Effective Date: 01 June 2015 | Last Review Date: 01 April 2025 | Owner: Management | Version: 1.2
Neutrino Group and its entities are committed to conducting all business with integrity, transparency, and in full compliance with applicable anti-bribery and anti-corruption laws, including the UAE Penal Code, UK Bribery Act 2010, and the US Foreign Corrupt Practices Act (FCPA).
1. Purpose
This policy sets out Neutrino Group’s commitment to preventing bribery and corruption in all its forms across all business operations, partnerships, and third-party relationships.
2. Scope
This policy applies to:
- All employees, directors, independent consultants, and contractors of Neutrino Consulting FZE, Neutrino International FZE.
- All business activities in the UAE and
- All third parties acting on behalf of Neutrino Group, including reseller and partnership
3. What Is Prohibited
Neutrino Group strictly prohibits:
- Offering, giving, receiving, or soliciting any bribe, kickback, or improper payment in any
- Facilitation payments — small payments to expedite routine government
- Payments or gifts to government officials to obtain or retain
- Any payment made through a third party that would be prohibited if made
- Accepting gifts or hospitality that could influence, or be perceived to influence, a business
4. Gifts & Hospitality
Reasonable and proportionate gifts and hospitality are permitted only when they are:
- Transparent, modest in value, and not given with the intent to
- Compliant with the recipient’s own organization’s
- Not offered to government officials or public
Any gift or hospitality above AED 500 (or equivalent in any other currency) in value must be disclosed to management.
5. Responsibilities
All personnel must:
- Read and comply with this policy
- Promptly report any suspected bribery or corruption to management
- Cooperate fully with any investigation
Management is responsible for ensuring this policy is communicated, implemented, and reviewed annually.
6. Reporting & Non-Retaliation
Neutrino Group encourages reporting of concerns in good faith. Any individual who raises a genuine concern will not face retaliation, regardless of the outcome. Reports may be made directly to senior management.
7. Consequences of Breach
Breach of this policy may result in disciplinary action up to and including termination of employment or contract, and may be reported to relevant law enforcement authorities.
8. Record Keeping
Neutrino Group maintains accurate books and records of all transactions. No off-book accounts or falsified records will be tolerated.