No supplier shall enter into a financial or any other relationship with a Safaricom employee that creates a conflict of interest for Safaricom.
Supplier Code of Conduct: Code -SAF-FIN-SCM-PUR-001 by Safaricom Limited.
Companies of Interest
- Pavicon Group
- Tetranet Services Limited
- Pavicon Kenya Limited
- Techminds Technologies Limited
- Nextgen Networks Limited
- Fireside Communications Limited
- Hatikvah Communications and General Engineering Limited
- Egypro East Africa Limited
Safaricom Employees
- Peter Ndegwa
- Paul Gathura
- Anthony Gacanja
- Elaine Kyalo
- James Maitai
- Nyagaka Ondiere
- Kevin Ochieng
- Catherine Maina
- Kelvin Mulongo
- Maryanne Karanja
- James Langat
- Wycliffe Kadima
- Suzanne Buku
- Edwin Ogero
- James Njuguna
- Felix Otero
- Evelyn Gitau
- Michelle Njeru
Associated with Safaricom Employees and/or Companies of Interest
- Rachael Kamau
- Caroline Gichina
- Caroline Ndumba
- Charles Njenga
- Jacquiline Cheboi
- Joel Kanyi
- Josephine Ngugi
- Robert Kinga
- Emily Nyongesa
- Macharia Kinga
- Martin Mwita
- Caroline Njoroge
- Annette Kamau
- Davis Kipkirui
- Joseph Kamau
- Rebecca Wanjiku
These reference boxes contain names of some of the companies, Safaricom employees, and other people mentioned in this post. These reference boxes appear throughtout this post to allow for easy referencing of individuals and companies.
If any person or company believes that it has been unfairly mentioned in this post, they can get in touch with us with their complaints. I recommend they text via WhatsApp.
This post is a product of research on Paul Gathura and his relationship with the chief executive officer (CEO) of Safaricom PLC, Peter Ndegwa. The information I received last year was that Gathura had skewed the procurement and tender awarding process to favor a select group of companies, which had been onboarded onto Safaricom’s supplier network. There were also allegations of employee intimidation, unprocedural hiring of new employees, and unprocedural promotion of employees in the company. Other allegations were that Gathura influenced the termination of 7 employees in the procurement department, as well as ensured that tenders were awarded to companies that are controlled by politically well-connected individuals from Murang’a county.

The initial plan was to write an expose on Gathura, which I declined. Such an expose would have caused Safaricom to suffer reputational damage that could be compounded by fines for breaching corporate governance laws, ethical rules, and both in-house and internationally accepted anti-corruption protocols. So, why did I decline to write the expose?
The reason is simple, Gathura was a symptom of corporate malady afflicting Safaricom, and it was better to address this malady than addressing individual employees. Tender fraud in Safaricom cannot be lumped upon the shoulders of a single person in the supply chain department i.e Gathura cannot be the scapegoat. It is a systemic malady that affects this department. The principal losers in this fraud are the shareholders and customers of Safaricom.
Gathura will get an entire section in this post, but the information that was to be included in his expose served to provide names of companies that are alleged to have benefitted from tender fraud in Safaricom. These companies are among the companies of interest in this post.
On February 1, 2025, a new voluminous data set came online that simplified the process of searching for companies and their owners. For this research, this data set made it easier to unmask the proxy persons and proxy entities associated with these companies of interest.
I have to admit that I did not know the listed owners of some of these companies, and even information about their ultimate beneficial owners was scanty. Fortunately, this data set is helping to fill the gaps.
Another important piece of information provided by this data set is the extent of layering in the companies of interest. So far, I have not noticed any of these companies issuing bearer shares (the equity equivalent of bearer bonds). Issuance of bearer shares by a company is a sure sign that some of its owners want to remain unknown, and this raises the obvious question: why do they want to hide their identities?
A brilliant and persuasive research into Safaricom PLC should be able to accelerate price discovery of its share price. This acceleration is dependent on whether the public float is shorted or not. If the research proves that Safaricom has been engaging in fraud and corporate misgovernance, then its share value can decline.
Preliminary Notes on Upcoming Report on Safaricom Group
Layering
Layering is the process by which a company owns another company. In multi-jurisdictional layering, the owned company and its owner (company) are registered in different countries. This form of layering is not universally illegal as it provides an avenue for a company to access financing from foreign financiers, among other legal, reputational, and financial benefits.
For example, Peter Waititu Ndegwa is one of the directors of Circle Gas Limited, which was incorporated in the United Kingdom (UK) on September 26, 2018 as a private limited company whose company number is 11588906. Circle Gas Limited was previously known as Safarigas Limited. Circle Gas Limited is hosted in the same address as CircleTech Limited which was incorporated in the UK on May 20, 2019 as a private limited company whose company number is 12004360. CircleTech Limited was previously known as Kopa Tech Limited. With this information, one can easily guess that these two companies must have (or had) operations in Kenya. I knew that both Circle Gas Limited and CircleTech Limited are associated with M-Gas – a product powered by Safaricom Group. By being registered in the UK, Circle Gas and CircleTech allow M-Gas to benefit for European equity and debt financing, while accessing high-quality European technology for the product that it offers Kenyans. This way, the Kenyan customer benefits from this arrangement.
This post considers other forms of multi-jurisdictional layering with relation to companies of interest and fraud. For now, there is need to mention another form of layering.
An interesting form of layering in association with this post is same-jurisdiction layering. This means that the owned company and the owner (company) are registered in the same jurisdiction/country. For example, Pavicon Kenya Limited owns Pavicon Technologies Limited, and both companies are registered in Kenya. What is unique about this form of layering is that it allows the same beneficial owners to bid for the same contracts as different companies, thus improving their odds of winning the bids, while disadvantaging competitors as they can quote lower prices (as different companies) thus creating the perception that other bidders are expensive.
Pavicon Group – The Unregistered Entity Contracted by Safaricom Group
What is interesting about Pavicon Group is that it is not registered as a company in Kenya as of January 20, 2025. Still, this has not stopped Josephine Kanyi from publicly presenting herself as the CEO of Pavicon Group for months, even inviting senior Safaricom employees to visit ongoing projects by “Pavicon Group”. So, is Safaricom working with an unregistered company which is against its own (company) corporate rules?

The answer to this question is a Schrödingeresque yes and no. What has happened is that the owners of the registered company want it to appear bigger, wealthier, and more capable than it really is. This could be due to the desire to get more tenders and/or more better-paying tenders. The apparent image of a wealthy and successful company that owns subsidiaries has the quantitative benefit of attracting more businesses (including tenders and contracts) as well as the qualitative advantage of bagging high paying contracts and being in good position to get good terms of debt financing.
Safaricom tenders pay better than tenders the company got previously, such as the tender the registered company got in September 2020 with a government agency. So, what is the registered company and what tender did it get? The registered company is Pavicon Kenya Limited as explained later. The tender is described hereafter.
On September 23rd, 2020, Pavicon Kenya Limited was awarded a tender worth KES 21,278,869 by the Rural Electrification and Renewable Energy Corporation (REREC). REREC is a government agency that works closely with Kenya Power. For reference, the tender number was 1000000462, and members of the evaluation team were Jonathan Mbutu, Nicholas Muigai, John Otido, and Caroline Kelly. On the same day, this evaluation team also awarded tenders to Bizrate Enterprises and Go Solar Systems. This information is enough to confirm that Pavicon was awarded a tender on the said date by a government agency. Now, the focus shifts to the company.
The apparent image of a wealthy and successful company that owns subsidiaries has the quantitative benefit of attracting more businesses (including tenders and contracts), as well as the qualitative advantage of bagging high paying contracts and being in good position to get good terms of debt financing.
As mentioned earlier, Pavicon Group was not registered at the time this post was first published. The company that I have confirmed to be registered is Pavicon Kenya Limited which was duly-registered in 2011 with the registration number CPR/2011/52865 and company PIN P051363817W.
Pavicon Kenya Limited (or Pavicon (K) Limited) has two listed directors and two corporate secretaries. The directors are Joel Kanyi Kimani and Josephine Njeri Ngugi. Josephine Njeri Ngugi is the majority shareholder with 700 shares, while Joel has 300 shares. The two corporate secretaries are Charles N. Njenga and Emily Nafula Nyogesa.
Apart from Pavicon (K) Limited, Joel Kanyi is registered as the owner of two other companies – Pabit Enterprises and Fufu Enterprises– as well as the director of two companies – Prunes Plastic Limited and Expedition Motors Limited. For Josephine Njeri, she is listed as the owner of Robinia Enterprises and Aqualet Enterprises, as well as the director of Espin Limited and Pavicon Technologies Limited (which was mentioned earlier in this post).
In Kenya, a private company can have a corporate secretary – commonly described as the company secretary – who can be registered with the Institute of Certified Secretaries (ICS). According to Muhoro and Gitonga Associates – a law firm – the company secretary serves to ensure that the company complies with legal and mandatory regulatory frameworks, as well as promote good corporate governance while aiding directors in making strategic decisions that impact the viability of the company. This means that the corporate secretary can be involved in creation of informal business names and change of names of a registered business entity.
So, did Charles Njenga and Emily Nyongesa give the green light for the registered company to present itself publicly as Pavicon Group? If yes, does this expose the companies associated with these two secretaries to reputational risks, as well as legal and compliance risks? These two secretaries are associated with over two dozen companies/businesses.
Charles Njenga is associated with 20 other companies/businesses, namely:
- Adept Designs and Creations Limited
- Afribridge Construction Company Limited
- Africem Engineering Limited
- Afrinova Insurance Agency Limited
- Aquinas Construction Company Limited
- Babuji Supplies Limited
- Gemini Logistics Limited
- Jerewaithemu Investments Limited
- Kewell Investments Limited
- Kings Gate Development Limited
- Kuja Trading Company Limited
- Ngorika Limited
- Prime Home Depot Limited
- Prime Roofing Limited
- Ruiru Academy Limited
- Salnatek Investments Limited
- Tokop Kenya Limited
- Touchon Computer System Limited
- Vivacity Limited
- World Class Motorcade Limited
Apart from Pavicon Kenya Limited and Nyongesa Nafula and Company Advocates, Emily Nyongesa is associated with 6 other companies,/businesses, namely:
- Asili Food Produce Limited
- Convey Dot Africa Limited
- Globe Oil Service Station Kenya Limited
- Greladies Investments Limited
- Jubilee Ventures Limited
- Kikingi Holdings Limited
On February 2, 2025, a search made for Charles Njenga in the membership list provided by the ICS returned a negative result i.e he is not listed as an ICS-certified company secretary. A similar search for Emily Nyongesa on the ICS membership list expectedly returned a negative result. This was to be expected as she is an advocate whose practicing status is indicated as active by the Law Society of Kenya (LSK). Her work place is listed as Nyongesa Nafula & Co. Advocates as shown below.

Because one of the corporate secretaries was an advocate, I considered that Charles Njenga can also be an advocate practicing commercial law and/or corporate law. So, I searched for his name in the LSK advocate list and it returned a result for a Charles Ngugi Njenga whose license number is P.105/5734/05 and the assigned LSK practice number is LSK/2025/008139. His work place is listed as MKN & Co. Advocates as shown below. To me, what is interesting is that MKN & Co. Advocates was not listed by the Business Registration Service (BRS) as one of the entities associated with Charles Njenga of Pavicon (K) Limited.

Now, we move away from the company owners and corporate secretaries. The focus now is on relationship between Pavicon (K) Limited and Safaricom employees.
So, who are the Safaricom employees associated with Pavicon? They are …
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