Code of Conduct & Anti-Corruption Policy

BitLoop Global provides software development, AI integration, e-commerce and website solutions to businesses in the United Arab Emirates. We are trusted with our clients’ systems, data and budgets, and we work alongside technology vendors and platform partners whose partner programmes depend on integrity. This Code exists to make our standards explicit.

It applies to:

• every director, officer and employee of BitLoop Global, whether permanent, part-time or on probation;
• contractors, freelancers and interns engaged by BitLoop Global; and
• agents, resellers, subcontractors and other third parties acting on BitLoop Global’s behalf, who are expected to uphold equivalent standards.

Where the law that applies to the Company sets a higher standard than this Code, the law applies. Where this Code sets a higher standard than the law or local custom, this Code applies.

“BitLoop Global competes on the quality of its work, not on favours, gifts or improper influence. We do not pay bribes, we do not accept them, and we do not ask anyone to look the other way. No contract, partnership or deal is worth compromising on this. Every person who works with BitLoop Global has our full support in refusing an improper request, even if it costs us business, and in reporting one when they see it.”

— The Directors, BitLoop Global - FZCO

BitLoop Global takes a zero-tolerance approach to bribery and corruption in any form. We comply with the anti-bribery provisions of UAE Federal Decree-Law No. 31 of 2021 (Crimes and Penalties Law), and with every other anti-corruption law that applies to our business, including laws with extraterritorial reach such as the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act where they are engaged.

A bribe is anything of value that is offered, promised, given, requested or accepted with the intention of improperly influencing a decision or securing an improper advantage. It includes cash, cash equivalents, gifts, hospitality, travel, employment or internship offers, donations, discounts, kickbacks and personal favours.

No one acting for BitLoop Global may:

• offer, promise or give a bribe to any person, whether a public official or a private individual;
• request, agree to receive or accept a bribe;
• make or accept a payment or benefit through a third party that would be prohibited if made directly;
• offer anything of value to a government official, public body or state-owned entity to obtain or retain business, licences, permits or favourable treatment; or
• use BitLoop Global or client funds, assets or resources for any unlawful or improper purpose.

This applies regardless of local custom, competitive pressure or the value involved. We would rather lose a contract than win it improperly.

Facilitation payments are small, unofficial payments made to speed up routine government action such as processing permits, customs clearance or licence approvals. They are bribes and are prohibited, even where they are locally common.

The only exception is a payment made under duress where there is an imminent threat to a person’s health, safety or liberty. Any such payment must be reported to a director immediately and recorded accurately in BitLoop Global’s books.

Modest gifts and hospitality can be a normal part of building business relationships. They become a problem when they are intended, or could reasonably be seen, to influence a decision.

Gifts, hospitality or entertainment given or received on behalf of BitLoop Global must be:

• reasonable and proportionate, infrequent, and consistent with normal business courtesy;
• given openly and never in secret;
• recorded accurately in BitLoop Global’s books;
• never cash, cash equivalents (vouchers, gift cards, cryptocurrency) or loans;
• never offered or accepted during a tender, quotation, renewal or contract negotiation in which the other party is involved; and
• never offered to a public official or a member of their family without the prior written approval of a director.

Anyone acting for BitLoop Global must obtain a director’s approval before giving or accepting any gift, hospitality or entertainment worth more than AED 300 (or the equivalent in another currency) per person per occasion, and must decline anything that cannot be approved. Vendor rebates, partner incentives and platform promotions belong to the Company, are disclosed to clients where relevant, and are never retained personally.

BitLoop Global competes fairly and on the merits. We comply with UAE Federal Decree-Law No. 36 of 2023 on the Regulation of Competition, and with equivalent laws wherever we do business.

We do not:

• agree with competitors on prices, discounts, margins, terms or bids;
• rig bids, rotate tenders, or agree not to compete for particular customers or markets;
• share commercially sensitive information such as pricing, costs, bids, customer lists or strategy with competitors, including informally at vendor or industry events; or
• misuse confidential competitor information obtained from a client, vendor or former employer.

Resale prices and quotations are set independently by BitLoop Global. Participation in vendor and platform partner programmes is on the published terms of those programmes and never involves collusion with other partners.

Clients trust BitLoop Global with administrative access to their systems and with their personal and business data. We comply with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and any applicable free zone data protection regulations, and with any other data protection law that applies to the data we handle, including the EU General Data Protection Regulation where a client’s data is subject to it.

Everyone acting for BitLoop Global must:

• collect, use and disclose personal data only for the purpose for which it was provided and with the necessary consent or legal basis;
• access client systems and data only to the extent needed to deliver the agreed work, and never out of curiosity or for personal purposes;
• protect data with appropriate technical and organisational safeguards, including access control, encryption and secure credential handling;
• keep client information confidential during and after their engagement with BitLoop Global;
• report any suspected data breach or unauthorised access to a director immediately so that notification obligations can be assessed; and
• return or securely destroy client data when it is no longer required.

We respect intellectual property rights, whether they belong to BitLoop Global, to a client or to a third party. In particular:

• software is used only under a valid licence. BitLoop Global does not install, distribute or tolerate unlicensed or counterfeit software, and resells licences only through authorised channels;
• the terms, trademarks and brand guidelines of vendor and platform partner programmes are honoured;
• code, designs, content and data belonging to a client remain the client’s, and ownership of deliverables follows the terms of the relevant engagement;
• open-source components are used in accordance with their licences; and
• confidential information and trade secrets, whether BitLoop Global’s, a client’s or a partner’s, are protected and used only for their intended purpose.

BitLoop Global respects the dignity and rights of everyone who works for it and in its supply chain.

• We do not use child labour. We comply with UAE Federal Decree-Law No. 33 of 2021 on the Regulation of Labour Relations and the employment regulations of the free zone in which the Company is established, and with the principles of the ILO Minimum Age Convention (No. 138) and Worst Forms of Child Labour Convention (No. 182). No one under the applicable minimum working age is employed or engaged.
• We do not use forced, bonded or involuntary labour. We do not retain workers’ identity documents or charge workers recruitment fees.
• We provide a workplace free from discrimination, harassment and bullying, and we pay in accordance with applicable law and our contracts.
• We expect suppliers, subcontractors and partners to meet these same standards, and we will end relationships with those who do not.

Everyone acting for BitLoop Global must avoid situations where personal interests, relationships or outside activities could conflict, or appear to conflict, with their duties to BitLoop Global or its clients. This includes financial interests in clients, suppliers or competitors; outside employment; and doing business with family members.

Actual or potential conflicts must be disclosed in writing to a director as soon as they arise. The person concerned must not take part in the affected decision unless a director has agreed how the conflict will be managed.

Bribery is often hidden in inaccurate records. All transactions, expenses, quotations, invoices and vendor incentives must be recorded accurately, completely and promptly in BitLoop Global’s accounts. No undisclosed or unrecorded funds or accounts may be kept for any purpose, and no entry may be made that misrepresents the true nature of a transaction. Financial records are retained in accordance with applicable law.

BitLoop Global can be held responsible for the conduct of those acting on its behalf. Before engaging a subcontractor, agent, referral partner or other intermediary, we consider their reputation and integrity and, where the risk warrants it, carry out appropriate due diligence. Our agreements with such parties require compliance with anti-corruption law and this Code, and we do not work with any party we believe is likely to pay or receive bribes on our behalf.

Payments to third parties are made only against a written agreement and a legitimate invoice, are proportionate to the services provided, and are never made in cash or to accounts unrelated to the party concerned.

Every employee receives this Code when they join BitLoop Global and confirms in writing that they have read and understood it. Training on anti-corruption, gifts and hospitality, competition, data protection and raising concerns is provided at onboarding and refreshed at least annually, with additional guidance for anyone in a sales, procurement or partner-facing role. Records of training and acknowledgements are kept by the directors.

Anyone who suspects a breach of this Code or of the law, or who is unsure whether something is permitted, is encouraged to speak up. This applies to employees, contractors, clients, suppliers and members of the public alike. Concerns can be raised:

• In person or in writing to any director

  Directly, at any time, without needing to go through a manager.

• By email to support [at] bitlooptech [dot] com

  Please put “Code of Conduct” in the subject line.

• Anonymously

  Email from an address that does not identify you. Anonymous reports are looked into in the same way as any other.

Reports are treated confidentially to the fullest extent the law allows, are looked into promptly and, wherever possible, are handled by a director who is not the subject of the concern. BitLoop Global does not tolerate retaliation of any kind against anyone who raises a concern in good faith or who assists an investigation, even if the concern turns out to be unfounded. Retaliation is itself a breach of this Code.

Concerns about corruption can also be raised directly with the relevant authorities in the United Arab Emirates.

Breaches of this Code are taken seriously. For employees, a breach may result in disciplinary action up to and including dismissal. For contractors and business partners, it may result in termination of the engagement. Where the law has been broken, BitLoop Global will cooperate with, and may refer the matter to, the relevant authorities.

Ignorance of this Code is not a defence, and neither is an instruction from a manager, a client or a partner.

This Code is owned by the directors of BitLoop Global - FZCO, who are responsible for its implementation and for answering questions about it. It is reviewed at least annually, or sooner when the law or our business changes, and the current version is always published at bitlooptech.com/ae/code-of-conduct.

Questions about this Code can be sent to support [at] bitlooptech [dot] com .