| 1. |
VASPs must establish, maintain and publish methods of contact including, but not limited to, a telephone line, for receiving reports of any violation or possible violation of any applicable laws and regulations relevant to anti-bribery and corruption by the VASP, or its Board or Staff on its behalf. |
| 2. |
Any member of the Board or Staff must report to the CO as soon as possible if they believe or suspect that an action in conflict with the anti-bribery and corruption Rules in this Part VI of this Compliance and Risk Management Rulebook has occurred, or may occur, or has been solicited by any other Entity. |
| 3. |
The CO shall investigate any report of a violation or possible violation of the anti-bribery and corruption Rules in this Part VI of this Compliance and Risk Management Rulebook and shall follow the below procedures—
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a. |
An investigation file should be opened. In the case of an oral report, the CO should prepare a written summary. |
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b. |
The CO shall appoint an independent Entity who shall promptly commission the conduct of an investigation. The investigation will document all relevant facts, including Entities involved, times and dates. |
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c. |
The CO shall advise the Board of the existence of an investigation. |
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d. |
The identity of the individual disclosing relevant information to the CO should be treated in accordance with applicable UAE laws and regulations. |
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e. |
On completion of the investigation, a written investigation report will be provided by the Entity employed to conduct the investigation to the CO. If any unlawful conduct is found, the CO must advise the Board accordingly. |
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f. |
If any unlawful conduct is found, the VASP shall take such remedial action as the Board deems appropriate to achieve compliance with its internal anti-bribery and corruption policy and all applicable anti-bribery and corruption laws. The Entity employed to conduct the investigation shall prepare a written summary of the remedial actions taken. |
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g. |
The written investigation report and a written summary of the remedial actions taken shall be retained by the CO for a period of no less than eight [8] years from completion of the remedial action. Such reports shall be made available to VARA upon request.
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