Anti-Bribery and Corruption (“Policy”)

Objective: At United Insurance Brokers (Emirates) LLC (UIBE), we uphold honesty, integrity, fairness, and transparency. We reject bribery and corruption in all aspects of our operations.

Policy Details:

Corruption and Bribery: Corruption involves misusing power for personal gain, while bribery is offering benefits for illegal actions.

Prohibition against Bribes: UIBE and its partners are prohibited from:

  • Giving or receiving bribes related to our business.
  • Offering advantages to influence improper actions.
  • Engaging in activities that breach this policy.

Specified Activities:


  • Cash gifts are not allowed.
  • Report gifts exceeding customary courtesies.
  • Consult your supervisor for gifts that may seem improper.

Entertainment and Hospitality:

• Acceptable hospitality must be reasonable and reported to supervisors.
• Sponsored travel needs a valid business purpose and prior approval.

Facilitating Payments:

  • Payments to government officials are usually prohibited unless approved.

Business Partners:

  • Partners must follow our Anti-Bribery and Corruption Policy or risk termination of the relationship.

Anti-Bribery and Corruption ("Policy") and Implementation

Created and developed by: Regina Doumit – Head of Compliance and Regulatory Affairs
Effective Date: 27th April 2023
Last update: 20th December 2023

1. Objective

United Insurance Brokers (Emirates) LLC (“UIBE”) prides itself on upholding ethical business practices, underlying values of honesty integrity, fairness and transparency. UIBE is dedicated to ethical business practice and we do not tolerate any form of bribery or corrupt conduct, either within UIBE activities or those of the parties with whom we seek to do business.

2. Scope

UIB’s compliance with this policy is the responsibility of the entire Governing Body including the Board of Directors, Senior Management as well as all UIBE personnel.

3. Responsibilities

  1. The Head of Compliance is responsible for development, maintenance, enforcement and endorsement of the policy.
  2. All Employees are responsible to read, understand, adhere, and sign-off on this policy as it relates to their day-to-day activities.
  3. The Head of Compliance is responsible to conduct training about this policy to employees.
  4. The Chief Executive Officer of the Company shall endorse this policy for its effective implementation.
  5. This policy shall form an integral part of the company compliance handbook after its endorsement by the Chief Executive Officer.

4. Policy in details

4.1 What is Corruption and Bribery?

  • 4.1.1 Corruption is the misuse of public office or power for private gain, or misuse of private power in relation to business outside the realm of government. Acts of bribery or corruption are designed to influence the individual in the performance of their duty and induce them to act dishonestly.
  • 4.1.2 Bribery is the most common form of corruption and can be broadly defined as the offering, promising, giving, accepting or soliciting of an advantage as an inducement or reward for an action which is illegal or a breach of trust.

4.2 Prohibition against bribes

UIBE personnel and business partners are prohibited from:

  • 4.2.1 Making or receiving bribes in regard to the Company’s business;
  • 4.2.2 offering or receiving any financial or other advantage to or from another party with the intention to influence or reward the improper performance of an activity;
  • 4.2.3 give, promise to give, or offer, a payment, loan, reward, gift or entertainment, to a Public Official, or any Third Party with the expectation or hope that a business advantage will be received, or to reward a business advantage already given (i.e. securing a permit, securing or renewing a contract with favourable terms, influencing a Public Official to take or omit an action in violation of his or her lawful duty etc.)
  • 4.2.4 Hospitality or entertainment of an inappropriate nature or which is offered/accepted for something in return. – threaten or retaliate against any person who has refused to commit a bribery offence or who has raised concerns under this policy;
  • 4.2.5 engage in any activity that might lead to a breach of this policy

4.3 Specified Activities

The following “Guidelines” explain how the Policy applies to certain types of activities:

  • 4.3.1 Gifts
  • Receiving/Giving gifts of cash is strictly prohibited.
  • You may not give or receive a gift from, anyone with whom the Company conducts business where the gift would exceed customary courtesies associated with accepted ethical and general commercial practice. You must ensure that the offer or acceptance of a gift does not create an obligation, or be construed by others to allege favoritism, discrimination or other unacceptable practice. When you receive a gift whatsoever the value please report the same to compliance by completing the following form
  • If you are requested to offer gifts that exceed the customary courtesies or that could give the appearance of impropriety, you must immediately consult your supervisor who shall inform Head of Compliance.
  • 4.3.2 Entertainment and Hospitality
  • Hospitality includes meals, invitations to events, functions or other social gatherings in connection with matters related to the business of the Company. These activities are acceptable provided they fall within reasonable bounds which seeks to improve the image of the Company, better to present its services and products, or establish cordial relationships. Any such acceptance/offer of entertainment and hospitality must be reported to the supervisor who shall inform the Head of Compliance.
  • Sponsored Travel. The Company may sponsor reasonable and bona fide travel expenses of customers, potential customers or a third party in appropriate circumstances, if such expenses are directly related to: – Promotion of products and services; – To perform a contract with customer; Sponsored travel expenses must have a legitimate business purpose and require prior written approval from Head of Compliance.
  • 4.3.3 Facilitating Payments
  • Facilitating payments are payments made to government officials to expedite or secure the performance of a routine governmental action such as payment to obtain permits, licenses or other documents to allow the Company to do business, to process visas and labor orders, to provide police protection, etc. There are limited circumstances in which the Company and its personnel may be permitted to make a payment to a government official without violating the applicable Anti-Corruption Law (Federal Law No. 3/1987 – The Penal Code).
  • It is the UIBE’s policy not to make or permit Facilitating Payments of any kind, except in certain limited situations in which a Facilitating Payment is lawful and unavoidable. All Facilitating Payments must be approved by the Head of Compliance and the Chief Executive Officer.
  • 4.3.4 Business Partners
  • UIBE will only establish the relationship with a business partner when it acknowledges to receive and comply with the provisions of Anti-Bribery and Corruption Policy of UIBE. Any business partner who is found to be violating any provision of this policy will be subject to termination of the relationship with the Company

5. Training

  • 5.1 to the extent that it is relevant to their role, UIB employees shall be made aware of and receive appropriate training in respect of the requirements under the UIBE Anti Bribery and Corruption Compliance Policy;
  • 5.2 in accordance with the UIBE Anti Bribery and Corruption Compliance Policy, records of all relevant training provided shall be maintained (where the records shall state the name, title and contact information of each trainee);

6. Policy compliance

  • 6.1 All UIB Employees must comply with the requirements of this policy.
  • 6.2 All UIB employees, to report any violations and/ or potential violations of applicable laws and regulations regarding bribery and corruption to the Head of Compliance.
  • 6.3 Any violation or breach to the policy may be subject to disciplinary actions including termination from job and/or referral to National Law Enforcement authorities against violator. Violator may also be subject to fines and/or imprisonment for breaches of the Anti-Corruption Law (Federal Law No. 3/1987 – The Penal Code)
  • 6.4 If UIB Employees are unsure or not clear of anything in this policy, they should seek clarification or advice from Compliance Team
  • 6.5 The Head of Compliance reserves the right to check the compliance of this policy on a periodic basis.