Ethics and anti-corruption

Private sector appointments

When and how may former government employees take up appointments in the private sector and vice versa?

There are no restrictions relating to former government employees joining the private sector or former private sector employees joining government entities.

Addressing corruption

How is domestic and foreign corruption addressed and what requirements are placed on contractors?

There is no specific law in Qatar governing corruption. However, the Qatar Penal Code (Law No. 11 of 2004) includes provisions relating to the bribery of public officials, which is widely defined to include employees and those working in ministries, other government agencies, authorities and public institutions as well as:

  • arbitrators, experts, administrators, liquidators and receivers;
  • chairmen and members of the board of directors and all other employees in private institutions and associations, cooperatives and companies if one of the ministries, or other government agency, authority or public institution is a shareholder therein;
  • anyone who carries out work relating to public service upon instructions from a public official; and
  • chairs and members of legislative committees and the municipality committees and others who have a public representative type role whether appointed or elected.

Additionally, government entities, including ministries and other authorities (with some exceptions), as well as companies in which the government holds a majority shareholding, private institutions for public benefit and pensions funds are subject to the supervision of the State Audit Bureau. Pursuant to Law No. 11 of 2016, the State Audit Bureau has the right to review the accounts of entities subject to its supervision and to prosecute the perpetrators of any financial irregularities.

The provisions of the Qatar Tender Law No. 24 of 2015, which apply to all government ministries and other public institutions (with certain exceptions), provide for a contract awarded to a contractor being void if it is proven that the contractor used fraud or manipulation in obtaining or performing the contract or if it is proven that the contractor either directly or indirectly bribed a government official.

There are no provisions relating to foreign corruption. However, Qatar has ratified the United Nations Convention against Corruption and the 2010 Arab Convention for Fighting Corruption, which include definitions of foreign public officials (ie, public officials who may be in Qatar but exercising the function on behalf of a foreign country). However, there are no specific provisions reflected in domestic law.


What are the registration requirements for lobbyists or commercial agents?

Generally, any person undertaking business activities in Qatar needs to be licensed by the Ministry of Economy and Commerce and various other agencies. In addition, commercial agencies in Qatar fall into two categories. There is a category of registered agents that are governed by the Commercial Agencies Law (Law No. 8 of 2002: Registered Agencies) and unregistered agencies that are governed by the Commercial Code (Law No. 27 of 2006: Unregistered Agencies). Registered agencies must be registered at the Ministry of Economy and Commerce. There may be internal rules and practices within government departments that require that only ‘approved’ intermediaries be used.

Limitations on agents

Are there limitations on the use of agents or representatives that earn a commission on the transaction?

There are no such limitations in laws. However, internal rules and practices within government departments may impose such limitations.

The general position under Qatar law is that the parties are free to contract and as such there are no restrictions on the amounts to be paid. However, the law governing registered agencies imposes a limit on commission received. Such commission must be restricted to 5 per cent of the value of the goods sold.