BitGo Anti-Bribery & Corruption (ABC) Policy
Introduction
BitGo MENA FZE operates as a Dubai World Trade Centre entity and affiliate within the BitGo Group of Companies (BitGo Holdings, Inc. USA and subsidiaries). The policy encompasses obligations under VARA Virtual Assets regulations, UAE Federal laws, and Group Policies.
Objectives
The Global Anti Bribery and Corruption policy extends to BitGo MENA. This addendum supplements the Global ABC Policy, establishing core standards for sound anti-bribery programs at the Company level.
Scope
The policy applies to all employees, officers, directors, contractors, vendors, and outsourced service providers of BGM ("BitGo Personnel").
Anti-Bribery and Corruption Standards
The Company maintains zero-tolerance toward bribery and corruption. The Compliance Officer oversees investigations and violation reporting, with records retained for 8+ years.
Prohibited Activities
-
Offering payments, gifts, or hospitality expecting business advantage
-
Facilitating routine procedures through improper payments
-
Accepting benefits with expectation of reciprocal advantage
-
Threatening staff reporting violations
-
Activities violating VARA Compliance rules
Corrupt Payments
-
Prohibited: Payments where portions could constitute bribes
-
Required: Appropriate justification for all payments related to legitimate services
Investigating and Reporting
Contact Methods: Email: compliance@bitgo.com, Telephone: +971 50 468 2188
Process: Board/Staff must report suspected violations immediately. The Compliance Officer investigates reports. An independent entity conducts the investigation. The Board receives notification. A written investigation report is generated. Documents are retained 8 years minimum.
Information and Training
-
Regular anti-bribery training mandatory for Board and Staff
-
Training included in new hire induction
-
Compliance monitoring required
Policy Responsibility
-
Board: Overall policy oversight and legal compliance
-
Compliance Officer: Implementation and effectiveness monitoring
Breach Consequences
Violations result in severe consequences, including disciplinary action and immediate termination.