Anti-Bribery & Anti-Corruption Policy
Zero Tolerance.
HORECA 360 maintains a zero-tolerance approach to bribery and corruption in any form, in every market we serve.
No Bribery
We prohibit offering, promising or accepting anything of value to improperly influence business decisions.
- No bribes, direct or indirect
- No improper advantages
- Applies to all staff & partners
- Applies to public & private sector
No Facilitation Payments
Facilitation or speed payments are prohibited.
- No payments to expedite routine actions
- Documented, transparent payments only
- Third-party due diligence
- Agent & intermediary vetting
Conflict of Interest
Actual and potential conflicts must be declared and managed.
- Mandatory declarations
- Recusal from affected decisions
- Ongoing disclosure duty
- Management review & recording
Gift Policy
Gifts and hospitality must be modest, lawful and transparent.
- Nominal value thresholds
- Approval & recording
- No gifts that influence decisions
- Reciprocal, proportionate hospitality
Whistleblower Protection
Good-faith reporters are protected from retaliation.
- Confidential reporting
- No retaliation tolerated
- Anonymous reporting option
- Protection of reporters
Investigation Process
All reports are investigated promptly and impartially.
- Triage & acknowledgement
- Impartial investigation
- Evidence-based findings
- Confidentiality maintained
Reporting
Concerns can be raised through multiple channels.
- compliance@horeca360.ae
- Line management
- Confidential channel
- External authorities where required
Disciplinary Action
Proven breaches result in disciplinary and legal action.
- Up to and including termination
- Contract termination for partners
- Legal referral where warranted
- Recovery of improper gains
Responsibilities
This policy applies to all Complete Horeca Three Sixty Trading LLC (trading as Horeca 360) directors, employees, contractors, agents, suppliers and business partners. Leadership is accountable for embedding its principles; every individual is responsible for upholding them in daily operations.
- Tone from the top: executive ownership of compliance
- Clear roles for procurement, quality, finance and legal teams
- Supplier acknowledgement of policy terms
- Regular training and awareness programmes
Reporting Concerns
Concerns about non-compliance, misconduct or breaches may be raised in good faith without fear of retaliation. Complete Horeca Three Sixty Trading LLC is committed to investigating reports promptly, fairly and confidentially.
- Email our governance team at compliance@horeca360.ae
- Speak with your assigned business contact
- Reports handled confidentially and without retaliation
- Timely investigation and appropriate corrective action
Review Process
This policy is reviewed at least annually and whenever significant legal, operational or regulatory changes occur, to ensure it remains current, effective and aligned with best practice.
- Annual policy review cycle
- Interim reviews on regulatory change
- Version control and change log
- Approval by senior management
Partner with Confidence
Whether you are a supplier, manufacturer, distributor or hospitality business, HORECA 360 is committed to building lasting partnerships through transparency, quality and trust.