External Whistleblower Protection Policy

External Whistle-blower Protection Policy: Approach adopted by Department of Tourism & Commerce Marketing to protect whistle-blowers.

DET: Department of Economy and Tourism (which includes DET, DCTCM, DFRE & DCT)

DCTCM: Dubai Corporation for Tourism & Commerce Marketing

DFRE: Dubai Festivals & Retail Establishment

DCT: Dubai College of Tourism

Director General: Director General of DET

Senior Management: CEO'S and Executive Directors of DET, DCTCM, DFRE and DCT

Directors: Heads of Departments

Corporate Governance: An integrated system of policies and rules for the control and guidance at the institutional level that determines the responsibilities, rights and relations between the owner and senior leadership with the departments, customers, partners, suppliers, and human resources, and monitors the procedural and financial decision-making to ensure the achievement of institutional integrity, combat corruption in the work environment, support justice, transparency and institutional accountability and enhance trust and credibility to achieve good governance.

Whistleblower: A person who reports fraud or other unethical issues within the sector, as well as among stakeholders and entities that are engaged in business with DET, including without limitation, all customers, partners, suppliers, the community (public, and the agents of third, parties & their representatives.

Violations: Malpractices, including any criminal or financial violations, breach of any legal or regulatory obligations or internal organiational requirements or any acts that pose a threat to health, safety or environment.

Unethical Issues: Intentional or unintentional acts or practices that are contrary to morals, harm reputation, lack equity or do not conform with the approved labor standards or proper professional or social behaviour.

Fraud: An unethical, irregular or illegal act or practice characterised by dishonesty and the premeditated intention to conceal a fact, either in words, acts or counterfeiting, which would result in financial or non-financial loss to DET. It includes erroneous accounting practices or false financial reporting with fraudulent intention.

Integrity: Treating everyone fairly and without discrimination or bias and acting professionally and objectively in public affairs management and in relationship with others.

As a part of The Department of Economy and Tourism (hereinafter referred to as "DET") to meet the optimal standards of organisational ethics, effective communication, and as a part of DET's corporate governance, the Whistle-blower protection Policy (hereinafter referred to as the "Policy") was introduced to DET to embrace transparency, disclosure, justice, integrity, responsibility & accountability so as to achieve the supreme and broader intended goal of the application of corporate governance at DET.

External whistleblowers will be protected against reprisal provided the disclosure is made in good faith and on the basis that they reasonably believe that a breach, malpractice or impropriety has occurred relevant to the tourism sector, DET, or employees and addressing this act appropriately.

If an allegation is made in good faith, but is not confirmed through investigation, no action shall be taken against the whistleblower. However, in making a Complaint the individual should take care to ensure that the information provided is accurate. Any malicious, frivolous or repeated complaints will be treated with disciplinary action.

All DET staff and representatives must observe the rules of honesty and integrity in the performance of their responsibilities and comply with all applicable laws & regulations. DET is committed to achieving the highest possible quality, credibility & openness standards in the exercise of all its activities in application of the corporate governance methodology.

DET is committed to developing an integrated framework for whistleblower protection. The main objective of this policy is to ensure that no whistleblower sustains any potential damage, in the present or future, and protect them from any harm as a result of reporting any violations, fraud, or unethical issues.

DET is committed to ensuring the protection of whistle-blowers who are covered by DET Whistleblowing Policy through the detection of violations, ensuring full confidentiality and dealing with the report covered by this policy based on specific and credible information or documents, without violation of any ethical rules recognized by DET.

A Whistle-blower will have the following protection:

1. Non-disclosure of information concerning his identity & whereabouts unless required by relevant authorities as per their jurisdictions.
2. No whistle-blower will be considered to have violated the provisions of legalization, agreements & representations related to disclosure of confidential information, whether in the entity for which the whistle-blower works or deals with, unless the report is false.

Damage or injury from which the whistle-blower may be protected:

1. Revenge, harassment or prosecution by other employees.
2. Bias against the whistle-blower (internally/externally) in the present or the future.

Director General

• Adopt the policy in accordance with the applicable procedures.
• Refer reports presented to him to the relevant department.
• Take decision on an employee who caused the damage, according to rules, procedures, regulations and laws. The Director General may appoint a special committee to look into the matter.
• Director General may authorize Internal Audit to conduct an investigation into the matter, where necessary.

Director of Human Resources & Work-related Offences Committee

• Take disciplinary action against employee who caused damaged. i.e. violations, unethical issues, and fraud.
• Ongoing review to assess the performance of employee in act of violation.

Director of Internal Audit

• Investigate the matter referred by Director General.
• Report results of investigation to Director General for necessary action.

Call Centre & Customer Service

• Conduct preliminary assessment on the received whistle blow to determine whether it's a complaint or whistle blow.
• Consider all reports presented to them as serious and sensitive.

International Legal Advisory

• Provide legal guidance in dealing with allegations involving violations, fraud, or unethical issues.

Employees

• Awareness and adherence to this policy.
• Any employee involved in any conduct that causes damage to the whistle-blower, as a result of reporting any unacceptable conduct, will be considered to violate this policy and will lead to taking disciplinary measures against this employee.

External Stakeholders

• Ensure that no damage or harm is incurred to a known person who reports an unacceptable conduct.
• Protect the whistleblower from any potential career damage.

Independent Auditor

• Auditor shall assess internal controls design and effectiveness, to mitigate risks that may arise from potential fraud.

Whistleblowing cases may vary from corruption, to fraud, to money laundry.

Fraud

Fraud is commonly used to describe a wide range of misconducts including theft, corruption, embezzlement, bribery, forgery, misrepresentation, collusion, money laundering and concealment of material facts. It often involves the use of deception to make a personal gain for oneself, a connected person or a third party, or a loss for another - intention is the key element that distinguishes fraud from irregularity. Fraud does not just have a potential financial impact, but it can cause damage to the reputation of an organisation responsible for managing funds effectively and efficiently.

Money Laundry

Money laundering is the illegal process of making large amounts of money generated by a criminal activity, such as drug trafficking or terrorist funding, appear to have come from a legitimate source. The money from the criminal activity is considered "dirty", and the process "launders" it to make it look clean.

All data and information provided by the Whistle-blower will be confidential. Neither DET or any of its employees may disclose such information or use it for any purpose other than the intended purposes or if required by relevant authorities as per their jurisdictions.

If the result of the investigation and legal advice results in evidence of criminal activity, applicable laws and procedures shall be followed.

If a DET employee violates this policy, action will be taken according to the relevant laws and regulations of Department of Dubai Government Human Resources (DGHR).