CONSUMER PROTECTION REGULATIONS

Presented by
Pijush Kanti Das Powered By
27th Feb 2024 Crowe UAE Academy
 LEARNING OUTCOMES

• Who is a Consumer?
• Why Consumer Protection?
• What are Consumer Rights?
• Fair Consumer Outcomes?
• What are the Consumer Protection Standards?
• Consumer Responsibilities
• A Code of Conduct for Consumer Protection
• Conduct Risk Management
• Penalties

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 WHO IS A CONSUMER?

• A Consumer is a customer
• A Customer is any:
✓Natural Person or
✓Sole Proprietor
• Who obtains or may prospectively obtain Financial Services and/or Products
• with or without charge
• to satisfy his/her personal need or others’ needs.

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 WHY CONSUMER PROTECTION?

• Fair Market
• Improved Standards
• Economic growth
• Active Transaction system
• Unity amongst Consumers
• Ethical Conduct of businesses
• Redressal of Complaints

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 CONSUMER RIGHTS IN THE UAE

• Right to Safety
• Right to Know
• Right to Choose
• Right to be Heard
• Right to Consumer education
• Right to Seek Redressal
• Right to Privacy
• The Right to get Compensation:
• Right to Seek respect for religious values

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 OTHER CONSUMER RIGHTS

• The right to have access to basic Financial services at reasonable prices.

• The right to fair treatment without undue discrimination between another
consumer of the same service.
• The right to be protected against misleading marketing communications and
practices.
• The right not to receive unsolicited electronic communications messages (SPAM)

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 WHY IS CONSUMER PROTECTION IMPORTANT?

Consumers:
• Consumers need to be able to obtain accurate, unbiased information about the
products and services they purchase.
• Enables them to make the best choices based on their interests and prevents
them from being mistreated or misled by businesses.
• Increase consumer welfare by ensuring that businesses can be held
accountable.

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 WHY IS CONSUMER PROTECTION IMPORTANT?

• Businesses that are known to treat consumers fairly will gain a good reputation
and become more sought after
• This increases their profitability and competitiveness which will also lead to
economic growth in the long run
• It also keeps unethical business in check

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 WHY IS CONSUMER PROTECTION IMPORTANT?

• Economic growth and competitiveness

• Consumer protection contributes to dynamic and effective markets for
businesses to grow.
• Consumer demand drives innovation and economic development as businesses
are required to maintain fair prices and good quality of their products and
services.

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 WHY IS CONSUMER PROTECTION IMPORTANT?

• Protection of Consumers
• Stability of the Financial Services industry
• Build Consumer Trust

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 CONSUMER OUTCOMES

Suitability and appropriateness

I have access to quality services that are affordable and appropriate to my
preferences and situation, and I receive advice and guidance appropriate to my
financial situation.

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 CONSUMER OUTCOMES

Choice
I can make an informed choice among a range of products, services, and
providers based on appropriate and sufficient information and advice that are
provided in a transparent, non-costly, and easy-to-understand way.

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 CONSUMER OUTCOMES

Safety and security

My money and information are kept safe. The provider respects my privacy and
gives me control over my data.

Fairness and respect

I am treated with respect throughout my interactions with the provider, even when
my situation changes, and I can count on the provider to pay due regard to my
interests.

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 CONSUMER OUTCOMES

Voice
I can communicate with the provider through a channel that I can easily access
and have my problems quickly resolved with minimal cost to me.

Meets purpose
By accessing and using products designed and delivered in accordance with the
principles outlined above and by getting the services I need, I am in a better
position to increase control over my financial life, to manage a shock, or to attain
other goals.

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 10 PILLARS OF CONSUMER PROTECTION STANDARDS

1. Disclosure & Transparency

2. Institutional oversight

3. Market conduct

4. Business Conduct

5. Data protection

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 10 PILLARS OF CONSUMER PROTECTION STANDARDS

6. Complaints management

7. Financing/lending practices

8. Financial Education

9. Financial inclusion

10. Islamic banking

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 DISCLOSURE AND TRANSPARENCY

• Disclosure is the process of making facts or information known to the Consumer.

• Transparency is the timely disclosure of information, that is clear and
understandable
• Responsible Advertising& Marketing

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 DISCLOSURE

• Quality, accuracy, completeness, and effectiveness of the information provided to

Consumers are fundamental to an open, transparent, and competitive Market.
• Consumers must be proactively provided with all the information necessary to
make an informed decision regarding Financial Products and/or Services.

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 TRANSPARENCY

• Transparency is positive conduct, which complements Disclosure.

• Transparency goes beyond the simple act of disclosure regarding a product
and/or service provided to a Consumer.
• It means that Licensed Financial Institutions must proactively provide useful
information and advice in the Market.

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 RESPONSIBLE ADVERTISING & MARKETING

• Advertising and marketing can utilize multiple channels to access the public for
the promotion of a Licensed Financial Institution and its Products and/or
Services.
• Advertising issued by Licensed Financial Institutions must not be deceptive,
misleading, fraudulent or unfair and must be easily understandable by a
Consumer.
• All text and numbers must be clearly visible and understandable.

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 INSTITUTIONAL OVERSIGHT

Consumer Protection Framework is effectively implemented by :

✓establishing an appropriate organizational structure
✓a supportive and constructive corporate culture
✓engaging well-qualified staff
✓defining clear policies and procedures
✓creating proper monitoring and controls supported by proper overall governance.
The principle is to promote positive institutional conduct in serving all Consumers
fairly.
A Conduct Risk Management framework must be established

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 MARKET CONDUCT

Responsible Market Conduct

✓Must uphold the integrity of the financial market through responsible Market
activities that contribute to the overall stability of and confidence in the financial
system.
✓Must sell and provide Consumers with appropriate products and/or services
Promoting Competition
✓By improving the freedom of choice through transparency,
✓Eliminating unreasonable and unfair barriers to competition, and
✓Requiring access to comparative information on products and/or services.
✓Avoiding collusive practices

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 BUSINESS CONDUCT

Responsible Business Conduct

✓Responsible business conduct is based on the internal culture and behavior
✓Appropriate Business conduct instills a culture of integrity and ethics in its
services and activities
✓product design, development, promotion, sales, distribution
✓minimizing Conflict of Interest and Consumer risks
✓ improving the financial well-being of its Consumers.
Fair Treatment of Consumers
✓address the gap between the level of the public’s financial literacy and the
complexity and risks of the Financial Products and/or Services being offered.

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 PROTECTION OF CONSUMER DATA AND ASSETS

Consumer Data Protection

• Protect Consumers’ Data and ensure their confidentiality.

• Data Minimization
• Protection of Consumer Assets, Information and Data against Financial Crimes,
Misappropriation and Misuse
• Sound and effective management and business practices for security within the
first line of defense.
• Make appropriate efforts and investments to stay on top of these risks and make
use of the latest technology and solutions to protect Consumer assets and Data.

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 RESPONSIBLE FINANCING PRACTICE

• Financing must be provided responsibly to protect Consumers, prevent over-

indebtedness, and support economic stability.

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 COMPLAINT MANAGEMENT AND COMPLAINT RESOLUTION

Complaint Management and Complaint Resolution

✓Transparent with Consumers and operate in a fair, honest, and competitive manner.
✓must have in place a fair, accessible, and transparent process provided without charge for
addressing Complaints with Consumers that are resolved promptly.
Complaint and Inquiries Management Data
✓Data collected on Complaints and inquires is a critical source for analysis that can improve a
Licensed Financial Institution’s overall conduct as well as problems with its product offering.
✓Prompt analysis of trends helps to identify deficiencies in Licensed Financial Institutions’ sales
practice, business conduct, and product design and system defects.

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 CONSUMER EDUCATION AND AWARENESS

• Financial education and awareness must play an important role in the Consumer
protection framework.
• Financial education can help to reduce the risk exposure of Consumers by
enabling them to make financial decisions that are in their best interests.
• The collaboration between the Central Bank and Licensed Financial Institutions
to expand efforts to increase awareness will help to mitigate risks to Consumer
and aid Consumers in making informed financial decisions.

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 Financial Inclusion

Inclusion

✓To be able to fully participate in society and the financial market, access must be
inclusive.
✓Consumers including vulnerable groups and People of Determination must have
access to Financial Products and/or Services,
✓ Minority Groups have differing financial needs.
✓Licensed Financial Institutions have a responsibility to ensure there is
appropriate access to their products and/or services for Minority Groups.

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 SHARI’AH COMPLIANCE FOR FINANCIAL SERVICES

• Given the critical significance of Shari’ah compliance in the Islamic finance

business, Islamic Institutions the State must strive for the best international
standards by incorporating Shari’ah principles in all aspects of their business
comprised of operational, reporting, business conduct, risk management and
oversight functions.

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 DISCLOSURE & TRANSPARENCY

Standard applies to
✓All Financial Products and services
✓Through all communication channels of service including branches, telephone
banking, mobile applications, internet banking and all other channels.
✓Arabic and English
✓At all branches
✓Accessible in a format requested by people of determination
✓Assess the most suitable format
✓Information must be in clear and plain language

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 DISCLOSURE & TRANSPARENCY

• use official documents for all transactions

• the name of your Bank must be accurately displayed in the documents.
• State that it is Licensed by CBUAE
• must clearly and prominently display the full legal/trade name on the main
signage of the licensed premises, websites, letterheads, business cards,
transaction receipts, and all other marketing/branding materials.
• When giving Advice of any kind, they must not make statements that are untrue,
misleading, or omit information that is necessary to understand the nature, costs,
risks, terms, and conditions of the Financial Products and/or Services

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 DISCLOSURE & TRANSPARENCY

• Schedule for Fees, including Third Party Fees, must be clearly on display in all
branches and on the Licensed Financial Institution’s website.
• Provide consumers with a Key Facts Statement prior to providing a Financial
Product and/or Service or on the Consumer’s request.
• Prior to signing the contract, the Consumer must sign to acknowledge receipt of
a Key Facts Statement for the product or service being purchased.

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 KEY FACTS STATEMENT

• For each product or service

• Stand-alone document
• Concise & Plain language
• Accurate description of each Financial Product and/or Service;
• Specify whether the Licensed Financial Institution reserves the right to change
terms and conditions at a later date/ Specify the notice period
• Specify, as applicable,, Fees, key terms & conditions, key obligations, limitations
and key requirements
• Use “Warning” boxes to highlight key risks

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 INFORMATION TO BE PROVIDED AT ALL STAGES OF
CUSTOMER LIFECYCLE

Provide appropriate information to the potential and existing Consumer at all

stages of the relationship.

✓Prior to providing a Financial Product and/or Service

✓At point of entering the contract:
✓During the term of the contract:

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 WHAT IS TRANSPARENCY?

Transparency is giving information in a way people understand very easily

✓Provide competent Advice that is sound, constructive, and understandable

✓Advise Consumers of all reasonable options, substitutes, and choices available from
the LFI based on Consumer needs;
✓Eliminate the use of fine print and legal jargon
✓Correspond in clear and plain language;
✓ Explain the full impact of any risks, key restrictions, and obligations;
✓Negative impact of interest rates/profit rates Exchange rate fluctuations
✓Information must be timely, up-to-date, and provided at each stage of the contractual
process

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 WHAT IS TRANSPARENCY?

• Providing Comparative Information/Options

• LFI must not deliberately withhold or conceal the existence of reasonable
alternative Financial Products and/or Services that may be appropriate to the
Consumer including those with lower costs, financing rates and Fees.
• Advertising-Be accurate, honest and understandable and not be misleading or
contrary to actual factual information.

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 MARKET CONDUCT

• Protect consumers – securing an appropriate degree of protection

• Protect financial markets – protect and enhance the integrity of the UAE financial
system
• Promote competition – promote effective competition in the interests of
consumers

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 MARKET CONDUCT

• Appropriate Market Conduct

• Encourage Consumers’ trust in the safety and the integrity of the financial
marketplace, LFIs must conduct themselves with integrity and in a fair, honest,
competent and transparent manner at all times.
• Appropriate location for carrying out Business
• Qualified Retail Staff-No previous record, qualifications are tested-appropriately
qualified and fit-and-proper
• Disclosure of Employer
• Sales, Pricing and Financial Promotional Activities
• Monitoring of Market Conduct by Management

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 MARKET CONDUCT

Promote Competition-absence of collusion

✓Setting currency and foreign exchange Fees, spreads and rates
✓charge maximum allowable Fees regardless of differences in actual costs
• Promoting Consumer Mobility in the Marketplace

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 BUSINESS CONDUCT

• Culture of integrity and ethics

• Minimizing Conflict of interest & Consumer risks and conduct risks
• improving the financial wellbeing of its Consumers
• must act, with due skill, care and diligence, fairly, honestly and professionally
• Internal Code of conduct
• Provide Training
• Monitoring complaints

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 BUSINESS CONDUCT

• Staff who directly interact with Consumers

• Competently, efficiently and professionally discharge their duties
• provide prospective and existing Consumers with the information and services
they are entrusted to provide or sell.
• Have sufficient knowledge of products and/or services required to help and
educate Consumers
• Have the professional qualifications at all times necessary to provide Advice and
carry out transactions.
• Avoidance of mis-selling, unreasonable risk-taking, Conflict of interest and other
irresponsible behavior

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 BUSINESS CONDUCT

• must not adopt abusive or unreasonable contractual terms.

• monitor for misleading or aggressive sales practices and exploitation of
Consumers due to their vulnerabilities, apathy or lack of knowledge.

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 BUSINESS CONDUCT

• All Consumers must be treated equitably, honestly and fairly at all stages of their
relationship with Licensed Financial Institutions.
• Customers rights and obligations to be explained
• must not restrict Consumer’s choices, such as tied selling and bundling of
products and/or services
• LFIs must not benefit from their Errors. Errors must be rectified without undue
delay upon identification. Consumers affected by an Error must be immediately
informed in writing of the cause, impact and rectification of Errors
• prohibit undue and coercive pressure on Consumers in collection of
repayments/payments or debts due.

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 PROTECTION OF CONSUMER DATA AND ASSETS

• Licensed Financial Institutions must have policies, procedures and control

frameworks regarding the collection, protection, confidentiality and authorized
use of Consumers’ Data.
• Consumers must be informed in Writing with respect to how their personal
information will be processed, e.g. collected, used, disclosed, Data mined and
profiled.
• LFIs must advise Consumers regarding any directed and repeated attempts of
online fraud on their accounts for the Consumers to take additional precautions.
• LFIs must provide employee training and awareness programs on their Data
control framework for accessing and handling Consumer Data and reporting
security and policy breaches.

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 PROTECTION OF CONSUMER DATA AND ASSETS

• LFI must promote the importance of protecting Consumer’s Data as an ongoing

responsibility of Staff with reminders sent on an annual basis
• Control of Access rights-maintain logs for access
• Data must be collected:
✓for a lawful purpose
✓Adequate and not excessive(Data Minimization)
✓with appropriate security and protection measures against unauthorized or
unlawful processing and accidental loss, destruction, or damage.
• Disclosure regarding sharing consumer’s personal Data
• Consumer must give free consent

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 PROTECTION OF CONSUMER ASSETS

• LFIs must put in place strict internal controls to effectively protect Consumers’
deposits, savings, funds held by stored value facilities and other assets as well
as Consumer information and Data, against internal frauds.
• Licensed Financial Institutions must apply sufficient resources to be able to
detect both external and internal frauds quickly and ensure they are fully
addressed with future prevention measures.
• Licensed Financial Institutions must compensate Consumers in a timely manner
for financial losses and expenses resulting from Financial Crimes,
misappropriation, cyber-attacks and misuse of assets and information unless it
can be proven that the loss was due to the gross negligence or fraudulent
behavior of the Consumers.

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 PROTECTION OF CONSUMER ASSETS

• must demonstrate they have carried out sufficient Consumer awareness activities
related to educating Consumers of the need to protect themselves from Financial
Crime

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 COMPLAINT MANAGEMENT AND COMPLAINT RESOLUTION

• a fair, accessible and transparent process provided without charge for addressing
Complaints with Consumers and that are resolved in a timely manner.
• Independent Complaint management system with independent Policies and
procedures.
• LFIs must ensure Consumers are aware of their rights when they seek to resolve
their problems through complaints
• Time frames for addressing complaints must be adhered to
• Training of staff for handling complaints
• Inform consumer about complaint resolution process

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 COMPLAINT AND INQUIRIES MANAGEMENT

• Data collected on Complaints and inquires is a critical source for analysis that
can improve a Bank’s overall conduct as well as problems with its product
offering.
• Prompt analysis of trends help to identify deficiencies in Licensed Financial
Institutions’ sales practice, business conduct, and product design and system
defects.
• establish standards for Complaint and inquiry Data to be gathered, collected,
classified, stored, analyzed and reported

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 RESPONSIBLE FINANCING

• Financing must be provided in a responsible manner to protect Consumers,

prevent over-indebtedness, and support economic stability.
• Obtain credible and independent information regarding the financial situation of
the Consumer requesting financing.
• Assess the related financial obligations, dependencies, capabilities and needs of
their Consumers before agreeing to provide them with a financing product,
Advice or service.
• Must ensure at the time of granting of Credit, the Credit does not cause over
indebtedness and/or undue financial burden on the Consumer.
• Must not charge unreasonable fees.

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 RESPONSIBLE FINANCING

• Must not provide excessive Credit beyond amounts of Credit that the Consumer
requires and / or that is reasonable, affordable and suitable for the Consumer’s
needs
• Must apply proper criteria in the method for carrying out due diligence and stress
testing for the affordability and suitability of a Credit product for the Borrower /
Financee.
• Must not grant or extend any form of Credit without expressed and documented
consent by the Consumer.
• Staff incentivization programs should not encourage excessive credit
granting/monitor credit granting by sales representatives

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 CONSUMER EDUCATION AND AWARENESS

• LFIs should work together to raise public awareness of the types of banking
services and financial products and their inherent risk through all means of
communications and media
• Financial education and awareness must play an important role in the Consumer
protection framework.
• Financial education can help to reduce the risk exposure of Consumers by
enabling them to make financial decisions that are in their best interests
• Must set up a Consumer Education and Awareness(CEA) function

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 FINANCIAL INCLUSION

• Vulnerable Consumers are Consumers who, due to their personal circumstances,

are particularly susceptible to abuse, discrimination and harm, especially when
Licensed Financial Institutions do not act with appropriate levels of fairness and
due care.
• Vulnerable Consumers normally encompass low-income, Minority Groups,
People of Determination or any other disadvantaged groups.
• Licensed Financial Institutions must demonstrate to the Central Bank their
compliance with the provisions of Federal Law No. (29) of 2006
• Licensed Financial Institutions must ensure vulnerable Consumers have access
to services provided by Licensed Financial Institutions on equivalent terms with
others Consumer.

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 FINANCIAL INCLUSION

• Licensed Financial Institutions must incorporate anti-discrimination principles into

their internal code of conduct
• LFIs must, with due skill, care and diligence, act fairly, honestly and
professionally in their relationship with all Consumers, regardless of their religion,
gender, age, income level, and marital status.
• Public information must be suitable to vulnerable groups
• LFIs should ensure branches and points of services used for public access and
ATMs can accommodate the needs of vulnerable Consumers.
• LFIs must establish and implement a procedure to annually train Staff to provide
service equally regardless of family status, gender, Minority Group status or age
of Consumer
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 CASE STUDY: STARBUCKS

• On April 12, 2018, at a Starbucks location in Philadelphia, two black men,

Rashon Nelson and Donte Robinson, were waiting for a friend, Andrew Yaffe.
• Nelson and Robinson were entrepreneurs and were going to discuss business
investment opportunities with Yaffe, a white real estate developer.
• As they waited, an employee asked if she could help them. They said “no,” that
they were waiting for a business meeting. Then a manager told Nelson that he
couldn’t use the restroom because he was not a paying customer.

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 CASE STUDY: STARBUCKS

• Because the two black men had not purchased anything yet, a store manager
called the police.
• At least six Philadelphia Police Department officers arrived. The police officers
did not ask the men any questions; they just demanded that they leave
immediately. They declined. The police officers then proceeded to arrest the men
for trespassing.
• The two men were taken out in handcuffs. They were taken to the police station,
photographed, and fingerprinted. They were held for almost nine hours before
being released from custody because there was no evidence.

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 CASE STUDY:STARBUCKS

• After a video of the arrest went viral, Starbucks CEO Kevin Johnson released a
statement:
• “We apologize to the two individuals and our customers and are disappointed this
led to an arrest.
• We take these matters seriously and clearly have more work to do when it
comes to how we handle incidents in our stores.
• We are reviewing our policies and will continue to engage with the community
and the police department to try to ensure these types of situations never happen
in any of our stores.”
• Johnson then announced that every company-owned Starbucks location in the
nation would close on May 29, 2018, for “racial-bias education.

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 CONFLICTS WITH OTHER REGULATIONS

• If these Regulations conflict with any other Regulation , then these Regulations
prevail

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 WELL FARGO- CASE STUDY

• Beginning in the early 2000s, corporate managers at Wells Fargo bank began
pressuring branch employees to engage in aggressive “cross-selling” –
marketing multiple financial products such as bank accounts, credit cards, or
overdraft protection services to customers.
• Employees faced sales quotas, many of which were nearly impossible to meet,
and they were regularly hounded over their progress.
• The failure to meet these quotas carried dire consequences: official reprimands
and even dismissal.

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 WELL FARGO- CASE STUDY

• The predictable result of this relentless pressure was that many of the bank’s
employees resorted to unethical practices to meet their impossible quotas.
• They sold their clients products they did not need or could not afford.
• When even that was not sufficient to satisfy management’s expectations, they
set up accounts, credit cards, monitoring programs, or loans for clients without
their knowledge or permission.
• In many cases, the bank’s retail salespeople carried out these fraudulent
activities with the approval, and even the encouragement, of supervisors

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 WELL FARGO- CASE STUDY

• These fake accounts caused massive harm to affected Wells Fargo customers,
especially lower-income account holders. The bank admitted to cheating
customers out of nearly $11 million in improper charges related to the fake
accounts, though the total damages are likely far higher.

• Which of the Pillars of Consumer Protection Standards were absent??

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 CONSUMER RESPONSIBILITIES

1. Be honest with the information you provide - Always give full and accurate information when
you are filling in any bank documents. Do not give false details or leave out important
information.

2. Carefully read all information provided by your Bank-When you submit your application, you
should receive full details on the obligations for your service. Make sure you have access to the
details of your obligations, that you understand them, and that you can comply with them.

3. Ask questions - It is important to ask questions to Bank employees about anything that is
unclear or a condition that you are unsure about. The staff will answer any questions in a
professional manner to help you in your decision-making.

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 CONSUMER RESPONSIBILITIES

4. Know how to make a complaint - You can be proactive in using this service and know how to
escalate your issue to higher levels, if appropriate. Your Bank will provide you with details on how
to complain and the timeframe for their response.

5. Use the product or service in line with the terms and conditions.

6. Avoiding risk: Do not purchase a product or service where you feel that the risks do not suit
your financial situation. Some financial products or services carry risks, and your Bank should
clearly explain these to you.

7. Apply for products and/or services that meet your needs- When requesting a product or
service, you should make sure that it suits your needs.

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 CONSUMER RESPONSIBILITIES

8. Do not disclose your financial information. Under no circumstances should you provide any
bank account details or other sensitive personal or financial information to any other party.

9. Updating information - You should update your personal information, including contact
information so that it is updated continuously and also when so requested by the bank. You are
responsible for failing to provide all relevant information to the Exchange House.

10. Your mail address - Use your own mail address (regular mail and e-mail) when giving contact
details to your bank. Do not use other friends’ or relatives’ mail addresses which can expose your
financial information to others.

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 CONSUMER RESPONSIBILITIES

11. Power of Attorney - Be careful when dealing with ‘Power of Attorney’. Know what information
that you are giving access to and to whom you are giving power over your financial matters.

12. Do not sign uncompleted forms - Make sure all of the required fields and numbers are
completed in a form that is presented to you for signing or initialing. Do not sign empty or partially
completed forms.

13. Review all of your documents - Review all of your documents before you sign them to ensure
no errors are made in the account number or amount. Your signature is an approval and agreement
of the document content.

14. Keeping copies of your documents

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 CODE OF CONDUCT

• We treat consumers fairly-We do not engage in illegal, fraudulent, unethical or

unfair business practices that can harm consumers.
• We uphold our responsibilities. We value consumer rights
• We comply with laws and regulations

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 CODE OF CONDUCT

• We ensure quality and safety.

• We communicate honestly and truthfully-We provide easily accessible, complete
and correct information about our services, and adhere to fair advertising and
marketing practices.
• We are transparent about our costs. We are open about the prices we charge
and do not hide any additional costs

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 CODE OF CONDUCT

• We keep proper records of purchases. We provide complete records of the

services purchased and have them delivered in the promised time.
• We offer options for cancellation-We allow consumers to review their transaction
before making the final purchase, and to withdraw from a confirmed transaction
in appropriate circumstances.

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 CODE OF CONDUCT

• We take consumer complaints seriously-We have a fair and transparent system

to address complaints and provide appropriate compensation.
• We keep private information private. We actively protect the privacy of
consumers, and ask for permission if we collect, use or share personal data.
• We make sure online payments are safe-We safeguard sensitive data by
choosing the appropriate secure technology and protocols, such as encryption or
SSL, and display trust certificates to prove it.

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 CODE OF CONDUCT

• We avoid online spamming - We allow consumers to choose whether they wish

to receive or opt out from commercial messages by e-mail or other electronic
means.
• We do not produce fake online reviews - We do not restrict the ability of
consumers to make critical or negative reviews of our services.
• We educate consumers about financial and cyber risks.

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 CONDUCT RISK MANAGEMENT

• Conduct risk is the risk of behavior, action or omission by individuals employed

by, or on behalf of, the Exchange or taken collectively in representing the
Exchange that may have a negative outcome for clients, counterparties, the
communities and markets in which the Exchange operates, our staff, or the
Exchange

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 CONDUCT RISK MANAGEMENT

Such behaviors, actions, or omissions may include:

✓breaches of laws or regulations
✓disregard for principles of What the Exchange Stands For or the Code of
Conduct
✓negligence and/or a lack of reasonable care and diligence
✓failure to escalate improper conduct
✓inadequate product design and distribution.

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 MANAGE CONDUCT RISK THROUGH CONTROLS

• The Exchange has a range of controls and processes in place to identify and
manage conduct risk, including:
✓new and emerging conduct risks are identified through the annual strategy and
business planning process

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 MANAGE CONDUCT RISK THROUGH CONTROLS

• Conduct risks that may arise when the Exchange establishes a new business or
product, or makes a significant change to an existing business, product, process
or system are identified and assessed through the new business and product
approval process

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 MANAGE CONDUCT RISK THROUGH CONTROLS

• the Risk and Control Self-assessment requires businesses to identify and assess
their key conduct risks
• supporting the efficient operation of markets through appropriate controls and
monitoring

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 MANAGE CONDUCT RISK THROUGH CONTROLS

• independent monitoring and surveillance conducted by RMG, in addition to front-

line supervisory activities performed by the business
• where incidents occur, the underlying contributing behaviors are investigated,
and the root cause of the incidents recorded

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 MANAGE CONDUCT RISK THROUGH CONTROLS

• an Integrity Office that is an independent point of contact for staff to safely raise
concerns about misconduct, unethical behavior or breaches of the Code of
Conduct, and protects those who raise concerns under Whistleblower Policy
• a global Staff Hotline for staff who wish to speak up anonymously

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 CONDUCT RISK APPETITE

• The Exchange is committed to fair outcomes for clients and preserving the
integrity of financial markets.
• Exchange therefore seek to minimize the conduct risk that arises, or could arise,
while doing business.
• This risk appetite is reflected in the design and delivery of products and services,
governance and procedures, and the client-driven culture and behaviors they
foster.

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 ENFORCEMENT AND SANCTIONS

• Violation of any provision of this Regulation and the accompanying Standards

may be subject to supervisory action, sanctions and penalties as deemed
appropriate by the Central Bank.

• Without prejudice to the provisions of the Decretal Law, supervisory action and
sanctions by the Central Bank may include fines, replacing or restricting the
powers of Senior Management or Members of the Board

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 Questions &
Answers
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 Answer the Quiz Your feedback is important
for us

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© 2023 Crowe Academy Professional and Management Training
 Pijush Das
Director – Training and Development

Crowe Academy Professional and Management Training

Level 7, The Prism, Business Bay PO Box 6747, Dubai, UAE

+971 4 447 3951

+971 55 385 9021

pijush.das@crowe.ae

Crowe Global is a leading international network of separate and independent accounting and consulting firms that may be licensed to use "Crowe," or “Crowe Mak" in connection with the provision of accounting, auditing, tax, consulting or other professional services to their clients. Crowe Global itself is a non-practicing entity and does not provide professional services in its own right. Neither
Crowe Global nor any memberis liable or responsible for the professional services performed by any other member.

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