1. Purpose This policy outlines our commitment to delivering safe, high-quality, and responsive customer service in the supply and support of medical and industrial gases. We recognize the critical role our products play in healthcare and industrial operations, and we are dedicated to upholding the highest service standards in all customer interactions. 

2. Scope This policy applies to all employees, technicians, delivery personnel, contractors, and customer service representatives involved in the production, handling, distribution, and support of medical and industrial gas products.

3. Our Commitments We are committed to: • Safety and Compliance: Ensuring all products and services meet or exceed applicable safety, health, and regulatory standards (e.g., ISO, OSHA, PPB, KEBS). • Reliable Supply Chain: Maintaining consistent product availability and timely deliveries, especially for critical-use medical gases. • Responsive Customer Support: Providing fast, knowledgeable, and respectful support to all customers — hospitals, clinics, manufacturers, fabricators, food processors, labs, and others. • Accurate Information: Offering clear documentation and labeling for all gas types, including safety data sheets (MSDS) and handling guidelines. • Traceability and Quality Assurance: Ensuring batch traceability, quality testing, and compliance with good manufacturing/distribution practices (GMP/GDP). • Training and Education: Supporting customers with guidance on gas handling, cylinder safety, and emergency procedures. • Continuous Improvement: Using feedback, audits, and performance metrics to constantly improve service quality and reliability.  

4. Service Standards Service Area Standard Emergency Medical Deliveries Available 24/7; delivered within 2–4 hours (urban areas) Standard Orders Processed and scheduled within 24 hours Technical Support Response within 4 business hours Complaint Resolution Acknowledged within 24 hours, resolved within 5 business days as per the documented SOP for handing customer complains

5. Customer Communication We ensure clear and transparent communication: • Ordering: Multiple easy channels (phone, web portal, email). • Invoices and Documentation: Accurate billing and delivery paperwork with each delivery.

6. Feedback and Complaints We treat feedback as an opportunity to improve: 1. Submit feedback via email, phone, or our website. 2. All complaints are tracked and reviewed by our Quality Assurance and Business Development Team 3. Root cause analysis conducted, when necessary, with corrective actions documented.

7. Employee Responsibilities Every employee must: • Adhere to regulatory and internal safety protocols at all times. • Be trained in customer communication and complaint handling. • Maintain professionalism, confidentiality, and courtesy with every customer. • Report safety incidents or quality concerns immediately.

8. Monitoring & Review This policy will be reviewed annually or following any regulatory updates, incident investigations, or significant customer feedback.

Contact Information Customer Service: +254 733 999 191

Emergency Medical Gas Support (24/7): +254 729 839 015

Email: [email protected]

Website: www.gasafrica.com

Effective Date: 25th September 2024

Review Date: Annually or as Required

Approved by: Managing Director

Doc Ref: GAL/QMS/POL/CSP/01 Rev:00 Issue:01

1. Purpose

This policy outlines Gas Africa Limited’s commitment to conducting business with the highest standards of integrity and in full compliance with anti-bribery laws. As a supplier of medical and industrial gases, we recognize our critical role in healthcare, manufacturing, and research sectors, where transparency and ethical conduct are vital.

2. Scope

This policy applies to all employees, officers, directors, agents, distributors, contractors, and business partners acting on behalf of Gas Africa Limited regardless of their location or role.

3. What is Bribery?

Bribery is offering, promising, giving, or receiving anything of value with the intent to improperly influence a decision, secure an advantage, or gain business. In the context of medical and industrial gases, bribery risks may arise in situations such as:

• Securing supply contracts with hospitals, government agencies, or manufacturers
• Regulatory approvals for gas cylinders, storage facilities, or new products
• Customs clearances or logistics facilitation

Examples of prohibited actions:

• Offering hospital procurement staff a gift to win a contract for oxygen supply
• Making facilitation payments to customs officials to expedite clearance of gas cylinders
• Giving commissions or incentives to distributors that are not disclosed or documented

4. Policy Requirements

Personnel must not:

• Offer or accept bribes in any form, including cash, gifts, hospitality, or favors
• Make facilitation payments (small, unofficial payments to speed up services)
• Use third parties to indirectly engage in bribery
• Fail to report suspicious activity or known breaches of this policy

5. Gifts, Hospitality, and Sponsorships

We understand that business courtesies can be part of normal professional relationships. However, in our industry, where patient safety and regulatory oversight are critical, extra caution is required.

Permissible activities must:

• Be of modest value and infrequent
• Not involve government or hospital officials without prior approval
• Be transparently recorded in Gas Africa’s gift and hospitality log

All promotional or educational sponsorships (e.g., conferences for hospital staff) must be pre-approved by the Managing Director

6. Donations and Contributions

• Charitable donations must not be used to gain business advantage and should be approved and documented.
• Political contributions are strictly prohibited unless authorized by senior management and legally compliant.

7. Third-Party Risk

Vendors, agents, distributors, and contractors must be vetted and agree to comply with this policy. Contracts should include anti-bribery clauses and provide the right to audit.

8. Reporting and Whistleblowing

Employees and third parties are encouraged to speak up if they suspect bribery or corruption. You can report through:

• Your manager or HR
• Managing Director
• Anonymous whistleblowing channels (if available)

Retaliation against whistleblowers is strictly prohibited.

9. Compliance and Training

• Annual training will be provided to all relevant staff
• Breaches of this policy may result in disciplinary action, termination, and legal prosecution
• Regular audits and reviews will be conducted to assess compliance

Doc Ref: GAL/QMS/POL/ACP/01

Rev:00

Issue:01

Effective Date: 16th August 2021
Review Date: Annually or as Required
Approved by: Managing Director

Purpose: To establish guidelines for clear, compliant, and consistent communication internally and externally, ensuring safety, trust, and operational efficiency.

1. Policy Objectives

• Ensure all communications reflect the company's mission, values, and safety-first approach.
• Comply with all relevant industry regulations (e.g., OSHA, KEBS, PPB, ISO standards).
• Promote transparent and consistent communication with stakeholders.
• Support emergency communication and incident response.

2. Scope

This policy applies to:

• All employees, contractors, and partners
• All communication channels (verbal, written, electronic, social media, etc.)
• Both internal (employee) and external (customer, regulatory, media) communication

3. Types of Communication Covered

• Operational Communication: Safety alerts, logistics, maintenance updates
• Marketing & Public Relations: Advertisements, website, brochures
• Customer Service: Order handling, technical support
• Regulatory Communication: Incident reporting, audits, certifications
• Crisis Communication: Emergency protocols, press releases

4. Key Principles

A. Accuracy

• Verify technical data (e.g., gas concentrations, safety data sheets)
• Use approved templates and terminology for safety-critical info

B. Clarity

• Avoid jargon with external audiences
• Use plain language where possible

C. Confidentiality

• Protect customer data, intellectual property, and medical information
• Use NDAs where needed

D. Timeliness

• Respond to incidents, inquiries, or internal issues promptly
• Follow escalation procedures for emergencies

E. Compliance

• Adhere to laws (OSHA etc.)
• Include disclaimers and regulatory references where required

5. Roles & Responsibilities

6. Internal Communication Channels

• Email (for formal notices)
• Approved messaging platforms
• Safety meetings / Toolbox talks

7. External Communication Channels

• Website and official email
• Customer support hotlines
• Social media (by authorized personnel only)
• Press releases and media statements

8. Emergency & Crisis Communication

• Trigger Events: Gas leaks, contamination, injury, equipment failure
• Protocol:
  1. Notify supervisor and QAM team immediately
  2. Use designated spokesperson who is the Managing Director
  3. Follow approved incident report templates
  4. Communicate with regulators within required timelines
  5. Update customers and public as appropriate

9. Training & Review

• Annual training on communication protocols and emergency messaging
• Regular audits of external-facing communication
• Policy will be reviewed annually or following any regulatory updates, incident investigations or significant internal or external feedback.

10. Violations

• Unapproved communication may result in disciplinary action
• Leaks or misinformation that endanger safety may lead to termination or legal action

Doc Ref: GAL/QMS/POL/CMP/01

Rev:00

Issue:01

Effective Date: 23rd September 2024
Review Date: Annually or as Required
Approved by: Managing Director

The Management and personnel of Gas Africa are unwavering in their commitment to customer satisfaction by affording its customers Medical and Industrial gases that adhere to stringent international technical and quality standards and benchmarks
Understanding customer’s requirements now and in the future is paramount to providing the best suited product and services

The SHEQ Policy aims to ensure alignment to the Gas Africa vision and values, where integrity of the product is key and it is this dedication to safety that ensures that harm is not inflicted upon its employees, customers, contractors, service providers, or the environment, Gas Africa assets, as well as members of the public affected by its operations, infrastructure, and all operational activities within the scope of its business

Gas Africa management and all employees are committed to well-being and protection of human life, environmental duty of care, protection of assets and customer satisfaction by applying our Code of Conduct in all its activities

Gas Africa has integrated safety, health, environment and quality requirements into all activities; more specifically in the Product realization process and care for preventive maintenance to improve performance and achieve stakeholder requirements
Our commitment to Safety, Health, Environment, and Quality management is achieved through:

1. Achieving compliance with applicable legislation and other requirements to which Gas Africa subscribes and in the absence of these, setting internal standards to meet the intent of this policy
2. Addressing the needs and expectations of Gas Africa customers and stakeholders
3. Setting SHEQ objectives goals and measuring our performance (KPI’s) against these with the objective of continual improvement
4. Periodical task-based risk surveillance for all Gas Africa activities, to monitor and manage occupational risks inherently present in the nature of our business
5. SHEQ training and safety-based behavior training for all employees
6. Ensuring that our suppliers and service providers meet and adhere to Gas Africa requirements
7. Promoting open communication with all stakeholders and sharing of our SHEQ knowledge
8. Manufacture, distribute and sale of products in a safe, secure, efficient, and environmentally responsible manner

Responsibilities

It is the primary responsibility of the company’s management supported by the board of directors to ensure full and effective compliance with the requirements of the SHEQ Policy
They will establish and monitor the organization as well as the arrangements for those areas and activities over which they have control and responsibility
Full and effective compliance with the legal duties placed on Gas Africa can only be achieved with the active involvement of the entire workforce
This requires the full support and cooperation of all employees and contractors

GAS AFRICA MANAGEMENT

Doc Ref: GAL/QMS/POL/QSHE/04

Rev:03

Issue:04

Effective Date: 17/04/2025

Approved By: Managing Director

Review Date: Annually or as Required

Gas Africa Limited is committed to operating responsibly and sustainably in the production, storage and supply of medical and industrial gases. We recognize our duty to protect the environment for present and future generations and strive to minimize the environmental impact of our operations while ensuring the safety and reliability of our products.

Our Commitments

1. Compliance

• Comply with all applicable environmental laws, regulations, and industry standards.
• Meet or exceed environmental requirements specified by our customers, partners, and regulators.

1. Pollution Prevention

• identify and reduce sources of emissions, effluents, and waste.
• Implement effective measures to prevent contamination and spillage of gases, chemicals, or hazardous materials.

1. Resource Efficiency

• Optimize energy and water usage in our operations.
• Promote efficient transportation and logistics to reduce our carbon footprint.

1. Product Stewardship

• Design and deliver products and services that are safe, environmentally responsible, and support sustainable development.
• Provide clear guidance to customers on the safe and environmentally sound use of our gases.

1. Continuous Improvement

• Monitor and review our environmental performance through measurable objectives and targets.

1. Training and Awareness

• Educate and train employees at all levels to enhance their understanding of environmental responsibilities.
• Foster a culture of environmental accountability throughout our organization.

1. Stakeholder Engagement

• Engage with key stakeholders to promote sustainable practices.
• Transparently report our environmental performance and respond to concerns with integrity.

Responsibility and Review

This policy is supported by top management and is reviewed annually or whenever significant changes occur in our operations or environmental legislation. All employees and contractors are expected to uphold the principles outlined in this policy.

Doc Ref: GAL/QMS/POL/ES/03

Rev:02

Issue:03

Effective Date: 17/04/2025

Review Date: Annually or as Required

Approved By: Managing Director

1. Purpose

This policy outlines the principles, responsibilities, and procedures designed to protect employees, property, customers, and the environment from fire and related hazards associated with the storage, handling, production, and distribution of medical and industrial gases.

2. Scope

This policy applies to all company facilities, operations, vehicles, and personnel involved in the manufacturing, storage, handling, and delivery of medical and industrial gases.

3. Policy Statement

We are committed to ensuring a safe and fire-resilient working environment by:

• Complying with applicable national and international fire safety regulations (e.g., OSHA, ISO).
• Implementing proactive fire risk assessments and controls.
• Providing fire safety training and resources to all employees.
• Maintaining fire detection, suppression, and emergency response systems.

4. Key Fire and Safety Principles

4.1 Hazard Identification and Risk Assessment

• Conduct regular risk assessments for all fire-prone operations.
• Identify ignition sources, flammable materials, and potential release scenarios.
• Implement mitigation measures and update them based on operational changes.

4.2 Fire Prevention Measures

• Eliminate ignition sources near gas storage and production areas.
• Ensure proper ventilation in enclosed spaces.
• Use explosion-proof equipment and anti-static clothing in designated zones.
• Implement and enforce "No Smoking" policy.

4.3 Gas Cylinder Storage and Handling

• Store cylinders upright, secured, and clearly labeled
• Maintain safe distances from ignition sources and electrical equipment.
• Regularly inspect for leaks, rust, or mechanical damage.

4.4 Fire Detection and Suppression Systems

• Install and maintain fire suppression systems and equipment
• Equip facilities with appropriate fire extinguishers (CO₂, dry powder, foam).
• Regularly inspect and test all systems.

5. Employee Roles and Responsibilities

5.1 Management

• Ensure implementation of this policy across all facilities.
• Allocate resources for training, equipment, and system maintenance.
• Review and update the policy annually or after major incidents.

5.2 Safety Officer

• Conduct training and drills.
• Perform risk assessments and fire inspections.
• Investigate fire incidents and recommend corrective actions.

5.3 Employees

• Comply with all safety instructions and procedures.
• Report unsafe conditions or fire hazards immediately.
• Participate in fire drills and training sessions.

6. Emergency Preparedness

• Establish and communicate an emergency evacuation plan.
• Conduct bi-annual fire drills involving all staff.
• Train employees in the use of fire extinguishers and first aid.
• Designate and train emergency response teams.

7. Training and Awareness

• Conduct periodic refresher courses.
• Display fire safety signage and instructions prominently.

8. Record Keeping

• Maintain logs of inspections, training sessions, incidents, and drills.
• Ensure access to Material Safety Data Sheets (MSDS) for all gases.

9. Compliance and Continuous Improvement

• Periodic internal and third-party audits of fire safety practices.
• Corrective actions and improvements based on audit findings.
• Stay updated with best industry practices and technological advancements.

10. Enforcement

Non-compliance with this policy may result in disciplinary action, including retraining, suspension, or termination, depending on the severity of the violation.

Doc Ref: GAL/QMS/POL/FS/03

Rev:02

Issue:03

Effective Date: 17/04/2025

Review Date: Annually or as Required

Approved By: Managing Director

1. Policy Statement

Gas Africa is committed to delivering high-quality medical and industrial gases that meet or exceed customer expectations, regulatory requirements, and applicable national and international standards.

We operate under a robust Quality Management System (QMS) in line with ISO 9001:2015 and the regulatory framework of the Pharmacy and Poisons Board (PPB), the Kenya Bureau of Standards (KEBS), and other relevant bodies.

2. Strategic Intent and Alignment

Our Quality Management System is designed to reflect the purpose and strategic direction of Gas Africa — to be a dependable, safe, and compliant partner in the supply of high-quality medical and industrial gases. The QMS framework integrates seamlessly into our business strategy, ensuring alignment between quality outcomes and company goals.

We are committed to:

• Manufacturing, packaging, and distributing medical gases in full compliance with PPB guidelines and GMP.
• Producing and supplying industrial gases that meet applicable KEBS standards and client specifications.
• Ensuring safety, purity, traceability, and integrity of gases through controlled and validated processes.
• Achieving customer satisfaction through on-time delivery, product quality, and responsiveness to feedback.
• Continual improvement of our QMS and operational performance through audits, training, corrective actions, and review mechanisms.

3.Framework For Objectives

This policy provides the foundation for setting and reviewing measurable quality objectives across our departments. These objectives focus on:

• Reliability and traceability of medical and industrial gases.
• Compliance with good manufacturing practices and safety standards.
• Timely delivery and responsive service to meet customer needs.
• Operational efficiency and resource optimization.

Performance against these objectives is monitored, reported, and used as a basis for continuous learning and action.

4. Regulatory and Standards Compliance

We comply with:

• ISO 9001:2015 – Quality Management Systems
• KEBS specifications for industrial gases
• PPB Guidelines for manufacture and distribution of medical gases
• GMP principles applicable to medical gas production
• Environmental, health, and safety regulations under NEMA and DOSHS

5. Scope

This policy applies to all departments and activities related to the manufacture, quality control, storage, transport, and supply of medical and industrial gases at all our sites.

6. Responsibilities

• Top Management ensures that QMS is maintained and resourced.
• Quality & Regulatory Affairs oversees compliance with local and international standards.
• Operations & Technical Teams ensure that SOPs and quality procedures are followed.
• All Employees are responsible for upholding quality and safety in their roles.

7. Communication and Review

This policy is reviewed annually or as required due to changes in regulations, customer needs, or business strategy. It is communicated across the organization and made available to stakeholders, regulators, and customers upon request.

Effective Date: 6th May 2025

Review Date: Annually or as required
Approved By: Managing Director

Introduction

In the course of its activities, Gas Africa Limited processes personal data of its employees, customers and their agents, suppliers, visitors, service providers, shareholders, directors and other stakeholders (hereinafter, the “Data Subjects” “you”, or “your”).

This policy describes the information privacy practices that Gas Africa Limited follows when handling personal information that we collect or receive in conducting our business. Such information is normally collected through business transactions and interactions, websites, employee(s) and user application(s) such as emails and network platforms.

This privacy policy statement demonstrates our commitment to protect the privacy of individuals with respect to personal identifiable information and is designed to assist you in understanding our policies and practices in relation to the collection, use, retention, transfer and access of your personal information. 

Personal Identifiable Information (PII)

Personal Identifiable Information (also referred to as personal data in this policy) means any information relating to an identified or identifiable natural person (the data subject). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location information, an online identifier or by one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of the natural person.

Application of this privacy policy

This policy applies to all those who have access to PII in our possession. This includes our employees, all service providers and consultants who are our agents or working on our behalf or in our name, through outsourcing of services and processes or any business activity.

Independent contractors and consultants will be made aware of the Privacy Policy as it applies to our staff, potential and/or existing customers and counterparties in their dealings with them. This policy also serves to inform the public of the personal data collected by Gas Africa Limited, the purpose of collection and how that data is handled.

Data subject rights

As a data subject, you have rights regarding the processing of your personal information as follows:

- To be informed of the use your personal data is to be put by us

- Request access to any personal information held about you by us and details of the processing of your personal information by us;

- Object to or restrict the processing of your personal data (including profiling), including where the processing is unlawful or no longer necessary;

- Have inaccurate personal data amended or erased, and to have incomplete personal data completed;

- To deletion of false or misleading data about them.

In exercise your rights, you may:

- Withdraw any consent you have given, or are deemed to have given, in relation to our collection or use of your personal information;

- Request the erasure of your personal data where: (i) the processing was not lawful, (ii) where the data is no longer necessary for the purpose which it was collected, (iii) where you withdraw consent which was the lawful basis of processing, (iv) where the erasure is necessary to comply with legal obligation, (iv) where processing was for direct marketing, or (v) you object to processing and there is no overriding legitimate interest for us to continue processing.

- Request to receive your personal data in a format suitable for transmission to another data controller;

- Object to processing of your personal information for direct marketing.

- Object to any decision about you based solely on automated processing (including any profiling) that produces legal effects or otherwise significantly affects you; and

- Complain to the relevant data protection supervisory authority, if you think that we are not complying with our obligations in relation to our processing of your personal information.

You can make a request to us in relation to these rights at any time by contacting us via email at [email protected]. All requests will be dealt with promptly, in line with the provisions of Data Regulations of 2021. Any information to which you are entitled will be provided within a reasonable timeframe, subject to any exemptions stipulated in applicable data privacy laws.

Collection of personal data and purpose of processing

1. Employment and recruitment

We may collect information you provide to us through the recruitment processes such as name, passport sized image of you, date of birth/age, gender, contact information, identification number, education and academic qualifications, professional and employment history, reference contacts and current employment remuneration details.

On your employment with Gas Africa Limited, we collect additional information related to your bank account number, next of kin details, details relating to personal good conduct, medical history, biometrics such as finger print, and other information relevant to meeting our obligations under the employment laws and to process the periodic payroll. We may also collect and retain background information as permitted under applicable law.

This information is only collected for the purposes of recruitment and background reference checks, human resource management and development, staff welfare, and payroll processing.

This information is only collected for the purposes of human resource management and development, payroll processing and recruitment.

2. Business partners

For all counterparties doing business with us, we collect information that might be PII in nature. This could be names, personal email addresses or phone numbers provided in course of communications, individual tax PIN numbers, physical addresses of (company) agents and representatives.

Information collected though these processes is only used for legitimate trading purposes such as facilitating processing of transactions, receipting and making of payments.

To ensure we do business with reputable, honest and qualified business partners and agents, we may also conduct due diligence checks on companies and their directors and shareholders to establish the legal status of all potential new business partners to evaluate whether they may be involved in illegal or corrupt practices. Such checks may include the collection of personal identification documents for such directors and shareholders.

3. Information provided through our security procedures

As part of our security procedures, we obtain information from our visitors. This information may include the name, national identification number, phone number, vehicle registration, name of employer, CCTV footage, and other business contact details. Such information is only processed for purposes of maintaining a record of our visitors for security management purposes.

4. Information you provide to us through our website

We may collect information you provide to us through our web-based enquiries. This information includes your name, your phone number and email address. This information is only processed for business purposes.

5. Information we may receive from our counterparties

We may receive personal information about you from our counterparties (sales representatives) who may recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products you have shown interest in or may be interested in purchasing from us.

We may also obtain personal information about you from our counterparties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction.

If we use such information to contact you, it will only be to see if you are interested in our products. We will not use this information for other purposes without your consent. In addition, if you inform us that you are not interested in these products, we will stop using the information to contact you.

6. Others who may get in touch with us

We collect personal data when an individual gets in touch with us with a question, complaint, comments or feedback such as name, contact details and content of the communication. In this case, we will only use the data for the purpose of responding to the communication and handling the matter.

7. Visitors

We collect identification details of visitors to our premises such as name, mobile numbers and the Identification card number for the purposes of security measures.

8. CCTV installations

Our premises are equipped with CCTV cameras for the purposes of safety and security.

Use of personal information

a) For business use

We use your personal information to facilitate our ongoing and proposed business dealings with you. This includes:

- To process business transactions with us;

- To communicate with you about updates, maintenance, outages or other technical matters concerning these products;

- To verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products;

- To respond to questions or inquiries that you or your company may have about our products.

We may use your personal information as required for us to comply with relevant laws and regulations relating our business.

b) Marketing Purposes

With your consent or as otherwise permitted by applicable law, we may use your personal information for purposes relating to the marketing of our products, or those of our business partners where you may have shown interest in. This means we may from time to time:

- Send you newsletters, press releases, event announcements and other similar communications regarding the products that we offer;

- Market or promote our products to you;

- Solicit input from you regarding improvement of our products;

- Send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products; and

- Use your personal information for other purposes that we disclose to you at the time we obtain your consent.

You may at any time opt-out to receiving marketing related communication from us, by contacting us at [email protected].

c) Employment

As permitted by applicable laws we maintain employment records of our current and former employees. With respect to current employees, we only use the processed personal information for human resources management activities, staff welfare and legal obligations.

With respect to former employees, we archive the records and only use them on lawful basis only as permitted by the law. After the required retention period (in line with Income Tax Act and Companies Act), the records are destroyed.

d) Recruitment

We may use your personal information you provide to us through job applications, using our online website, email or via fax solely for the purposes of processing your job application for the position you have shown interest in and in accordance with this privacy notice and applicable law. This may also include data we collect from third parties such as recruiting firms, your references, prior employers and educational history in order to identify and evaluate candidates for potential employment. We may conduct vetting for specific job roles, which may include background checks as permitted by local laws. With your consent, we may retain a record of your job application and references for a period of 1 year.

Personal data integrity

While you are responsible for the accuracy of all personal information that you provide to us, we will use reasonable efforts to maintain the accuracy and integrity of your personal information, and to update that information as appropriate. We will take reasonable steps to ensure that the personal information we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorised by you.

Personal data sharing

a) Internal

Gas Africa Limited may transact business with affiliated parties. From time to time we may share your personal information within Gas Africa Limited structures. Such information may be used for internal business, operational, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorised by you.

b) External

We may disclose or transfer your personal information with our service providers. Normally, these would include Gas Africa Limited lawyers, auditors and consultants.

We may also, from time to time, employ service providers to perform services on our behalf, such as hosting our data (including your personal information), websites, products and other applications; fulfilling and processing orders for our products; or performing other administrative services for us. Prior to allowing these service providers to access your personal information, we will enter into a formal agreement with them to ensure that they handle and process the information in accordance with this Privacy Policy and applicable law and ensuring they have adequate technical and organisational controls in place to safeguard your personal data.

We will not share your personal information with third parties outside of Gas Africa Limited for their marketing purposes without your consent. However, we may share such information with our counterparties as described for the purposes disclosed to you at the time you provided the information, or as subsequently authorised by you or as permitted by applicable laws.

The personal information that we collect from you may be transferred to, and stored at, a destination outside Kenya. It may also be processed by members of staff operating outside of the country who work for us or one of our service providers.

If your personal information is held by us within Kenya, it will only be transferred outside the country after the following considerations – as provided by the law:

- The appropriateness of data protection safeguards during transfer;

- The transfers are to a country where adequate level of protection is ensured;

- The transfer is based on necessity and approved by the Office of Data Protection Commissioner; or

- If you have given consent to such transfer.

c) Legal Protections and Law enforcement

We may access, use, preserve, transfer and disclose to our counterparties your personal information for the following purposes:

- To satisfy any applicable law, regulation, or legal or regulatory process, if in our opinion such is required or permitted by law or reasonably requested by a regulatory authority (including the tax authorities);

- To protect and/or defend this privacy policy or other internal policies or terms of use applicable, including investigations of potential violations thereof, ensuring the protection of the safety, rights, property or security of Gas Africa Limited or any of our counterparties; and

- To detect, prevent or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as internet service providers, wireless service providers and/or law enforcement agencies, to access and use your personal information in order to identify you. We may take any of these steps without prior notice to you to the extent permitted by law.

Protection of personal information

We put in place reasonable safeguards and measure based on internationally recognised information security standards to protect your personal information in our possession from misuse, unauthorised access, disclosure, alteration, destruction or loss. We have a framework of policies, procedures and training/awareness in place covering data protection, confidentiality and security. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as categories of data deemed as sensitive under applicable data protection laws.

While we strive to secure your personal information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.

Data retention

We will not retain personal information for longer than is necessary for the purposes for which it was collected, except where retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. We have developed an internal data retention policy which is guided by the applicable laws.

Access, objection to processing, rectification and data erasure

Should you require to communicate to us in regard to access of your data, object to processing, request for rectification or erasure, kindly contact us through [email protected].

Request by employees can be communicated through the Human Resource department or in writing through [email protected].

Monitoring and enforcing this policy

We will conduct periodic internal compliance audits and assessments of our relevant privacy practices to verify adherence to this privacy policy.

Policy revision

This privacy policy is kept under regular review and is therefore subject to change.

Effective Date: 11th June 2025

Review Date: Annually or as required
Approved By: Managing Director