FractionalFRACTIONAL|DUBAI
Role guide · UAE regulated firms

Fractional Head of Ethics and Integrity for UAE firms

Integrity failures rarely start as headlines. They start as a concern nobody felt safe to raise. A Head of Ethics and Integrity sets the standards, runs the channels for speaking up and makes sure concerns are handled fairly.

Speak upWhistleblowing channels
ConductCode and conflicts
OngoingFractional cover
A Head of Ethics and Integrity listening to a colleague at a small table in a sunlit room
At a glance

The Head of Ethics and Integrity in brief

The senior leader who sets the firm’s standards of conduct, runs its whistleblowing channels and leads an independent response when a concern is raised.

Also searched as: Head of Ethics and Compliance, whistleblowing lead
Regulatory status
Not usually an approved role.
Reports to
The chief executive, with direct access to the board or audit committee chair.
Works closely with
The Head of Compliance, HR, legal and internal audit.
Where it sits
Second line, with independent access to the board.[1]
Typical commitment
Agreed days each month, with more when a concern is raised or an investigation is running.

What the rules say

  • No UAE regulator licenses Head of Ethics and Integrity as a title, so it is not usually an approved role. The work it covers is increasingly required.
  • DIFC firms must have written, effective whistleblowing policies to receive, assess and escalate concerns about regulatory breaches, and must keep records of reports. DIFC law protects good-faith whistleblowers from dismissal or other detriment.[2]
  • ADGM’s Whistleblower Protection Regulations 2024 require every ADGM entity to have arrangements for protected disclosures, with written policies for FSRA-regulated firms.[3]
  • UAE federal AML law protects people who report suspicions in good faith from criminal, civil and administrative liability.[4]
What they do

The speak-up cycle

ISO 37002 sets out how a whistleblowing system should work: make it easy and safe to raise a concern, assess it promptly, address it properly and close it out fairly, while protecting the person who spoke up. The Head of Ethics and Integrity owns that cycle and the code of conduct around it.[5]

What they own

  • Code of conduct and ethics framework
  • Whistleblowing and reporting channels
  • Conflicts of interest
  • Assessment and investigation of misconduct and fraud concerns
  • Remediation of controls
01

Set standards

Write the code of conduct and the policies on conflicts of interest, gifts and hospitality, and make them practical.

02

Receive

Run confidential, accessible channels for raising concerns, including anonymous routes, and acknowledge every report.

03

Assess

Triage each concern quickly and decide whether it needs an investigation, and by whom.

04

Address

Lead or oversee an independent, fair investigation, and protect the reporter from retaliation throughout.

05

Learn

Close each case properly, fix the controls that failed and report themes to the board.

Why it matters

Why a UAE firm needs a Head of Ethics and Integrity

Rarely a regulatory title in its own right, but the work it covers is expected of every well-run firm.

  1. 01

    Speaking up is now a rule

    DIFC and ADGM both require firms to have working whistleblowing arrangements, not just a policy on file.[2],[3]

  2. 02

    Protection has to be real

    Good-faith whistleblowers are protected by law. A firm that lets retaliation happen has a legal problem as well as a cultural one.[2]

  3. 03

    There is a recognised way to do it

    ISO 37002 sets out how a whistleblowing system should work, built on trust, impartiality and protection.[5]

  4. 04

    Conflicts and bribery need an owner

    Codes of conduct, conflicts of interest, and gifts and hospitality are where integrity failures usually begin. ISO 37001 treats them as core anti-bribery controls.[6]

How it works

How a fractional Head of Ethics and Integrity works with us

One brief, one accountable appointment. The person you meet is the person named on the appointment and doing the work.

01

Brief

Tell us where you are regulated, what stage you are at and why the role is needed. We screen the firm and any open regulatory matters before recommending an appointment.

02

Shortlist

We put forward senior candidates with relevant tenure in your role, sector and jurisdiction. You meet the person who will do the work, not a sales lead.

03

Approval

Where the role needs regulatory approval, we help prepare the application and the candidate for the fit and proper assessment. The regulator holds final acceptance.

04

Ongoing

Your appointee works agreed days each month, reports to your board and steps up around licensing, inspections and remediation.

The first 90 days

Days 1 to 30

Listen

  • Review the code of conduct and any whistleblowing policy
  • Check how concerns are raised today, and what happened to past ones
  • Handle any open concern that cannot wait

Days 31 to 60

Build

  • Set up or improve confidential reporting channels
  • Agree an investigation protocol and who does what
  • Refresh the conflicts, gifts and hospitality policies

Days 61 to 90

Launch

  • Communicate the channels and protections to all staff
  • Train managers on receiving concerns
  • Report to the board on themes and next steps
Brief a search for this roleCompare all seven roles
Choosing the model

Fractional, full-time or outsourced?

All three can work. What matters is independence: the person handling concerns must be trusted, senior and free to act.

Fractional
Full-time hire
Outsourced provider
Who does the work
FractionalThe named senior individual you appointed
Full-time hireYour own employee
Outsourced providerA provider’s team, under a named lead
Time commitment
FractionalAgreed days each month, flexing with need
Full-time hireFull time, whatever the workload
Outsourced providerSet by the service contract
Cost basis
FractionalA share of a senior salary, for the time you use
Full-time hireFull salary, benefits, visa and hiring costs
Outsourced providerA service fee, often plus ad hoc charges
Getting started
FractionalNo full recruitment cycle
Full-time hireA full search and notice period
Outsourced providerQuick to contract
Continuity
FractionalStays as long as you need; handover planned
Full-time hireDepends on retention
Outsourced providerStaff may rotate across clients
Best when
FractionalYou need senior, independent ownership of ethics and speak-up without a full-time role.
Full-time hireA large workforce generates a steady flow of concerns and investigations.
Outsourced providerYou want an external hotline alongside an internal owner.
When to engage

Signs it is time

  • A whistleblowing report has been made
  • Misconduct or ethics concerns have surfaced
  • There is no whistleblowing framework in place
  • The board wants independent assurance on culture and conduct
Who we place

What good looks like

Relevant tenure and experience in ethics, integrity or investigations.

  • Experience in ethics, integrity, investigations or employee relations
  • Sound judgement on confidentiality and fairness
  • The standing to investigate senior people
  • A calm, trusted manner with people raising concerns
Brief a search for this role
Related roles

Often appointed alongside

Most regulated firms need more than one of these roles. Each has its own guide.

  1. Head of ComplianceThe senior leader accountable for the whole compliance framework, who oversees the Compliance Officer and MLRO and represents the firm to the regulator.
  2. Head of Financial CrimeThe senior specialist who owns the firm’s defences against money laundering, sanctions breaches, fraud and bribery, and proves they work.
  3. Chief Risk Officer (Head of Risk)The senior leader who identifies and measures the risks the firm runs, agrees with the board how much risk it will take, and reports honestly against that limit.
All seven Risk and Compliance roles
Common questions

Head of Ethics and Integrity, answered

In DIFC and ADGM, yes. DIFC firms must have written whistleblowing policies and keep records of reports, and ADGM entities must have arrangements for protected disclosures under the Whistleblower Protection Regulations 2024. Elsewhere it is good practice, and investors and banks often expect it.

No. Compliance covers regulatory obligations; ethics and integrity covers conduct, conflicts and speaking up. In smaller firms the Head of Compliance may own both.

Yes. Independence often matters more than proximity: an experienced outsider can investigate senior people without the conflicts an insider may have.

Yes. We can place someone to assess the concern, protect the person who raised it and run or oversee a fair investigation.

Brief a compliance search

Need a Head of Ethics and Integrity? Tell us where you are regulated.

We screen why the role is needed, triage any regulatory action and recommend the appointment your risk profile requires.

Brief a search for this role

Sources

  1. [1]The Institute of Internal Auditors, Three Lines Model: Assurance and Advice in Support of Effective Governance (2026).
  2. [2]Dubai Financial Services Authority, DFSA Rulebook, General Module (GEN), GEN 5.4, whistleblowing.
  3. [3]Abu Dhabi Global Market, Whistleblower Protection Regulations 2024.
  4. [4]United Arab Emirates, Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing, Articles 18, 19, 29 and 37.
  5. [5]International Organization for Standardization, ISO 37002:2021 Whistleblowing management systems.
  6. [6]International Organization for Standardization, ISO 37001:2025 Anti-bribery management systems.

Plain-English summaries, reviewed September 2026. Rulebooks change, so always check the current text. Fractional places qualified executives into regulated appointments. We do not provide legal advice, and final acceptance of any appointment rests with the relevant regulator; we work alongside your appointed legal and compliance advisers. Appointments to roles requiring regulatory approval are subject to the relevant authority’s requirements.