1. Purpose and scope
DMS HOLDINGS LLC does not tolerate bribery or corruption in its business. This policy applies to everyone acting for DMS and sets out what we expect of suppliers, intermediaries and others who deal with us. The anti-bribery law of each place where the activity happens must be followed.
Under UAE law, including the Crimes and Penalties Law (Federal Decree-Law No. 31 of 2021), offering or accepting a bribe is an offence in both the public and private sectors, including where a foreign public official is involved.
2. What is not allowed
Do not offer, promise, give, request or accept money or any other benefit to improperly influence a commercial or official decision. This includes payments made indirectly through an agent, consultant, relative or other intermediary.
Do not make facilitation payments, meaning unofficial payments to speed up a routine official action. If a demand comes with an immediate threat to someone’s safety, put safety first, then report what happened as soon as it is safe and record any payment accurately.
3. Gifts, hospitality and conflicts
Gifts and hospitality must be lawful, modest, open and unconnected to gaining an improper advantage. Cash or cash equivalents, hidden benefits and anything meant to influence a live purchasing or official decision are not acceptable.
Ask DMS before offering or accepting a benefit connected with its business if you are unsure. Declare any personal, financial or family interest that could affect a business decision. Donations and sponsorship must never be used to disguise an improper payment.
4. Intermediaries, payments and records
Fees and commissions must be for legitimate services and be documented. Warning signs include unexplained commissions, requests to pay unrelated parties or accounts, vague descriptions of services and pressure to hide who receives a payment.
Invoices, expenses and payment records must show what actually happened. Do not create false invoices, misleading descriptions or off-record arrangements. Ask for an explanation when a proposed payment has no clear business purpose.
5. Reporting a concern
Report a concern in good faith to info@dmsholdings.ae with Anti-bribery concern in the subject line. Describe the parties, the transaction and what happened, and include any evidence you are entitled to share. Do not put yourself at risk to investigate.
DMS will consider the report and may ask for more information, pause a transaction or take other action under the law and the agreements in place. No one should suffer retaliation for raising a concern in good faith or for refusing to take part in bribery.
A report may need to be shared with advisers, counterparties or the authorities to assess it or to meet a legal duty, so we cannot promise complete confidentiality or a particular outcome.