1. Purpose and scope
Excolo Ventures and Excolo Management Consultants FZCO, address: Dubai, UAE, prohibits bribery and corruption in public and private business. This policy applies to directors, employees, contractors, agents, introducers and other persons acting on our behalf. Compliance with applicable anti-bribery laws is required wherever the relevant activity takes place.
2. Prohibited conduct
No person may offer, promise, give, request, agree to receive or accept money or anything of value to improperly influence a decision or secure an improper advantage. This includes kickbacks, concealed commissions and benefits passed through intermediaries, family members or connected businesses. Small unofficial payments to speed up routine actions are prohibited; lawful, published service fees are different.
3. Gifts, hospitality and expenses
Gifts or hospitality must be lawful, reasonable, transparent and for a legitimate business purpose. Cash or cash-equivalent gifts, lavish benefits and anything intended to influence a pending decision are prohibited. Obtain prior management approval where a benefit could create a conflict or involves a public official; approval cannot make an unlawful benefit acceptable. Keep accurate records of the recipient, purpose and value.
4. Agents, fees and conflicts
Before appointing an intermediary, assess identity, ownership, capability, reputation, connections and the commercial rationale for the appointment. Services and fees must be documented, proportionate and supported by genuine work. Unexplained third-party payments, unusual payment locations, secrecy requests or excessive commissions must be escalated. Disclose actual or potential conflicts of interest and do not use donations, sponsorship or political contributions to obtain improper advantage.
5. Records and controls
Transactions must be recorded accurately with appropriate supporting documents and approval. False invoices, hidden accounts, misleading descriptions and circumvention of payment controls are prohibited. Personnel must refuse improper requests and seek guidance before proceeding where concerns remain. Where a payment is compelled by an immediate threat to personal safety, prioritise safety and report and document the incident as soon as it is safe to do so.
6. Reporting and response
Report concerns to connect@excolovc.com, using “Confidential — Anti-Bribery Concern” as the subject. Reports must be assessed fairly and information restricted as far as practicable, subject to legal disclosure duties. Retaliation for an honest report or refusal to participate in bribery is prohibited. Breaches may lead to disciplinary action, termination of a relationship and reporting to authorities, subject to applicable law and fair process.
7. Oversight
Management is responsible for oversight, proportionate risk assessment and review of this policy. Personnel and representatives must familiarise themselves with relevant requirements and seek guidance where needed. This policy sets required standards; it is not a certification of completed due diligence, training or regulatory approval.
Contact
Excolo Ventures and Excolo Management Consultants FZCO
Dubai, UAE
connect@excolovc.com