We In UG are commited to fighting corruption in all of its forms doing business with transparency and integrity, For this we do not accept any form of Bribery or corruption and our business conduct is based on zero tolerance of corruption.

The purpose of this Policy is to:

set out the responsibilities of Universal Gate General traiding L.L.C., and all individuals who work for UG, in observing and upholding the Company's position on bribery and corruption.

• provide information and guidance to those individuals working for Universal Gate General traiding L.L.C on how to recognise and deal with bribery and corruption issues.


Bribery Offence:

Bribe :A bribe is a reward offered, promised or provided in order to gain anycommercial, contractual, regulatory or business or personal advantage.

An Inducement: is something which helps to bring about an action or desired result.

Kickbacks is a form of negotiated bribery in which a commission is paid to the bribe-taker in exchange for services rendered.

Extortion means to directly or indirectly demand or accept a bribe, facilitation payment or kickback.


2.1 It is prohibited for Universal Gate General Trading L.L.C. or its directors, officers, employees, consultants or contractors to :

(a) give, promise to give, or offer, a payment, gift or hospitality to a third party or otherwise engage in or permit a bribery offence to occur, with the expectation or hope that an advantage in business will be received, or to reward a business advantage already given.

(b) give, promise to give, or offer, a payment, gift or hospitality to a thirdparty to "facilitate" or expedite a routine procedure.

(c) accept a payment, gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the Company in return.

(d) threaten or retaliate against another employee or worker who has refused to commit a bribery offence or who has raised concerns under this Policy.

(e) engage in any activity that might lead to a breach of this Policy.

2.2 Non-compliance with the Policy may result criminal or civil penalties which will vary according to the offence. An employee acting in contravention of the Policy will also face disciplinary action up to and including summary dismissal.


3.1 All directors, officers, employees, consultants and contractors of Universal Gate General Trading L.L.C. must read, understand and comply with this Policy.

3.2 The prevention, detection and reporting of bribery offences and other forms of corruption are the responsibility of all those working for Universal Gate general Trading L.L.C. or under its control. All such persons are required to avoid any activity that might lead to, or suggest, a breach of this Policy.

3.3 All directors, officers, employees, consultants and contractors of Universal Gate General Traiding must notify the Compliance Officer or make a disclosure as soon as possible if they believe or suspect that an action in conflict with this Policy has occurred, or may occur in the future, or has been solicited by any person.

3.4 Any person who breaches this Policy will face disciplinary action, which could result in dismissal for gross misconduct. Universal Gate General Traiding reserves its right to terminate its contractual relationship with other persons if they breach this Policy.

4. Sponsorship, charitable or political donations

We do not permit charitable or political donations or sponsorships as a way of concealing a bribe. It is never acceptable to make donations to political parties.

5. Gifts, business hospitality, entertainment, customer travel

Gifts, business hospitality, entertainment and customer travel are only offered or accepted within the limits of local legislation and Group Instruction – Anti-Bribery and Corruption. We do not offer or accept gifts, business hospitality, entertainment or customer travel to encourage or reward a decision.


6.1 The Company's Board of Directors has overall responsibility for ensuring this Policy complies with Universal Gate General Traiding L.L.C. `s legal and ethical obligations, and that all those under UG's control comply with it.

6.2 The Compliance Officer has primary and day-to-day responsibility for implementing this Policy, and for monitoring its use and effectiveness. Management at all levels is responsible for ensuring those reporting to them are made aware of and understand this Policy.


7.1 The Company is engaged in conducting business in places where personal safety may not be guaranteed by local officials. If you are subjected to an immediate threat to personal safety you may put your personal well-being first, even if it means that you make a payment that contravenes this Policy.

7.2 The details of all incidents must be reported to the Compliance Officer immediately.