ANTI-BRIBERY AND CORRUPTION POLICY

About OFZA
OFZA Fintech Virtual Asset Exchange Services LLC (the “Firm”, “the Company”, “OFZA”) is licensed and regulated by the Dubai Virtual Assets Regulatory Authority (VARA) as a Virtual Asset Service Provider (VASP Reference: VL/24/12/002) for the following Virtual Asset Activities:
• Exchange Services,
• Broker-Dealer Services
• Management & Investment Services.
OFZA has its registered office at Office 21C13, i-Rise Tower, Al Thanyah First, Al Barsha Heights, Dubai, United Arab Emirates.
General Principles
1. OFZA is committed to conducting all business activities with integrity, honesty, and transparency, maintaining a zero-tolerance stance toward all forms of bribery, corruption, facilitation payments, and related misconduct.
2. The purpose of this Policy is to define OFZA’s principles, responsibilities, and controls for preventing, detecting, and responding to bribery and corruption across all business activities.
3. OFZA has established clear mechanism so that Entities outside of OFZA can reports and OFZA will ensure that it will protect the identity and confidentiality of the Entity who has made a report at all times.
4. The Policy aims to:
  1. Define clear responsibilities for employees, representatives, and third parties in identifying, preventing, and reporting bribery or corruption.
  2. Ensure that the Board and all Staff must act professionally, fairly and with integrity in all business dealings and relationships
  3. Implement effective anti-bribery controls, due-diligence procedures, and transparent record-keeping standards to safeguard OFZA, its clients, and stakeholders from legal, financial, and reputational harm.
  4. Promote awareness of bribery and corruption risks and provide practical guidance on their prevention, detection, and reporting.
  5. Provide regular training and awareness programs to reinforce OFZA’s zero-tolerance culture. Establish structured mechanisms for escalation, whistleblowing, and investigation of suspected breaches.
  6. Whistle-blowers acting in good faith are protected from retaliation, discrimination, or any form of adverse treatment. Ensure continuous monitoring, auditing, and annual review of this Policy to maintain compliance with the VARA Compliance and Risk Management Rulebook and applicable UAE legislation.
  7. Foster a culture of integrity, transparency, accountability, and ethical decision-making throughout the organization.
Scope and Applicability
1. Bribery and corruption often intersect with money laundering, organized crime, and terrorist financing. To mitigate operational, legal, compliance and reputational risk, OFZA maintains robust internal controls, ongoing monitoring, and secure reporting channels to prevent, detect, and address any bribery, corruption misconduct.
2. This Policy applies to:
  1. All members of the Board of Directors, Senior Management, and Employees of OFZA.
  2. All contractors, consultants, intermediaries, agents, and third parties acting for or on behalf of OFZA; and
  3. All subsidiaries, affiliates, and controlled entities in every jurisdiction where OFZA operates.
  4. Where UAE laws or regulatory requirements impose stricter standards, those standards shall prevail. All covered persons must comply with this Policy irrespective of local customs or business practices.
  5. OFZA ensures that its zero-tolerance approach toward bribery and corruption is embedded in every aspect of its operations through clear governance, compliance controls, and staff accountability.
  6. The Board of Directors and Senior Management reaffirm their responsibility for promoting ethical conduct, ensuring that all employees and third parties acting on behalf of OFZA uphold these principles and promptly report any suspected breach or unethical behaviour.
  7. The Board shall 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 OFZA conducts its business.
  8. The primary and day-to-day responsibility oversight and periodic review of the implementation and effectiveness of this Policy-including the monitoring of gifts, hospitality, and potential conflicts of interest-shall be undertaken by the Compliance Officer (‘CO’).
Prohibited and Restricted Policies
1. It is prohibited for any OFZA employees, members of the Board to:
  1. 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.
  2. give, promise to give, or offer a payment, gift or hospitality to a third party to facilitate or expedite a routine procedure.
  3. 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 OFZA in return.
  4. It is given directly to an employee or board member on behalf of company or secretly as gift or hospitality which includes cash or cash equivalents also.
  5. 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
  6. engage in any activity that might lead to a breach of the anti-bribery and corruption that VARA has stipulated in Compliance and Risk Management Rulebook and accordance with this policy.
2. It is strictly prohibited to offer, give, solicit, or accept any gift, hospitality, or other benefit to or from any Public Official or Politically Exposed Person (PEP)- including employees of government bodies, state-owned enterprises, political parties, or public international organizations - without obtaining prior written approval from the CO and Board, acting under delegated authority from Senior Management and the Board.
3. Gifts or hospitality must never be offered or accepted with the intention, expectation, or appearance of influencing business judgement, regulatory outcomes, or obtaining an improper advantage. Any action that could reasonably be perceived as an attempt to improperly obtain or retain business, or to secure an unethical advantage, is strictly prohibited.
Permitted Courtesies, Approval and Declaration Requirements
1. OFZA do not prohibit normal and appropriate hospitality (given or received in accordance with the OFZA Anti-Bribery Corruption Policy) to or from third parties, provided relevant policies are complaint with applicable laws. OFZA permits giving or receiving of normal business courtesies provided that such courtesies:
  1. Serve a legitimate business purpose.
  2. Are lawful in the recipient’s jurisdiction; and
  3. Do not create an actual or perceived conflict of interest.
  4. Does not violate VARA Regulations and Rulebook mandates
  5. Are in line with OFZA internal policy.
2. Any gift, meal, entertainment, or hospitality exceeding AED 500 in value—or multiple gestures from the same source collectively exceeding AED 500 within a calendar year—shall be handled in accordance with OFZA internal approval and reporting procedures.
3. Gifts or hospitality must never be offered or accepted with the intention, expectation, or appearance of influencing business judgement, regulatory outcomes, or obtaining an improper advantage.
4. For any other circumstances, such as where the recipient is unable to return the gifts, invitations and/or hospitality, or that the Employee would like to provide a gift to a business partner, strict compliance with the internal approval and reporting procedures must be followed.
5. The CO shall review the purpose, value, timing, and context of each declaration or proposed benefit to determine whether it is lawful, proportionate, and transparent, and consistent with this Policy, and applicable regulations.
6. Any identified deficiencies or breaches shall be documented and escalated to Senior Management and the Board for corrective and remedial action and will be notified to VARA in accordance with supervision reporting requirements.
7. All declarations, approvals, and supporting documentation shall be accurately recorded, securely retained, and periodically reviewed in accordance with OFZA’s record-keeping policy for a period of eight (8) years in compliance with VARA regulations.
Conflicts of Interest and Relatives of Officials
1. OFZA shall ensure that all actual, potential, or perceived conflicts of interest are identified, disclosed, and appropriately managed. Conflicts of interest may create or appear to create improper influence or corruption risk.
2. All Employees must promptly disclose to the CO any situation that may compromise objectivity, independence, or regulatory integrity.
Reporting Channels
1. 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 has occurred, or may occur, or has been solicited by any other Entity.
2. The CO shall investigate any reported or suspected violation of this Policy and ensure the process is conducted confidentially and independently.
3. Reports may be submitted through multiple channels, including a telephone hotline, dedicated email, or secure portal. OFZA has established dedicated email and through mobile number for receiving reports of any violation or possible violation of any applicable laws and regulations relevant to anti-bribery and corruption by OFZA, or its Board or Staff on its behalf. The reports can be made through.
  1. Dedicated email for receiving any bribery or corruption [email protected]
  2. Notify by calling direct official line +971521069982
Investigation Procedures
1. The CO shall investigate any report of a violation or possible violation of the anti-bribery and corruption and shall follow the below procedures:
  1. An investigation file should be opened. In the case of an oral report, the CO should prepare a written summary.
  2. The CO shall appoint an independent Entity who shall promptly commission the conduct of an investigation. The investigation will document all relevant facts, including Entities involved, times and dates.
  3. The CO shall advise the Board of the existence of an investigation.
  4. The identity of the individual disclosing relevant information to the CO should be treated in accordance with applicable UAE laws and regulations.
  5. The CO will appoint an independent Entity who shall promptly commission the conduct of an investigation.
  6. On completion of the investigation, a written investigation report will be provided by the Entity employed to conduct the investigation to the CO.
  7. If any unlawful conduct is found, the CO must advise the Board accordingly. If any unlawful conduct is found, OFZA shall 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 Entity employed to conduct the investigation shall prepare a written summary of the remedial actions taken.
2. Following closure of an investigation, the CO shall ensure that control gaps are addressed through corrective measures, disciplinary actions are taken where misconduct is proven, any illicit gains are recovered (where applicable), and relevant policies, procedures, and training are updated to prevent recurrence.
3. All investigation and remediation activities must comply with UAE laws and the VARA laws, with supporting documentation maintained for regulatory review. 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 will be made available to VARA upon request.
4. In cases where allegations of bribery or corruption involve the CO:
  1. The Board shall appoint an independent third party or OFZA independent director/chairperson to lead the investigation.
  2. The CO shall be excluded from any involvement in the investigation to prevent conflicts of interest and maintain the integrity of the process.
  3. The investigation shall be conducted with strict confidentiality, in line with VARA's regulatory standards and OFZA’s Governance & Oversight Framework, to protect sensitive information and ensure procedural fairness.
  4. All findings, actions, and outcomes shall be documented and reported in accordance with VARA regulations, including updates to the Conflicts of Interest Register and any required disclosures to relevant authorities. In case the allegations are identified as true, Board will take necessary disciplinary actions against the CO including but not limited to suspension, termination and prompt notification to VARA.
Information and Training
1. OFZA has developed and provide a comprehensive training program for all members of the Board of Directors, Senior Management, and Employees to ensure understanding and adherence to the principles of this Policy and all applicable laws.
2. The training program shall be conducted on a regular basis and include induction training upon joining, periodic refresher sessions to maintain ongoing awareness of anti-bribery and anti-corruption obligations and regulatory developments.
3. Participation in all training sessions is mandatory for all Board members and Employees. Attendance and completion are monitored by the CO, and records of participation are maintained for regulatory inspection and audit purposes.
4. All members of the Board and Employees have continuous access to the most current version of this Policy. The Compliance Department ensures that any amendments or updates are promptly communicated to all relevant personnel.
5. Training forms an integral part of OFZA’s onboarding and induction program for all new Board members, Employees, and Representatives. Induction training includes OFZA’s ethical standards, reporting channels, and zero-tolerance stance toward bribery and corruption.
Accountability and Consequences
1. OFZA prohibits the offer, promise, or provision of any bribe, kickback, or improper advantage, directly or indirectly through any intermediary, agent, consultant, vendor, introducer, service provider, or other third party, regardless of jurisdiction or business context.
2. All Employees, Board Members and Representatives must recognize that participating in, concealing, or failing to report any known or suspected act of bribery or corruption constitutes a serious breach of duty and may amount to a criminal offence under applicable UAE laws, the VARA Rulebook, and this Policy.
3. Any individual who deliberately conceals relevant information, provides false or misleading statements, obstructs an internal review, or fails to co-operate with an investigation shall be subject to disciplinary action, up to and including termination of employment or contract and where applicable CO shall report such incidents to VARA, UAE-FIU through goAML platform and law enforcement authorities.
4. Where warranted, such conduct shall be reported to competent authorities, including the Virtual Assets Regulatory Authority and may result in civil, regulatory, or criminal liability.
5. All confirmed breaches will be handled in accordance with Investigation & Remediation, ensuring independent review, fair treatment, and timely corrective action.
Facilitation Payments (“Greasing”)
1. OFZA strictly prohibits the giving, offering, soliciting, or acceptance of any facilitation, expediting, or “grease” payment by any Employee, Director, or Representative. Such conduct violates OFZA’s zero-tolerance commitment to bribery and corruption.
Charitable Donations and Sponsorships
1. In line with international standards (Transparency International, OECD, and FATF Recommendations) and applicable UAE anti-corruption laws, charitable donations, community investments, and sponsorships are recognized as high-risk areas that may be misused as channels for bribery or improper influence.
2. Improper payments must never be disguised as contributions to charities or community projects, particularly where such organizations are linked to public officials, Politically Exposed Persons (PEPs), or decision-makers.
3. To mitigate these risks:
  1. Prior written approval from the CO and Board is required before any donation or sponsorship is made.
  2. Risk-based due diligence must be conducted on all recipient organizations to verify their legitimacy, ownership, and purpose.
  3. Ad-hoc or unplanned donations are prohibited unless expressly approved by Senior Management and reviewed by the CO.
  4. All approved donations and sponsorships must be accurately recorded and subject to compliance review and Board oversight.