted forums, or private Member communications is shared in confidence. Members shall not share such information externally without the express consent of the originating party.

7.3 This obligation of confidentiality survives termination of membership for a period of three (3) years.

8 Digital Conduct on the Member Portal

8.1 Members shall use the GATA Member Portal only for legitimate membership-related purposes and in accordance with the Platform Terms and Conditions.

8.2 The following activities are expressly prohibited on the Member Portal:

• Sending unsolicited commercial messages (spam) to other Members through the Portal or Directory;
• Uploading, sharing, or linking to illegal, defamatory, or harmful content;
• Attempting to access or harvest data beyond what is necessary for legitimate membership use;
• Creating false profiles or impersonating another organisation or individual;
• Using automated tools or scripts to interact with the Portal without GATA's written approval.

9 Compliance with Laws and Regulations

9.1 Members shall, at all times, comply with all laws and regulations applicable to their business operations, including trade laws, customs regulations, sanctions, environmental regulations, and employment law.

9.2 Membership of GATA does not exempt any Member from compliance with applicable law and does not imply any endorsement by GATA of the Member's business practices.

9.3 Members subject to international trade sanctions shall not use GATA membership, events, or networks to circumvent those sanctions.

10 Reporting Concerns

10.1 Members are encouraged to report concerns about potential breaches of this Code promptly and in good faith. Reports can be made to:

• Email: conduct@gata.africa
• Post: GATA Secretariat, Upper Hill, Nairobi, Kenya (marked Confidential)

10.2 Reports may be made anonymously. GATA will treat all reports with confidentiality to the extent permitted by law and will not victimise any person who raises a concern in good faith.

10.3 Deliberately filing a false or vexatious complaint against another Member is itself a breach of this Code.

11 Enforcement and Sanctions

11.1 GATA takes breaches of this Code seriously. Upon receiving a complaint or becoming aware of a potential breach, GATA will:

• Conduct a fair and prompt investigation;
• Give the Member an opportunity to respond to any allegations;
• Take action proportionate to the severity and circumstances of the breach.

11.2 Sanctions available to GATA, applied on a graduated basis, include:

• ⚠️Formal Written Warning — issued for minor or first-time breaches, with guidance on expected future conduct.
• ⏸️Suspension of Portal Access — temporary suspension of access to the Member Portal and Benefits pending investigation or pending rectification of conduct.
• 🚫Suspension of Membership — suspension of full membership rights, including event participation and Directory listing, for a defined period.
• ❌Termination of Membership — immediate or notice-based termination of membership for serious or repeated breaches, including but not limited to bribery, fraud, harassment, or sanctions evasion.
• 🔨Referral to Authorities — for matters involving suspected criminal activity, GATA may refer the matter to relevant law enforcement or regulatory authorities.

11.3 Members who have their membership terminated for breach of this Code are not entitled to a refund of Subscription Fees and may not reapply for membership without the express written consent of the GATA Board.

12 Acknowledgement

By submitting a membership application and checking the Code of Conduct checkbox, the Member confirms that:

• They have read this Code in full and agree to abide by it;
• They have authority to bind their organisation to this Code;
• They will communicate the requirements of this Code to all relevant personnel;
• They understand that breach of this Code may result in sanctions up to and including termination of membership.