Anti-Bribery & Corruption Policy
Public Summary
Last updated: January 2026
Naucom L.L.C (“Naucom L.L.C.”, “we”, “us”, “our”) is committed to conducting business ethically, transparently, and in compliance with applicable anti-bribery and anti-corruption laws and regulations.
This public summary outlines our high-level approach to preventing bribery and corruption and is provided for informational purposes only.
1. Our Commitment
Naucom L.L.C. maintains a zero-tolerance approach to bribery, corruption, facilitation payments, kickbacks, and improper inducements in any form.
We are committed to:
- complying with applicable anti-bribery and anti-corruption laws in the United Arab Emirates and other jurisdictions in which we operate;
- aligning our practices with internationally recognised standards, including those reflected in the UK Bribery Act 2010 and similar legislation; and
- promoting ethical conduct in all business relationships.
2. Scope
This policy applies, on a risk-based basis, to:
- customers and counterparties;
- business partners, intermediaries, and introducers;
- suppliers and service providers; and
- transactions and engagements involving Naucom L.L.C..
3. Prohibited Conduct
Naucom L.L.C. prohibits, whether directly or indirectly:
- offering, promising, giving, requesting, or accepting bribes or improper advantages;
- facilitation payments, regardless of local custom or practice;
- kickbacks, secret commissions, or undisclosed benefits; and
- any conduct intended to improperly influence a decision or secure an unfair advantage.
This prohibition applies to dealings with both public officials and private parties.
4. Gifts, Hospitality & Expenses
Gifts, hospitality, or business courtesies must be:
- reasonable, proportionate, and transparent;
- lawful under applicable regulations; and
- not intended to influence, or appear to influence, business decisions.
Naucom L.L.C. reserves the right to decline or prohibit gifts or hospitality that do not meet these standards.
5. Third Parties & Intermediaries
Naucom L.L.C. recognises that bribery and corruption risks can arise through third parties. We therefore expect business partners, intermediaries, and service providers to act ethically and in compliance with applicable laws.
Engagements may be refused, suspended, or terminated where bribery or corruption risks cannot be adequately mitigated.
6. Books, Records & Controls
Naucom L.L.C. maintains appropriate records and controls designed to support transparency and accountability and to prevent improper payments or benefits.
7. Reporting & Cooperation
Suspected bribery or corruption concerns may be raised through appropriate business channels. Where required by law, Naucom L.L.C. will cooperate with competent authorities and comply with lawful requests.
8. Consequences of Non-Compliance
Breaches of applicable anti-bribery or anti-corruption laws, or of this policy, may result in disciplinary action, termination of relationships, and potential legal consequences.
9. No Reliance
This public summary:
- does not constitute legal advice;
- does not create contractual rights or obligations; and
- should not be relied upon as a complete description of Naucom L.L.C.’s internal anti-bribery and anti-corruption procedures, which are maintained separately and are not publicly disclosed.
10. Contact
For general questions regarding this policy summary, please contact:
Naucom L.L.C.
Email: services@naucomllc.com