Purpose and scope
This policy prevents bribery and corruption in Blue Palm’s sourcing, procurement, sales, logistics, tendering, licensing and other business activities. It applies to directors, employees, temporary and agency workers, consultants and anyone acting for Blue Palm, with contractual controls for relevant third parties.
Core standard
Blue Palm has zero tolerance for bribery. No person may offer, promise, give, request, agree to receive or accept an improper advantage to influence a decision, secure business, avoid a requirement or reward improper conduct.
Gifts, hospitality and expenses
Gifts and hospitality must be lawful, modest, infrequent, transparent and for a legitimate business purpose. Cash and cash equivalents are prohibited. Public-official hospitality requires advance Compliance approval; commercial gifts or hospitality above AED 200 or IQD 75,000 per person require advance approval and register entry.
Facilitation payments and duress
Facilitation payments are prohibited. Where there is an immediate threat to health or safety, the individual should prioritise safety and report the event within 24 hours. Commercial delay or threat to goods is not, by itself, duress.
Conflicts, donations and payments
Personal, family, financial or outside-business interests that could affect an objective decision must be disclosed. Political contributions in Blue Palm’s name are prohibited. Charitable donations and sponsorships require written approval, verified beneficiaries and complete records. Payments must be made only against valid evidence and to the contracted party’s verified account.
Reporting, training and review
Concerns must be raised through the Blue Palm speak-up route. Retaliation is prohibited. Relevant personnel receive induction and refresher training, and required registers and records must be retained securely. The policy is reviewed at least annually and after significant incidents or legal or operational changes.
Legal & standards reference
This is a concise website presentation of the legal and standards references contained in the supplied policy. The official text, local legal advice and applicable entity or licence conditions should be checked before relying on a provision.
| Instrument | Relevance |
|---|---|
| Iraq Penal Code No. 111 of 1969, Articles 307–314 | Bribery and related public-function offences in Iraq. |
| Federal Commission of Integrity and Illicit Gain Law No. 30 of 2011, as amended | Federal integrity framework relevant to public-sector corruption in Iraq. |
| UAE Federal Decree-Law No. 31 of 2021, as amended | UAE bribery and corruption offences. |