The UAE has no general private-sector whistleblower statute of the kind found elsewhere, so **the protection here is what the employer commits to and demonstrates**. In a workforce where residence depends on employment, a policy that does not address the fear of retaliation directly will not be used — and silence will be read as the absence of a problem.
Speaking Up
Reporting wrongdoing and how we respond
The UAE has no general private-sector whistleblower statute of the kind found elsewhere, so the protection here is what the employer commits to and demonstrates. In a workforce where residence depends on employment, a policy that does not address the fear of retaliation directly will not be used — and silence will be read as the absence of a problem.
| Item | Detail |
|---|---|
| Organisation | [COMPANY NAME], [licence] [NUMBER] |
| Applies to | Employees, contractors, agency staff, suppliers |
| Report to | [NAME], [EMAIL], [PHONE] |
| Alternative, outside management | [NAME / external line] |
| Anonymous reporting available | [Y/N — how] |
| Languages available | [LIST] |
| Approved by | [NAME], [DESIGNATION], on [DATE] |
| Reviewed | Annually |
1. What to Report
| Category | Examples |
|---|---|
| Financial wrongdoing | Fraud, theft, false accounting, misuse of company funds |
| Bribery and corruption | Payments to officials, kickbacks, facilitation payments |
| Employment breaches | Wage non-payment, charging candidates fees, passport retention, permit contraventions |
| Fictitious employment | Names on the file who do not work — including for quota purposes |
| Safety | Unsafe practices, midday ban breaches, unreported injuries |
| Data | Unauthorised access, disclosure, unreported breaches |
| Tax and regulatory | False filings, unrecorded transactions, evasion |
| Harassment and discrimination | Also covered by the respect at work policy |
| Sanctions and money laundering | Including suspicion of it |
| Concealment of any of the above | Including pressure not to report |
1.1Report a genuine concern even if you are not certain. You do not need proof, and you will not be penalised for raising something that turns out to be mistaken, provided you acted honestly.
1.2A personal grievance about your own employment goes through the grievance procedure instead — both routes exist and neither is a lesser option.
2. Our Commitments
2.1We will not retaliate against anyone who raises a genuine concern. No dismissal, no visa cancellation, no reduction in hours, no transfer, no exclusion.
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The UAE has no general private-sector whistleblower statute of the kind found in some jurisdictions. That makes the employer’s own commitment, and its visible behaviour, the whole protection. A policy nobody believes is worse than none, because it establishes that the organisation knew what it should be doing.
Where residence depends on employment, the fear that reporting costs you your status is the single reason these policies go unused. Say plainly that it will not, and back it with the arbitrary dismissal point so the commitment has something behind it.
Dismissal because an employee raised a legitimate complaint may amount to arbitrary dismissal with compensation of up to three months’ salary in addition to everything else. That is worth stating — it tells employees the protection is not purely discretionary.
Nothing in the policy, the contract, an NDA or a settlement agreement should appear to prevent reporting to a regulator or authority. A confidentiality clause that seems to suppress reporting is objectionable and may be unenforceable.
Where a senior person is implicated, an investigation conducted by someone answerable to them is not an investigation. Use an external investigator or an uninvolved director, and be seen to do so.
Anonymous reports cannot be clarified, the reporter cannot be kept informed, and they cannot be protected from retaliation nobody knows about. Accept them, take them seriously, and explain why identifying yourself to one named person is better.
Dates, amounts, documents and systems can be investigated. A general allegation usually cannot. Say so in the policy so reporters know what helps.
Retaliation typically starts quietly once attention moves on — reduced hours, exclusion, a poor review. Scheduled follow-up at four and twelve weeks catches it, and its absence is why reporters say speaking up made things worse.
Systems, records and access logs need preserving before anyone is alerted or anything is cleared. Investigations announced before evidence is secured routinely find that the relevant material has gone.
However serious the finding, any disciplinary penalty must be one the Law permits. An invented sanction creates a claim even where the wrongdoing was proven — the employer then loses on the remedy rather than the facts.
Money laundering suspicion for a designated business means a goAML report, and tipping off is a criminal offence. Data breaches, work injuries and tax irregularities each carry their own routes. Take advice early — proactive disclosure is treated very differently from discovery by the authority.
Where an internal report reveals names on the file who do not work, including arrangements made to meet a quota, the exposure runs to substantial penalties and criminal liability. This is not an internal matter to be quietly corrected.
A speak-up policy circulated only in English to a multilingual workforce has been distributed, not communicated. Translate it, and accept reports in those languages.
One report is an incident; the same area, team or individual recurring is a pattern that no individual investigation reveals. A quarterly review also checks whether the corrective actions actually happened.
Reflects UAE law and practice current as of {{DATE OF USE}}. Arbitrary dismissal provisions, permitted disciplinary penalties, AML reporting obligations for designated businesses, data breach notification and the MOHRE complaint process all change — confirm the current position and take legal advice where a report reveals conduct that may need to be disclosed externally.
This is a ready-to-use template provided for convenience. Laws and requirements change, and every situation is different — please have it reviewed by a qualified professional (a lawyer, corporate secretary, or accountant as relevant) before you rely on it.