1. Scope
This policy applies to all third-party relationships including customers, suppliers, agents, distributors, consultants, and joint venture partners.
2. Objectives
Identify and mitigate risks related to bribery, corruption, money laundering, sanctions violations, and reputational harm.
Comply with international and local legal frameworks, including UAE Anti-Money Laundering Laws and global trade compliance requirements.
3. Due Diligence Process
Before onboarding, the following checks must be completed:
Identity Verification: Legal name, address, and registration documents.
Beneficial Ownership & UBO Check: Identification of individuals holding 25% or more .
Sanctions Screening: Screening against OFAC, EU, UN, and local sanctions lists.
Reputation & Litigation Check: Internet and database searches for negative media or legal actions.
Business Justification: Clear rationale for engaging the partner, including expected value and scope.
4. Ongoing Monitoring
Annual re-evaluation of key partners.
Transaction-level reviews in high-risk jurisdictions or sectors.
Escalation of red flags to the Compliance Officer.
5. Approval & Recordkeeping
All KYBP assessments must be documented and approved by the Compliance Officer before any contractual or financial engagement. Records must be retained for a minimum of 5 years.
6. Roles and Responsibilities
Sales/Procurement Team: Initiate KYBP checks.
Compliance Department: Conduct and approve due diligence.
Management: Ensure adherence to KYBP procedures.
7. Training & Awareness
Employees involved in onboarding or managing third parties must undergo annual KYBP training.
8. Enforcement
Failure to comply with this policy may result in disciplinary actions and cancellation of the business relationship.

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