1. What does your policy cover?
1.1. This anti-bribery policy exists to set out the responsibilities of Mitsumi Distribution LLC and those
who work for us in regards to observing and upholding our zero-tolerance position on bribery and
1.2. It also exists to act as a source of information and guidance for those working for Mitsumi
Distribution. It helps them recognise and deal with bribery and corruption issues, as well as
understand their responsibilities.
2. Policy statement
2.1. Mitsumi Distribution is committed to conducting business in an ethical and honest manner, and is
committed to implementing and enforcing systems that ensure bribery is prevented. Mitsumi
Distribution has zero-tolerance for bribery and corrupt activities. We are committed to acting
professionally, fairly, and with integrity in all business dealings and relationships, wherever in the
country we operate.
2.2. Mitsumi Distribution will constantly uphold all laws relating to anti-bribery and corruption in all
the jurisdictions in which we operate.
3. Policy statement Who is covered by the Policy?
3.1. This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent),
consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff,
volunteers, interns, agents, sponsors, or any other person or persons associated with us (including
third parties), or any of our subsidiaries or their employees, no matter where they are located
(within or outside of the UAE).
3.2. In the context of this policy, third-party refers to any individual or organisation our company meets
and works with. It refers to actual and potential clients, customers, suppliers, distributors, business
contacts, agents, advisers, and government and public bodies – this includes their advisors,
representatives and officials, politicians, and public parties.
3.3. Any arrangements our company makes with a third party is subject to clear contractual terms,
including specific provisions that require the third party to comply with minimum standards and
procedures relating to anti-bribery and corruption.
4. Definition of bribery
4.1. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or
soliciting something of value or of an advantage so to induce or influence an action or decision.
4.2. A bribe refers to any inducement, reward, or object/item of value offered to another individual in
order to gain commercial, contractual, regulatory, or personal advantage.
4.3. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe
and they accept it, they are also breaking the law.
4.4. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly,
passively (as described above), or through a third party (such as an agent or distributor). They must
not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree
and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must
seek further advice from the company’s compliance manager.
5. What is and what is NOT acceptable
5.1. This section of the policy refers to 4 areas:
• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.
5.2. Gift and Hospitality
Mitsumi Distribution accepts normal and appropriate gestures of hospitality and goodwill (whether
given to/received from third parties) so long as the giving or receiving of gifts meets the following
a. It is not made with the intention of influencing the party to whom it is being given, to obtain or
reward the retention of a business or a business advantage, or as an explicit or implicit exchange for
favours or benefits.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individual’s name.
e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank
you to a company for helping with a large project upon completion).
g. It is of an appropriate type and value and given at an appropriate time, taking into account the
reason for the gift.
h. It is given/received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing
j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager
(usually in excess of 300 AED).
k. It is not offer to, or accepted from, a government official or representative or politician or political
party, without the prior approval of the company’s compliance manager.
5.3. Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a
certain religion/culture who may take offence), the gift may be accepted so long as it is declared to
the compliance manager, who will assess the circumstances.
5.4. Mitsumi Distribution recognises that the practice of giving and receiving business gifts varies
between countries, regions, cultures, and religions, so definitions of what is acceptable and not
acceptable will inevitably differ for each.
5.5. As good practice, gifts given and received should always be disclosed to the compliance manager.
Gifts from suppliers should always be disclosed.
5.6. The intention behind a gift being given/received should always be considered. If there is any
uncertainty, the advice of the compliance manager should be sought.
5.7. Facilitation Payments and Kickbacks
Mitsumi Distribution does not accept and will not make any form of facilitation payments of any
nature. We recognise that facilitation payments are a form of bribery that involves expediting or
facilitating the performance of a public official for a routine governmental action. We recognise that
they tend to be made by low level officials with the intention of securing or speeding up the
performance of a certain duty or action.
5.8. Mitsumi Distribution does not allow kickbacks to be made or accepted. We recognise that kickbacks
are typically made in exchange for a business favour or advantage.
5.9. Mitsumi Distribution recognises that, despite our strict policy on facilitation payments and
kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may
put their/their family’s personal security at risk. Under these circumstances, the following steps
must be taken:
a. Keep any amount to the minimum.
b. Ask for a receipt, detailing the amount and reason for the payment.
c. Create a record concerning the payment.
d. Report this incident to your line manager.
5.10. Charitable Contributions
Mitsumi Distribution accepts (and indeed encourages) the act of donating to charities – whether
through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees
to disclose all charitable contributions it makes.
5.11. Employees must be careful to ensure that charitable contributions are not used to facilitate
and conceal acts of bribery.
5.12. We will ensure that all charitable donations made are legal and ethical under local laws and
practices, and that donations are not offered/made without the approval of the compliance
6. Employee Responsibilities
6.1. As an employee of Mitsumi Distribution, you must ensure that you read, understand, and comply
with the information contained within this policy, and with any training or other anti-bribery and
corruption information you are given.
6.2. All employees and those under our control are equally responsible for the prevention, detection,
and reporting of bribery and other forms of corruption. They are required to avoid any activities
that could lead to, or imply, a breach of this anti-bribery policy.
6.3. If you have reason to believe or suspect that an instance of bribery or corruption has occurred or
will occur in the future that breaches this policy, you must notify the compliance manager.
6.4. If any employee breaches this policy, they will face disciplinary action and could face dismissal for
gross misconduct. Mitsumi Distribution has the right to terminate a contractual relationship with an
employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1. This section of the policy covers 3 areas:
a. How to raise a concern.
b. What to do if you are a victim of bribery or corruption.
7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Mitsumi
Distribution, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain
about whether a certain action or behaviour can be considered bribery or corruption, you should speak
to your line manager, the compliance manager, the director, or the Head of Governance and Legal.
7.3 Mitsumi Distribution will familiarise all employees with its whistleblowing procedures so employees can
vocalise their concerns swiftly and confidentially.
7.4 What to do if you are a victim of bribery or corruption
You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are
asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if
you have reason to believe that you are a victim of another corrupt activity.
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or
corruption, Mitsumi Distribution understands that you may feel worried about potential repercussions.
Mitsumi Distribution will support anyone who raises concerns in good faith under this policy, even if
investigation finds that they were mistaken.
7.6 Mitsumi Distribution will ensure that no one suffers any detrimental treatment as a result of refusing to
accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential
act(s) of bribery or corruption.
7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in
relation to the concern the individual raised.
7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal
to accept a bribe, you should inform your line manager or the compliance manager immediately.
8 Training and Communication
8.1 Mitsumi Distribution will provide training on this policy as part of the induction process for all new
employees. Employees will also receive regular, relevant training on how to adhere to this policy, and
will be asked annually to formally accept that they will comply with this policy.
8.2 Mitsumi Distribution ’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly
communicated to all suppliers, contractors, business partners, and any third-parties at the outset of
business relations, and as appropriate thereafter.
8.3 Mitsumi Distribution will provide relevant anti-bribery and corruption training to employees etc. where
we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice,
all businesses should provide their employees with anti-bribery training where there is a potential risk
of facing bribery or corruption during work activities.
9 Record keeping
9.1 Mitsumi Distribution will keep detailed and accurate financial records, and will have appropriate
internal controls in place to act as evidence for all payments made. We will declare and keep a written
record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts
and acts of hospitality are subject to managerial review.
10 Monitoring and reviewing
10.1 Mitsumi Distribution ’s compliance manager is responsible for monitoring the effectiveness of this
policy and will review the implementation of it on a regular basis. They will assess its suitability,
adequacy, and effectiveness.
10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to
regular audits to ensure that they are effective in practice.
10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer
their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this
nature should be addressed to the compliance manager.
10.4 This policy does not form part of an employee’s contract of employment and Mitsumi Distribution
may amend it at any time so to improve its effectiveness at combatting bribery and corruption.L