Anti-Bribery and Corruption Policy

Anti-Money Laundering Policy

Whistleblower Policy

Anti-Bribery and Corruption Policy

1. Policy Statement:

At AHOY, we uphold our core values of integrity, transparency, and accountability in all our business dealings. We are committed to conducting our operations ethically and legally, strictly prohibiting bribery, corruption, and any other unethical conduct that could damage our reputation, undermine our integrity, or violate applicable laws, including those of the United Arab Emirates (UAE). This policy affirms our zero-tolerance stance towards any form of bribery and corruption and sets out the principles and standards required of all employees, directors, contractors, agents, consultants, and third-party representatives.

2. Purpose and Objectives:

To reinforce the importance of ethical conduct and compliance under UAE anti-bribery laws.
To provide clear guidance on acceptable and unacceptable behaviors related to bribery and corruption.
To prevent, detect, and address bribery and corruption within our business operations.
To establish a strong culture of integrity that supports sustainable growth and stakeholder confidence.

3. Scope and Applicability:

This policy applies to all AHOY personnel, including full-time employees, temporary staff, contractors, consultants, agents, board members, and third-party partners acting on behalf of AHOY, both within the UAE and in internationally operating contexts. All individuals involved in AHOY’s business activities must familiarize themselves with and adhere to this policy.

4. Legal Framework and Principles:

This policy is aligned with and designed to comply with UAE Federal Law No. 3 of 1987 (UAE Penal Code) concerning anti-bribery and corruption, as well as other relevant UAE laws and regulations, including:

UAE Federal Anti-Commercial Fraud Law
UAE Law Concerning Criminal and Civil Penalties for Bribery and Corruption
UAE’s commitment to international anti-bribery conventions, including those by the United Nations and the Organisation for Economic Co-operation and Development (OECD).

Our principles are based on:

Zero tolerance for bribery and corruption.
Commitment to lawful conduct and ethical integrity.
Maintaining transparency in all dealings.
Ensuring fair treatment of all stakeholders.
Providing training and resources to prevent misconduct.
Encouraging a speak-up culture for compliance concerns.

5. Definitions and Clarifications:

Bribery: Offering, promising, giving, accepting, or soliciting anything of value (e.g., money, gifts, favors, hospitality, or other benefits) to influence the actions or decisions of a person in a position of authority or to gain an improper advantage.
Corruption: Abuse of entrusted power or position for personal gain or to benefit a third party dishonestly, including bribery, kickbacks, embezzlement, or facilitation payments.
Facilitation Payments: Small, unofficial payments made to secure or expedite routine government actions or services, which are strictly prohibited under this policy and UAE law.
Third Parties: Any external entity or individual acting on behalf of AHOY, including vendors, contractors, agents, partners, or representatives.

6. Prohibited Conduct and Conduct Expectations:

Offering Bribes: Employees are strictly forbidden from offering, promising, or giving any bribe or illicit benefit directly or through intermediaries, regardless of whether such conduct is legal in the jurisdiction.
Receiving Bribes: Employees must refuse any inducement to influence or compromise their impartiality.
Gifts and Hospitality: All gifts, entertainment, or hospitality provided or accepted must be reasonable, proportionate, transparent, and permissible under local laws and AHOY policies. Gifts of substantial value or that might influence business decisions are prohibited unless explicitly approved by senior management and properly documented.
Third-Party Engagements: Before engaging third parties, conduct due diligence to assess risks and include contractual provisions requiring strict compliance with anti-bribery laws.
Facilitation Payments: Absolutely prohibit any facilitation payments, regardless of size or perceived urgency.
Use of Intermediaries: Ensure transparency in dealings with intermediaries; avoid schemes that conceal corrupt intent.

7. Due Diligence and Risk Management:

Conduct comprehensive risk assessments and due diligence when selecting new business partners, agents, or contractors, focusing on their compliance with anti-bribery laws.
Regularly review and monitor third-party compliance through audits, performance assessments, and contractual obligations.
Maintain a register of high-risk transactions and third-party relationships for ongoing oversight.

8. Gifts, Hospitality, and Donations:

Gifts, hospitality, or donations should always be modest, transparent, and within reasonable standards customary in business practice.
All gifts and hospitality exceeding predefined monetary limits or considered potentially influential require prior approval from senior management and must be properly documented.
Donations to charities or political entities must be transparent, compliant

Anti-Money Laundering Policy

1. Policy Statement

At AHOY, we are committed to preventing money laundering, terrorist financing, and related financial crimes. We uphold the highest standards of integrity, compliance, and transparency in all our business operations. This Anti-Money Laundering (AML) Policy reflects our dedication to compliance with applicable laws and regulations in the United Arab Emirates (UAE), including Federal Law No. 20 of 2018 Concerning Anti-Money Laundering and Combating the Financing of Terrorism, and associated regulations.

2. Purpose and Objectives

To establish a robust framework for detecting, preventing, and reporting potential money laundering and terrorist financing activities.
To ensure compliance with UAE AML regulations and international best practices.
To educate and empower employees to identify and mitigate AML risks.
To safeguard AHOY’s reputation and integrity by fostering a culture of compliance and transparency.

3. Scope and Applicability

This policy applies to all employees, officers, directors, contractors, agents, consultants, and any third parties acting on behalf of AHOY across all geographic jurisdictions, particularly within the UAE. It covers all aspects of AHOY’s operations, including but not limited to financial transactions, client onboarding, and third-party engagements.

4. Definitions

Money Laundering: The process of concealing the origins of illegally obtained money, typically by complex transactions, to make it appear as legitimate funds.
Terrorist Financing: Providing financial support for terrorist activities, regardless of the source.
Suspicious Activity: Any transaction or activity that raises concerns about potential money laundering or terrorist financing.
Customer Due Diligence (CDD): Procedures to verify the identity of clients and assess AML risks before establishing a business relationship.
Enhanced Due Diligence (EDD): Additional verification measures for higher-risk clients or transactions.

5. Legal and Regulatory Framework

AHOY commits to full compliance with applicable AML laws, including:

UAE Federal Law No. 20 of 2018 on AML and Terrorism Financing.
UAE Executive Regulations and related guidelines issued by the UAE Central Bank and the Financial Intelligence Unit (FIU).
International AML standards from FATF (Financial Action Task Force) and other relevant bodies.

6. Customer Due Diligence (CDD) and KYC Procedures

All clients and third parties must undergo appropriate CDD and KYC checks prior to establishing or continuing business relationships.
Customer identification must include verification of identity documents, source of funds, and assessment of AML risks.
High-risk clients and transactions will undergo EDD with stricter scrutiny and ongoing monitoring.
Ongoing monitoring of all transactions is required to identify suspicious activity.

7. Detection and Reporting of Suspicious Activities

Employees are trained to recognize red flags such as inconsistent transaction patterns, unusual client behavior, or suspicious documentation.
Any staff suspecting money laundering or terrorist financing must report promptly to the designated AML compliance officer or department.
All reports will be handled with confidentiality and in accordance with UAE legal obligations.
Suspicious activity reports (SARs) must be submitted to the UAE FIU without delay, following established reporting procedures.

8. Record Keeping

Maintain detailed records of all AML-related activities, including customer information, transaction records, risk assessments, and SARs.
Records must be retained for a minimum of five years from the end of the business relationship or transaction, in accordance with UAE law.
Recordkeeping must ensure data confidentiality and security.

9. Training and Awareness

All relevant personnel will receive ongoing AML training to stay informed of legal requirements, red flags, and reporting obligations.
Training will be conducted periodically and tailored to employees' roles and exposure to AML risks.

10. Internal Controls and Compliance

Establish and maintain effective internal controls, policies, and procedures to prevent AML violations.
Designate an AML Compliance Officer responsible for oversight, monitoring, and enforcement of this policy.
Conduct periodic AML risk assessments and audits to identify vulnerabilities and improvement areas.
Implement independent reviews and audits on AML compliance.

11. Due Diligence in Third-Party Relationships

Conduct thorough AML risk assessments for third-party relationships, including due diligence on clients, vendors, partners, and agents.
Incorporate contractual provisions requiring compliance with AML laws and this policy.

12. Policy Review and Continuous Improvement

This AML Policy will be reviewed annually or upon regulatory updates to remain current and effective.
Updates and improvements will be incorporated based on new risks, regulatory changes, or audit findings.

13. Disciplinary Actions

Non-compliance with this AML policy may result in disciplinary action, up to and including termination of employment or engagement, and legal prosecution under UAE law.
Employees are encouraged to report any concerns

1. Policy Statement

2. Purpose and Objectives

To establish a robust framework for detecting, preventing, and reporting potential money laundering and terrorist financing activities.
To ensure compliance with UAE AML regulations and international best practices.
To educate and empower employees to identify and mitigate AML risks.
To safeguard AHOY’s reputation and integrity by fostering a culture of compliance and transparency.

3. Scope and Applicability

4. Definitions

Money Laundering: The process of concealing the origins of illegally obtained money, typically by complex transactions, to make it appear as legitimate funds.
Terrorist Financing: Providing financial support for terrorist activities, regardless of the source.
Suspicious Activity: Any transaction or activity that raises concerns about potential money laundering or terrorist financing.
Customer Due Diligence (CDD): Procedures to verify the identity of clients and assess AML risks before establishing a business relationship.
Enhanced Due Diligence (EDD): Additional verification measures for higher-risk clients or transactions.

5. Legal and Regulatory Framework

AHOY commits to full compliance with applicable AML laws, including:

UAE Federal Law No. 20 of 2018 on AML and Terrorism Financing.
UAE Executive Regulations and related guidelines issued by the UAE Central Bank and the Financial Intelligence Unit (FIU).
International AML standards from FATF (Financial Action Task Force) and other relevant bodies.

6. Customer Due Diligence (CDD) and KYC Procedures

All clients and third parties must undergo appropriate CDD and KYC checks prior to establishing or continuing business relationships.
Customer identification must include verification of identity documents, source of funds, and assessment of AML risks.
High-risk clients and transactions will undergo EDD with stricter scrutiny and ongoing monitoring.
Ongoing monitoring of all transactions is required to identify suspicious activity.

7. Detection and Reporting of Suspicious Activities

Employees are trained to recognize red flags such as inconsistent transaction patterns, unusual client behavior, or suspicious documentation.
Any staff suspecting money laundering or terrorist financing must report promptly to the designated AML compliance officer or department.
All reports will be handled with confidentiality and in accordance with UAE legal obligations.
Suspicious activity reports (SARs) must be submitted to the UAE FIU without delay, following established reporting procedures.

8. Record Keeping

Maintain detailed records of all AML-related activities, including customer information, transaction records, risk assessments, and SARs.
Records must be retained for a minimum of five years from the end of the business relationship or transaction, in accordance with UAE law.
Recordkeeping must ensure data confidentiality and security.

9. Training and Awareness

All relevant personnel will receive ongoing AML training to stay informed of legal requirements, red flags, and reporting obligations.
Training will be conducted periodically and tailored to employees' roles and exposure to AML risks.

10. Internal Controls and Compliance

Establish and maintain effective internal controls, policies, and procedures to prevent AML violations.
Designate an AML Compliance Officer responsible for oversight, monitoring, and enforcement of this policy.
Conduct periodic AML risk assessments and audits to identify vulnerabilities and improvement areas.
Implement independent reviews and audits on AML compliance.

11. Due Diligence in Third-Party Relationships

Conduct thorough AML risk assessments for third-party relationships, including due diligence on clients, vendors, partners, and agents.
Incorporate contractual provisions requiring compliance with AML laws and this policy.

12. Policy Review and Continuous Improvement

This AML Policy will be reviewed annually or upon regulatory updates to remain current and effective.
Updates and improvements will be incorporated based on new risks, regulatory changes, or audit findings.

13. Disciplinary Actions

Non-compliance with this AML policy may result in disciplinary action, up to and including termination of employment or engagement, and legal prosecution under UAE law.
Employees are encouraged to report any concerns

Whistleblower Policy

1. Policy Statement:

At AHOY, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct across all aspects of our operations. We recognize that issues such as misconduct, dishonesty, or legal violations can occur despite our best efforts. To uphold our commitment, we encourage all employees, contractors, and stakeholders to report any concerns about unethical, illegal, or suspicious activities without fear of retaliation. This Whistleblower Policy provides a clear framework to protect individuals who report in good faith and ensures that reports are handled fairly, confidentially, and effectively, in compliance with UAE laws.

2. Purpose and Objectives:

To provide a secure and feasible mechanism for reporting concerns regarding misconduct or violations of laws, regulations, or company policies.
To protect whistleblowers from retaliation, discrimination, or unfair treatment.
To promote a transparent culture rooted in accountability and integrity.
To uphold compliance with UAE Federal Law No. 7 of 2016 on Combating Commercial Frauds and Money Laundering and other relevant legal frameworks.

3. Scope and Applicability:

This policy applies to all employees, directors, contractors, vendors, business partners, and any other stakeholders associated with AHOY. It covers a broad spectrum of concerns, including but not limited to:

Fraud, corruption, or bribery
Financial irregularities or misreporting
Violations of laws, regulations, or company policies
Harassment, discrimination, or unethical conduct
Data breaches or misuse of proprietary information
Environment, health, and safety violations

4. Reporting Channels

To facilitate safe and accessible reporting, AHOY provides multiple channels:

Dedicated Whistleblower Hotline: Confidential telephone line managed by an external provider.
Email Reporting: Secure email address monitored by the designated compliance or HR team.
Anonymous Reporting Portal: Secure online portal enabling anonymous submissions.
In-Person Reporting: Direct communication with designated compliance officers or senior management, if preferred.

All reports will be treated with the utmost confidentiality, respecting the whistleblower’s identity and privacy.

5. Confidentiality and Anonymity

AHOY commits to protecting the identity of whistleblowers to the greatest extent possible, subject to legal and investigative requirements. Whistleblowers are encouraged to disclose their identity to enable proper investigation; however, anonymous reports are also accepted and will be seriously considered and investigated.

6. Protection Against Retaliation

No Retaliation Policy: AHOY prohibits retaliation, discrimination, harassment, or any adverse action against anyone making a good-faith report. Retaliation offenders will face disciplinary measures, including termination of employment or contractual relationship, and legal action if applicable.
Good-Faith Reporting: Whistleblowers are expected to provide honest and factual information. Malicious or unfounded reports made with malicious intent may be subject to disciplinary action.
Protection Measures: Whistleblowers will be protected from dismissal, demotion, harassment, or any adverse treatment related to their reporting.

7. Investigation Process

All reports will be recorded, reviewed, and investigated promptly and thoroughly by a designated Compliance Officer or a special investigations team.
Investigations will be conducted confidentially, maintaining fairness and due process.
The whistleblower may be interviewed as part of the investigation process, and their input will be considered.
Findings and recommendations will be documented, and appropriate corrective actions will be implemented.

8. Handling of Reports

Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.

9. Record Keeping

Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.

10. Training and Awareness

All reports, investigation records, and follow-up actions will be securely stored, access limited to authorized personnel.
Data will be retained in accordance with applicable laws and internal policies.

11. Review and Continuous Improvement

This policy will be reviewed annually to ensure effectiveness, relevance, and compliance with UAE legal requirements.
Feedback from employees and stakeholders will be incorporated to improve the reporting and protection mechanisms.

12. Legal and Regulatory Compliance

AHOY’s whistleblowing procedures are designed to align with relevant UAE laws, including Federal Law No. 7 of 2016 concerning anti-money laundering and anti-fraud measures, as well as other applicable regulations.
Disclosures made in good faith and in compliance with

1. Policy Statement:

2. Purpose and Objectives:

To provide a secure and feasible mechanism for reporting concerns regarding misconduct or violations of laws, regulations, or company policies.
To protect whistleblowers from retaliation, discrimination, or unfair treatment.
To promote a transparent culture rooted in accountability and integrity.
To uphold compliance with UAE Federal Law No. 7 of 2016 on Combating Commercial Frauds and Money Laundering and other relevant legal frameworks.

3. Scope and Applicability:

Fraud, corruption, or bribery
Financial irregularities or misreporting
Violations of laws, regulations, or company policies
Harassment, discrimination, or unethical conduct
Data breaches or misuse of proprietary information
Environment, health, and safety violations

4. Reporting Channels

To facilitate safe and accessible reporting, AHOY provides multiple channels:

Dedicated Whistleblower Hotline: Confidential telephone line managed by an external provider.
Email Reporting: Secure email address monitored by the designated compliance or HR team.
Anonymous Reporting Portal: Secure online portal enabling anonymous submissions.
In-Person Reporting: Direct communication with designated compliance officers or senior management, if preferred.

All reports will be treated with the utmost confidentiality, respecting the whistleblower’s identity and privacy.

5. Confidentiality and Anonymity

6. Protection Against Retaliation

No Retaliation Policy: AHOY prohibits retaliation, discrimination, harassment, or any adverse action against anyone making a good-faith report. Retaliation offenders will face disciplinary measures, including termination of employment or contractual relationship, and legal action if applicable.
Good-Faith Reporting: Whistleblowers are expected to provide honest and factual information. Malicious or unfounded reports made with malicious intent may be subject to disciplinary action.
Protection Measures: Whistleblowers will be protected from dismissal, demotion, harassment, or any adverse treatment related to their reporting.

7. Investigation Process

All reports will be recorded, reviewed, and investigated promptly and thoroughly by a designated Compliance Officer or a special investigations team.
Investigations will be conducted confidentially, maintaining fairness and due process.
The whistleblower may be interviewed as part of the investigation process, and their input will be considered.
Findings and recommendations will be documented, and appropriate corrective actions will be implemented.

8. Handling of Reports

Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.

9. Record Keeping

Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.

10. Training and Awareness

All reports, investigation records, and follow-up actions will be securely stored, access limited to authorized personnel.
Data will be retained in accordance with applicable laws and internal policies.

11. Review and Continuous Improvement

This policy will be reviewed annually to ensure effectiveness, relevance, and compliance with UAE legal requirements.
Feedback from employees and stakeholders will be incorporated to improve the reporting and protection mechanisms.

12. Legal and Regulatory Compliance

AHOY’s whistleblowing procedures are designed to align with relevant UAE laws, including Federal Law No. 7 of 2016 concerning anti-money laundering and anti-fraud measures, as well as other applicable regulations.
Disclosures made in good faith and in compliance with