Introduction

Al Ansari Financial Services (AAFS) has established this policy to provide guidance, to implement and maintain an effective Anti-Bribery & Corruption (ABC) Programme, prevent any acts of bribery and corruption, and facilitate the development of controls. The policy provides guidance on the standards of behaviour to which all must adhere and the good business practices to follow in AAFS. This policy is designed to help us identify when something is prohibited so that bribery and corruption are avoided, provide clear guidelines, and assign responsibility for the development of controls against ABC.

Policy Statement

The ABC policy confirms AAFS’ zero-tolerance stance on bribery and corruption. It sets out the organisation’s commitment to conducting all business activities in an honest and ethical manner.

The policy plays a key role in helping AAFS mitigate any risk originating from corruption and bribery, and ensures appropriate responses  to such matters that may cause damage to the organisation’s reputation, customers, financial standing and/or any other forms of loss. It is created the instill a culture of integrity and ethical behaviour fostering a work environment that is conducive to growth. In addition, it emphasises the importance of each employee’s individual responsibility in curbing any unethical or illegal activities in the organisation, along with helping AAFS in safeguarding its funds, maintaining integrity and complying with all relevant policies, procedures and regulations issued by the SCA/other regulatory authorities.

• AAFS takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly, and with integrity in all its business dealings and relationships.
• AAFS is committed to avoiding any acts which might reflect adversely upon the integrity and reputation of the Group.
• AAFS is committed to upholding all laws relevant to countering bribery and corruption in each of the jurisdictions in which it operates.
• AAFS is committed to developing a culture where it is safe for employees and stakeholders to raise concerns about any poor or unacceptable practice/ or any event of misconduct.
• AAFS strictly prohibits the giving or receiving of bribes—this includes promising, offering, giving, soliciting, or receiving anything of value, directly or indirectly, if improperly intended to influence decisions or gain undue advantage.
• AAFS assures all stakeholders that any suspected incidents will be thoroughly investigated. Prompt corrective and preventive actions will be taken, including disciplinary measures against individuals found guilty of such misconduct.

Risk Based Approach

AAFS adopts a Risk-Based Approach (RBA) for the adequate development and implementation of programmes to prevent, detect, and report acts of bribery and corruption. To achieve this, AAFS periodically assesses its business model including the locations in which it does business, its customer base, products and services, procurement, outsourcing activities and the means by which it obtains and retains business—such as the use of Intermediaries and engagement with other third parties.

Enterprise-Wide Risk Assessments (EWRA) as well as periodic assessments, enable AAFS to identify inherent risks and adopt policies, procedures, and controls that are proportionate to the identified risks. AAFS ensures to periodically assess the nature and extent of the bribery and corruption risks to which it is exposed, arrive at a residual risk rating that is the net result of the control effectiveness (the effectiveness of controls designed to mitigate those risks) and the inherent risk assessment.

Anti Bribery & Corruption Standards

Bribery and Corruption involves the following:

• When a financial or other advantage is offered, given or promised to another person with the intention to induce or reward them or another person to perform their responsibilities or duties improperly (it does not have to be the person to whom the bribe is offered that acts improperly); or
• When a financial or other advantage is requested, agreed to be received or accepted by another person within the intention of inducing or rewarding them or another person to perform their responsibilities or duties inappropriately (it does not have to be the person who receives the bribe that acts improperly)
• It does not matter whether the bribe is given or received directly or through a third party (such as someone acting on AAFS’ behalf or for the benefit of the recipient or some other person).
• Bribes can take many forms, for example:
• Money (or cash equivalent such as shares)
• Unreasonable gifts, entertainment or hospitality
• Kickbacks
• Unwarranted rebates or excessive commissions
• Unwarranted allowances or expenses
• Facilitation payments/payments made to perform their normal job more quickly or prioritise a particular customer
• Political/charitable contributions
• Uncompensated use of company services or facilities or
• Anything else of value
• It is prohibited for AAFS or its board, executive and senior management, employees, consultants or contractors to:
• Give, promise to give, or offer, a payment, gifts or hospitality to a third party or otherwise engage in or permit a bribery offense to occur, with the expedition or hope that an advantage in business will be received or to reward a business advantage already given.
• Give, promise to give, or offer, a payment, gift or hospitality to a third party to “facilitate” or expedite a routine procedure.
• Accept a payment, gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the Company in return.
• Threaten or retaliate against another employee or worker who has refused to commit a bribery offense or who has raised concerns under this policy.
• Engage in any activity that leads to a breach of this policy.

Elements of an ABC Programme

While no ABC Programme can prevent or protect completely against any bribery and corruption risks, and there is no one-size-fits-all solution, this policy is intended to help AAFS mitigate bribery and corruption risks across the following areas:

1. General Prohibition

All forms of bribery and corruption are prohibited; AAFS will not tolerate any act of bribery and corruption. A bribe does not actually have to take place- just promising to give a bribe or agreeing to receive one is prohibited.

2. Gifts, Hospitality and Entertainment

• Giving or receiving gifts or hospitality is often an important part of maintaining and developing business relationships. However, all gifts and hospitality should be for genuine purposes, reasonable, given in the ordinary course of business, and should comply with the Gifts, Hospitality and Entertainment (GHE) policy.
• Anything of Value: Giving (including promising, offering, or authorising) or receiving anything of value, including gifts and hospitality, employment, work experience (paid or unpaid), donations and charitable contributions, corporate sponsorships, and political contribution. Reasonable GHE is defined in the Gifts, Hospitality and Entertainment policy.

3. Facilitation Payments

• Facilitation payments are any payments, no matter how small, given to an official to increase the speed at which they do their job. For example, this could speed up compliance checks for processing a transaction or providing exemptions from internal policies/ procedures.
• All facilitation payments are generally prohibited, any request for a facilitation payment should be reported to Line Manager and Group Risk & Fraud Prevention Department.

4. Third Party Providers

• AAFS could be liable for the acts of people that act on behalf of AAFS; this includes agents, distributors, vendors, suppliers, contractors and joint venture partners together called as third parties.
• To promote commitment with effective anti-bribery and corruption policies by all third parties acting on behalf of AAFS, all third parties should be made aware of the terms and of their obligations to comply with it.
• All arrangements with third parties should be subject to clear contractual terms and conditions, including specific provisions requiring them to comply with minimum standards and procedures in relation to bribery and corruption. Appropriate wording to be included in the contracts; same to be vetted/ obtained from Legal.
• AAFS employees or subsidiaries shall not engage with any third parties known or reasonably suspected of engaging in bribery and corruption.
• Appropriate due diligence shall be undertaken before any third parties are engaged.

5. Dealing With Public Officials/Government

• All AAFS personnel must exercise caution and due diligence when interacting with government officials. Activities that may be permissible with private sector partners may be improper or illegal when working with a government official.
• If there are any questions regarding whether interactions with government officials are appropriate, the line manager should be contacted immediately.

Breaches and Reporting

Report any instances of non-compliances or incidents at [email protected] or at [email protected].