Bribery Prevention and Anti-corruption  Policy

1. Policy Objective

This Bribery Prevention and Anti-Corruption 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?

The Bribery Prevention and Anti-Corruption 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.

6. Employee Responsibilities

a) All employees shall comply with the requirements contained within this policy.

b) All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption.

c) If there is a reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, all employees must notify the same to the Compliance Manager.

If any employee breaches this policy, he or she will face disciplinary action and could face dismissal for gross misconduct. Equilibrium Engineering Consultancy has the right to terminate the contractual relationship with such an employee.

7. What happens if an employee needs to raise a concern?

a) How to raise a concern.

If any employee suspects an instance of bribery or corrupt activities occurring in relation to Equilibrium Engineering Consultancy, he is encouraged to raise concern at as early a stage as possible. If he is uncertain about whether a certain action or behaviour can be considered bribery or corruption, he should speak to the Compliance Manager.

Equilibrium Engineering Consultancy will familiarise all employees with its whistleblowing procedures so employees can express concerns swiftly and confidentially.

b) What to do if you are a victim of bribery or corruption

You must tell the Compliance Manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

If you refuse to accept or offer a bribe or you report a concern relating to potential act (s) of bribery or corruption, Equilibrium Engineering Consultancy understands that you may feel worried about potential repercussions. Equilibrium Engineering Consultancy will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

Equilibrium Engineering Consultancy will ensure that no one suffers detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

If any employee has a reason to believe that he has been subjected to unjust treatment as a result of a refusal to accept a bribe, he should inform the Compliance Manager immediately.

8. Training and Communication

Equilibrium Engineering Consultancy will provide induction on this policy for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with his policy.

Equilibrium Engineering Consultancy's bribery prevention and anti-corruption policy and zero tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.

Equilibrium Engineering Consultancy will provide relevant anti-bribery and corruption training to all its employees whenever the Company feels that their knowledge on this requirement needs to be enhanced.

9. Record Keeping

Equilibrium Engineering Consultancy will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made..