10 August 2023


XSML Capital and African River Funds are incorporated in the Republic of Mauritius and licensed by the Financial Services Commission. 

This compliance policy consists of an Anti-Financial Crime Policy (last updated September 2023), Anti-Bribery and Corruption Policy (September 2023), and Anti-Money Laundering and Combating the Financing of Terrorism Framework Policy (February 2023). It applies to XSML and all its affiliates: XSML Partners Holding, XSML Capital, KingKuba Capital SARL (‘KingKuba’), XSML Management B.V, XSML Capital Uganda Ltd, XSML Capital DRC (Democratic Republic of Congo), XSML Angola and any future affiliate or subsidiary (all named ‘XSML’) as well as all the funds under the management of an XSML entity. 

We strive to ensure that our investors, shareholders, employees, portfolio companies and all parties with whom we do business can rely on us to work responsibly and ethically. Transparency and disclosure are essential to us.   

Business integrity and Anti-Money Laundering Policy
XSML is committed to the prevention of financial crime such as money laundering, the funding of terrorist activity, bribery, corruption and fraud, and through risk-based internal procedures, policies, systems and controls strive to ensure that high standards of crime prevention and awareness are maintained by all Partners, Directors, employees and consultants, whether under a contract of employment or a contract of service or otherwise (staff). 

XSML’s anti-money laundering (AML) policy is designed to ensure compliance with the requirements and obligations set out in EU directives, OECD guidelines and other pertinent regulations, rules, and industry guidance. This policy includes the appointment of a Money Laundering Reporting Officer (MLRO) who has responsibility for oversight of XSML’s compliance with the relevant legislation, regulations, rules, and industry guidance. Our staff receive relevant AML training annually. 

Anti-bribery and anti-corruption
XSML has a zero-tolerance approach towards bribery and corrupt practices and will always operate fairly and transparently and act proportionately to comply with relevant Anti-Bribery Regulations, in particular those of our main regulator, Finacial Services Commission in Mauritius, but also applicable EU Directives and OECD guidelines. XSML’s Code of Conduct and Ethics endorses the zero-tolerance approach to bribery and corruption and sets the standards to be applied to the conduct of XSML’s business. Corruption, bribery and unfair or anti-competitive practices have a negative effect on the workplace and our business and XSML takes pride in its ethical approach to doing business. We insist on integrity in our staff and expect the same from all those that we do business with. 

XSML is committed to preventing fraud from occurring and to developing an anti-fraud culture. It has developed and maintains effective controls to prevent fraud, ensures that if a fraud occurs a prompt investigation takes place, takes appropriate disciplinary or legal action where justified, reviews systems and procedures to prevent similar frauds and records and reports all cases of fraud. To this end, XSML has an Anti-Financial Crime Policy. 

 XSML staff are required to have the highest standards of honesty and integrity in the exercise of their duties. XSML will not tolerate fraud, impropriety or dishonesty and will investigate all instances of suspected fraud, impropriety or dishonest conduct by its staff or external organizations. 

Any person who believes that an XSML staff member is involved in bribery and corruption, or fraud is strongly encouraged to report their concerns on our speak-up/complaints page. 

XSML is committed to the highest standards of transparency and reporting and has voluntarily agreed to conform on a “comply or explain” basis with the obligations of the National Code of Corporate Governance for Mauritius. 

Conflicts of interest
XSML recognizes that there might be some situations that may present its employees with a possible conflict of interest, involving personal and or professional loyalties. We have in place policies to facilitate discussion about any potential conflict of interest and have developed ways to ensure all such conflict is properly cared for.