WHISTLEBLOWING PROCEDURE

1. Purpose

This procedure establishes a clear, secure, and confidential framework for reporting suspected misconduct, including bribery, corruption, fraud, and violations of laws or company policies.

2. Scope

This procedure applies to:

• All employees (permanent, temporary, and contract)

• Directors and management

• Contractors, consultants, vendors, and business partners

• Any external party interacting with the Company

3. Reportable Matters

The following matters should be reported:

• Bribery or corruption

• Fraud or financial misconduct

• Conflict of interest

• Abuse of power or authority

• Breach of Company policies or legal requirements

• Any unethical or improper conduct

4. Reporting Channels

Reports may be made through any of the following channels:

• Email: [Insert official email address]

• Telephone: [Insert contact number]

• Written Submission: Addressed to the Compliance Officer or Management

• In Person: Direct reporting to the designated officer

The Company shall appoint a Whistleblowing Officer or Compliance Officer to receive and manage all reports.

5. Confidentiality

All reports will be handled with strict confidentiality. The identity of the whistleblower will be protected to the fullest extent possible, unless disclosure is required by law.

Anonymous reporting is permitted; however, providing contact details is encouraged to facilitate investigation.

6. Protection Against Retaliation

The Company strictly prohibits any form of retaliation against individuals who report concerns in good faith. Retaliation includes dismissal, demotion, harassment, or discrimination.

Any employee found to have engaged in retaliation will be subject to disciplinary action.

7. Investigation Process

All reports will be addressed through the following process:

7.1 Acknowledgement

Receipt of the report will be acknowledged within a reasonable timeframe, where contact details are provided.

7.2 Preliminary Assessment

An initial review will be conducted to determine the validity and seriousness of the report.

7.3 Investigation

A fair, impartial, and thorough investigation will be carried out by authorized personnel.

7.4 Outcome and Action

Appropriate corrective or disciplinary actions will be taken based on the findings of the investigation.

7.5 Closure

The case will be formally closed, and the whistleblower may be informed of the outcome, where appropriate and permissible.

8. Record Keeping

All reports and investigation outcomes shall be properly documented and securely maintained for reference and compliance purposes.

9. False or Malicious Reporting

Reports made in good faith will not result in any penalty, even if unsubstantiated. However, knowingly making false or malicious allegations is strictly prohibited and may result in disciplinary action.

10. Responsibility

• Management: Ensure effective implementation and enforcement of this procedure

• Compliance Officer: Manage reports and investigations

• Employees and Stakeholders: Report concerns and cooperate with investigations

11. Review of Procedure

This procedure shall be reviewed periodically to ensure its effectiveness and alignment with applicable laws and best practices.