Anti-Bribery and Corruption Policy
Our commitment to ethical business practices
Policy Statement
ZINBLOCK FZE is committed to conducting business with integrity and in compliance with all applicable anti-bribery and anti-corruption laws, including UAE Federal Law No. 3 of 1987 (Penal Code) and international standards. We maintain a zero-tolerance policy towards bribery and corruption in all forms.
Prohibited Conduct
Bribery
Offering, giving, soliciting, or receiving anything of value to influence business decisions or gain improper advantage.
Kickbacks
Providing or receiving compensation in exchange for preferential treatment or referrals.
Facilitation Payments
Making unofficial payments to expedite routine government actions or services.
Conflicts of Interest
Engaging in activities where personal interests conflict with company interests without proper disclosure.
Gifts and Hospitality
Reasonable business gifts and hospitality are permitted under strict guidelines:
Must be reasonable in value and frequency (maximum $250 per occasion)
Must be given openly and transparently with proper documentation
Cannot be cash or cash equivalents
Must not create obligation or expectation of preferential treatment
Gifts to or from government officials require prior approval
Third-Party Due Diligence
We conduct risk-based due diligence on all third parties including:
Service Providers
Property managers, legal advisors, consultants, and contractors
Business Partners
Joint venture partners, strategic alliances, and distributors
Agents & Intermediaries
Sales agents, brokers, and commission-based representatives
Property Sellers
Developers, individual sellers, and real estate companies
Employee Responsibilities
All employees, officers, and directors must:
- •Comply with this policy and all applicable anti-corruption laws
- •Complete annual anti-bribery and corruption training
- •Report any suspected violations immediately through designated channels
- •Maintain accurate books and records of all transactions
- •Cooperate fully with internal and external audits
Reporting Mechanisms
We maintain multiple confidential channels for reporting concerns:
Compliance Hotline: +971 800 779726 (available 24/7)
Email:ethics@zinblock.com
Whistleblowing Portal: Accessible through our internal platform
Direct Reporting: Chief Compliance Officer or Legal Department
All reports are investigated promptly and confidentially. We prohibit retaliation against anyone who reports concerns in good faith.
Consequences of Violations
Violations of this policy may result in:
Compliance Monitoring
The Compliance Department conducts regular audits, reviews transactions for red flags, and maintains an ongoing training program. This policy is reviewed annually and updated as needed to reflect regulatory changes and best practices.
For questions about this policy or guidance on specific situations, contact the Compliance Department at compliance@zinblock.com