Anti-Bribery & Anti-Corruption

Standard

NETREX INC prohibits bribery in every form, whether offered, promised, given, requested or accepted, directly or through a third party. This policy is aligned to the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and applicable UAE and GCC anti-corruption law.

Specific prohibitions

• Facilitation payments to speed up routine government action.
• Political donations made in the name of the company.
• Gifts or hospitality intended to influence a business decision.
• Kickbacks in supplier, referral or partner arrangements.

Third parties and record keeping

Agents, resellers and referral partners are screened before appointment and contractually bound to equivalent standards. All payments must be recorded accurately in our books with supporting documentation.

Reporting

Concerns can be raised confidentially at ethics@netrexinc.com. Retaliation against anyone reporting in good faith is itself a disciplinary offence.

Regional legal framework

NETREX applies this policy through the contract, delivery location and data flows relevant to each engagement. Requirements can differ by jurisdiction, industry and client role, so the signed agreement and applicable law take priority over this general policy.

• United Arab Emirates: UAE federal laws and relevant free-zone requirements, including applicable personal data protection, electronic transactions, cybercrime, employment and commercial rules.
• Pakistan: applicable data, electronic transactions, employment, tax and company requirements, together with sector-specific directions where they apply.
• United Kingdom: UK GDPR, Data Protection Act 2018, PECR, Equality Act 2010, Bribery Act 2010 and Modern Slavery Act 2015 where applicable.
• Germany and the European Economic Area: GDPR, ePrivacy requirements, accessibility rules and applicable German commercial and employment obligations.
• United States: applicable federal and state privacy, consumer protection, accessibility, employment, anti-bribery and breach-notification requirements determined by the engagement and affected individuals.
• Canada: PIPEDA and applicable provincial privacy, consumer, employment and electronic communications requirements.
• Australia: Privacy Act 1988, Australian Privacy Principles, Spam Act 2003, consumer law and applicable workplace requirements.
• Saudi Arabia: Personal Data Protection Law, electronic transaction, cybercrime, employment and commercial requirements where the engagement is in scope.
• Singapore: Personal Data Protection Act, Computer Misuse Act, anti-spam and applicable employment and commercial requirements.

Accountability and evidence

• A named engagement owner is responsible for applying contractual and policy controls.
• Material decisions, approvals, access changes and incidents are documented in the relevant project records.
• Personnel receive instructions appropriate to their role, and access is reviewed when responsibilities change.
• Supplier and sub-processor obligations are assessed according to the service, information handled and delivery location.
• Records are retained only for operational, contractual or legal needs and disposed of through controlled processes.

Review, questions and escalation

This document is reviewed at least annually and after a material legal, operational or security change. Questions, evidence requests or concerns may be sent to info@netrexinc.com for routing to the appropriate NETREX owner.

This public document describes our operating approach and is not legal advice, a certification statement or a replacement for a signed client agreement. NETREX obtains specialist advice where a project creates jurisdiction-specific obligations outside the agreed delivery scope.