About us

Whistleblowing Disclosure

We are committed to conducting business with the highest levels of integrity, standards, transparency and professionalism. Our Whistleblowing Policy and Program are a key element to support a culture of ethical behavior, strong corporate governance and effective compliance and risk management to prevent and detect misconduct and ensure compliance with laws and regulations. Our Whistleblowing Policy and Program aim 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 FFA, by FFA or by those that FFA has relationships with
• Protect the whistleblower (internal and external) from any retaliation that may arise as a result of reporting suspected or actual wrongdoing in compliance with the DFSA legal protections regime (Article 68A of the Regulatory Law).

WHAT CAN BE REPORTED?

It is important that we are aware of any information which allows us to appropriately manage risks to our employees, partners, business and reputation. FFA encourages the reporting of any suspected misconduct in good faith that you have reasonable grounds to suspect, in relation to:

• misconduct (which includes fraud, dishonesty or unethical behavior)
• conduct that constitutes a contravention or breach of laws, rules and regulations
• fraud, money laundering, or any other financial crime
• offering or accepting of a bribe
• financial irregularities
• failure to comply with, or breach of, legal or regulatory requirements
• conduct that violates any of FFA policies and procedures (applicable and in force from time to time)
• Conflict of interest

There is information that needs to be provided by the Whistleblower to help initiate an investigation which includes as a minimum:

• Type of incident
• Brief details of incident – i.e. time, place, occurrence, activity, involved individuals, etc.
• Triggers of the incident
• Any evidence to help support the intended allegations
• Any other relevant information that could help provide further clarity to successfully proceed with the investigation.

The Whistleblower may be contacted for further information that may be needed during the investigation.

CONFIDENTIALITY

We treat all disclosures made by a Whistleblower as confidential and privileged to the greatest extent practicable and permitted by the DFSA laws, rules and regulations and apply due care to keep the identity of the Whistleblower as confidential to ensure fair treatment of the Whistleblower.
In compliance with the DFSA laws, rules and regulations, FFA, where appropriate, may escalate whistleblowing reports to the senior management and, if necessary, to the DFSA for inspection or to any other relevant authority.
All cases will be reviewed and investigated. The length of an investigation will vary depending upon the circumstances of each case.
Once an investigation has been concluded, the Whistleblower has the right to be informed of the outcome of the findings of any investigation where it is possible and practical to do so. However, any action taken against an employee as a consequence of the investigation may be personal and confidential, in which case, it cannot be disclosed.

HOW TO RAISE A CONCERN?

Whistleblowing incidents can be reported in good faith using various secure and protected channels managed by the Chief Compliance Officer / MLRO.

• by email to Whistleblowing@ffaprivatebank.com or
• report anonymously in writing to: FFA Private Bank (Dubai) Limited Dubai International Financial Center Gate Precinct, Building 5, Officer 410 PO Box 506567 Dubai United Arab Emirates
• There may be circumstances where the Whistleblower may prefer to report the concerns directly to the DFSA by email to whistle@dfsa.ae