Emirates
Anti-Bribery and
Corruption Policy
1. Introduction
1.1. The Group is committed to ethical business practices and in particular, to compliance at all times with
applicable anti-bribery and anti-corruption laws in all countries where the Group carries on business
(collectively, the Anti-Corruption Laws).
1.2. The principles in this anti-bribery and corruption policy document (the Policy) apply to the full range of the
Group’s business activities around the world. In addition to legal requirements, the Group believes that
long-term, successful business relationships are built on honesty, fairness, and the strength of the Group’s
products and services, and not on unethical business practices. The Policy provides clear rules for Group
personnel and third parties engaged in Group business, to ensure compliance with the Anti-Corruption Laws
and the Group’s ethical standards and expectations.
2. Responsibility for compliance with this Policy
2.1. This Policy applies to all Group Personnel and all of the Group’s Business Partners. For these purposes:
2.1.1. Authorities Manual means the authorities manual for the time being of the relevant Group entity;
2.1.2. Business Partners includes all third parties who are specifically appointed to engage in business for
or on behalf of the Group, including, without limitation, representatives, agents, lobbyists, consultants
and joint venture partners and excludes third parties who supply goods or services to the Group;
2.1.3. Group means all and any of dnata, dnata World Travel and Emirates, and any of their subsidiaries,
branches, businesses or divisions;
2.1.4. Group Personnel includes all employees, officers, and directors of the Group and any of them.
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3. Prohibition against bribes and improper payments
3.1. Group Personnel and Business Partners are prohibited from:
3.1.1. making or receiving bribes in connection with Group business; and
3.1.2. 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.
3.2. Bribes can take on many shapes and forms but typically they involve corrupt intent. There will usually be an
expectation for something in return – both parties will benefit.
3.2.1. A bribe could be a direct or indirect promise, offering or authorization of anything of value or the offer
or receipt of any kickback fee, reward or other advantage.
3.2.2. Bribery is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for
an action which is illegal or unethical.
3.2.3. 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.
3.2.4. Acts of bribery or corruption are designed to influence the individual in the performance of their duty
and induce them to act dishonestly.
3.3. If any Group Personnel breaches paragraph 3.1, disciplinary action may be taken against such individual up
to and including termination.
3.4. The use of intermediaries (including agents) for the payment of bribes or other improper payments is
prohibited.
3.5. There are no exceptions to the prohibition contained in this Policy against bribes or improper payment
activity. The fact that Group Personnel, for example, may be pursuing business in a country where that
individual believes corruption is widespread, is part of the culture or way of doing business, or where legal
standards governing bribery are unclear, or in a transaction where a Group employee has been solicited for a
bribe, will not serve as excuses for engaging in improper payment activity. Nor will evidence that the Group’s
competitors may be engaged in improper conduct. Group Personnel should never engage in improper
payment activity because instructed to do so by a manager or co-worker. If this situation ever arises such
individual must report this in accordance with relevant reporting procedures. No Group employee or Business
Partner will suffer adverse consequences for refusing to engage in improper payment activity, even if this
results in loss of business.
4. Extortion
4.1 Subject to Clause 4.2, the Group will actively resist extortion and all other demands for improper payments
made under duress.
4.2. The health, safety and liberty of Group Personnel will always be a priority. Therefore, if your personal health,
safety or freedom could be at risk if you do not make a payment which is being demanded, you may make
the payment. These payments must be promptly reported and accounted for by local senior management
and will be subject to audit.
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5. Guidelines on specified activities
The following “Guidelines” explain how the Policy applies to certain types of activities:
5.1 Facilitating Payments
5.1.1. There are limited circumstances in which the member of the Group concerned may be permitted
to make a payment to a government official without violating the applicable Anti-Corruption Laws.
Some Anti-Corruption Laws have a narrow exception for what are known as “facilitating payments” –
payments to government employees to expedite or secure the performance of a routine governmental
action (Facilitating Payments). Under this exception, for example, it may be permissible to make a
Facilitating Payment to obtain permits, licenses or other documents to allow the member of the Group
concerned to do business in a certain country; to process governmental papers such as visas and
work orders; to provide police protection, mail pick-up and delivery or scheduling inspections; or to
provide phone service, power and water supplies, or loading and unloading of cargo.
5.1.2. It is the Group’s policy not to make or permit Facilitating Payments of any kind, except in limited
situations in which a Facilitating Payment is lawful and unavoidable. Any Facilitating Payments must
be approved by the EVP/DSVP/SVP of the relevant business unit (in respect of dnata, dnata World
Travel or Emirates) or the CEO and board (in respect of subsidiaries). In addition, all Facilitating
Payments must be fairly and accurately recorded and accounted for.
5.2 Gifts
5.2.1. You may not give or offer a gift to, or accept a gift from, anyone with whom the Group conducts
business where the gift would exceed customary courtesies associated with accepted ethical
commercial practice. Any gift you offer, give or receive must be given as a legitimate, justified
business courtesy and never in exchange for obtaining an inappropriate advantage or benefit.
5.2.2. Receiving or giving gifts of cash (or cash equivalents such as gift vouchers) is strictly prohibited.
5.2.3. 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 and/or the head of your
business unit. A gift should not be accepted when to do so is either prohibited under local law or
could be viewed as done for the purpose of influencing a business decision or appears to create a
conflict of interest for those involved.
5.3 Business entertainment and hospitality
5.3.1. Hospitality includes meals, invitations to events, functions or other social gatherings in connection
with matters related to the business of the Group. These activities are acceptable provided they fall
within reasonable bounds.
5.3.2. Reasonable and proportionate hospitality which seeks to improve the image of the Group and its
services and products, or to establish cordial relationships, is recognised as an established and
important part of doing business. In order to amount to a bribe, hospitality must be intended to induce
a person to perform a function improperly.
5.3.3. Determining the acceptability of a particular form of business entertainment or hospitality requires the
exercise of individual judgement. In arriving at this judgement, ask yourself the following:
• What is the intent – is it to build a relationship or is something else?
• Apply the ‘newspaper test’ – would a newspaper be likely to report the business entertainment or
hospitality, and if it did, what would the public’s perception be? For example, an all-expenses paid
overseas golfing weekend prior to a tender evaluation would almost certainly give rise to an adverse
impression if reported.
• Would you be comfortable in justifying the entertainment/hospitality to management?
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• If you find it difficult to answer one of these questions, there may be a risk involved which could
potentially damage the Group’s reputation and business
Circumstances that are usually acceptable include:
• Meals with someone with whom the Group does business that are reasonable in value and
frequency;
• Occasional attendance at sporting, theatre and other cultural events or social gatherings.
Circumstances which are not acceptable include:
• Hospitality or entertainment which is offered in return for an inappropriate advantage or benefit or
which could influence the independence of the receiver; and
• Entertainment of an inappropriate nature (for example, lavish or offensive entertainment).
5.3.4. The form and cost of acceptable business entertainment or hospitality will depend on a number of
factors, including the nature of the relationship with the host or guest, the cost and standard of living
in the region and the acceptable forms of business entertainment or hospitality in the region. Should
you have any doubt as to what is acceptable in any particular situation you should consult your
supervisor and/or the head of your business unit.
5.3.5. Particular caution must be used in providing entertainment to government officials.
5.3.6. Business entertainment or hospitality expenses must be properly recorded in the books and records
of the relevant Group entity.
5.4 Sponsored travel
5.4.1. In appropriate circumstances, the Group may sponsor reasonable and legitimate travel expenses of
customers, potential customers and others that are directly related:
• to promoting or demonstrating the Group’s products and services; or
• to performing a contract between the Group and the customer; or
• to a fact finding mission to understand relevant foreign markets and regulatory environments.
5.4.2. These expenses must have a legitimate business purpose and must be limited to those necessary to
carry out such purpose.
5.4.3. Sponsored travel expenses require prior written approval in accordance with the provisions of the
Authorities Manual.
5.5 Political support and contributions
5.5.1. All employees and anyone acting on behalf of a Group entity contemplating lobbying or political
support must act with honesty, integrity and transparency at all times. You must:
• seek advice from the relevant government relations team or legal adviser (with a copy to Vice
President, International, Government and Environment Affairs of Emirates Group) to ensure
compliance with local laws and regulations; and
• ensure that the information that you provide about this lobbying activity is transparent, factually
accurate and fairly represented.
5.5.2. Any third party conducting lobbying activity on behalf of a Group entity must be approved in
accordance with the provisions of the applicable Authorities Manual.
5.5.3. The Group does not make donations or contributions to any political parties or public international
organisations. You may not make any donations to any political party or public international
organisation.
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5.6 Business Partners
5.6.1. The Group will only engage Business Partners of known integrity who will not expose the Group to
unacceptable reputational or legal risks. No Business Partners may be retained except in the manner
and following the requirements for evaluating, selecting and retaining such Business Partners as set
out below.
5.6.2. Business Partners may be engaged only in accordance with the provisions of the Authorities Manual.
5.6.3. Business Partners may be hired only after the completion of an appropriate level of due
diligence. Such due diligence may include: ownership, background checks, reviews of letters of
recommendation, reviews of credentials, reviews of financial statements, contact with local Chambers
of Commerce, independent confirmation of the candidate’s history of government employment and
evaluation of the candidate’s other connections to government officials, including family relations.
5.6.4. All written agreements with Business Partners will include as a minimum standard contract provisions
as follows relating to compliance with Anti-Corruption Laws and this Policy:
(A) For the purposes of this clause, “Business Partner” means [insert name of Business Partner] and
“Company” means [insert name of Group company].
(B) The Business Partner acknowledges that it has received a copy of the Company Anti-Bribery and
Corruption Policy (the Policy) and agrees to comply with the provisions of the Policy at all times
during the term of this Agreement. The Business Partner shall indemnify the Company and each
of its directors, officers and employees from and against any liability, fine, loss or damage arising
out of or in connection with any breach of the Policy by the Business Partner. In the event of any
breach of the Policy by the Business Partner, Company may immediately terminate this Agreement
by written notice to the Business Partner. The indemnity provided by the Business Partner in this
clause shall survive any termination of this Agreement.
5.6.5. Business Partners may be paid by cheque or wire transfer only, and never in cash. All payments will
be made pursuant to invoices, receipts or other documentation documenting services rendered in
detail. All agreements with Business Partners will contain standard contract language setting out
these requirements.
5.6.6. It is the responsibility of anybody interacting with a Business Partner to look out for “red flags” and, if
any are found, to report these to their line manager.
6. Doing business with the government
6.1. Group Personnel must be especially vigilant in dealing with all government officials. Activities that may
be permissible when working with private sector partners may be improper or illegal when working with a
government official.
6.2. Group Personnel who have any questions regarding whether interactions with government officials are
appropriate should immediately contact their line manager.
7. Compliance
7.1 It is the responsibility of all Group Personnel to understand and comply with this Policy. Additional guidance
and procedures relating to the Policy may be issued from time to time.
7.2. In respect of subsidiaries, the CEO and board are: accountable for ensuring that the relevant business
complies with this Policy and associated guidelines; and responsible for final determinations made pursuant
to this Policy and any guidelines.
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8. Implementation
8.1. Local management is responsible for implementation of this Policy and ensuring their employees are aware
of the Policy. Any Group Personnel who has any question in respect of the Policy should address this to his
local management.
9. Record keeping
9.1. All of the books and records of the members of the Group must fully and fairly reflect all expenditures of the
members’s funds. Attempts to create false or misleading records are forbidden. These requirements apply
to all books and records of the members of the Group. No payment on behalf of any member of the Group
may be approved without adequate supporting documentation or made with the understanding that all or
part of such payment is or has been used for purposes other than those identified in supporting documents.
No undisclosed or unrecorded funds of any member of the Group, such as “off the books” accounts,
shall be established for any purpose. No payments can be made, directly or indirectly, to undisclosed or
unknown recipients, or any other individuals with whom the Group employee responsible for maintaining the
relationship is unable to vouch for his or her credentials.
10. Breaches and reporting
10.1. Breach of this Policy may result in disciplinary action for Group employees up to and including termination
and/ or referral to national law enforcement authorities. Breaches of the Anti-Corruption Laws could also
subject the individual who committed the violation to civil or criminal penalties, including substantial fines
and potentially lengthy imprisonment. For Business Partners, breach of this Policy will lead to termination of
the relationship with the Group.
10.2. If you are not sure whether the Policy has been breached, you should report your concerns to your line
manager in the first instance.
10.3. All persons subject to this Policy are required promptly to report any instances of non-compliance with this
Policy to:
10.3.1. for dnata, dnata World Travel or Emirates: the applicable DSVP / SVP of your business unit AND
SVP Legal of Emirates Group;
10.3.2. for subsidiaries and joint venture companies: CEO & board members AND SVP Legal of
Emirates Group.
10.4. If you require further guidance on this subject matter please consult your normal source of legal advice.
11. Speak Up
11.1 All employees are encouraged to speak up if they know of, or suspect, (i) a breach of this Policy, or (ii) an
offer or request by a third party for anything that is, or could reasonably be considered as, a bribe.
11.2 If you do not feel comfortable raising your concerns with your line manager or through the other
reporting mechanisms listed in the Policy, you can raise your concerns via Speak Up, our confidential
disclosure programme.
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