Bribery Prevention & Anti-Corruption Policy
1. Policy Objective
This anti-bribery policy sets out the responsibilities of Equilibrium Engineering Consultancy and our employees, with regards to observing and upholding our zero-tolerance position on bribery and corruption.
2. Policy Statement
Equilibrium Engineering Consultancy is committed to practicing the following with regards to having a zero-tolerance towards bribery and corruption:
- Conduct our business in an ethical and honest manner.
- Uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate.
- Implement and enforce systems that ensure bribery is prevented.
- Act professionally, fairly and with integrity in all business dealings.
- EEC recognises that bribery and corruption are punishable and can damage our reputation. It is with this in mind that we will not commit to such activities in our business and take our legal responsibilities seriously.
3. Who is covered by this policy?
This anti-bribery policy applies to all employees (whether temporary, fixed-term or permanent), consultants, contractors, trainees, seconded staff, agency staff, interns, agents, sponsors or person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside the UAE).
4. Definition of Bribery
Bribery refers to the act of offering, giving, promising, receiving, accepting or solicitating something of value or of an advantage to induce or influence an action or decision.
A bribe refers to any inducement, reward, or object / item of value being offered to another individual in order to gain a commercial, contractual, regulatory, or personal advantage.
Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
If an employee is uncertain about whether something is a bribe or a gift or an act of hospitality, they must seek advice from the company’s Compliance Manager.
5. What is and what is not acceptable
A. Gifts and Hospitality
Equilibrium Engineering Consultancy accepts normal and appropriate gestures of hospitality, goodwill (whether given / received from third parties), so long as the giving or receiving of gifts meets the following requirements:
- It is not made with the intention of influencing the party as an explicit or implicit exchange for favours or benefits and follows local laws.
- It is given in the name of the company, not in an individual’s name.
- It does not include cash or a cash equivalent (vouchers or gift card).
- It is appropriate for the circumstances (i.e. giving small gifts around during a period of celebration or as a small thank you to a company for helping with a large project upon completion).
- It is of an appropriate type and value and is given at an appropriate time.
- It is given / received openly, not secretly and is not selective to a key influential person, clearly with the intention of directly influencing them.
- It is not above a certain excessive value, as pre-determined by the Company (usually in excess of AED 1,000).
- It is not offered to, or accepted from, a government official or representative or politician or political party without prior approval by the Company.
Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/ culture who may take offence), the gift may be accepted so long as it is declared to the Compliance Manager for assessment. As good practice gifts given and received should always be disclosed to the Compliance Manager. Gifts from supplies should always be disclosed.
B. Facilitation Payments and Kickbacks
Equilibrium Engineering Consultancy does not accept and will not make any facilitation payments of any nature since they are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action.
C. Political Contributions
Equilibrium Engineering Consultancy will not make donations, whether in cash, kind, or by any other means to support any political party or individual.
