Whistleblower Policy

1. Purpose

This policy aims to encourage the reporting of misconduct, protect whistleblowers from retaliation, and ensure reports are handled in a secure and confidential manner, in line with ADGM Whistleblowing Regulations.

2. Scope

This policy applies to all employees, directors, contractors, and other stakeholders of Waasl Limited

3. Definition of Protected Disclosure

A "Protected Disclosure" refers to any disclosure made in good faith concerning:

• Breaches of legal or regulatory obligations
• Financial misconduct or fraud
• Corruption or bribery
• Endangerment to health or safety
• Unethical behaviour or harassment

4. Reporting Channels

Internal Reporting:

• Reports can be submitted to:
• Whistleblowing Officer: Tariq Alameri, CEO / Founder, tariq.alameri@outlook.com

External Reporting:

• Reports may also be made directly to the ADGM Office of Data Protection or relevant regulatory authority (e.g. FSRA for regulated firms).

5. Confidentiality and Protection

• All reports will be treated confidentially and securely.
• Identities will be protected where requested and feasible.
• Retaliation of any kind against whistleblowers is strictly prohibited. Any attempt at retaliation will result in disciplinary action.

6. Handling and Escalation

• All disclosures will be assessed within [5–10] business days.
• If the disclosure warrants further investigation, an independent process will be initiated.
• Summary findings may be shared with senior management, excluding the identity of the whistleblower (if confidentiality is requested).

7. Awareness and Communication

This policy will be:

• Communicated through onboarding of all employees
• Made available via the company policies documentation

8. Data Protection

Any data collected as part of a disclosure or investigation will be handled in accordance with the ADGM Data Protection Regulations 2021.

9. Policy Review

This policy will be reviewed annually to ensure ongoing compliance and effectiveness. Records of reviews will be maintained by the compliance function.