Anti-Bribery & Corruption Policy

1. Purpose & Scope

This Policy establishes SKYLINE's commitment to operating with integrity and complying with all applicable anti-bribery laws, including the Saudi Anti-Bribery Law (Royal Decree No. 36/1412), UK Bribery Act 2010, US Foreign Corrupt Practices Act (FCPA), and OECD Anti-Bribery Convention. This Policy applies to all employees, directors, contractors, suppliers, and business partners.

2. Definitions

• Bribery: Offering, promising, giving, requesting, or accepting anything of value to improperly influence a business decision.
• Corruption: Abuse of entrusted power for private gain.
• Public Official: Any person working for government, international organization, political party, or state-owned enterprise.
• Facilitation Payments: Small unofficial payments to expedite routine government actions — prohibited at SKYLINE.

3. Prohibited Practices

SKYLINE employees or representatives must not:

• Offer, promise, or give any bribe to any person (public or private) to obtain improper advantage
• Accept or request any bribe from any party
• Make facilitation payments (even if locally legal)
• Use intermediaries or consultants to make bribes on behalf of the Company
• Make charitable or political contributions in exchange for business advantage

4. Gifts & Hospitality

Reasonable gifts and hospitality are permitted provided they are:

• Transparent and documented
• Reasonable in value (maximum SAR 500 per gift)
• Not cash or cash equivalents (vouchers, gift cards)
• Appropriate for legitimate business purpose
• Not given to influence a specific decision
• Disclosed to the Compliance Officer if exceeding SAR 200

No gifts of any kind may be offered to government officials or public employees without prior written approval from the Compliance Office.

5. Third-Party Due Diligence

We conduct anti-bribery due diligence on all agents, consultants, distributors, and partners before contracting. Third parties are screened against sanctions lists (OFAC, EU, UN), corruption reports (Transparency International), and court records. Third-party contracts include anti-bribery clauses.

6. Record Keeping

All payments and expenses must be recorded accurately and honestly in Company books. Creating false, hidden, or misleading records is prohibited. All payments are subject to dual financial controls (Maker-Checker).

7. Training & Awareness

All employees receive mandatory annual training on anti-bribery policy. Employees in high-risk positions (sales, procurement, government relations) receive specialized training.

8. Consequences

Violations lead to strict disciplinary action including immediate termination, reporting to Saudi authorities (Oversight and Anti-Corruption Authority "Nazaha"), criminal prosecution, and civil recovery claims.