1. Scope
This policy applies to:
• All employees (full-time, part-time, and consultants)
• Board members and management
• Commercial agents and business partners
• Any individual representing ProjexOne in an official capacity
2. Definition of Conflict of Interest
A conflict of interest occurs when an individual’s personal interests – family, financial, or otherwise – interfere or appear to interfere with the interests of ProjexOne. It may involve:
• Self-dealing: Conducting business with a company in which the individual has a financial interest
• Undue influence: Using one’s position to benefit friends, family, or affiliates
• Outside employment or consulting: Working for or advising a competitor, supplier, or client without disclosure
• Gifts and hospitality: Receiving gifts that could be perceived as influencing business decisions
3. Key Principles
• Employees must disclose any situation that could lead to a conflict of interest.
• All decisions should be made objectively, prioritizing ProjexOne’s interests over personal gain.
• No employee shall participate in any transaction or decision where there is a conflict unless expressly authorized.
4. Disclosure & Reporting
Employees must report any actual or potential conflict to their immediate supervisor or the Compliance Officer. Disclosures must be made in writing and include:
• Description of the conflict
• Relationship or interest involved
• Steps taken to mitigate the conflict
5. Resolution & Consequences
• Management may require recusal from decision-making or reassign responsibilities.
• Breaches of this policy may result in disciplinary action, including termination, contract cancellation, or legal recourse, depending on the severity.
6. Gifts and Business Courtesies
• Nominal gifts (not exceeding AED 300) may be accepted if refusal would be culturally inappropriate and if disclosed.
• Gifts in the form of cash or cash equivalents (e.g., gift cards) are strictly prohibited.
• Any hospitality or travel must be approved in advance by management if paid for by a vendor or client.
7. Confidentiality
All conflict disclosures and investigations will be handled with strict confidentiality, and no retaliation shall occur against employees making good-faith disclosures.
8. Policy Review
This policy shall be reviewed annually by management and updated as needed to ensure ongoing compliance with best practices and applicable laws.
9. Acknowledgment
All employees and representatives must sign a Conflict of Interest Declaration Form upon joining the company and annually thereafter.

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