BitGo Anti-Bribery & Corruption (ABC) Policy
Introduction
BitGo Custody MENA FZE
BitGo Custody MENA FZE. (the “Company”, “Our”, “We” or “BGM”), is a Dubai World Trade Centre -based entity and affiliate of the BitGo Group of Companies (BitGo Holdings, Inc. USA and its subsidiaries).
The obligations within the scope of this policy include but are not limited to the VARA Virtual Assets and Related Activities regulations and, the VARA rules and guidelines; the United Arab Emirates (UAE) Federal laws and regulations, and Group Policies.
Objectives
Global Anti Bribery and corruption policy apply to Bitgo Custody MENA as well. This Addendum is to be read in conjunction with the Global ABC Policy and other related policies and procedures and serves as a supplement outlining the local requirements applicable to BGM only. Together, the Global Policy and this Addendum establish the core standards and elements of a sound Anti Bribery and Corruption program for the Company.
Scope
This Addendum applies to all employees, officers, directors, contractors, vendors and other outsourced service providers of BGM (“BitGo Personnel”).
Anti-Bribery and Corruption
The Firm conducts all business honestly and ethically and takes a zero-tolerance approach to bribery and corruption. The Board and all Staff must act professionally, fairly, and with integrity in all business dealings and relationships.
The CO is the responsible person for investigating and reporting violations or possible violations of the anti-bribery and corruption Rules. All the records will be maintained for at least 8 years.
Staff will be trained as per the global policy and possible ways of reporting to the CO any violation that they become aware of.
It is prohibited for any members of the Board and all Staff, to:
- give, promise to give, or offer, a payment, gift, or hospitality to a third party or otherwise engage in or permit a bribery offense to occur, with the expectation or hope that an advantage in business will be received or to reward a business advantage already given.
- give, promise to give, or offer, a payment, gift, or hospitality to a third party to facilitate or expedite a routine procedure.
- accept a payment, gift or hospitality from a third party if it knows or suspects that such payment, gift or hospitality is offered or provided with an expectation that a business advantage will be provided by the Company in return;
- threaten or retaliate against another member of the Board or Staff who has refused to commit a bribery offence or who has raised concerns; and
- engage in any activity that might lead to a breach of the anti-bribery and corruption Rules in VARA Compliance and Risk Management Rulebook.
Please refer to the Firms Group Anti-Bribery & Corruption (ABC) Policy. In addition to this policy, the following VARA specific obligations will be complied with:
| Condition | Requirement |
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| Corrupt Payments | - The Firm, its Board, Staff, consultants or contractors, any Group company, agent, business partner, contractor or suppliers are prohibited to make any payment[s] to a third party where there is any reason to believe that all or any part of such payment will go towards a bribe or otherwise facilitate any corruption.
- All payments made by the Firm must be appropriate and justifiable for the purpose of legitimate services provided.
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| Investigating and Reporting | - The Firm must establish, maintain and publish methods of contact including, but not limited to, email: compliance@bitgo.com, and telephone: +971 50 468 2188 for receiving reports of any violation or possible violation of any applicable laws and regulations relevant to anti-bribery and corruption by the VASP, or its Board or Staff on its behalf.
- Any member of the Board or Staff must report to the CO as soon as possible if they believe or suspect that an action in conflict with the anti-bribery and corruption Rules.
- The CO will investigate any report of a violation or possible violation of the anti-bribery and corruption Rules.
- The CO will appoint an independent Entity who shall promptly commission the conduct of an investigation.
- The CO will advise the Board of the existence of an investigation.
- On completion of the investigation, a written investigation report will be provided by the Entity employed to conduct the investigation to the CO.
- If any unlawful conduct is found, the Firm will take such remedial action as the Board deems appropriate to achieve compliance with its internal anti-bribery and corruption policy and all applicable anti- bribery and corruption laws.
- The written investigation report and a written summary of the remedial actions taken shall be retained by the CO for a period of no less than eight [8] years from completion of the remedial action. Such reports shall be made available to VARA upon request.
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| Information and Trainings | - The Firm will implement and provide an anti-bribery and corruption training programme for the Board and all Staff on a regular basis and monitor their compliance with all established procedures. All members of the Board and Staff must participate in all such trainings.
- Training on the anti-bribery and corruption policy will form part of the induction programme made available to all new Board members and Staff.
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| Policy Responsibility | - The Board will have the overall responsibility for ensuring its anti-bribery and corruption policy is up-to-date and complies with all applicable laws and regulations in all jurisdictions where the Firm conducts its business.
- The CO has the primary and day-to-day responsibility for implementing the anti-bribery and corruption policy and for monitoring its effectiveness.
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| Breach Consequences | - Failure to comply with a Firm's anti-bribery and corruption policy should result in severe consequences, including internal disciplinary action and termination of employment without notice.
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