Anti-Bribery & Anti-Corruption Policy

Working draft — pending review by UAE-licensed legal counsel before being relied on for external audits or procurement due diligence. Last updated: September 13, 2026.

1. Purpose

This policy sets out DXI Logistics LLC’s (“DXI”) zero-tolerance approach to bribery and corruption, in compliance with the anti-corruption provisions of UAE Federal Decree-Law No. 31 of 2021 (the UAE Penal Code) and related federal anti-corruption legislation.

2. Scope

This policy applies to all DXI directors, employees, agents, and third parties acting on DXI’s behalf, in all dealings with government officials, customers, suppliers, and business partners, in the UAE and abroad.

3. Prohibited Conduct

Employees and representatives of DXI must never, directly or indirectly:

• Offer, promise, give, request, or accept any bribe, kickback, or improper payment to obtain or retain business or a business advantage.
• Make facilitation payments to speed up routine government processes.
• Offer or accept gifts, hospitality, or entertainment that could improperly influence a business decision.
• Use third parties (agents, brokers, customs clearance agents) to do indirectly what is prohibited directly.

4. Gifts & Hospitality

Modest, reasonable business gifts and hospitality, given openly and not tied to any decision, may be acceptable. Anything exceeding [GIFT_VALUE_THRESHOLD] must be declared to [COMPLIANCE_CONTACT_EMAIL] before being accepted or given.

5. Third-Party Due Diligence

DXI conducts reasonable due diligence on agents, customs brokers, and intermediaries acting on its behalf, and requires them to comply with anti-bribery standards consistent with this policy.

6. Reporting & Whistleblowing

Concerns about actual or suspected bribery should be reported to [COMPLIANCE_CONTACT_EMAIL]. Reports are treated confidentially, and DXI will not tolerate retaliation against anyone who raises a genuine concern in good faith.

7. Consequences of Non-Compliance

Breach of this policy may result in disciplinary action up to and including termination, and may expose the individual and DXI to criminal liability under UAE law.

8. Policy Review

This policy is reviewed at least annually. Approved by: [APPROVER_NAME_AND_TITLE].