Anti-Bribery & Corruption Policy
ShipFinex FZCO | VARA IPA: IPA/26/01/002 | Published: April 2026 | Version: 1.0
ShipFinex FZCO operates a zero-tolerance policy towards bribery and corruption in all forms. This policy applies to all directors, officers, employees, contractors, agents, and third-party representatives acting on behalf of ShipFinex FZCO, in all jurisdictions in which ShipFinex operates.
1. Legal Framework
This policy has been established in compliance with the following legislative frameworks:UAE Federal Decree-Law No. 31 of 2021 on the Promulgation of the Crimes and Penalties Law (UAE Penal Code), which criminalises the offering, promising, or giving of a bribe to a public official or private sector employee, and the solicitation or acceptance of a bribe.UAE Federal Law No. 4 of 2016 on Financial Activities and their Supervision, and VARA Compliance & Risk Management Rulebook requirements on integrity and market conduct.United Nations Convention Against Corruption (UNCAC), to which the UAE is a signatory.UK Bribery Act 2010 (to the extent applicable to ShipFinex FZCO's UK-connected business activities and counterparty relationships).
2. Prohibited Conduct
The following conduct is strictly prohibited for all persons covered by this policy:Offering, promising, giving, requesting, or accepting any financial or non-financial advantage intended to improperly influence a business decision, regulatory outcome, or official action — whether in the public or private sector.Facilitation payments — small payments made to expedite routine government actions — are prohibited regardless of local custom or perceived materiality.Using a third party (agent, intermediary, joint venture partner, or contractor) to offer or accept a bribe on behalf of ShipFinex FZCO, or knowingly benefiting from such conduct.Providing false, misleading, or incomplete information to ShipFinex FZCO's compliance function, auditors, or regulators in connection with any anti-bribery investigation or due diligence process.
3. Gifts, Hospitality & Expenses
Gifts and hospitality may be offered or accepted only where they are: modest in value (within the limits set in ShipFinex's internal Gifts & Hospitality Register policy); provided openly and not in secret; not offered or accepted during any active regulatory review, procurement process, or negotiation where they could improperly influence an outcome; and in compliance with the recipient's own organisation's policies.All gifts and hospitality above the de minimis threshold must be recorded in the internal Gifts & Hospitality Register maintained by the Compliance Officer. Cash gifts are prohibited in all circumstances.
4. Third-Party Due Diligence
ShipFinex FZCO applies proportionate due diligence to third parties — including agents, brokers, introducers, consultants, and joint venture partners — before entering into business relationships, and on a periodic basis thereafter. Due diligence is risk-rated based on the nature of the relationship, the jurisdictions involved, and the counterparty's exposure to public officials or politically exposed persons (PEPs).Third parties engaged by ShipFinex FZCO on a contractual basis are required to confirm, by written representation, that they comply with applicable anti-bribery and corruption laws and that they have not committed any act of bribery in connection with their engagement with ShipFinex FZCO.
5. Political Contributions & Sponsorships
ShipFinex FZCO does not make political contributions of any kind — monetary or in-kind — to any political party, candidate, or campaign in any jurisdiction.Corporate sponsorships and charitable donations may be made only following approval by the Compliance Officer and CEO, and must be recorded. No sponsorship or donation may be used as a mechanism for disguising a bribe or improper payment.
6. Reporting & Whistleblowing
Any director, officer, employee, or third party who suspects or becomes aware of a breach or potential breach of this policy is required to report it immediately. Reports may be made:To the Compliance Officer / MLRO directly: [email protected] the ShipFinex Whistleblowing channel (see Whistleblowing Policy for details of the confidential reporting mechanism).ShipFinex FZCO prohibits retaliation of any kind against any person who, in good faith, raises a concern under this policy or the Whistleblowing Policy. Any act of retaliation is itself a disciplinary offence.
7. Consequences of Breach
Breach of this policy by an employee may result in disciplinary action up to and including immediate dismissal. Breach by a director or officer will be reported to the Board Compliance Committee and, where legally required, to VARA and other applicable regulators. ShipFinex FZCO will cooperate fully with any regulatory or law enforcement investigation into suspected bribery or corruption.ShipFinex FZCO reserves the right to terminate any contractual relationship with a third party found to have breached applicable anti-bribery laws or the representations made in their engagement agreement.
8. Training & Awareness
All directors, officers, and employees of ShipFinex FZCO are required to complete anti-bribery and corruption training upon joining and at intervals of no less than every two years thereafter. Training records are maintained by the HR function and are available for inspection by the Board Audit Committee and VARA upon request.
9. Policy Ownership & Review
This policy is owned by the Compliance Officer / MLRO and is reviewed annually by the Board Compliance Committee. Any material changes to the policy are approved by the Board and notified to VARA where required under the IPA conditions or VARA Rulebooks.
Policy Version: 1.0 | Effective Date: April 2026 | Next Review: April 2027
Approved by: Board Compliance Committee, ShipFinex FZCO
Regulatory Notice: This policy is published in compliance with VARA Compliance & Risk Management Rulebook Part III and VARA VA Broker-Dealer Activity Rulebook Part I. ShipFinex FZCO operates under VARA IPA/26/01/002.