CWB has policies and associated training to support all of us in fulfilling our compliance responsibilities and to protect the reputation of the firm. We each need to follow the firm’s risk policies and report any policy breaches. Our main risk policies are summarised below.

• Anti-bribery and corruption – we have a zero-tolerance approach to bribery and corruption and comply with all applicable anti-corruption laws. No one should give or receive any gift or benefit or other advantage in connection with CWB’s business unless it falls within specific permitted exceptions or appropriate approval has been obtained.

• Combating financial crime – breaches of financial crime laws such as sanctions, anti-money laundering or counter-terrorist financing (together “FC”) can lead to criminal liability for individuals and the firm. We should each be familiar with our FC obligations, including any reporting requirements, ensure that we conduct customer due diligence before starting work for new clients, understand the risk profile of our clients and matters, remain alert to key FC risks throughout the duration of our client relationships and matters, and be aware of the jurisdictions or sectors targeted by sanctions. If any of us comes across a FC issue, we should discuss it with the Compliance Officer looking after our office, our Head of Office, or with a member of the firm’s Executive Team.

• Competition and avoiding anti-competitive behaviour – we are prohibited by law from being involved in anti-competitive agreements or conduct. Competition and antitrust laws impose severe penalties upon firms and, in some jurisdictions, impose criminal sanctions upon individuals who violate the laws. We should follow appropriate rules of engagement in discussions with other firms or third-party vendors. In particular, we should not discuss matters such as fees and other terms of engagement, salaries or other terms of employment and vendors’ terms such as pricing.

• Complaints and claims against the firm – if a mistake has been made or a client notifies any of us of a potential negligence claim against the firm, we should immediately inform our Head of Office or a member of the firm’s Executive Team, who will advise on how to proceed.

• Confidentiality and non-disclosure – we must not disclose or make use of any confidential client or CWB information inside or outside the firm other than in the proper performance of our work. Failure to adequately protect confidential information could lead to potential legal and regulatory claims. In some jurisdictions, a breach of professional secrecy rules may also amount to a criminal offence.

• Conflicts and acceptance of new business – we should always clear conflicts for a new client or matter (or a material change to an existing matter) before accepting instructions or commencing work, by undertaking a conflicts check.

• Data protection and information security – we apply high standards to all personal information that we handle and comply with applicable data protection legislation. We are each responsible for the security of the information we handle and must comply with the firm’s Information Security Policy. We should ensure that we treat all personal data appropriately and in accordance with our Privacy Policies.

• Dealing in securities – we are obliged to keep all information about our clients and matters confidential, and not to exploit it for personal gain. Any individual who buys or sells listed securities whilst possessing inside information may commit a criminal offence. We and our family members must not buy or sell listed securities based on information gained from the conduct of our clients’ matters.

• Outside interests – everyone must obtain prior approval if they wish to take on a role outside CWB which does not fall within one of the permitted exceptions (e.g. if you want to provide any services to or become an employee of another organisation, including your own business) since these roles may lead to possible conflicts of interest or liabilities which may impact on the ability of our people to properly perform their roles within the firm.

• Taxation – the firm may commit a criminal offence if tax evasion (under either UAE or local laws) has been enabled by a shareholder, employee or agent of CWB acting on its behalf. A particular risk for CWB is agreeing to invoicing arrangements that enable clients and/or third parties to unlawfully avoid paying taxes on our fees. We must ensure that we follow billing guidelines and correctly apply VAT and withholding tax rules when invoicing clients.

“Our policies and training programs are there to support all of us in fulfilling our compliance responsibilities and to protect the reputation of the firm.”