Overview
At DFF we are committed to conducting business with the highest levels of integrity, objectivity and independence. We expect all third parties with whom we conduct business to maintain high standards in accordance with our Code of Conduct.
This Policy is a key element to support a culture of ethical behavior, strong corporate governance and effective compliance and risk management. DFF strongly encourages you to speak up if you suspect or witness any matters of concern. DFF will take all reports made under this Policy seriously.
Purpose
This Policy aims to:
- identify and respond to concerns, and foster a culture of continuous improvement;
- encourage the reporting of suspected or actual wrongdoing, misconduct, or an improper state of affairs within DFF, by DFF or by those that DFF has relationships with; and
- protect the whistleblower (internal and external) from any retaliation that may arise as a result of reporting suspected or actual wrongdoing.
This Policy sets out the procedures and avenues available to a whistleblower reporting to DFF. This document also provides information about DFF’s approach to handling whistleblowing.
Whistleblowers should speak up and raise their concern via the channel through which they feel most comfortable.
Who is a whistleblower?
A whistleblower is defined as anyone who discloses Reportable Conduct (as defined below) under this Policy. This will include any entity or person who has dealings with DFF whether as a service provider, supplier, consultant or recipient of services from DFF.
What can be reported?
It is important that DFF is aware of any information which allows it to appropriately manage risks to its employees, its partners, its property, its business and its reputation. DFF encourages the reporting of any Reportable Conduct.
Reportable Conduct is anything that you have reasonable grounds to suspect, in relation to DFF, is:
- misconduct (which includes fraud, dishonesty or unethical behavior) or an improper state of affairs in relation to DFF or any related DFF entity;
- conduct that constitutes a contravention or breach of laws;
- conduct that represents a danger to the public;
- illegal conduct such as theft, violence or threatened violence, and criminal damage against property;
- fraud, money laundering or misappropriate of funds;
- offering or accepting of a bribe;
- financial irregularities;
- dangerous or will affect public interest;
- failure to comply with, or breach of, legal or regulatory requirements;
- engagement or threatening to engage in Detrimental Conduct (see Section 4);
- conduct that violates any DFF policies and procedures (applicable and in force from time to time); and
- Conflict of interest.
Reportable Conduct excludes personal work-related grievances as described below.
Personal grievances
A personal grievance is a report of behavior or dispute between the discloser and an employee of DFF or DFF itself that has implications for the discloser personally and which conduct does not amount to Reportable Conduct as defined above. Examples include:
- an interpersonal conflict between you and an employee of DFF; or
- a decision relating to your contractual engagement with DFF.
Anyone reporting Reportable Conduct must act in good faith, and have reasonable grounds for believing that the information shared in the report indicates that Reportable Conduct has occurred. ‘Reasonable grounds to suspect’ is based on objective reasonableness of the reasons for suspicion. In practice, a mere allegation with no supporting information is unlikely to reach that standard. However, a whistleblower does not need to prove their allegations. In addition, the disclosure can still qualify for protection even if the disclosure turns out to be incorrect.
A concern can be reported by you in a way that is either attributed to the individual raising the matter or can be reported anonymously.
If a prospective whistleblower is uncertain whether the matters concerning them are within the scope of this Policy (for example, if they suspect any Reportable Conduct but are uncertain as to whether the law has been broken, or whether a person is acting outside the scope of their authority), DFF encourages a prospective whistleblower to report the concerns.
Whistleblowers are kindly reminded not to discuss their reporting with any of their colleagues, supervisors, or contacts at DFF etc. even after the case is investigated and closed.
Attributed reporting
The following methods are available to all:
Access via a secure web link: https://stage.dffstg.site/wb
Send a direct email to the external provider at –[email protected]. This will also be secure, however if you wish to remain anonymous, please use the Online Submission channel.
Please write your information in a detailed letter and send to:
Attention: Chief of Legal Affairs
Level 3, Dubai Future Foundation
Emirates Towers, Dubai, UAE
P.O Box 555509
If you are making a disclosure concerning the Chief of Legal Affairs, you may directly report the Reportable Conduct to the CEO of DFF for investigation.
Anonymous reporting
You can choose to make your disclosure anonymously by using https://stage.dffstg.site/wb and in doing so, you will still be protected under this Policy. However, requiring complete anonymity may practically make it more difficult for us to investigate the issue or take the action we would like to take. In this regard, DFF cannot guarantee the complete investigation of all anonymous allegations due to the limitations of conducting a thorough investigation in the absence of additional information from the whistleblower.
It is preferable for whistleblowers to reveal their identity. By letting us know who you are, we can contact you directly to discuss your concerns, which will help us investigate the compliant more quickly and efficiently.
What is required to be included in a report?
Please provide as much detailed information as possible so that your report can be investigated. Some useful details include:
- Name, position and contact numbers of the whistleblower (if willing);
- Full name and position of the person(s) being complained about / reported;
- Details of the Reportable Conduct;
- Relevant/material facts and reasonable grounds for the Reportable Conduct; and
- Evidence(s) that support the report (if any).
For ease of reference please see form https://stage.dffstg.site/wb.
All reported disclosures will be reviewed and will be investigated at the earliest opportunity. Any findings will be managed promptly. The way a disclosure is managed is subject to what it involves and each disclosure will be dealt with on a case by case basis.
To ensure that any investigations and actions undertaken are fair and unbiased, it may be necessary to:
- obtain specialist, independent advice or to refer the matter confidentially to a third-party investigation firm, if deemed appropriate based on the nature of the disclosable matter(s);
- refer the matter to law enforcement where disclosures refer to or includes criminal behavior.
What is the investigation process?
In the conduct of an investigation, DFF may proceed as follows:
- Determine the nature and scope of the investigation;
- Speak to anyone who may be affected or involved in the disclosure, so they are provided with the opportunity to respond to the allegation(s);
- Consider these responses; and
- Speak to witnesses (where there is a dispute as to the facts surrounding the allegations).
DFF may issue further policies and procedures regarding the investigation process from time to time and will inform employees accordingly.
The findings of any investigation into a disclosure will be recorded and reported to DFF and will be subject to the record-keeping policies of DFF (from time to time) and the confidentiality obligations set out in this Policy. Where necessary, any final investigation report may be redacted to protect the whistleblower’s identity or information that may identify the whistleblower.
What happens after an investigation?
DFF will notify you once an investigation has been completed but please be aware that DFF may be unable to disclose particular details or the outcome of the investigation.
Confidentiality and fairness
DFF limits the number of people who have access to the details of a concerns raised and information obtained through any investigation process. Concerns will be thoroughly investigated in order to identify verifiable facts and ensure fairness. Decisions around the investigation process and any action required are not made by any person alleged to have been involved in inappropriate conduct or wrongdoing.
All individuals who contribute information to an investigation are directed to maintain confidentiality. We take this step-in order to protect and respect all individuals involved in the process. If a report concerns the conduct of a particular person, then the matters raised in the report may be discussed with them to obtain an understanding of their perspective. They will be directed to maintain confidentiality, to maintain compliance with DFF’s Code of Conduct, policies, procedures and the DFF values, and to take no action that could be considered retaliating in nature.
We encourage and will support individuals who report under this Policy, regardless of the outcome of the matter raised. DFF does not tolerate any form of Detrimental Conduct resulting from a whistleblowing disclosure. Under this Policy, anyone found to be victimizing or disadvantaging someone for making a disclosure or proposing to make a disclosure, will be subject to disciplinary action.
Detrimental Conduct means any negative action taken against any person who, in good faith, disclosing Reportable Conduct or assists or participates in an investigation of the disclosure and as a result suffers a detriment. Examples of detriment include:
- dismissal of any Employee or alternation of an Employee’s position/duties to their disadvantage, or negative performance feedback that is not reflective of actual performance;
- harassment, intimidation or bullying; or
- threats to cause detriment.
Further DFF shall not:
- subject the whistleblower to any civil, criminal or administrative liability (including disciplinary action) for whistleblowing;
- enforce a contractual or other remedy or exercise a contractual or other right against the whistleblower based on the whistleblowing; or
- cause any determined to the whistleblower or threaten to cause any detriment to the whistleblower based on the whistleblowing.
Malicious Allegations
Whistleblowers are discouraged from making false and malicious allegations. Where it is shown that a person making a report has made malicious, false or vexatious allegations of Reportable Conduct, then making that report will be considered a serious matter and may render the person concerned subject to further action. Additionally, whistleblowers should be aware that malicious allegations attract financial and criminal consequences under the UAE legal framework.
Effective Date
This Policy is applicable, effective immediately.
Amendment
DFF may amend/modify this Policy in whole or in part from time to time.
Contact Information
All queries in relation to this policy should be directed to Legal Affairs Department at [email protected]
Further information
This Policy is available to all third parties with whom we conduct business on request.