Version #1
Effective Date: 14/10/2025
Last Revised Date: 14/10/2025
Gate Technology FZE ("Company", "we", "us", "our" or "ours") is committed to conducting business in an honest and ethical manner. We have a zero-tolerance approach to bribery and corruption. As such, we have established a Business Gifts, Anti-Corruption & Bribery Policy ("Policy") to observe and uphold the Company's stance and provide guidelines to all relevant stakeholders. The Policy applies to all jurisdictions where the Company operates.
The Policy applies to all Employees, Board members, and Agents of the Company and covers all countries or territories where the Company operates. "Employee" means any and all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), trainees, seconded staff, remote workers, casual workers, volunteers, interns, or any other person associated with us, or any of our subsidiaries, affiliates or joint ventures. "Board" means the board of directors of the Company. "Agent" means any individual or organization that is appointed or authorized by the Company to act as its agent.
The Policy emphasizes that all forms of bribery and corruption, whether direct or indirect, are strictly prohibited with no exceptions. Employees or Board members who breach this Policy may face disciplinary action, and any third parties, such as customers, service providers, or business partners, who breach this Policy may have their contracts terminated immediately.
Making facilitation payments is illegal in many jurisdictions, and the Company does not make or accept such payments. In exceptional cases, a one-time exemption may be granted for facilitation payments made under coercion, provided that strict compliance with internal reporting procedures is observed.
The Policy does not prohibit normal and appropriate gifts. However, Employees shall not give, offer or receive gifts from anyone with whom the Company does business if the gift exceeds customary courtesies in line with industry practices. Conflicts of interest, whether actual or perceived, shall be avoided and addressed in accordance with the Company's policies. The following gifts and invitations are strictly prohibited:
In addition to the above, in general, gifts received or given shall not at any time exceed USD 100. Gifts exceeding USD 100 must be handled in accordance with internal approval and reporting procedures.
In other circumstances, such as when the recipient is unable to return gifts, invitations, and/or hospitality, or when an Employee wishes to provide a gift to a business partner, strict compliance with internal approval and reporting procedures is required.
The Company, its Employees, Board members, or Agents may make donations for charitable or philanthropic causes, subject to internal approval and certain conditions. Contributions to associations are also subject to internal approval and reporting procedures. Please note that the Company is not affiliated with any political parties and does not intend to support or promote any political parties; therefore, the Company shall not make contributions to any political parties.
Any suspicion or belief of bribery, corruption, or any breach of this Policy must be reported to the Chief Compliance Officer via email or direct phone call. An investigation will be conducted in accordance with internal investigation procedures. To ensure effective implementation of the Policy, the Company commits to protecting whistleblowers and Employees who refuse to participate in bribery or corruption from any detrimental treatment or retaliation.
The Company is committed to reporting any conduct that violates anti-bribery and anti-corruption laws or regulations to the Dubai Virtual Assets Regulatory Authority (VARA).
The Board has overall responsibility for ensuring the compliance of this Policy with applicable laws and regulations.
The Compliance Officer is responsible for implementing the Policy and monitoring its effectiveness. Management at all levels shall ensure those reporting to them acknowledge and understand this Policy and receive regular training.
To ensure the effective implementation of the Policy, the Company provides training on the requirements of this Policy, as well as relevant laws and regulations, to all Employees and Board members on both an annual and ad-hoc basis.
The Company monitors compliance with this Policy and periodically reviews its effectiveness. Internal controls and procedures are also subject to periodic audits.