The UAE criminalises bribery of public officials and commercial bribery between private parties, and a company operating here may also be caught by **foreign legislation with extraterritorial reach** — UK, US and others — through its investors, banks, customers or group. Assume more than one regime applies.
Business Conduct
Anti-bribery, gifts, conflicts and sanctions
The UAE criminalises bribery of public officials and commercial bribery between private parties, and a company operating here may also be caught by foreign legislation with extraterritorial reach — UK, US and others — through its investors, banks, customers or group. Assume more than one regime applies.
| Item | Detail |
|---|---|
| Company | [COMPANY NAME], licence [NUMBER] |
| Applies to | Employees, managers, contractors, agents and intermediaries |
| Compliance contact | [NAME], [EMAIL] |
| Gift and hospitality threshold | AED [AMOUNT] — above this, approval required |
| Register held by | [ROLE] |
| Foreign regimes potentially applicable | [UK Bribery Act / US FCPA / other — assess] |
| Approved by | [NAME], [DESIGNATION], on [DATE] |
| Review | Annually |
1. The Rules
1.1No one acting for the Company shall offer, promise, give, request or accept any financial or other advantage intended to induce or reward improper performance of a function.
1.2This applies whether the other person is a public official or a private party, and whether the advantage is offered directly or through an intermediary.
1.3Facilitation payments — small payments to speed up a routine process someone is already obliged to perform — are prohibited, however normal they may appear.
1.4The prohibition applies to anything of value: cash, gifts, hospitality, travel, employment for a relative, a charitable donation directed by a counterparty, or a business favour.
1.5Never make a payment to avoid a fine, expedite a permit, or influence an inspection. Where a demand is made, refuse and report it to [ROLE] immediately.
1.6Where a payment is genuinely extorted under threat to personal safety, protect the person first, then report it immediately and record the circumstances in full.
2. Gifts and Hospitality
| Situation | Position |
|---|---|
| Modest gift at a customary occasion | Acceptable — record if above the threshold |
| Meal with a business counterparty | Acceptable if proportionate and not lavish |
| Anything to or from a public official | Approval required before offering or accepting |
| Cash or cash equivalent, any amount | Never |
| Gift or hospitality during a tender, negotiation or dispute | Never — timing alone makes it improper |
| Travel or accommodation paid for a counterparty | Approval required; must have a genuine business purpose |
| Repeated gifts from the same source | Report — the pattern matters more than each item |
| Gift to a family member of a counterparty | Treated as a gift to the counterparty |
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UAE law criminalises bribery of public officials and commercial bribery between private parties. A company here may also be within the reach of foreign legislation — UK, US and others — through its investors, banks, customers or group companies, some of which impose strict corporate liability with an adequate-procedures defence. Design the policy for the strictest applicable standard.
A small payment to speed up a routine process someone is already obliged to perform is a bribe under most applicable regimes. Staff encountering the practice routinely assume it is acceptable because it is common. Say explicitly that it is not.
Sponsors, PROs, consultants, agents, distributors and introducers act in the Company’s name, and their conduct becomes the Company’s problem. The due diligence in Section 3 is the single highest-value control in this policy — corporate liability in this area most often arrives through a third party.
A large success fee for vaguely described government relations or consultancy, paid to an account in a third country, is what every investigator looks for. Each element may be innocent alone. Together they are not, and the combination is what needs approval.
Hospitality that would be unremarkable in an ordinary month is improper during a tender, a negotiation or a dispute. The test staff can actually apply: would you be comfortable if the counterparty’s competitor knew about it?
Cash and cash equivalents have no legitimate place in gifts or hospitality, whatever the value. A blanket rule is easier to apply and easier to enforce than a threshold that invites judgement.
Routing a benefit through a spouse, child or relative is the most common way a gift rule is circumvented. State it explicitly so nobody can claim the point was unclear.
Where a payment is genuinely demanded under threat to personal safety, the individual’s safety comes first. Report immediately afterwards and record the circumstances fully — the contemporaneous record is what distinguishes extortion from a bribe.
Clause 6.4 is what makes the policy real. If a salesperson believes that losing a deal for refusing a payment will count against them at review time, no amount of policy language will change behaviour. Senior management has to mean it and be seen to mean it.
False invoices, unrecorded accounts and mischaracterised expenses are how bribery is funded and how it is detected. Accurate books are both a legal requirement and the strongest practical deterrent.
Lists change and counterparties change ownership. Screening at onboarding only is a snapshot. Periodic rescreening catches the counterparty that became a problem after the relationship started.
Real estate brokers, dealers in precious metals and stones, auditors, accountants and corporate service providers are subject to the full anti-money-laundering framework including goAML registration and reporting. Many businesses in these categories do not realise they are in scope.
Where a suspicious transaction report is made, the customer must not be told and the business must not behave in a way that reveals it — including declining a transaction in a manner that signals a report. Train customer-facing staff on this specifically.
Gift, hospitality and conflict registers are useful only if someone reads them. A quarterly review looking for patterns — the same counterparty, the same individual, clustering around a decision — is where the signal is.
Reflects UAE law and practice current as of {{DATE OF USE}}. UAE anti-bribery, anti-money-laundering and sanctions requirements change, DNFBP categories are amended, and applicable foreign legislation varies with your investor, banking and customer relationships — take legal advice on which regimes apply to your group and confirm the current position before relying on this policy.
This is a ready-to-use template provided for convenience. Laws and requirements change, and every situation is different — please have it reviewed by a qualified professional (a lawyer, corporate secretary, or accountant as relevant) before you rely on it.