Interdev Technology is committed to maintaining the highest standards of transparency, ethical conduct, honesty, and integrity in all transactions with stakeholders, including partners, government agencies, and within the company. This document outlines the essential requirements that all employees are expected to comply with at all times in all dealings within and outside the organization.
The Code of Conduct is binding for all employees (referred to as "You") in dealings both inside and outside the organization. All employees are also expected to adhere to the vendor code of conduct for the brands they represent.
Interdev is committed to maintaining the highest standards of ethics and integrity. This Anti-Corruption Policy is designed to prevent bribery, kickbacks, and all forms of corruption, ensuring full compliance with UAE law. In particular, this policy aligns with the provisions of the UAE Federal Penal Code (Federal Law No. 3 of 1987, Articles 234-239), which criminalizes bribery in both public and private sectors. Violations under these articles can result in imprisonment (up to five years) and fines (equal to the bribe amount, but not less than AED 5,000). In addition, guidelines from the UAE Accountability Authority (UAEAA) further support these measures. This policy applies to all Interdev board members, employees, and any third parties engaged on our behalf.
Interdev strictly prohibits any form of bribery or corruption. All employees, directors, and third parties must:
Comply with UAE Legal Requirements: Adhere to the UAE Federal Penal Code and all applicable local regulations regarding bribery and corruption.
Maintain Full Transparency: Ensure that all business transactions, gifts, and benefits are fully documented and recorded in accordance with our internal controls.
Avoid Conflicts of Interest: Promptly disclose any actual or potential conflicts that might compromise the integrity of decision-making processes.
Under this policy, it is strictly forbidden to:
Offer, Promise, or Provide Anything of Value: This includes cash, gifts, travel, services, or any other benefit intended to influence an official decision or secure an improper business advantage.
Act as an Intermediary: Serving as an intermediary between the giver and the recipient of a bribe is a criminal offense under UAE law.
Facilitate or Encourage Bribery: Any action that indirectly facilitates the exchange of bribes or kickbacks is prohibited.
Circumvent Legal Provisions: Any attempt to avoid or undermine UAE anti-bribery laws will result in strict disciplinary and legal action.
"Anything of Value" includes any tangible or intangible benefit that could be perceived as an inducement, regardless of its monetary value.
Interdev is required by UAE law to maintain complete, accurate, and transparent financial records. Accordingly:
Proper Documentation: Every payment, gift, or benefit must be fully authorized, documented, and recorded in our accounting system.
Regular Audits: Internal controls are subject to periodic audits to verify compliance with both our policies and UAE legal requirements.
To preserve ethical standards:
Mandatory Disclosure: Employees must immediately report any potential or actual conflicts of interest to the Legal Department.
No Personal Favors: Employees are prohibited from soliciting or accepting personal benefits that could compromise objective decision-making.
Interdev prohibits any facilitating payments that may be construed as bribery under UAE law. For any legitimate government fees (such as visa processing or permits):
Transparent Handling: Such payments must be clearly identified, properly recorded, and must not serve as a cover for any corrupt practices.
Strict Compliance: All routine payments must adhere to the applicable UAE legal standards.
All third parties—including agents, consultants, contractors, and suppliers—must comply fully with this policy and UAE anti-corruption laws. To manage these relationships:
Pre-Approval Requirement: Engagements involving third parties, particularly those that interact with government officials, must receive prior written approval from the Legal Department.
Ongoing Monitoring: Regular reviews and audits will be conducted to ensure third-party compliance with our anti-corruption standards.
Reasonable gifts, entertainment, and hospitality may be part of legitimate business practices, provided they:
Are Modest and Appropriate: Must not be intended to influence any decision or secure an improper advantage.
Comply with UAE Regulations: For example, public sector employees may only accept symbolic gifts (with proper identification and through designated channels).
Are Fully Documented: All such expenses must be pre-approved (if required) and accurately recorded.
Corporate sponsorships must serve a genuine business purpose and be proportional to the benefits received. They must:
Be Transparent and Authorized: Sponsorships must be documented, approved in writing, and subject to periodic review.
Avoid Conflicts: Ensure that sponsorship arrangements do not lead to preferential treatment or create conflicts of interest.
Any deviation from this policy must be approved in advance by the General Counsel or an authorized designee from the Legal Department. All exceptions must be fully documented and maintained for audit purposes, and are subject to periodic review.
Violations of this Anti-Corruption Policy or any applicable UAE anti-bribery laws will result in severe consequences, including:
Disciplinary Actions: These may include suspension, termination of employment, or termination of third-party relationships.
Legal Prosecution: Offenders may face criminal charges under the UAE Federal Penal Code (Articles 234-239), including imprisonment (up to five years) and fines (equal to the bribe amount, but not less than AED 5,000).
Thorough Investigations: Any suspected breach will be rigorously investigated, and corrective measures will be enforced accordingly.
Interdev encourages all employees and associated third parties to report any suspected violations or concerns regarding corruption or bribery without fear of retaliation. Reports may be made by:
Contacting Your Supervisor or the Legal Department Directly
Using the Anonymous Reporting Hotline/Email: legal@interdevtechnology.com
All reports will be treated confidentially and investigated promptly, ensuring that no individual faces adverse consequences for reporting concerns in good faith.
Federal Penal Code (Federal Law No. 3 of 1987, Articles 234-239): This is the primary legal framework addressing bribery and corruption in the UAE, applicable to both public and private sectors.
Penalties: Convictions under these articles can lead to imprisonment (up to five years) and fines (equal to the bribe amount, but not less than AED 5,000).
UAE Accountability Authority (UAEAA): The UAEAA is responsible for protecting government funds, ensuring proper allocation, and combating fraud and corruption. More details are available on their website (https://uaeaa.gov.ae/en/core/Pages/anticorruption.aspx).
Intermediary Offense: Acting as an intermediary between the giver and the recipient of a bribe is a criminal offense.
Foreign Bribery: The UAE actively combats foreign bribery as part of its international obligations under conventions such as the United Nations Convention Against Corruption (UNCAC) and the Arab Convention on combating corruption.
Public vs. Private Sector: Public sector employees are prohibited from accepting gifts or bribes beyond symbolic offerings with strict controls, while bribery in the private sector is addressed under Article 236 of the Penal Code.
Whistleblowing: UAEAA supports mechanisms for reporting corruption and financial violations, ensuring that whistleblowers can report concerns without discrimination.
For further guidance or clarification on any aspect of this policy, including its alignment with UAE anti-bribery laws, please contact the Legal Department at legal@interdevtechnology.com standards.
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