| 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 the 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 the 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. |
| | 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.
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