Scope of the Policy

• This policy applies to:

  • All employees (permanent, temporary, or contractual)

  • Agents, consultants, suppliers, and third-party business partners

  • Subsidiaries and joint ventures under the company’s operational control

Prohibited Conduct

• We strictly prohibit the following activities:

  • Offering, giving, soliciting, or receiving bribes or kickbacks

  • Facilitating payments to expedite routine procedures

  • Using third parties to engage in corrupt practices on our behalf

  • Providing gifts, hospitality, or entertainment with the intent to improperly influence decision-making

Gifts and Hospitality

• Gifts and hospitality must:

  • Be of nominal value

  • Be lawful and culturally appropriate

  • Not be offered during tenders, negotiations, or approvals

• All gifts above [Insert threshold, e.g., AED 500] must be declared and approved by management.

Reporting and Whistleblowing

• Employees and stakeholders are encouraged to report suspected violations confidentially by emailing: compliance@projexone.com

• ProjexOne ensures no retaliation against any individual who reports concerns in good faith.

Training and Awareness

• All staff will undergo annual compliance training. New employees must review and acknowledge this policy as part of onboarding.

Compliance and Monitoring

• We conduct periodic reviews and audits to ensure compliance with this policy. Any breach may result in disciplinary action, including termination and legal prosecution.

Legal Framework

• This policy aligns with:

  • UAE Federal Law No. 3 of 1987 (Penal Code)

  • UAE Anti-Commercial Fraud Law

  • International anti-corruption frameworks (e.g., UN Convention Against Corruption)

Policy Review

• This policy is reviewed annually by the Compliance Team and updated as needed to reflect legal and regulatory developments.