Whistleblower Policy

Overview: The whistleblowing policy promotes ethical conduct, legal compliance, and transparency at SAMANA Group. It encourages employees to report concerns about criminal activities, health and safety risks, misconduct, or cover-ups. Reports should first be directed to line managers or the Head of HR, with confidentiality assured.

The objective of this policy:

• Maintain the highest standards of business conduct and ethics.

• Compliance with laws and regulations.

• Transparent communication.

• Feel comfortable in raising concern.

• Encourage to report suspected wrongdoing or concern.

• Provide guidance to raise such concerns.

Reportable Matters: Employees, vendors and business partners are encouraged to report various concerns outlined below. However, this mechanism should not be used for grievances related to personal circumstances.

• Fraud / Theft of SAMANA resources.

• Inappropriate use or spending of SAMANA Funds.

• Violations of SAMANA policy resulting in misuse of authority.

• Official misconduct, conflicts of interest, or offering or accepting bribes, vendor/ contractor complaints regarding alleged fraud / bribes etc.

• Falsifying of official documents or unethical behavior.

• Any threats to employee safety / well-being or Actions that harm the environment.

Raising a Whistleblowing Concern: Reportable matters can be reported via:

• Website: Anonymously report concerns from website Click Here.

• Email: whistleblower@samana-group.com (Anonymously write email) Click Here.

• Hotline Toll-Free Number: +971 4 559 5280 (available 24/7) Click Here.

• Courier Mail to Audit & Assurance Department: Head Office - 4th Floor, Building 7, Bay Square Business Bay, Dubai, United Arab Emirates.

Confidentiality:

• SAMANA is committed to safeguarding whistleblower identities and ensuring strict confidentiality for all reports.

• Whistleblowers are expected to keep the details of their concerns confidential to protect the integrity of the investigation.

SAMANA’s Hotline for Whistleblower Policy - Q&A

What is the purpose of the Hotline?

The hotline is designed to allow you to anonymously report any suspected fraud or abuse to us for an independent review.

How is my identity protected when using the Hotline?

You are not required to provide any personal information about yourself. Our phone lines do not have caller IDs, and our emails are set up anonymously through our website.

Who operates the Hotline?

The Audit & Assurance department administers the hotline. The department screens information and conducts the investigations. If deemed necessary, it may be turned over to the proper authorities.

Why should you contact the Hotline?

When there is fraud, waste, or abuse in our company, we all suffer, as employees, vendors, and associates.

When should an incident/ information (tip) be reported?

The tip should be reported as soon as possible. Remember that the longer you wait since the incident occurred, the more difficult it becomes to investigate.

What information do you provide on an incident/ information (tip)?

The more information you can provide, the more effective the investigation. You should provide the following information on the tip:

• Description of the incident.

• Agency, Department, or Person(s) involved.

• Identify any records of support and where located.

• Give dates, times, names, and places.

What should be reported and what should not be reported on an incident/ information (tip)?

Do not report general complaints, suggestions, or personnel issues. Only report material instances of fraud, waste, and abuse that you have witnessed (as examples stated above).

What happens after a fraud incident/ information (tip) is received?

After a tip is received, it is screened by us for a possible investigation. If an investigation is performed and fraud, waste, or abuse is found, management will be informed and will take corrective action. We will also issue an audit report with recommendations to strengthen control weaknesses that allowed the incident to occur.

Where to report?

Anonymously report concerns from Website Click Here, Email: whistleblower@samana-group.com (Anonymously write email) Click Here, Toll-Free Number: +971 4 559 5280 (Available 24/7) Click Here, or Courier Mail to Head office - 4th Floor, Building 7, Bay Square Business Bay, Dubai, United Arab Emirates.