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Diabos Anti-Bribery and Corruption Policy

1. POLICY STATEMENT

1.1.This Anti-Bribery and Corruption policy complements the core DIABOS values of transparency, honesty, integrity, and mutual respect in every relationship.
1.2.DIABOS adopts a zero-tolerance approach to bribery and corruption, and is committed to conducting business in a professional and ethical manner while abiding by laws, rules, and regulations framed to counter bribery and corruption.
1.3.The purpose of this policy is to:
 a.Prevent any DIABOS’ employee from engaging in any corrupt practices or activities that are against the laws, rules, and regulations of India or any other countries, and to define standards / rules for maintenance of accurate books and records, in accordance with FCPA-1977 (Foreign Corrupt Practices Act-1977), UKBA-2010 (United Kingdom Bribery Act-2010), Prevention of Corruption Act (Amendments) Bill - 2015 as well as other anti-bribery and corruption laws;
 b.Provide guidance to DIABOS’ employees pertaining to identification of and reporting any violations pertaining to bribery and corruption that they may encounter in the course of their work.

2. APPLICATION OF THE POLICY

2.1.This policy applies to all employees and third parties associated with DIABOS,
 a.Employees include directors, senior managers, officers, employees (whether permanent or temporary), consultants, and trainees amongst others;
 b.Third parties include agents, brokers, consultants, contractors, subcontractors, sponsors, service providers, and vendors amongst others.

3. WHAT IS A BRIBE?

3.1.Giving, offering, promising, authorizing the giving of, soliciting, or accepting anything of value to, or from, any government official or employee, consultants, contractors, trainees, representatives, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located, or other party whether affiliated with a government or government entity, or private entity, with the corrupt intent to obtain or retain business, or secure an unfair business advantage.

4. GIFTS AND HOSPITALITY

4.1. Gifts:
DIABOS’ employees will not offer or accept a gift to or from any Government official, vendor, agent, or any other third party, unless the gift is:
 a.given openly and transparently,
 b.modest in nature, not to exceed USD 250, and
 c.not in anticipation to gain business or to prevent any sort of disciplinary action by regulatory authorities.
4.2. Travel:
DIABOS’ employees will not offer or accept any kind of travel arrangements to or from, any Government official, vendor, agent, or any other third party, unless the travel is:
 a.necessary to accomplish DIABOS’ business;
 b.modest and consistent with DIABOS’ Travel Policy;
 c.not inclusive of any additional costs (e.g. airfare, meals) associated with any Family Member, or other guests who may travel with the recipient of the travel, unless such persons qualify to receive such travel support in their own right;
 d.not inclusive of any stopovers at locations other than the locations required by the business purpose of the travel, unless the recipient pays the cost of the stopover; and
 e.consistent with any applicable contractual requirements.
4.3.Meals:
DIABOS ’employees will neither provide a meal to, nor accept a meal from, Government officials, vendors, agents, or any other third party, unless the meal is:
 a.held in an environment that is conducive to business; and
 b.incidental to a legitimate discussion regarding DIABOS’ business, such as business development and operational issues ; and
 c.modest in nature, not exceed USD 250.

5. BUSINESS COURTESIES

5.1. DIABOS will neither directly nor indirectly:
 a.give, offer, promise, authorize the giving of, solicit, or accept ‘Business Courtesies’ to or from anyone in violation of law or in order to improperly induce, reward, or in any way influence:
  i.issuance of regulatory approvals by Governments or Government Entities;
  ii.award of contracts or other business from or with any Government or Government Entity;
  iii.any other activity to secure an unfair business advantage for DIABOS;
 b.give, offer, promise, authorize the giving of, solicit, or accept cash or cash equivalents (e.g., cheques, coupons, lottery tickets, gift certificates, gift cards) as ‘Business Courtesies’ to, or from, any third party under any circumstance; or
 c. use any third party to give, offer, and promise, authorize the giving of, solicit, or accept a ‘Business Courtesy’ that is inconsistent with this Policy.
5.2. DIABOS will ensure that:
 a.it accurately records and reports all expenses related to Business Courtesies in accordance with its policies governing expense reporting;
 b.all stakeholders consult the Compliance Cell with any questions regarding this Policy, including the appropriateness of specific Business Courtesies or Business Courtesies not directly covered by this Policy by writing to compliance@diabos.ae.
5.3. Procedures
 a.Approval to give/offer/provide a Business Courtesy
  i.An Employee wishing to provide a Business Courtesy should obtain a written prior approval from the Compliance Cell. The approval should include:
    • description of the proposed ‘Business Courtesy’;
    • monetary value of the ‘Business Courtesy’ to be provided/offered/given;
    • names of proposed recipients of the ‘Business Courtesy’, their titles, and names of the organization with which they are affiliated; and
    • business case for providing the ‘Business Courtesy’.
  ii.The Compliance Cell will:
    • assess compliance with this Policy, including, but not limited to, the appropriateness of the Business Courtesy under local law;
    • document its assessment;
    • provide the requestor :
      • written approval or denial; and
      • instructions for any additional steps that must be taken prior to, in conjunction with, or after providing the Business Courtesy, if approved.
 b.Approval to Accept a Business Courtesy
  i.An employee willing to accept the ‘Business Courtesy’ should obtain prior approval from the Compliance Cell;
  ii.Instance wherein an employee has accepted ‘Business Courtesy’ exceeding USD 250 should be immediately reported to the Compliance Cell.

6. DONATIONS

6.1.DIABOS will not give, offer, or promise contributions to any political candidates, parties, initiatives, referendums, or other political campaigns.
6.2.DIABOS may give, offer, or promise Contributions, Sponsorships, Education Grants, or grants to Charitable Organizations or other appropriate individuals or entities, if the contribution is:
 a.consistent with local laws;
 b.not connected to decisions related to:
   i.the issuance of regulatory approvals by Government or Government Entities;
   ii.the award of contracts or other business from, or with, any Government or Government entity, customer or vendor;
   iii.any other activity to secure an unfair business advantage for DIABOS.
  c.approved in advance by:
   i.the Compliance Cell in accordance with laid down procedures;
   ii.the Compliance Cell for any contribution to a single Charitable Organization or other applicable individual or entity, if the contribution, either individually or in aggregate with other contributions that have been made in the financial year, exceeds USD 500;
  d.paid directly to the Charitable Organization or other preapproved individual or entity benefiting from the contribution and not through a third party; and
  e. accurately recorded and reported in accordance with DIABOS’ accounting policies governing Corporate Contributions.
6.3.Records to be maintained:
The below mentioned records/ documents should be maintained with description of the recipient, its objectives, and any supporting documentation (e.g. fundraising materials, invitations, brochures);
 a.contribution amount and the mode of payment. Contribution amount should be preferably paid by a cheque / demand draft / bank transfer;
 b.contributions made in cash should be approved by the Compliance Cell;
 c. usage of contribution by the recipient;
 d.benefit derived by DIABOS (e.g. recognition in promotional materials, booth space), if any;
 e.certifications that the recipient does not take any contribution into account when awarding or renewing contracts, or when referring or purchasing goods, services, or other business.

7. STAKEHOLDERS’ RESPONSIBILITIES

7.1.DIABOS will obtain an annual confirmation from all employees (including senior management), vendors, agents and other third parties stating;
 a.All employees (including senior management), vendors, agents, and other third parties have not directly or indirectly on behalf of DIABOS:
  i.given, offered, promised, authorized to be given, solicited or accepted Anything of Value to, or from, any Government Official or any other party, whether affiliated with a Government or Government Entity, or private entity, with the corrupt intent to obtain or retain business, or secure an unfair business advantage; or
  ii.used or authorized any third party to perform activities that are inconsistent either with this policy or any other DIABOS’ policy or procedure, the Code of Conduct, or applicable laws and regulations;
 b.all transactions have been accurately recorded and reported; and
 c.potential violations, if any, have been appropriately recorded and disclosed and that they are not aware of any unreported suspected violations.
7.2.Employees, agents , vendors, and other third parties are responsible for:
 a.reading, understanding, and following the Code of Conduct, this Policy, and all other applicable DIABOS’ policies;
 b.monitoring for, and reviewing with the Compliance Cell, any indicators of potential corruption risk or situations that warrant additional anti-corruption scrutiny, including, but not limited to:
  i.contract terms with vague deliverables or no description of the work that will be performed;
  ii.insufficiently justified requests for amended contract terms;
  iii.requests for fees, bonuses, and other payments tied to the success of particular transactions;
  iv.requests for payments to be made to a different entity or in a different country;
  v.requests by a Government Official or Employee to use a particular Contractor, Family Member, or Other Third Party; or
  vi.invoices that do not appear genuine: e.g., backdated, duplicate, or consecutively numbered invoices, or round-dollar transactions;
 c.reporting all Suspected Violations to the Compliance Cell; and
 d.cooperating with any compliance inquiry, audit, investigation, or other activity related to this policy and the Code of Conduct or a Suspected Violation including, but not limited to, reviews of, and interviews concerning, payments to third parties, expense vouchers and reports, and sample transactions.
7.3. The Compliance Cell is responsible for:
 a.development, communication, and implementation of anti-bribery and corruption-related compliance policies;
 b.oversight, implementation, and monitoring of anti-corruption-related compliance training; and
 c.oversight and implementation of the Compliance Hotline, including review, investigation, and remediation of any reports of Suspected Violations.
7.4.DIABOS will:
 a.not tolerate any form of Retaliation for reporting a Suspected Violation in Good Faith; and
 b.apply Corrective Action to Employees, Third Party Intermediaries, and Contractors for substantiated Compliance-Related Violations.

8. RECORDS

8.1.DIABOS will keep financial records and have appropriate internal controls in place, which will evidence the purpose for making payments to third parties.
8.2.All expenses claims relating to hospitality, gifts or expenses, business courtesies, donations, meals incurred for the benefit of third parties are submitted in accordance with our expense policy and specifically record the reason for the expenditure.
8.3.All accounts, invoices, documents, and records relating to dealings with third parties, such as clients, suppliers, and business contacts, should be prepared and maintained with strict accuracy and completeness. No transactions may be kept "off-book" to facilitate or conceal improper payments.

9. HOW TO RAISE A CONCERN

9.1.Stakeholders are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If one is unsure whether a particular act constitutes bribery or corruption, or has any other queries, these should be reported to the DIABOS Compliance Cell by,
 a.Calling the Ethics Helpline on +971 4 372 40 25
 b.Writing an email to compliance@diabos.ae

10. PROTECTION

10.1.Employees who refuse to accept or offer a bribe, or those who raise concerns or report another person's wrongdoing are sometimes worried about possible repercussions. DIABOS encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
10.2.DIABOS is committed to ensure that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern.

11. TRAINING AND COMMUNICATION

11.1.Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy.
11.2.An online copy of the policy is available on the Intranet and is accessible to all employees. This online copy is periodically updated by the Compliance Cell.
11.3.Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and as appropriate thereafter.

12. MONITORING AND REVIEW

12.1.The DIABOS Compliance Team will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible.
12.2.The policy will continue to be in force unless superseded by a fresh policy. Management of DIABOS Global Fze reserves the right to withdraw, cancel, amend, abrogate, modify, or reinstate the policy fully or partially at any point of time.