1. Overview
Scintilla Network FZE (“Scintilla”) maintains a zero-tolerance approach to bribery and corruption. This policy applies universally across all business activities, operations, and relationships.
2. Scope & Applicability
This policy applies to all individuals and entities associated with Scintilla, including:
· Members of the Board of Directors, senior management, officers, and employees (full-time, part-time, and contractual).
· External consultants, contractors, agents, introducing partners, and representatives.
· Any third party, supplier, vendor, or counterparty acting on behalf of or providing services to Scintilla, regardless of geographical location.
3. Core Principles & Zero-Tolerance Stance
Scintilla operates under four fundamental principles:
1. Zero Tolerance: Scintilla strictly prohibits all forms of bribery and corruption, whether direct or indirect. Offering, promising, giving, soliciting, or receiving any financial or non-financial advantage to improperly influence a business decision or secure an unfair advantage is strictly forbidden.
2. Facilitation Payments: Scintilla explicitly prohibits "facilitation payments" or "grease payments" (small payments made to expedite or secure routine non-discretionary governmental actions).
3. Interactions with Public Officials: All dealings with government entities, public officials, and regulatory authorities (including VARA) must adhere to the highest standards of transparency, integrity, and local laws.
4. Third-Party Due Diligence: Scintilla will not enter into or maintain business relationships with third parties known or suspected to engage in corrupt practices. All partners must undergo risk-based anti-bribery screening prior to engagement.
4. Gifts, Hospitality & Political Contributions
To ensure commercial interactions remain objective and ethically sound:
· Gifts & Hospitality: Any gift, entertainment, or hospitality offered or accepted must be modest, reasonable, proportionate, and customary. They must never
be given or received with the intention of inducing or rewarding improper behavior.
· Prohibited Items: Cash or cash-equivalent gifts (e.g., gift cards, crypto assets, loans) are strictly prohibited under all circumstances.
· Declarations: All non-de minimis gifts and business hospitality must be recorded in Scintilla’s internal Gift & Hospitality Register and approved by the Compliance Officer.
· Political & Charitable Contributions: Scintilla does not make political contributions. Any charitable donations made by Scintilla must be transparent, lawful, and subject to prior compliance vetting.
5. Reporting, Whistleblowing & Protection
Scintilla relies on the vigilance of its employees, business partners, and clients to maintain an ethical environment:
· Reporting Duty: Anyone who suspects or becomes aware of an actual, attempted, or potential act of bribery or corruption is obligated to report it immediately to the Compliance Officer / MLRO.
· Confidentiality & Non-Retaliation: Reports can be submitted confidentially via dedicated compliance channels. Scintilla guarantees that no individual will suffer adverse consequences, retaliation, or detrimental treatment for refusing to participate in bribery or for reporting concerns in good faith.
6. Governance & Policy Oversight
· Implementation: The Compliance Department is responsible for implementing, monitoring, and updating this policy at least annually to ensure ongoing effectiveness and compliance with VARA regulations and UAE federal laws.
· Breach Consequences: Non-compliance by employees may result in immediate disciplinary action up to and including summary dismissal, alongside potential referral to criminal law enforcement authorities. Non-compliance by third-party service providers will result in immediate termination of the business relationship.
For questions or to report suspected policy breaches, contact: contactus@scintillanetwork.com
