GLA & Co (“the Firm”) is committed to conducting its business with the highest standards of honesty, integrity, transparency, and accountability. This Anti-Fraud, Bribery, and Corruption Policy (“Policy”) sets out the Firm’s zero-tolerance approach to all forms of fraud, bribery, corruption, misappropriation, embezzlement, facilitation payments, money-laundering, and any other dishonest or unethical conduct. It has been developed with reference to best practices adopted by leading international law firms and is intended to comply with, and in many respects to exceed, the requirements of applicable anti-fraud and anti-corruption legislation and professional regulations in the Middle Eastern countries in which the Firm operates.

This Policy applies to every partner, member, director, officer, employee, trainee, secondee, and intern of the Firm, and to all consultants, and any other third parties who act on the Firm’s behalf (collectively “Personnel”). Compliance with this Policy is a condition of employment, engagement, or retention by the Firm. All Personnel must familiarise themselves with the Policy, complete mandatory training when requested, and certify on request that they have read, understood, and will adhere to its provisions.

For the purposes of this Policy, “fraud” is defined broadly to include any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. This encompasses, without limitation, misrepresentation of material facts, falsification or alteration of documents or records, unauthorised diversion of funds or assets, misuse of client monies, submission of false expense claims, theft of cash or property, manipulation of financial statements, insider dealing, or any scheme devised to obtain an improper financial or personal advantage. “Bribery” includes the offering, promising, giving, requesting, or accepting of a financial or other advantage, directly or indirectly, with the intention of inducing or rewarding the improper performance of a function or activity. “Corruption” is the abuse of entrusted power for private gain and embraces both public-sector and private-sector conduct.

The Firm maintains a robust framework of internal controls designed to prevent, detect, and respond to fraud, bribery, and corruption. These controls include risk-based client and matter acceptance procedures, segregation of duties, multi-level authorisation requirements, periodic reconciliations, and regular internal and external audit reviews. All financial transactions must be accurately and promptly recorded in the Firm’s books and records in accordance with applicable accounting standards and regulatory obligations. No undisclosed or unrecorded accounts or funds may be established for any purpose. Client monies must be held strictly in accordance with professional conduct rules and never commingled with the Firm’s own funds.

All Personnel have an affirmative duty to be vigilant and to report promptly any suspicion, concern, or knowledge of fraudulent or corrupt activity. Reports may be made to the Managing Partner, the Chief Operating Officer, the General Counsel, the Head of Risk & Compliance, or through the Firm’s confidential whistleblowing hotline or secure email portal. Reports may be made anonymously where permitted by law, and the Firm will take all reasonable steps to maintain confidentiality consistent with a thorough investigation. Retaliation, victimisation, or detrimental treatment of any individual who, in good faith, raises a concern or participates in an investigation is strictly prohibited and will itself be treated as a serious disciplinary offence.

Upon receipt of an allegation, the Firm will initiate a timely, fair, and objective investigation, led by the General Counsel and, where appropriate, external counsel, forensic accountants, or other specialists. All Personnel must cooperate fully with any investigation and must preserve all relevant documents, data, and communications. Investigations will be conducted in accordance with applicable laws, professional duties of confidentiality, data-protection obligations, and the principles of natural justice. Findings will be reported to the Management Committee, which will determine what remedial, disciplinary, or legal actions are required. Proven misconduct may result in disciplinary sanctions up to and including dismissal for cause, termination of contractual relationships, referral to law enforcement or regulatory authorities, civil recovery proceedings, and pursuit of all other available remedies.

The Firm recognises that education and awareness are critical to fostering a culture of integrity. Comprehensive anti-fraud and anti-corruption training is provided to all new joiners and refreshed periodically for all Personnel, with enhanced modules for those in higher-risk roles or geographies. The Firm also conducts targeted training for third parties where appropriate and requires suppliers and other business partners to commit in writing to standards equivalent to those embodied in this Policy. The Firm’s Risk & Compliance function performs continuous monitoring, risk assessments, and policy reviews, reporting at least annually to the Management Committee on the effectiveness of the anti-fraud and anti-corruption framework and recommending improvements where necessary.

Any questions about the application or interpretation of this Policy should be directed to the General Counsel or the Head of Risk & Compliance. The Policy will be reviewed no less frequently than once every twelve months and may be amended at any time to reflect changes in law, regulation, professional standards, or the Firm’s business operations. All amendments will be circulated promptly to Personnel and will take immediate effect unless otherwise specified.

By acting on behalf of GLA & Co, each individual and entity acknowledges that they have read, understood, and agree to comply with this Anti-Fraud, Bribery, and Corruption Policy and that failure to do so may result in personal liability as well as disciplinary or contractual consequences. Through unwavering adherence to these principles, the Firm aims to safeguard its clients, its people, and its reputation, and to contribute to the broader fight against fraud and corruption in the global legal profession.