BAS / POL / 02

Anti-Bribery & Corruption Policy

BUILT’s work sits at the points on a project where money moves and decisions are made: tender award, valuation, variation, delay determination and certification. This policy states how BUILT conducts itself at those points.

Document
BAS / POL / 02
Revision
1
Issued
February 2026
Next review
February 2027
Owner
Richard Shotton, FCIOB

1Statement

  1. 1.1BUILT does not offer, give, solicit or accept bribes. There are no exceptions, and no commercial objective justifies a breach of this policy.
  2. 1.2This standard applies in every market in which BUILT operates, irrespective of local practice or custom.

2Scope

  1. 2.1This policy binds the Principal, any personnel BUILT deploys or recommends, and any party acting for or on behalf of BUILT.
  2. 2.2BUILT expects the same standard of any party it recommends to a client.

3Legal framework

  1. 3.1Bribery of both public officials and private persons is a criminal offence in the United Arab Emirates under Federal Law No. 31 of 2021 (the Penal Code), Articles 275 to 287. Private-sector bribery is addressed at Articles 278 and 279 and carries imprisonment of up to five years, a fine equal to the value of the bribe, and confiscation of it.
  2. 3.2BUILT operates to the standard of the UK Bribery Act 2010, and complies with that Act and with comparable legislation of extraterritorial effect wherever a client or project is subject to it.

4Prohibited conduct

  1. 4.1Offering or accepting money, a gift, a loan, a favour, employment for a relative or associate, or any other advantage intended to influence a decision.
  2. 4.2Facilitation payments — small payments made to secure or accelerate a routine action — regardless of local custom.
  3. 4.3Kickbacks and undisclosed commissions from contractors, subcontractors, suppliers or consultants.
  4. 4.4Collusion in tendering, including bid rigging, cover pricing, and disclosure of one tenderer’s price or position to another.
  5. 4.5Improperly influencing prequalification, tender evaluation, award recommendation, valuation, variation assessment, claim determination or the certification of work.
  6. 4.6Approving, certifying or accepting work known to be non-compliant in exchange for any benefit.
  7. 4.7Charitable or political donations made in order to obtain a commercial advantage.

5Points of heightened risk

  1. 5.1BUILT recognises specific exposure at the following points on a project and applies additional care at each: tender evaluation and award recommendation; assessment of variations, provisional sums and prime cost items; procurement of works packages and long-lead materials; assessment of interim payment applications; determination of extension of time and delay claims; approval of material substitutions, benchmarks and mock-ups; and the issue of completion and defects certificates.
  2. 5.2During any live tender, claim assessment or determination, BUILT accepts no gift or hospitality of any kind from a party with an interest in the outcome.

6Gifts and hospitality

  1. 6.1BUILT neither gives nor accepts cash or cash equivalents in any circumstances.
  2. 6.2Modest hospitality in the ordinary course of business — a working meal, refreshments at a meeting, attendance at an industry event — is acceptable where it is proportionate, infrequent, openly given, and could not reasonably be seen as influencing a decision.
  3. 6.3Anything beyond the modest business courtesy described at clause 6.2 is declined. Where declining would cause offence, it is accepted and declared in writing to the client.
  4. 6.4Gifts or hospitality offered by BUILT to a member of a client’s staff follow the client’s own policy. Where the client has none, clause 6.3 applies.

7Records

  1. 7.1BUILT keeps a written record of any gift or hospitality declined, accepted or declared under clause 6.
  2. 7.2Fees, expenses and disbursements are invoiced accurately and supported by records.
  3. 7.3BUILT does not make or receive payment through a third party where the purpose or effect is to disguise its nature, source or destination.

8Reporting a concern

  1. 8.1Any person may report a suspected breach of this policy to the Principal at richardshotton@built-me.com.
  2. 8.2A report made in good faith will not disadvantage the person making it.
  3. 8.3Where a report concerns a criminal offence, BUILT reports it to the client and, where required, to the competent authority.

9Consequences of breach

  1. 9.1Breach by any person deployed by BUILT results in immediate removal from the appointment and termination of engagement.
  2. 9.2BUILT withdraws from any appointment where it is required or pressed to act in breach of this policy.

10Review

  1. 10.1This policy is reviewed annually by the Principal.

Richard Shotton, FCIOBBUILT Advisory Services FZE LLC
P.O. Box 73111, Sharjah Publishing City Free Zone, Al Zahia, Sharjah, United Arab Emirates