Anti-Bribery Policy of A2B GOLD DMCC

1. Policy Objective
The Anti-Bribery Policy of A2B GOLD DMCC aims to ensure compliance with local, regional, and international anti-bribery and anti-corruption regulations. This policy seeks to prevent, detect, and address any form of bribery and corruption within the company’s operations, ensuring that A2B GOLD DMCC conducts its business with integrity and transparency.

2. Scope
This policy applies to all employees, directors, officers, contractors, suppliers, and third parties associated with A2B GOLD DMCC. It covers all jurisdictions where A2B GOLD DMCC operates, particularly the UAE, GCC region, EU, and any other regions subject to applicable anti-bribery laws such as the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and UAE Federal Penal Code.

3. Legal Framework
The following laws and regulations form the legal basis for the Anti-Bribery Policy:
  • UAE Federal Penal Code (Federal Law No. 31 of 2021) and Decree Law No. 36 of 2022, which define bribery as the act of offering, giving, receiving, or soliciting something of value as a means of influencing the actions of an individual in a public or private position.
  • U.S. Foreign Corrupt Practices Act (FCPA), which prohibits the bribery of foreign government officials for business advantages.
  • UK Bribery Act 2010, which criminalizes both public and private sector bribery, including facilitation payments.
  • EU Anti-Corruption Framework, including the Treaty on the Functioning of the EU (TFEU), which treats corruption as a serious cross-border crime.

4. Key Policy Principles
A2B GOLD DMCC adopts a zero-tolerance stance on bribery and corruption, which is reflected in the following principles:
  • Prohibition of Bribery: No employee, contractor, or agent of A2B GOLD DMCC may offer, give, solicit, or receive any bribe, kickback, or other improper payment to gain a business advantage.
  • Gifts and Hospitality: Any gift or hospitality that could influence decision-making or be perceived as a bribe is strictly prohibited. Nominal gifts of low value may be accepted if they are customary in the local business context, but they must be reported to the compliance department.
  • Third Parties: A2B GOLD DMCC must ensure that its agents, suppliers, and third-party service providers comply with this policy. Contracts must include anti-bribery clauses to prevent third-party corruption.
  • Facilitation Payments: Facilitation payments (small payments made to expedite routine actions by officials) are prohibited under this policy and the laws of the UAE, UK, and EU.

5. Procedures for Compliance
  • Due Diligence: Enhanced due diligence must be conducted on all business partners, suppliers, and third parties, particularly in high-risk jurisdictions or sectors. All third-party relationships must be scrutinized to prevent indirect involvement in corrupt practices.
  • Training and Awareness: Regular training sessions on bribery and corruption must be provided to all employees and relevant third parties. These sessions will ensure that everyone understands the policy and the importance of compliance.
  • Whistleblowing and Reporting: A2B GOLD DMCC will maintain a confidential whistleblowing mechanism for reporting suspected bribery or corruption. All reports will be investigated thoroughly, and appropriate actions will be taken.

6. Penalties and Disciplinary Actions
  • Employees or third parties found in violation of this policy will face severe disciplinary measures, including termination of employment or business relationships. Additionally, they may be subject to legal action under applicable anti-corruption laws.
  • Violations may also result in significant fines and imprisonment, as outlined in the UAE Federal Penal Code, with fines equal to the value of the bribe or higher.

7. Monitoring and Auditing
The Compliance Department is responsible for monitoring compliance with the Anti-Bribery Policy. Regular internal audits will be conducted to identify potential risks or violations, and any non-compliance will be reported to senior management.

8. Contact Information
For any questions or concerns regarding this policy or to report suspicious activities, please contact our Compliance Officer at compliance (at) a2bgold.com.