Anti-Corruption Policy
Purpose and scope
Norvica Logistics has zero tolerance for bribery and corruption. This policy applies to all directors, employees, and contractors, and to agents, sub-contractors, and other third parties who act on our behalf anywhere in the world. It is consistent with UAE anti-bribery law and with international standards such as the OECD Anti-Bribery Convention, the UK Bribery Act, and the US Foreign Corrupt Practices Act, where they apply.
What is prohibited
No one acting for Norvica may offer, promise, give, request, agree to receive, or accept any financial or other advantage — directly or through a third party — intended to induce or reward the improper performance of a function, or to influence an official act or decision. This covers cash, gifts, hospitality, “consulting” fees for which no real service is provided, charitable or political donations used as a cover, offers of employment, and anything else of value.
Government and customs officials
We deal regularly with customs, ports, aviation authorities, and embassies. We do not make payments — of any size — to secure or speed up routine actions, to clear cargo improperly, or to obtain favourable treatment. The only payments we make to authorities are official, published fees, properly documented and receipted.
Facilitation payments
So-called “facilitation” or “grease” payments — small payments to expedite a routine governmental action someone is already entitled to — are prohibited, even where they are customary locally. If a payment is demanded under threat to someone’s personal safety, comply if you must, then report it to Norvica management as soon as you safely can.
Third parties
We conduct due diligence on agents and sub-contractors before engaging them, set anti-corruption expectations in our contracts, pay only reasonable fees for genuine services, and monitor the relationship. We can be held responsible for bribes paid on our behalf, so we choose our partners accordingly.
Gifts, hospitality, donations, sponsorship
These are permitted only within the limits of our Gifts & Entertainment Policy, never to improperly influence anyone, and they must be recorded where the policy requires it.
Red flags
Be alert to, and escalate, things such as: requests to pay an unexpected account or a third country; “commissions” out of proportion to the work; a partner who refuses to accept anti-corruption terms; demands for cash; vague or inflated invoices; or pressure to bypass controls or “make it happen.”
Books and records
All transactions must be recorded accurately and completely. There are no off-book funds and no false or misleading documentation.
Training and advice
Personnel in roles exposed to these risks receive guidance on recognising and avoiding bribery. If a situation is unclear, ask Norvica management before acting.
Reporting and protection
Report any suspected breach, demand, or red flag to Norvica management immediately. We investigate, and we do not tolerate retaliation against anyone who reports in good faith — even where it costs us business.
Consequences
Breaching this policy may lead to disciplinary action up to and including dismissal, termination of a contract or supplier relationship, and criminal referral. Individuals involved in bribery can face personal fines and imprisonment.
This policy is maintained by the management of Norvica Logistics. For questions, or to report a concern, contact info@norvica.ae. Norvica may update this policy from time to time; the version published here is the current one.