Title: Announcement Regarding Issuance of Disciplinary Board Resolution No. (36/2021 Disciplinary Board) (16/2021 Authority) and imposition of a fine of (4) thousand Dinars against 1- Al Imtiaz Group Company 2- Shuaib Abdullah Shuaib - RSM Albazie & Co. Office for violating (Clients' Funds and Clients' Assets - Conduct of Business - Corporate Governance).

Announcement Regarding Issuance of Disciplinary Board Resolution No. (36/2021 Disciplinary Board) (16/2021 Authority) and imposition of a fine of (4) thousand Dinars against 1- Al Imtiaz Group Company 2- Shuaib Abdullah Shuaib - RSM Albazie & Co. Office for violating (Clients' Funds and Clients' Assets - Conduct of Business - Corporate Governance).

For the following reasons:

First: Al Imtiaz Group Company:
1. Provision of Item No. (5) of (First / Aspects Related to All Forms of Investment Portfolios), and Item (5) of (Second / Aspects Related to Investment Portfolios in the Management of the Licensed Person) of Article (5-4-1) of Module Seven (Clients’ Funds and Clients’ Assets) from the Executive Bylaws of Law No. 7 of 2010 and their amendments:
The investment portfolio management policy prepared and approved by the Company does not include the following:-
1) A detailed guide to the procedures followed in the event of an error when executing clients' orders for all forms of investment portfolios.
2) Maximum limits for concentrations in the components of the investment portfolio (investment portfolios managed by the Licensed Person), for each type of security, the sector in which it is invested, the country in which it is invested, and the issuer of the security.

2. Provisions of Items No. (5) and (6) of Article (1-4) of Module Eight (Conduct of Business) of the Executive Bylaws mentioned above:
The contracts and agreements concluded with the clients of the Company’s portfolios do not include the following:
a. Procedures followed in the event of an error in executing the client's orders, the mechanism that is implemented to address this error, and the person responsible for it.
b. Departments concerned with making the decisions in favor of the client in the Company.

3. Provision of Item No. (5) of Article (6-3) of Module Fifteen (Corporate Governance) of the aforementioned Executive Bylaws:
The Company’s risk management unit did not submit recommendations to the Board of Directors regarding the deal that the Company concluded with Al Ritaj Investment Company (an associate company owned by 49.81% of Al Imtiaz Investment Group Company) on August 23, 2020, nor did it present or submit the report it prepared to the Board of Directors although it reviewed the deal and prepared a report on the deal on it on August 17, 2020.

Second: - Dr. Shuaib Abdullah Shuaib (RSM Albazie & Co. Office) in his capacity as the external auditor of Al Imtiaz Investment Group Company, for violating the provision of Article (2- 5) of Module Seven (Clients’ Funds and Clients’ Assets) of the above-mentioned Executive Bylaws:
For his failure to ensure that the Company complies with the rules and requirements stipulated in the provision of Item (5) of (First / Aspects Related to All Forms of Investment Portfolios) and Item No. (5) of (Second / Aspects Related to Investment Portfolios Managed by the Licensed Person) of Article (5-4-1) from Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments through his report for the financial year ending on December 31, 2019, as the report did not address the stipulated procedures that the auditor followed when reviewing the policies and procedures for managing the investment portfolios of the aforementioned Company, in addition to the fact that the results he concluded in the report did not address the review of those policies and procedures.

The Resolution included the infliction of the following penalty: -
“First: - Al-Imtiaz Investment Group Company is fined an amount of one thousand Dinars for each violation.
Second: - Dr. Shuaib Abdullah Shuaib (RSM Albazie & Co. Office) in his capacity as the external auditor of the Al Imtiaz Investment Group Company, is fined an amount of one thousand Dinars for the attributed violations.”

In this regard, the CMA emphasizes the implementation of CMA Law and its Executive Bylaws on all persons dealing in securities activities, and urges them to comply with these Laws in order to promote investors' confidence, create a sound investment environment, and implement the Law according to the principles of fairness, transparency, and integrity in line with the best international practice.