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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.