Our commitment
As a pioneer in Islamic Banking, we at QIB have a moral and ethical commitment and duty to act with the highest standards of integrity and honesty at all times to maintain our position as one of the leading regional banks. We will not, and shall never, tolerate any act of bribery or corruption committed by any of QIB employees and/or officers at all levels, including members of the Board of Directors, and any third-party acting for or on behalf of QIB.
QIB’s commitment to anti-bribery and anti-corruption builds on the bank’s corporate and social responsibility to our customers, shareholders, stakeholders and related parties to prevent, investigate, detect, and adversely react against those who would seek to facilitate any form of financial crimes through QIB.
Consistent with all local regulations of The State of Qatar including the Qatar Penal Code, international benchmarks on anti-corruption – such as the recommendations of the OECD, the U.S. Foreign Corrupt Practices Act (FCPA); QIB commits to build sound and transparent business practices, in line with the company’s Financial Crime Compliance Framework, and seeks to combat attempted and actual acts of bribery and corruption.
Purpose and scope
To provide guidance on how to develop, implement and maintain an effective anti-bribery and anti-corruption. The overall objective is to promote a culture of ethical business practices and compliance with anti-bribery and anti-corruption legal and regulatory requirements.
QIB requires all employees, including Directors and anyone acting on our behalf (agents, other intermediaries, external consultants, third-party representatives, and business partners, contractors, subcontractors and suppliers) to act with honesty and integrity.
Employees and those acting on our behalf are prohibited from paying, offering, accepting or requesting a bribe, in any form; from making facilitation payments and from taking any action to circumvent established controls to deter, prevent, detect or respond to bribery.
How do we define bribery and corruption?
We define bribery as “a specific offence, which concerns the practice of offering or accepting something, usually money, to gain an unlawful advantage”.
Although money is the most common form of bribery, an offer and/or acceptance of any gift, fee, reward, or other advantage as an inducement to urge a dishonest act, an illegal act, or a breach of trust may fall within the bribery definition.
We define corruption as “an abuse of a position of trust in order to gain an undue advantage or private gain”. The term covers a wide range of misconduct often associated with the abuse of entrusted power, of which bribery can be part.
Governance & role and responsibilities
In order to achieve an effective governance structure, roles and responsibilities are allocated as shown below, considering the final goal of establishing and maintaining a set of standards of behaviour that achieve a culture of ethical business practices and compliance with anti-bribery & anti-corruption legal and regulatory requirements:
Governance Committee: Equipped with sufficient authority, expertise and resources and endorsed by the Board of Directors (“Board”), is responsible for the overall oversight of the bank’s anti-bribery & anti-corruption guidance. Periodic updates and material issues reporting, especially those requiring the board’s attention, are made to this committee.
Guidance Leader: With the requisite expertise and authority, the guidance is primarily led by the bank's Compliance Division. The Guidance Leader is assisted, as and when appropriate, by other entities of QIB, such as human capital, risk group, legal, audit, etc. In coordination with the Legal Division, the guidance leader reports to the GCEO, as appropriate, relevant data and status of material internal investigations into alleged corruption/bribery to further assess the effectiveness of the guidance.
Business lines / functions: The bank’s business personnel, officers and staff, who have the primary responsibility for achieving compliance with the established anti-bribery & anti-corruption requirements.
The control structure of the bank’s guidance is periodically verified, reviewed and tested for adequacy by the Internal Audit and Legal Functions of the bank as well as the bank’s external auditors.
Implementing a risk-based approach to mitigation
To help ensure our business is conducted without bribery and corruption, we are committed to:
- Conducting regular risk assessments of our business practices to identify inherent risk, mitigate and control potential bribery and corruption risks.
- Assessing risk and undertaking appropriate due diligence of third parties acting on our behalf to allow us to be satisfied that the third-party is genuine and trusted to conduct business without bribing. This may include terminating relationships in some instances, if and when appropriate.
- Implementing oversight, assurance and audit programs to demonstrate compliance with anti-bribery requirements.
- Ensuring that requests to engage in giving or receiving charitable donations, event sponsorship and gifts, entertainment and hospitality do not lead to unacceptable levels of risk.
- Ensuring that anyone found to be involved in bribery is considered for internal disciplinary action in line with Human Capital’s disciplinary policy.
- Supporting law enforcement and regulatory bodies in any prosecutions by investigating and reporting promptly.
Managing third-party relationships
Relationships with third-party providers can create varying degrees of bribery and/or reputational risks to QIB as well as substantial legal liability. Such risks may include third-party providers making corrupt payments when acting for, or on behalf of the bank, or providing personal benefits to the bank’s employees in return for business mandates that may cause harm to the bank.
To appropriately manage such relations before and throughout the lifecycle of the engagement, QIB has in place certain policies (e.g., Business Service Management, Outsourcing, and Vendor Management) with clear controls to address various risks arising from the procurement of goods and services and the selection of third-party service providers. All management and supervisory personnel are expected to adopt all necessary steps to create a compliant culture within their respective departments and to ensure their staff are aware of their responsibilities and obligations towards QIB.
Training and awareness
QIB’s anti-bribery & anti-corruption, whistleblowing, and related compliance policies and standards are effectively communicated to appropriate employees (e.g. customer/government-facing, vendor managers and relevant control functions) upon joining the bank and thereafter on a periodic basis.
Training and/or communications are also provided to third parties, as might be appropriate, to reinforce their understanding and ensure effective implementation. QIB employees are also provided with all-time access to all company policies and ethical guidelines.
Reporting
QIB provides all employees with the opportunity to report potential bribery in a confidential manner and protects employees from retaliation for good-faith reports. For this effect, a Whistleblowing Policy had been established, with mechanisms for receiving, investigating, and resolving reports of alleged misconduct, including bribery and corruption, and ensuring appropriate confidentiality throughout the process (i.e., a need-to-know basis) as well as compliance with applicable laws and regulations.
When an investigation confirms a violation, appropriate disciplinary measures are taken. Employees who engage in or facilitate bribery, or fail to comply with all applicable anti-bribery and anti-corruption and Conflict of Interest laws, regulations and the bank’s anti-bribery and related policies, may be subject to disciplinary action, up to and including termination.
QIB further reserves the right to terminate immediately any business relationship that violates our high ethical standards and our commitment to responsible finance.
Approvals and review
The Compliance Department has overall responsibility to ensure QIB’s compliance with legal and ethical obligations. QIB supports colleagues who do speak up, and no colleague will be discriminated against in any way for raising an issue in good faith.
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