Get In Touch

Anti-Bribery

Growth Execution FZCO Anti-Bribery Policy

1. Policy Statement

Growth Execution FZCO is committed to conducting business with the highest ethical standards and in compliance with all applicable anti-bribery laws. We have zero tolerance for bribery and corruption in any form.

2. Scope

This policy applies to all employees, contractors, agents, consultants, and third parties acting on behalf of Growth Execution FZCO in all jurisdictions where we operate.

3. Prohibited Conduct

Employees and associated persons are strictly prohibited from:

Offering, giving, or receiving bribes, kickbacks, or any inducement to influence business decisions

  • Providing or accepting gifts or hospitality that could be perceived as influencing business decisions
  • Falsifying records or financial statements to conceal improper payments
  • Engaging in facilitation payments or any form of corruption
  • Acting as intermediaries in bribe transactions

4. Gifts and Hospitality

Gifts and hospitality may only be offered or accepted if they are:

  • Reasonable and proportionate
  • Not intended to influence business decisions
  • Properly documented and approved in accordance with Growth Execution FZCO procedures

Employees must declare and keep a written record of all gifts and hospitality offered or received.

5. Conflicts of Interest

Employees must avoid situations where personal interests conflict with those of Growth Execution FZCO. Any actual or potential conflicts must be promptly disclosed to management.

6. Accurate Books and Records

All transactions must be accurately recorded in Growth Execution FZCO financial systems. Employees must ensure that records reflect the true nature of transactions and are subject to regular audits.

7. Reporting and Whistleblowing

Employees are encouraged to report any concerns about bribery or corruption without fear of retaliation.

  • Direct communication with a manager or HR
  • The anonymous reporting hotline or email

All reports will be treated confidentially and investigated promptly.

8. Training and Awareness

All employees will receive training on this policy during onboarding and at regular intervals thereafter. Training will be tailored to specific roles and responsibilities.

9. Disciplinary Action

Violations of this policy may result in disciplinary action, up to and including termination of employment or contract. Legal action may also be pursued where appropriate.

10. Policy Review

This policy will be reviewed annually or as required by changes in law or company structure. Updates will be communicated to all employees.