1. Purpose and Scope
We believe in winning business purely on the quality of our work, our competitive pricing, and our reputation. This Anti-Bribery and Corruption (ABC) Policy sets out our strict standards against bribery and corruption.
This policy applies to every employee, executive, and board member, as well as any third party acting on our behalf—including agents, consultants, suppliers, and joint-venture partners.
2. Our Position on Bribery
We have a zero-tolerance policy toward bribery and corruption. We do not offer, give, solicit, or accept bribes in any form, under any circumstances.
Under UAE Federal Law, bribery is a serious criminal offense that applies strictly to both the public sector (government officials) and the private sector (commercial business dealings).
3. Defining Bribery and Corruption
- Bribery: Offering, promising, giving, requesting, or receiving anything of value to improperly influence an action, secure an unfair business advantage, or affect a professional decision.
- "Anything of Value": This is not limited to cash. It includes gifts, hospitality, entertainment, travel, job offers, loans, discounts, or charitable donations.
- Corruption: The abuse of entrusted power or position for personal or commercial gain.
4. Key Rules and Expectations
Gifts, Hospitality, and Entertainment
While building professional relationships is a normal part of business, gifts and hospitality must never be used to influence a decision.
- What is acceptable: Occasional, modest tokens of appreciation or standard corporate hospitality (such as a business lunch) that are transparent, reasonable, and compliant with our internal limits.
- What is prohibited: Any gift or hospitality offered during active contract negotiations, tenders, or bidding processes. Cash or cash equivalents (like gift vouchers) are strictly forbidden.
Public and Government Officials
Dealings with government entities and public officials require extreme care.
You must never offer anything of value to a public official to influence a regulatory decision, secure a permit, or clear customs.
Facilitation Payments: Small, unofficial payments made to secure or speed up routine government actions (sometimes called "grease payments") are illegal under UAE law and are strictly prohibited by our company.
Third-Party Representation
We can be held legally responsible for the actions of third parties acting on our behalf.
- We conduct appropriate due diligence on agents, consultants, and suppliers before working with them.
- Our contracts require all partners to commit to anti-bribery standards identical to our own.
- We do not pay commissions or fees that are unusually high or unrecorded, as these can be used to disguise bribes.
5. Raising a Concern
If you are offered a bribe, asked to pay one, or suspect any corrupt activity within our business operations or supply chain, you must speak up immediately.
How to report:
- Contact your line manager or the Legal / Compliance Department.
- Use our secure, anonymous Whistleblower Channels.
Our Promise of Protection: No employee will suffer demotion, penalty, or any negative consequence for refusing to pay a bribe, or for raising a genuine concern about corruption—even if it results in the company losing business.
6. Penalties and Enforcement
Breaches of this policy carry severe consequences for both the individuals involved and the company.
- Internal Sanctions: Any employee who violates this policy will face immediate disciplinary action, up to and including termination of employment.
- Criminal Liabilities: Under UAE law, individuals involved in bribery can face substantial personal fines and lengthy imprisonment. The company can also face severe financial penalties and the suspension of business licenses.