Compliance at Samchrome

We supply ferrochrome and chrome ore to customers around the world as the exclusive distributor for Samancor Chrome. The trust of our customers, suppliers and banks depends on how we do business, not only on what we deliver. This page sets out the rules we follow and what we ask of the companies we work with.

Integrity in every decision. Compliance in every action. Trust in every transaction.

Our commitment

Samchrome competes on the quality of its products, the reliability of its supply and the strength of its relationships. We have zero tolerance for bribery, for dealings that breach sanctions, for money laundering, and for any arrangement that restricts fair competition.

Chief Executive Officer, Samchrome FZE

Our compliance programme is led by the Chief Executive Officer and managed day to day by our Chief Compliance Officer and Legal & Compliance Department. It is built in line with the international standard for compliance management systems, ISO 37301:2021.

  • Who it applies toAll directors, officers and employees of Samchrome FZE, including our China branch office, and everyone who acts on our behalf.
  • How we checkDue diligence on customers and suppliers, internal inspections and audits, and annual management review.
  • How our people learnEvery employee signs a compliance commitment and completes annual compliance training.

Our policies

Summaries of the policies that govern how we trade. Select a policy to see what we commit to and what we expect from our business partners. Full policy documents are available on request from our compliance team.

Antitrust and fair competition

We set our prices independently and never coordinate with competitors.

Our commitment

  • We never agree with competitors on prices, sales terms, volumes, customers, territories or bids.
  • We do not exchange commercially sensitive information with competitors, directly or through third parties or industry associations.
  • Our benchmark and reference prices are set independently through an internal approval process.
  • We treat customers fairly and do not impose unjustified discrimination, tying or exclusivity.
  • We screen mergers, acquisitions and joint ventures for filing obligations before completion.

What we expect from you

  • Do not share with us confidential pricing or plans of your other suppliers or competitors.
  • Do not ask us to share information about other customers.
  • Set your own resale prices and commercial strategy independently.
  • Tell us if you believe any conduct in our dealings may restrict competition.

Legal basis: UAE Federal Decree-Law No. 36 of 2023 Regulating Competition and Cabinet Decision No. 3 of 2025, together with the competition laws of the countries where we sell.

Anti-bribery and anti-corruption

Zero tolerance for bribery and corruption in any form, direct or indirect.

Our commitment

  • We never offer, promise, give, accept or request anything of value to gain an improper advantage.
  • This covers money, gifts, loans, job offers, donations, sponsorships, business opportunities and favours.
  • Gifts, meals and hospitality must be reasonable, customary and lawful, never lavish.
  • Charitable donations are never used to disguise a bribe.
  • Our employees may not use their position for personal gain in sales, purchasing or trading.

What we expect from you

  • Do not offer our employees payments, kickbacks or gifts beyond modest, customary hospitality.
  • Do not make improper payments to officials or others in connection with our business.
  • Report to us any request for an improper payment by anyone claiming to act for Samchrome.

Applies to: our employees and to our customers, suppliers, consultants, distributors, joint venture partners and other representatives acting for or on behalf of Samchrome.

Sanctions compliance

We do not deal with sanctioned parties, countries or goods.

Our commitment

  • We do not trade with any person or entity on a sanctions or restricted list.
  • We do not trade goods originating from, destined for or transiting through sanctioned countries.
  • We screen customers, suppliers, agents and intermediaries, as well as vessels, freight forwarders and trade routes.
  • We suspend any transaction that raises a sanctions concern until it is cleared.
  • We keep screening and due diligence records for at least five years.

What we expect from you

  • Provide accurate information on your ownership, vessels, routes and final destination of goods.
  • Do not structure any transaction to avoid or conceal sanctions.
  • Tell us immediately if you, your owners or your partners become subject to sanctions.

Sanctions regimes we follow: United Nations, UAE Federal Government and Ministry of Economy, US Office of Foreign Assets Control (OFAC), European Union, and UK Office of Financial Sanctions Implementation (OFSI).

Anti-money laundering

Our business and our payments are never used to launder money or finance terrorism.

Our commitment

  • We do not accept money or assets that come from crime or whose origin is unclear.
  • We identify and verify the parties we deal with and the parties that finance our business.
  • We take special care where a party asks to remain anonymous.
  • We keep proper records of our counterparties and transactions.
  • We investigate and report any suspicion of money laundering or terrorist financing.

What we expect from you

  • Complete our Know Your Customer / Supplier form and provide supporting documents.
  • Give accurate details of your identity and ownership, and tell us when they change.
  • Do not request anonymous, unusual or unexplained payment arrangements.

Applies to: every entity related to Samchrome, our employees, officers and contractors, and any third party working on our behalf.

Compliance Handbook and code of conduct

How our compliance programme is organised and how we manage third parties.

How our programme works

  • Clear responsibilities from the CEO and Chief Compliance Officer to every department.
  • Regular assessment of the compliance obligations and risks that apply to our business.
  • Compliance commitments and annual training for all employees.
  • Routine and unannounced compliance inspections, internal audits and management review.
  • Confidential reporting channels, with strict protection against retaliation.

How we work with third parties

  • We choose partners with sound compliance practices and a good track record.
  • We carry out risk-based due diligence before and during the relationship.
  • We ask partners to sign our Compliance Commitment Letter.
  • We may review specific transactions, and we may end a relationship where serious misconduct is found.

Our code of conduct in brief: act with integrity and compete fairly, treat people with respect, and protect company assets, information and reputation.

For customers and suppliers

Before we start or renew a business relationship, we ask every customer, supplier, agent and service provider to complete four steps.

  1. Read our policies

    Review the policy summaries on this page and ask us for any full policy you need.

  2. Complete the KYC form

    Send us your company details, ownership information and supporting documents.

  3. Sign the commitment letter

    An authorised signatory signs and stamps our Compliance Commitment Letter.

  4. Return and stay in touch

    Email both documents to our compliance team and tell us about any material changes.

Download the Compliance Commitment Letter Download the KYC form Email signed documents

By signing the commitment letter, your company confirms that it

  • complies with all laws that apply to its business;
  • does not engage in price fixing, market sharing, bid rigging or other anti-competitive conduct;
  • does not offer, pay or accept bribes or kickbacks;
  • is not subject to sanctions and does not deal with sanctioned parties;
  • does not engage in money laundering, fraud or human rights abuses;
  • will cooperate with our due diligence and reviews;
  • will tell us promptly about any actual or suspected violation;
  • accepts that a serious breach may end the business relationship.

Report a concern

If you see or suspect conduct by anyone at Samchrome, or anyone acting for us, that breaches these policies or the law, please tell us. You can report in your own name or anonymously.

Whistleblowing email

Reviewed by the compliance team and handled confidentially.

whistleblowing@samchromefze.com

Anonymous online form

No name or contact details are required.

Open the reporting form

Compliance team

For questions about our policies or the commitment letter.

compliance@samchromefze.com

Every report is treated confidentially and investigated. We do not tolerate retaliation against anyone who raises a concern in good faith, even if no violation is found.

Contact our compliance team

Legal & Compliance Department
Samchrome FZE

compliance@samchromefze.com
Tel: +971 4 886 5446

JAFZA View 18, Office 802–804
Jebel Ali Free Zone, P.O. Box 263102
Dubai, United Arab Emirates

Page last updated: September 2026