GSB Capital Ltd. Whistle Blowing Policy
Contents
Whistleblowing Flow Chart
Should I make a whistleblowing disclosure?
- Direct communication via email or face-to-face with GSB
- Compliance Officers compliance@gsbglobal.com
- Via mail – P.O.Box 938542 – Attention to the Compliance officer
- If any concerns with direct communication to GSB, report to DFSA
- DFSA Level 13, The Gate, PO Box 75850, Dubai, UAE
- Telephone: +971 (0)4 362 1500
- Fax: +971 (0)4 362 0801
- Email: whistle@dfsa.ae
- The compliance officer will conduct a preliminary review.
- If required, this will be escalated to the SEO and the COO. The CO shall discuss the matter with the SEO & CCO without naming the whistleblower
- The CO together with the SEO & CCO (where possible) shall ensure the report is well-grounded, reasonable and based on true facts to determine the appropriate course of action.
- The CO shall communicate to the whistleblower, regular updates during and on conclusion of the investigation with the outcome.
Why is whistleblowing important
GSB’s policy is to keep an open door to tip-offs and complaints, whether from clients, providers or employees. The Firm considers whistleblowing an integral part of its scope, a cost-effective way to alert it to potential problems within the firm arising out of misconduct, malpractice, and breach of trust that will endanger the firm’s reputation.
GSB encourages disclosures from employees and other parties through a professional approach.
Why do we need this policy?
Fraud, corruption, and misconduct typically exhibit visible signs to the public eye. Therefore, they are normally identified and escalated to be resolved. However, there may be instances where concerns are ignored or inadequately addressed. You may want to raise your concerns but fear retaliation or would like to be anonymous. For such cases, GSB has adopted this whistleblowing policy to guide you on how you can raise your concerns in confidence and without the fear of retaliation. This policy also describes the process to be followed and what to expect if you make a report.
What concerns are covered by whistleblowing
The following are examples of concerns that can be raised using the whistleblowing policy (list is not exhaustive):
- Fraud, corruption and bribery
- Profiting from insider information on deals or other income-generating activity
- Disclosure or leak of restricted information
- Failure to abide by legal and regulatory obligations
- Any conduct resulting in adverse publicity or reputational damage to GSB Capital Ltd.
- Discrimination or harassment
- Endangering health and safety
- Deliberate concealment of critical information
- Violating GSB’s code of conduct
PLEASE DO NOT USE THIS POLICY FOR:
- Employment grievances
- Professional disagreements
- False accusations
When to make a whistleblowing report
First, you can contact your Compliance Officer and/or Deputy Compliance Officer via email, mail, or face-to-face. If you were not satisfied with the resolution or do not feel comfortable to raise your concerns via the Firm, you can escalate it to the Dubai Financial Regulatory Authority due to:
- The concerns you raised were not considered or were not dealt with appropriately
- Your concern may be related to or associated with the GSB management and point of contacts
- You fear retaliation or undue influence
- You wish to remain anonymous and keep your identity confidential
Whistleblowing procedure
(1) Make a Whistleblowing Report
- There are several channels available to you if you wish to make a whistleblowing report:
- Send an email to the Compliance officer at compliance@gsbglobal.com
- You may request a face-to-face meeting with the Compliance Officer in confidentiality
- You may mail the GSB office at PO Box – 938542, with the mail addressed to “Attention of the Compliance Officer”.
If, to the DFSA –
- Anonymously on the whistle@dfsa.ae or via DFSA line +971 (0)4 362 0801 or Fax: +971 (0)4 362 0801
- Mail to the DFSA Level 13, The Gate, PO Box 75850, Dubai, UAE
(2) Review of Whistleblowing Reports
Once you have made your whistleblowing report, the compliance officer will conduct a preliminary review to asses if:
- Your concerns fall within the scope of the whistleblowing policy and the compliance mandate
- Information or evidence provided raises reasonable doubt about the circumstances
- Compliance officer will conduct a preliminary investigation to verify the information and determine its impact
- Compliance officer, together with the SEO or CCO (where necessary), will determine the appropriate course of action
If the Compliance officer determines that the nature of the report is not within the scope of this policy, the reporter will be advised on appropriate next steps. If the initial information provided does not raise reasonable doubt, given the circumstances, the whistleblowing report will be closed, and the Compliance officer will not proceed to the investigation phase.
(3) Outcome of Investigation
Whenever possible, the Compliance officer will communicate with you and update you on the progress or outcome of your whistleblowing report. However, please note that the Compliance Officer may not be able to provide you with any or exact details on every occasion, especially if it would breach an existing duty of confidentiality or the law.
Confidentiality
You are encouraged to identify yourself when making a whistleblowing report, as this will allow for effective follow-up on concerns raised. The Compliance Officer will hold your details in confidence. Any emails or notifications made directly to the Compliance Officer shall not be saved on the server or in a folder; the Compliance Officer may discuss (where necessary and appropriate) the matter with the SEO & CCO without naming the whistleblower.
If you wish to stay completely anonymous to the Firm, you may email the DFSA to whistle@dfsa.ae or mail them.
Whistleblowers protection
GSB has zero tolerance towards retaliation against whistleblowers acting in good faith or persons cooperating during investigations. The Whistleblower shall not be subject to any civil or contractual liability for making the whistleblowing report. No contractual, civil or other remedy or right shall be enforced against the whistleblower by any other person for making the whistleblowing report. Furthermore, the whistleblower shall not be dismissed from employment within the firm or be subject to any action either by GSB or any of its related parties. The Compliance Officer will also monitor incidents or complaints reported by the whistleblower over a period of time.
For internal employees when whistleblowing – the Compliance officer along with the HR function (where necessary) shall monitor the performance evaluation and remuneration of the whistleblower for at least one year after receiving a report to ensure no detriment has been suffered by the whistleblower. Periodic follow-ups with the whistleblower may be conducted as required.
Other measures
Compliance Officer will maintain a register to record, monitor and evaluate key indicators such as volume, themes or outcomes related to whistleblowing reports. No confidential information will be maintained on this register as the register will purely be used for monitoring and testing purposes.