Vishram General Trading LLC Dubai, United Arab Emirates Last Updated: July 2026 Policy Reference: VGT-ABAC-2026-001

1.  Policy Statement

Vishram General Trading LLC (“Vishram”) is committed to conducting its business with the highest standards of integrity, ethics, and transparency. We have a zero-tolerance policy toward bribery, corruption, and all forms of unethical conduct in our business dealings. This Policy applies to all employees, directors, officers, agents, consultants, contractors, suppliers, and business partners (“Associated Persons”) acting on behalf of or in connection with Vishram. We comply with:

• UAE Federal Decree-Law 20 of 2018 on Anti-Money Laundering and Counter-Terrorism Financing
• UAE Federal Decree-Law 31 of 2021 on the Issuance of the Crimes and Penalties Law (Penal Code)
• UAE Federal Decree-Law 4 of 2016 on the Audit Profession (for financial transparency)
• UK Bribery Act 2010 (where applicable to our UK operations/partners)
• S. Foreign Corrupt Practices Act (FCPA) (where applicable to our U.S. operations/partners)
• OECD Convention on Combating Bribery of Foreign Public Officials

2.  Definitions Table

Term	Definition
Bribery	Offering, promising, giving, accepting, or soliciting anything of value to influence improperly the actions of another person.
Corruption	Abuse of entrusted power for private gain, including embezzlement, nepotism, cronyism, and fraud.
Public Official	Any person holding a legislative, administrative, or judicial office; any person exercising a public function; or any official of a public international organization.

 

Term	Definition
Facilitation Payment	A small unofficial payment made to secure or expedite a routine governmental action. (Strictly prohibited)
Kickback	A payment made to someone who has facilitated a transaction or appointment, typically in secret.
Gifts & Hospitality	Anything of value given or received in a business context, including meals, entertainment, travel, and merchandise.

3.  Prohibited Conduct

The following are strictly prohibited under all circumstances:

3.1  Giving or Offering Bribes

• No Associated Person shall offer, promise, or give any bribe, kickback, or improper advantage to any Public Official or private individual to:
  • Obtain or retain
  • Secure a contract or favorable
  • Influence a decision-making
  • Expedite or secure routine governmental

3.2  Accepting Bribes

• No Associated Person shall solicit, accept, or agree to accept any bribe, kickback, or improper advantage in connection with Vishram’s business.

3.3  Facilitation Payments

• Facilitation payments are strictly prohibited, even if customary or permitted under local practice. No payment shall be made to expedite routine governmental actions (e.g., visa processing, customs clearance, permit issuance).

3.4  Political & Charitable Contributions

• Political contributions made on behalf of Vishram are prohibited without prior written approval from the Board of Directors.
• Charitable donations and sponsorships must be:
  • Made to legitimate, registered

• Properly documented and
• Approved in writing by senior
• Not used as a conduit for bribery or to influence a Public

3.5  Gifts & Hospitality

Gifts and hospitality are permitted only if they:

• Are reasonable and proportionate in value (generally not exceeding AED 500 per occasion or
• AED 2,000 per individual per year).
• Are not in cash or cash equivalents.

• Are given openly and transparently, not in
• Do not create an obligation or expectation of reciprocal
• Are accurately recorded in company
• Comply with the recipient’s organizational

Prohibited Gifts:

• Cash, gift cards, or
• Expensive jewelry, watches, or luxury
• Gifts to Public Officials (unless of nominal, symbolic value and pre-approved).
• Gifts given during tender processes or contract

4.  Due Diligence on Third Parties

Before engaging any third party (agent, distributor, consultant, supplier, or joint venture partner), Vishram shall conduct risk-based due diligence, including:

• Verification of business registration and
• Background checks on beneficial owners and key
• Assessment of corruption risk in the relevant
• Review of the third party’s own anti-bribery policies and
• Contractual inclusion of anti-bribery representations, warranties, and audit

High-Risk Red Flags:

• Requests for payment to third-party accounts or shell
• Unusually high commissions or
• Lack of transparency in pricing or
• Close family or business ties to Public
• Operations in high-corruption-risk jurisdictions (per Transparency International CPI).

5.  Record Keeping & Financial Controls

• All transactions must be accurately recorded in Vishram’s books and
• No “off-book” accounts, hidden ledgers, or unrecorded transactions are
• Expenses must be supported by valid receipts, invoices, and proper
• All payments must be made through official banking channels; cash payments exceeding AED 10,000 require dual approval.
• Internal and external audits shall include anti-bribery compliance

6.  Reporting Concerns (Whistleblowing)

Vishram encourages all Associated Persons to report any suspected bribery, corruption, or policy violations without fear of retaliation.

Reporting Channels:

Table

Channel	Contact
Direct Supervisor	Immediate manager or department head
Compliance Officer	[Insert Compliance Officer Name & Email]
Ethics Hotline	[Insert Phone Number] (available 24/7, anonymous permitted)
Email	[Insert Ethics Email]
Online Portal	[Insert Secure Reporting Portal URL]

Protection: Vishram prohibits retaliation against anyone who reports concerns in good faith. Retaliatory action will result in disciplinary measures, up to and including termination and legal action.

7.  Consequences of Violations

Violations of this Policy will result in disciplinary action, which may include:

• Formal warning and mandatory
• Suspension without
• Termination of employment or contract.
• Civil liability for
• Criminal prosecution under UAE and applicable international
• Permanent debarment from future business with

Note: Under UAE law, bribery of Public Officials is punishable by imprisonment of up to 10 years and fines up to AED 500,000. Under the UK Bribery Act, companies can face unlimited fines and directors can face imprisonment of up to 10 years.

8.  Training & Awareness

• All employees and directors receive annual anti-bribery training.
• High-risk roles (procurement, sales, government liaison) receive quarterly refresher training.
• New hires receive training within 30 days of
• Training records are maintained for audit

9.  Policy Review

This Policy is reviewed annually by the Compliance Officer and Board of Directors, or sooner if:

• There are changes in applicable
• A significant compliance incident
• The business expands into new high-risk

10.  Contact & Questions

Chief Compliance Officer Vishram General Trading LLC [Insert Full Address] Dubai, United Arab Emirates Email: [Insert Compliance Email] Phone: [Insert Phone Number]

Summary Checklist for Implementation

Table

Document	Key Action Items
Terms of Trade	Insert license number, bank details, and authorized signatories. Have reviewed by a UAE-licensed lawyer.
Privacy Policy	Appoint a DPO, implement cookie consent banner, draft data processing agreements with third parties.
Cookie Policy	Configure cookie management tool (e.g., OneTrust, Cookiebot), audit all third-party scripts on website.
Anti-Bribery Policy	Train all staff, establish ethics hotline, conduct third-party due diligence, integrate ABAC clauses into all contracts.