Anti-bribery and corruption

Our position

Bribery and corruption are prohibited in all our dealings. Bribery means offering, promising, giving, requesting or accepting a financial or other advantage to induce or reward the improper performance of a function or an activity, or where accepting the advantage would itself be improper. Corruption means the abuse of an entrusted position for private gain. We do not engage in either, and we do not tolerate either by anyone who acts for us.

We compete on the quality of our people and our delivery. We never seek to win or keep business, or to gain any improper advantage, through a bribe or any other corrupt act.

Who this policy applies to

This policy applies to everyone who works for or acts on behalf of Corpshore Emirates. This includes directors, officers, employees, agency staff, contractors, consultants and any other third party who performs a service for us or represents us. Every such person is responsible for reading this policy, for understanding it, and for complying with it. Managers are responsible for making sure that the people they lead understand and follow it.

We also expect our clients, our suppliers and our business partners to share our commitment to honest conduct, and we reserve the right to end a relationship where that commitment is absent.

Gifts and hospitality

This policy does not prohibit reasonable and proportionate hospitality that is given or received in good faith to build a normal business relationship. It does prohibit any gift or hospitality that is intended to, or that could be seen to, improperly influence a decision. A gift or hospitality is acceptable only where all of the following are true.

• It is not made with the intention of influencing a person to act improperly, and it is not made to reward improper conduct.
• It is given openly, not secretly, and it is not offered in the form of cash or a cash equivalent.
• It is reasonable and proportionate in its value and its nature, taking account of the reason for it and local custom.
• It complies with the rules of the recipient organisation and with all applicable law.
• It is recorded where our internal procedures require a record.

Particular care is needed with a government official or a public body, where even a modest gift can be improper. If you are ever unsure whether a gift or an item of hospitality is acceptable, do not offer or accept it until you have asked for guidance.

Facilitation payments

Facilitation payments are prohibited. A facilitation payment is a small unofficial payment made to secure or speed up a routine action to which the payer is already entitled, for example the processing of a permit. We do not make or accept facilitation payments of any kind, and we do not allow anyone acting for us to make them, regardless of local practice. If you are asked for such a payment you must decline it and report the request.

Third-party and client due diligence

A significant bribery risk can arise through a third party who acts for us. We carry out risk-based due diligence on the agents, the intermediaries, the suppliers and the partners we engage, and on the clients we take on, so that we understand who we are dealing with and the risk they present. Where the risk warrants it, we include anti-bribery obligations in the contract, we reserve audit and termination rights, and we monitor the relationship through its life. We pay a third party only for a genuine service, at a rate that reflects the value of that service, and against a proper invoice.

Conflicts of interest

A conflict of interest can lead to corrupt conduct even where none is intended. Everyone who acts for us must avoid a situation where a personal, financial or family interest conflicts, or could be seen to conflict, with the interest of Corpshore Emirates or of a client. Where a conflict arises or may arise, you must declare it promptly so that it can be managed. You must not use your position with us for personal gain or for the gain of a person connected to you.

Record-keeping and controls

Accurate records are a defence against corruption. We keep complete and accurate books and records for all transactions, and we maintain internal financial controls that are designed to prevent and to detect bribery. No account, invoice or record may be false, misleading or incomplete, and no undisclosed or unrecorded fund or account may be established for any purpose. Expenses claimed in connection with a gift or an item of hospitality must be recorded honestly and in enough detail to show the reason for them.

How to raise a concern

You must report any bribery or corruption, and any suspicion of it, as soon as you become aware of it. If you are offered a bribe, if you are asked to make one, if you believe or suspect that any bribery or corruption has occurred or may occur, you must speak up. Raising a genuine concern in good faith is the right thing to do, and it will never lead to detrimental treatment, even if the concern turns out to be mistaken.

You can raise a concern through our whistleblowing policy at /legal/whistleblowing-policy, which explains the channels available and the protection given to anyone who reports in good faith. You can also contact us directly at info@corpshore.ae. We treat every report seriously, we handle it confidentially so far as we can, and we investigate it properly.

Consequences of breach

A breach of this policy is treated as a serious matter. For an employee it may lead to disciplinary action up to and including dismissal for gross misconduct. For a contractor, an agent or another third party it may lead to the immediate termination of the contract or the relationship. Bribery and corruption are also criminal offences under the laws of the United Arab Emirates and under the laws of other countries. A person who engages in them may face prosecution, a fine and imprisonment, and Corpshore Emirates itself may face significant legal and financial consequences. We cooperate fully with any competent authority in the investigation of a bribery or corruption offence.

Review of this policy

We review this policy regularly to keep it effective and aligned with the law and with good practice. The current version is always the version published on the website, and the date at the top shows when it last changed. If you have a question about this policy please contact us at info@corpshore.ae.