BUKHATIR GROUP

Strength through Diversity

Group Policy and Procedure

Group Supply Chain (GSC)

Code of Ethics & Anti-Bribery

Zero Tolerance for Corruption & Fraud

Document No: P-POL-010

Copyright © 2026 Bukhatir Group

Revision Control

This document is issued under the authority of Bukhatir Group and applies when carrying out the activities described. Revisions may be issued as necessary under the authority of the Group Head of Procurement. Revision history is recorded below with every revised policy.

Revision History

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Distribution List

1. Purpose & Objective

This policy establishes Bukhatir Group's zero-tolerance position on bribery, corruption, fraud and unethical conduct across all procurement and supply chain activities. It aligns the Group with UAE Federal Law, the UN Global Compact and the Group Code of Conduct.

2. Scope

Applies to all Group employees, officers, contractors, consultants, suppliers and intermediaries acting on behalf of Bukhatir Group in any procurement-related capacity, in the UAE and internationally.

3. Policy Statement

4. Prohibited Conduct

• Offering, promising, giving, soliciting or accepting any bribe, kickback, secret commission or improper advantage.
• Facilitation payments of any kind, in any jurisdiction.
• Fraudulent misrepresentation of specifications, prices, deliveries or performance data.
• Collusion, bid-rigging, price-fixing or market-sharing with competitors or between suppliers.
• Abuse of position for personal or third-party gain.
• Engagement of suppliers owned or controlled by sanctioned or politically exposed persons without approved due diligence.

5. Due Diligence

All suppliers shall be screened at onboarding and periodically thereafter against sanctions lists, PEP databases and adverse media. High-risk counterparties require enhanced due diligence including beneficial-ownership disclosure and anti-bribery warranties.

6. Training & Awareness

All procurement staff shall complete mandatory anti-bribery and ethics training annually. Completion is tracked by HR and Compliance.

7. Reporting & Investigation

Any suspected breach shall be reported immediately via the Group Whistleblowing Channel (see P-POL-018). Reports are investigated by Compliance and Internal Audit. No retaliation against a good-faith reporter is permitted.

8. Consequences of Breach

Breach may result in disciplinary action up to dismissal, civil and criminal prosecution under UAE law, supplier blacklisting, and recovery of any financial gain.

9. Definitions & Acronyms