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Anti-Bribery and Corruption Policy

 

Last updated: November 2025

1. Purpose

The Arkstone Project (“Arkstone”, “we”, “our”, or “us”) is committed to conducting all of its business activities with integrity, transparency, and the highest ethical standards.

This Anti-Bribery and Corruption Policy sets out our zero-tolerance position toward any form of bribery, corruption, or improper influence, and ensures compliance with applicable laws, including but not limited to:

  • UAE Federal Decree-Law No. 31 of 2021 (Penal Code);

  • UK Bribery Act 2010 (where relevant to cross-border activities); and

  • U.S. Foreign Corrupt Practices Act (FCPA) (where applicable).

2. Scope

This Policy applies to:

  • all Arkstone employees, officers, directors, and contractors;

  • all third-party service providers, consultants, intermediaries, and agents acting on Arkstone’s behalf; and

  • all business partners and issuers engaged with Arkstone’s platform.

3. Policy Statement

Arkstone strictly prohibits:

  1. Offering, giving, requesting, or receiving any form of bribe, kickback, facilitation payment, or other improper advantage, whether in cash or in kind.

  2. Attempting to influence business decisions, government actions, or regulatory outcomes through gifts, entertainment, donations, or favors intended to secure undue advantage.

  3. Authorizing or tolerating bribery by third parties or intermediaries acting for Arkstone.

Any such conduct (direct or indirect) will result in disciplinary action, up to and including termination and possible legal proceedings.

4. Gifts and Hospitality

Reasonable, transparent, and infrequent business courtesies (e.g., hospitality, meals, or promotional gifts) may be acceptable if they are:

  • modest in value;

  • lawful and customary in the relevant jurisdiction;

  • not intended to influence a decision or secure a business advantage; and

  • fully recorded in Arkstone’s internal registers.

All gifts and hospitality must comply with Arkstone’s internal approval thresholds and disclosure procedures. 

 

5. Political and Charitable Contributions

Arkstone does not make political contributions on behalf of the company, nor may employees use company resources for political purposes.
Charitable donations are permitted only when they are transparent, properly documented, and made in good faith, never as a conduit for bribery.

6. Responsibilities

  • All personnel are required to understand and comply with this Policy.

  • Managers and senior officers must promote a culture of compliance and lead by example.

  • Third-party partners must agree to Arkstone’s ethical standards within their contractual obligations.

Failure to adhere to this Policy may constitute gross misconduct and may lead to termination of employment or business relationship.

7. Reporting and Whistleblowing

Anyone who becomes aware of, or suspects, a violation of this Policy must report it immediately through one of the following channels:

Arkstone strictly prohibits retaliation against any person who, in good faith, reports suspected misconduct.

8. Record Keeping

All transactions, expense reports, invoices, and approvals must be accurately recorded and supported by appropriate documentation.
False, misleading, or incomplete records are strictly prohibited.

9. Training and Awareness

All employees and relevant contractors will receive periodic training on anti-bribery and corruption compliance.
Training completion is mandatory and forms part of Arkstone’s internal governance and regulatory audits.

10. Breaches and Consequences

Violations of this Policy will result in disciplinary action, which may include termination of employment or contract, restitution, and reporting to relevant authorities.

Arkstone reserves the right to pursue legal remedies and cooperate fully with law enforcement in any investigation related to bribery or corruption.

11. Review and Updates

This Policy will be reviewed annually or more frequently if required by changes in law, regulation, or Arkstone’s business operations.
Revisions will be approved by senior management and communicated company-wide.

12. Contact Information

For questions regarding this Policy or to report concerns, please contact: compliance@arkstoneproject.com

Summary (Plain Language)

  • Zero tolerance for bribery, corruption, or facilitation payments.

  • Applies to all employees, partners, and contractors.

  • Gifts and hospitality only if modest, lawful, and transparent.

  • Report violations immediately, no retaliation.