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C. Investigation and Reporting

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—
 
  a. An investigation file should be opened. In the case of an oral report, the CO should prepare a written summary.
  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.
  c. The CO shall advise the Board of the existence of an investigation.
  d. The identity of the individual disclosing relevant information to the CO should be treated in accordance with applicable UAE laws and regulations.
  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.
  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.
  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.