Anti-Bribery Policy.

Anti-Bribery Management System · ISO 37001:2025 · Version 2.0, 15 June 2026

Policy statement

Aromis International FZCO is committed to establishing, implementing, maintaining, and continually improving its Anti-Bribery Management System (ABMS), which complies with the international standard ISO 37001:2025.

We are committed to high standards of ethical behaviour and require all top management, employees, business associates, and other stakeholders with whom we conduct business to comply with this policy without exception. This policy provides the framework for setting and reviewing our anti-bribery objectives.

Anti-bribery commitments

The following are the policies of Aromis International FZCO:

• We will not engage in bribery, corruption, facilitation payments, or any other illegal act that would otherwise result in dismissal or termination of the business relationship.
• We only permit the receiving and giving of gifts and hospitality where it is reasonable and proportionate to a business relationship. It will not be undertaken if there is any risk that it may influence decision-making. Gifts and hospitality are assessed and recorded in our gifts and hospitality register.
• We will not accept business involving corrupt practices and will not continue with customer or other stakeholder relationships if any such instances arise.
• Where legal and commercial norms in certain countries differ from those expected by this policy, the General Manager decides on the due diligence required before any business relationship is entered into. Without exception, we do not offer or accept bribes or other inducements.
• Conflicts of interest are not acceptable. Top management and employees must not conduct private business, political, or charitable activities within the organisation without the prior written consent of the General Manager, which is a condition of employment. All conflict-of-interest declarations are recorded and reviewed at least annually.
• We do not make any political or charitable donations without the prior written agreement of the General Manager.
• Managers, staff, and contractors have confidential reporting channels to raise concerns (whistleblowing). Concerns may be reported by email to ethics [at] aromis.ae or in writing to the General Manager. Concerns may be raised in good faith and in confidence, and no one will suffer retaliation, dismissal or detrimental treatment for reporting a genuine concern or for refusing to take part in bribery. All line managers are briefed on how to handle concerns reported to them, and failing to report or investigate such concerns is a serious disciplinary matter.

Management commitment

• Management is committed to and supports implementing the ABMS in accordance with this policy and established objectives to adequately mitigate our bribery risk.
• Management is responsible for answering questions and clarifying bribery-related issues for employees.
• Aromis International FZCO is committed to fostering and maintaining an anti-bribery compliance culture throughout the organisation. The anti-bribery function, led by the Management Representative, has the authority and independence to operate effectively and has direct access to top management.

Implementation and review

The ABMS has been implemented to prevent Aromis International FZCO from engaging in corrupt practices and to address and report any such activities that may require further investigation and action. Regular reporting to the General Manager on all ABMS matters, and this policy and the processes that support it, is reviewed at least annually.

This policy is communicated internally and externally so that customers, business associates, stakeholders and employees are aware of Aromis International FZCO's commitment to anti-bribery. Any breach of this policy is treated as a serious disciplinary matter and may result in dismissal or termination of the relevant business relationship, in addition to any civil or criminal liability.

Approval

Approved and authorised for and on behalf of Aromis International FZCO.

General Manager
Date: 15 June 2026

This amended public edition omits individual names and internal document references. The complete controlled document (ARO-BCABMS-POL-01) is available on request via our contact page.