1. Policy Statement:

At AHOY, we uphold our core values of integrity, transparency, and accountability in all our business dealings. We are committed to conducting our operations ethically and legally, strictly prohibiting bribery, corruption, and any other unethical conduct that could damage our reputation, undermine our integrity, or violate applicable laws, including those of the United Arab Emirates (UAE). This policy affirms our zero-tolerance stance towards any form of bribery and corruption and sets out the principles and standards required of all employees, directors, contractors, agents, consultants, and third-party representatives. 

2. Purpose and Objectives:

• To reinforce the importance of ethical conduct and compliance under UAE anti-bribery laws. 

• To provide clear guidance on acceptable and unacceptable behaviors related to bribery and corruption. 

• To prevent, detect, and address bribery and corruption within our business operations. 

• To establish a strong culture of integrity that supports sustainable growth and stakeholder confidence. 

3. Scope and Applicability:

This policy applies to all AHOY personnel, including full-time employees, temporary staff, contractors, consultants, agents, board members, and third-party partners acting on behalf of AHOY, both within the UAE and in internationally operating contexts. All individuals involved in AHOY’s business activities must familiarize themselves with and adhere to this policy. 

4. Legal Framework and Principles: 

This policy is aligned with and designed to comply with UAE Federal Law No. 3 of 1987 (UAE Penal Code) concerning anti-bribery and corruption, as well as other relevant UAE laws and regulations, including: 

• UAE Federal Anti-Commercial Fraud Law 

• UAE Law Concerning Criminal and Civil Penalties for Bribery and Corruption 

• UAE’s commitment to international anti-bribery conventions, including those by the United Nations and the Organisation for Economic Co-operation and Development (OECD). 

Our principles are based on: 

• Zero tolerance for bribery and corruption. 

• Commitment to lawful conduct and ethical integrity. 

• Maintaining transparency in all dealings. 

• Ensuring fair treatment of all stakeholders. 

• Providing training and resources to prevent misconduct. 

• Encouraging a speak-up culture for compliance concerns. 

5. Definitions and Clarifications: 

• Bribery: Offering, promising, giving, accepting, or soliciting anything of value (e.g., money, gifts, favors, hospitality, or other benefits) to influence the actions or decisions of a person in a position of authority or to gain an improper advantage. 

• Corruption: Abuse of entrusted power or position for personal gain or to benefit a third party dishonestly, including bribery, kickbacks, embezzlement, or facilitation payments. 

• Facilitation Payments: Small, unofficial payments made to secure or expedite routine government actions or services, which are strictly prohibited under this policy and UAE law. 

• Third Parties: Any external entity or individual acting on behalf of AHOY, including vendors, contractors, agents, partners, or representatives. 

6. Prohibited Conduct and Conduct Expectations: 

• Offering Bribes: Employees are strictly forbidden from offering, promising, or giving any bribe or illicit benefit directly or through intermediaries, regardless of whether such conduct is legal in the jurisdiction. 

• Receiving Bribes: Employees must refuse any inducement to influence or compromise their impartiality. 

• Gifts and Hospitality: All gifts, entertainment, or hospitality provided or accepted must be reasonable, proportionate, transparent, and permissible under local laws and AHOY policies. Gifts of substantial value or that might influence business decisions are prohibited unless explicitly approved by senior management and properly documented. 

• Third-Party Engagements: Before engaging third parties, conduct due diligence to assess risks and include contractual provisions requiring strict compliance with anti-bribery laws. 

• Facilitation Payments: Absolutely prohibit any facilitation payments, regardless of size or perceived urgency. 

• Use of Intermediaries: Ensure transparency in dealings with intermediaries; avoid schemes that conceal corrupt intent. 

7. Due Diligence and Risk Management: 

• Conduct comprehensive risk assessments and due diligence when selecting new business partners, agents, or contractors, focusing on their compliance with anti-bribery laws. 

• Regularly review and monitor third-party compliance through audits, performance assessments, and contractual obligations. 

• Maintain a register of high-risk transactions and third-party relationships for ongoing oversight.

8. Gifts, Hospitality, and Donations: 

• Gifts, hospitality, or donations should always be modest, transparent, and within reasonable standards customary in business practice. 

• All gifts and hospitality exceeding predefined monetary limits or considered potentially influential require prior approval from senior management and must be properly documented. 

• Donations to charities or political entities must be transparent, compliant