Anti-Bribery and Corruption (ABC) Statement

1. Our Commitment to Ethical Conduct

MidChains FZE enforces a zero-tolerance policy toward all forms of bribery and corruption, including kickbacks and facilitation payments. We are committed to conducting our business ethically and in absolute compliance with all applicable VARA and UAE laws and regulations. This policy applies  to all internal stakeholders—including our Board of Directors, senior management, and employees—as well as all third-party counterparties, clients, suppliers, and service providers.

2. Prohibited Practices & Material Scope

We strictly prohibit offering, promising, giving, soliciting, or accepting anything of value to improperly influence any business decision or secure an unfair advantage. This restriction encompasses traditional financial assets, corporate hospitality, and charitable giving. Given our position in the digital asset ecosystem, this mandate extends with equal scrutiny to all digital forms of appreciation, including cryptocurrencies, digital tokens, and Non-Fungible Tokens (NFTs).

3. Gifts, Hospitality, and Third-Party Due Diligence

Corporate gifts and hospitality are only permitted if they are transparent, non-recurrent, pre-approved, and maintain a value under USD 250 (or a maximum of AED 1,000 under exceptional corporate circumstances). No gifts may be offered to or accepted from government officials. Furthermore, all corporate partners and vendors must undergo mandatory due diligence at onboarding, accept explicit anti-bribery contractual clauses, and clear all payments transparently through verifiable bank transfers.

4. Reporting, Whistleblower Protection, and Enforcement

Any known or suspected violations must be reported immediately to Compliance Officer via available means of communication or Complaint Form. MidChains guarantees absolute confidentiality and structural protection against retaliation or discrimination for all whistleblowers acting in good faith. Violations of this policy carry severe consequences, including immediate termination of employment, legal action, and mandatory notification to VARA and relevant law enforcement authorities.