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Whistleblowing Policy

Whistleblowing is the term used when a person passes on information concerning wrongdoing, such as immoral, illicit, unsafe or fraudulent / corruption, sexual harassment etc. Whistleblowing plays a critical role in keeping honesty, efficiency and responsibility at aafaq Islamic Finance. In recognition of this role, aafaq Islamic Finance provides the opportunity for all stakeholders including employees, entities, vendors, counterparties and the public to discreetly disclose wrongdoings by its Employees, Contractors, and Representatives in an environment free from the threat of retaliation. At aafaq Islamic Finance, we believe, Fraud and corruption can be averted and reputations protected if timely information is received and acted upon.

When to blow the Whistle

A requirement to blow the whistle may arise in various circumstances including but not limited to the following:

a) Knowledge or reasonable suspicion that an employee or client of aafaq Islamic Finance has committed, or is attempting to commit, unauthorized disclosure of confidential information or any other market abuse; The commission or likely commission of a criminal offence;
b) Where a person has failed, is failing, or is likely to fail to comply with a particular legal obligation, or regulatory standard;
c) Where a miscarriage of justice has occurred, is occurring, or is likely to occur;
d) Where the health or safety of any individual has been, is being, or is likely to be endangered;
e) Where there are unacceptable acts of behavior such as bullying, harassment or acting in an aggressive manner;
f) The environment has been, is being, or is likely to be damaged;
g) Where financial irregularities or mismanagement, or act of malfeasance is likely to occur, such as falsification or destruction of business or financial records; misrepresentation or suppression of financial information; non-adherence to internal financial reporting policy/controls, including management overrides; and auditor independence concerns;
h) Any act or suspicions of fraudulent and corruption misconducts, such as: theft; defalcation; insider trading; market manipulation; and corrupt practices including giving or receiving bribes or other improper benefits.
i) Unauthorized breach of aafaq Islamic Finance policy or procedures;
j) Violation of applicable Local or International laws and regulations;
k) Any personal conduct which is inappropriate or unbecoming; is contrary to the aafaq Islamic Finance Code of Conduct and Ethics; and/or would be reasonably expected to cause fear or significant offence;
l) The deliberate concealment of any of the matters listed above.

How can I report an issue under Whistleblowing?

You may do so by sending an email to address provided below or by visiting aafaq Islamic Finance Head Office:

Email Physical Address
whistleblower@aafaq.ae 18th Floor, Al Saqr Business Tower, DIFC Area, Dubai, UAE.


Where possible, try to provide information including but not limited to the following:

- An outline of the known or suspected wrongdoing;
- Details, to the best of your knowledge, about when, where and how it occurred;
- List of the names of those suspected of being involved (both within aafaq Islamic Finance and externally);
- List of the names of anyone who may have relevant information;
- Details of how you came to know about the suspected activities;
- What, if any, do you estimate to be the value of the loss to aafaq Islamic Finance or other parties;
- What, if any, breaches of internal controls, policy, procedure or other requirements you believe took place;
- Any specific recommendations you have for actions;
- Names of anyone who you have discussed with or reported this incident to;
- Your name and contact details (if you would like to disclose)
- The date and time of making the report.

What happens once a concern is received?

An investigation committee will be formed based on relevance and will carry out an investigation of the disclosure to determine whether there are grounds for a more detailed investigation to take place. Where appropriate, recommendations for action shall be provided by the Investigation Committee to the Senior Management with appropriate corrective and preventive actions.


Internal policies at aafaq Islamic Finance ensures strict confidentiality and the anonymity of the whistleblower communicating the concern.

Additionally, protected disclosures and investigatory records will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation; report results to the authorities as may be required by law or regulatory requirements; take necessary corrective actions; or implement protective measures.

All reports received shall be verified in an appropriate manner and acted upon in confidence. An incident may be reported to the Competent Authority in line with regulatory requirements, where aafaq Islamic Finance reserves the right to make such a referral without the ‘Whistle Blower’s’ consent.