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Friday, April 24, 2026

ADGM publishes Guiding Principles on Whistleblowing - Lexology

Introduction

On 6 December 2022, the Abu Dhabi Global Market (“ADGM”) published its “Guiding Principles on Whistleblowing” (the “Guidance”), setting out aims, objectives and best practice for its 55,000 registered companies to consider as part of their own whistleblowing frameworks.

Mr Emmanuel Givanakis, the CEO of the Financial Services Regulatory Authority (“FSRA”) of the ADGM, described the purpose of the Guidance as being to encourage “…all ADGM entities to review and align their own whistleblowing programs in line with these guidelines”. 1 In doing so, the ADGM and the FSRA are continuing to highlight their message that transparency and corporate accountability are hallmarks of good governance and risk management.

The Guidance comes nine months after the Dubai Financial Services Authority (“DFSA”) published its own Whistleblowing Regime, 2 which made changes to the DIFC Regulatory Law 2004 to enhance legal protection to whistleblowers under its jurisdiction in the Dubai International Financial Centre. It also follows the introduction by the UAE Central Bank in 2021 of a whistleblowing portal to allow employees and external stakeholders to report concerns around misconduct by any of the Central Bank’s employees or contractors. 3

Unlike the DFSA’s Whistleblowing Regime, the FSRA have opted against issuing legally binding provisions and instead intends for the Guidance to complement the ADGM’s existing regulatory framework. However, given the level of detail in the...



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