Anti-Trust & Anti-Competition 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

DXI Logistics LLC (“DXI”) competes for business solely on the merits of its services, pricing, and quality. This policy sets out our commitment to compliance with UAE Federal Law No. 4 of 2012 Concerning the Regulation of Competition (as amended) and its executive regulations.

2. Scope

This policy applies to all DXI directors, managers, and employees who interact with competitors, customers, or suppliers — including sales, pricing, procurement, and business development staff.

3. Prohibited Conduct

Employees must never, directly or indirectly:

• Agree with a competitor to fix prices, rates, or terms of service.
• Agree with a competitor to divide markets, customers, or geographic territories.
• Agree with a competitor to rig bids or coordinate tender responses.
• Abuse a dominant market position to exclude competitors unlawfully.
• Share commercially sensitive pricing or strategy information with competitors.

4. Interacting with Competitors

Legitimate contact with competitors (e.g., industry associations, trade events) is permitted, but employees must avoid any discussion of pricing, costs, capacity, customer allocation, or bidding strategy, and should leave and document any meeting where such topics arise.

5. Reporting Concerns

Any employee who becomes aware of actual or suspected anti-competitive conduct should report it to [COMPLIANCE_CONTACT_EMAIL]. Reports are treated confidentially and without retaliation against the reporter.

6. Consequences of Non-Compliance

Breach of this policy may result in disciplinary action up to and including termination, and may expose DXI and individuals to penalties under UAE competition law.

7. Policy Review

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