Komainu MEA FZE (“KMEA”) is committed to maintaining the highest standards of integrity, ethical conduct, and regulatory compliance in all aspects of its business activities. KMEA adopts a strict zero-tolerance approach to bribery and corruption and conducts its operations in accordance with applicable laws, regulations, and regulatory requirements, including those prescribed by the Dubai Virtual Assets Regulatory Authority (“VARA”).
KMEA strictly prohibits any form of bribery, corruption, facilitation payment, kickback, or other improper advantage, whether offered, promised, given, requested, solicited, or accepted directly or indirectly through any third party. Business decisions must be made solely on legitimate commercial, legal, and regulatory considerations and must never be influenced by improper inducements or personal benefit.
To support this commitment, KMEA has established and maintains a comprehensive Anti-Bribery and Corruption (“ABC”) framework comprising policies, procedures, controls, monitoring arrangements, and reporting mechanisms designed to identify, mitigate, prevent, detect, investigate, and remediate bribery and corruption risks.
KMEA’s ABC framework applies to all directors, officers, employees, contractors, consultants, and other persons acting on behalf of, or for the benefit of, KMEA. In addition, KMEA expects third-party service providers, business partners, vendors, and other relevant counterparties to maintain standards of conduct consistent with applicable anti-bribery and anti-corruption requirements.
As part of its ABC framework, KMEA:
- prohibits bribery, corruption, facilitation payments, kickbacks, and other forms of improper influence in any form
- maintains risk-based policies, procedures, and internal controls designed to prevent and detect potential bribery and corruption risks
- conducts appropriate due diligence and ongoing oversight of relevant third parties, business partners, suppliers, and service providers
- provides periodic training and awareness programmes to relevant personnel regarding anti-bribery and corruption obligations
- maintains procedures for the confidential reporting, escalation, investigation, and remediation of suspected or actual breaches of applicable anti-bribery and corruption requirements
- requires all personnel and relevant third parties to comply with applicable laws, regulations, internal policies, and ethical standards
- takes appropriate disciplinary, contractual, regulatory, and remedial action where misconduct or violations are identified
KMEA encourages the prompt reporting of any actual, suspected, or attempted acts of bribery, corruption, or other unethical conduct. Reports and enquiries relating to KMEA’s Anti-Bribery and Corruption framework may be notified: (i) to the Compliance Department by email at compliance@komainu.com; or (ii) in writing, addressed to “Komainu Compliance” at: Komainu MEA FZE, Floor 1, The Offices 4 – One Central, Dubai World Trade Centre.
KMEA reviews its Anti-Bribery and Corruption framework periodically to ensure its continued effectiveness and alignment with applicable legal, regulatory, and industry standards.