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Anti-Bribery and Corruption Policy

Purpose and Scope

At our company, we believe in earning business through the quality of our work, competitive pricing, and trusted reputation. This Anti-Bribery and Corruption (ABC) Policy outlines our commitment to conducting business ethically and with integrity.

This policy applies to all employees, executives, directors, and board members, as well as any third party acting on our behalf, including agents, consultants, suppliers, contractors, and joint venture partners.

Our Commitment

We maintain a zero-tolerance policy toward bribery and corruption. We do not offer, promise, give, request, or accept bribes or any improper advantage under any circumstances.

Under the applicable laws of the United Arab Emirates (UAE), bribery is a serious criminal offense in both the public sector (government officials) and the private sector (commercial business dealings).

Definitions

  • Bribery: Offering, promising, giving, requesting, or receiving anything of value to improperly influence a decision, secure an unfair business advantage, or affect a professional action.
  • Anything of Value: Includes cash, gifts, hospitality, entertainment, travel, accommodation, loans, employment opportunities, discounts, gift cards, charitable donations, or any other benefit.
  • Corruption: The misuse of entrusted authority or position for personal or commercial gain.

Gifts, Hospitality and Entertainment

Professional relationships may involve reasonable business hospitality. However, gifts or entertainment must never influence business decisions or create the appearance of improper conduct.

Acceptable

  • Occasional and modest gifts.
  • Reasonable business meals or hospitality.
  • Items that are transparent, properly recorded, and compliant with company policies.

Not Permitted

  • Cash or cash equivalents, including gift cards or vouchers.
  • Lavish gifts or entertainment.
  • Any gift or hospitality offered during tenders, contract negotiations, or bidding processes.

Government Officials

Interactions with government departments and public officials require the highest standards of integrity.

  • Never offer or provide anything of value to influence a government decision or obtain an improper advantage.
  • Facilitation payments (“grease payments”) intended to speed up routine government actions are strictly prohibited and illegal under UAE law.

Third-Party Relationships

We may be held responsible for the actions of third parties acting on our behalf. Therefore, we expect all business partners to maintain the same ethical standards.

  • Appropriate due diligence is conducted before engaging agents, consultants, suppliers, or contractors.
  • Business partners are required to comply with our Anti-Bribery and Corruption standards.
  • Unusual, excessive, or undocumented commissions or payments are prohibited.

Reporting Concerns

If you are asked to pay a bribe, offered a bribe, or suspect any form of corruption within our organization or supply chain, you must report it immediately.

Reporting Channels

  • Report the matter to your Line Manager.
  • Contact the Legal or Compliance Department.
  • Use our confidential or anonymous Whistleblower Reporting Channel, where available.

Protection Against Retaliation

Employees who refuse to participate in bribery or who report concerns in good faith will not face retaliation, discrimination, disciplinary action, or any adverse employment consequences, even if the company loses business opportunities as a result.

Enforcement and Consequences

Violations of this policy are treated seriously and may result in disciplinary and legal action.

  • Internal Action: Violations may result in disciplinary measures up to and including termination of employment or contractual relationships.
  • Legal Consequences: Individuals involved in bribery may face substantial fines, imprisonment, and other penalties under applicable UAE laws. The company may also face financial penalties, reputational damage, and regulatory action, including suspension of business licenses.

Policy Review

This policy is reviewed periodically to ensure continued compliance with applicable laws, regulations, and international best practices. All employees and business partners are expected to understand and comply with this policy at all times.