Scope and responsibility
This policy applies to the company, its directors and staff, and to anyone who acts on its behalf. The director is responsible for it. The compliance contact answers questions and receives reports, and can be reached through the contact page.
Know your customer
We do not sell to a buyer we have not identified. Before a first order we verify the legal entity, its licences, its directors and every owner of 25 percent or more, and we understand how the goods will be sold. We repeat these checks on a risk basis and whenever something changes.
Sanctions
We screen buyers, owners, suppliers and destinations against the UAE local terrorist list, the lists of the United Nations Security Council and other sanctions lists that apply to us. We do not trade with or for a listed party, and we do not ship to territories under comprehensive sanctions.
Anti money laundering
We follow the UAE laws on anti money laundering and countering the financing of terrorism. We apply these rules to every payment and every counterparty. Unusual activity is escalated internally and, where the law requires, reported to the UAE Financial Intelligence Unit.
Bribery and gifts
We do not offer, give, ask for or accept bribes, facilitation payments or gifts that could influence a business decision. This applies to public officials and private parties alike.
Product compliance
We supply only products that meet the requirements of the UAE or of the destination market: conformity certification and registration where required, health warnings in Arabic and English, digital tax stamps where they apply, and correct excise status. We do not trade in counterfeit, unlabelled or grey market goods, and we do not sell to anyone under 18.
Responsible trade
We supply licensed businesses only. We do not advertise tobacco to the public and we do not sell online to consumers. We expect our buyers to follow the laws on age verification, display and advertising in their own market.
Records and reporting
We keep identification records, contracts, invoices, shipping documents and payment records for at least five years. Anyone may raise a concern about our conduct, in confidence, with the compliance contact. No one will be penalised for raising a concern in good faith.