Reporting Wrong Doing
A guide on what to do if you suspect fraud,
misconduct or wrong doing
Why you should read this
TDIC is committed to maintaining the highest standards of business conduct and ethics, as well as
compliance with all applicable government laws, rules and regulations, and as a leading company in
the field of real estate development we are always at risk, or affected by, misconduct, fraudulent or
corrupt activity. As a TDIC employee you have a key role in deterring and tackling such malpractice or
wrongdoing, as this leaflet explains, the reasons you should not turn a blind eye to fraud and
misconduct are that it:
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Demoralizes you and your honest colleagues;
Strengthens bullies and incompetents;
Diverts precious resources from those who need it;
Undermines our clients confidence in your services;
Makes your job harder.
What is whistleblowing?
When someone blows the whistle they tell their employer or a relevant regulator or authority about
fraud, bribery, corruption or wrongdoing that they are aware of through their work.
What’s the difference between whistleblowing and grievances?
A whistleblowing concern is about a risk, malpractice or wrongdoing that affects others. It could be
something which adversely affects other staff, the organisation itself and/or the public. A grievance,
on the other hand, is a personal complaint about someone’s own employment situation. A
whistleblowing concern is where an individual raises information as a witness whereas a grievance is
where the individual is a complainant.
How do I raise a concern?
If you believe there is malpractice or wrongdoing, you can send an email to ethicsline@tdic.ae or
contact the Senior Manager – Compliance or the Executive Director of Internal Audit.
Why should I tell the Compliance Function?
The Compliance function, which is part of the TDIC Internal Audit Department, is assigned the
responsibility of Fraud Detection and Investigations as per the Company’s Internal Audit Charter and
Audit Committee Charter as approved by the Board of Directors.
The Compliance / Internal Audit functions are independent of management and report directly into the
Audit Committee and Board of Directors, and possess the necessary skills and resources to address
your concerns about fraud and corruption and may investigate further.
Reporting Wrong Doing
If I blow the whistle to the Compliance Function will they tell the Management?
The Compliance Function will aim to maintain confidentiality when looking at your concerns. They will
not identify you, or confirm your identity, unless they have your permission to do so, or it has been
required by the law.
Can I raise my concern anonymously?
To the extent permitted by the applicable laws and regulations in the country, the identity of the
whistleblower will be protected and will not be revealed unless required by a Law Enforcement
Authority or a Court of Law. However, it is important to note that in the case of anonymous reporting,
there are additional risks for instance it:
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Is harder for investigators to ask additional questions or clarify points on the concern raised;
Does not stop others from guessing or working out who raised the concern;
May shift the focus from the concern to the whistleblower because there may be a suspicion
that the whistleblower is just being malicious;
Does the Company Policy protect whistleblowers?
TDIC Whistleblower policy has a strong protection for any employee who blow the whistle on/ or
honestly raise a genuine concern about malpractice or wrongdoing. There should be no fear of
dismissal, disciplinary action or any method of discrimination or retaliation by the company.
Whistleblowers who believe they are suffering retaliation have the right to bring the matter to the
attention of the CEO and/or the Executive Director of Legal Services or the Executive Director of
Internal Audit.
Reporting Wrong Doing
Fraud And Corruption Some Do’s And Don’ts:
Do’s
 Do raise the matter
The earlier the problem is raised and looked into, the earlier any wrongdoing can be addressed and
you and others can be reassured that things are in order.
 Pass on any reasonable suspicion to someone
in authority
This is usually your manager, however if you are not confident or it is not possible for you to raise a
concern within the authorized chain of commands for whatever reason, you can raise your concern to
the Compliance Function within the Internal Audit Department or send an email with the details to
ethicsline@tdic.ae
 Do remember key details
If possible, make a note of key details, such as what caused your suspicion, when things happened
and who was involved.
 Do check the whistleblowing policy section of
the Code of Conduct
TDIC have a policy and procedures in place that tell you how you can safely raise a genuine
concerns. The policy and the procedures will tell you who you can talk to and you are advised to
follow it.
Reporting Wrong Doing
Don’t
 Don’t turn a blind eye
If you are worried that some wrongdoing is happening at work, please don’t keep it to yourself. Being
wise after the event helps nobody.
 Don’t investigate the matter
There are special rules surrounding the gathering of evidence. You may make matters worse if you
do. If you raise a concern you are not required to prove it. However, if you have any evidence please
give it to the investigator.
 Don’t report your suspicions to someone who
doesn’t have proper authority
The Compliance Function has appointed, trained and contracted with designated individuals who are
bounded with strict confidentiality requirements and are able to deal with, and guide you on
whistleblowing matters.
 Don’t delay
As you won’t be asked to prove your concern, raise it early when it’s a suspicion. Don’t wait for proof.
Reporting Wrong Doing