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Whistleblower Policy

Last Updated: December 05, 2025

1. Purpose

This policy provides an environment for employees, contractors, or affiliated parties to disclose information about suspected wrongdoing, illegal activities, fraud, misconduct, or violations of ShantKid Resorts' policies or applicable laws. This policy ensures that individuals who report suspected wrongdoing, mismanagement or unlawful conduct are able to do so without fear of retaliation or harassment.

2. Scope

This policy applies to all individuals employed with ShantKid Resorts including but not limited to:

  • All employees (full-time, part-time, temporary, contract)
  • Independent contractors
  • Volunteers and interns
  • Former employees
  • Vendors and partners
  • Patients (as per government)

3. Reportable Conduct

You should use this policy to report suspected conduct about suspected wrongdoing or dangerous violations of any of our policies or laws, including but not limited to:

  • Fraud, theft, embezzlement, or misappropriation of funds
  • False Claims
  • Failure to comply with laws or regulations
  • Breach of patient confidentiality
  • Unsafe or unethical healthcare practices
  • Discrimination or harassment (including sexual harassment)
  • Conflicts of interest
  • Retaliation or attempts to prevent lawful or proper reporting
  • Environmental or safety violations
  • Misuse or abuse of clinic resources

4. How to Report

a) Internal Reporting

Reports should be made to any of the following individuals:

  • Direct supervisor or manager
  • Human Resources Department
  • Compliance Officer
  • Chief Executive Officer (CEO)
  • Anonymous reporting (email: whistleblower@shantiresorts.com)
  • You can also report using our confidential hotline at +94 (XXX) XXXXXXX

b) Anonymous Reporting

If you prefer to remain anonymous, you may submit a report via email (whistleblower@shantiresorts.com) or through the confidential whistleblower hotline. While anonymous reports will be investigated, please note that the ability to follow up or ask additional questions may be limited.

5. Protection Against Retaliation

ShantKid Resorts strictly prohibits retaliation against any person who reports

Reports in good faith or supports an investigation or inquiry

Retaliation includes (but is not limited to):

Termination, demotion

Reduction in compensation or changes in job duties or terms

Threats, intimidation, or harassment

Retaliation is a serious violation of this policy, and anyone found to be retaliating against an individual for reporting suspected wrongdoing or participating in an investigation may be subject to disciplinary action, up to and including dismissal.

6. Investigation Process

a) Initial Assessment

Upon receipt of a report, the appropriate department will assess the report to determine the appropriate next steps and ensure that the investigation is conducted promptly and fairly.

b) Investigation

If a preliminary investigation reveals a reasonable basis for the allegations, the investigation will be conducted by an impartial investigator (internal or external) and may include interviewing the reporter, the accused, and other relevant parties, as well as reviewing documents.

c) Confidentiality

All whistleblower reports will be treated as confidential to the extent possible while making a thorough investigation.

d) Timeframe

Investigations will be conducted as promptly as possible. The timeframe may vary depending on the complexity of the issue.

7. Outcomes and Follow-up

Following the investigation:

Appropriate action will be taken if a violation is found, including but not limited to corrective measures and/or

The reporter will be updated on the outcome of the investigation (to the extent possible) within a law and confidentiality requirement

If the allegation is not substantiated, no action will be taken, and the matter will be considered closed

Whistleblowers reporting in good faith should not fear disciplinary action even if no wrongdoing is proven or not substantiated.

8. Good Faith Reporting

This policy is intended to be used to report legitimate concerns. While you are not required to prove that a violation has occurred, all reports should be made in good faith. If a report is made with malicious intent or is knowingly false or misleading, the person making the report may be subject to disciplinary action, including termination.

9. Record Keeping

All reports and investigations conducted under this policy will be documented and retained in accordance with applicable laws, regulations, and ShantKid Resorts' internal record-keeping policies.

10. External Reporting

In addition to our internal reporting mechanisms, you may also report illegal or unethical activities to external regulatory or law enforcement authorities, such as [NAME OF REGULATORY BODY]. This policy does not restrict your ability to report matters to external authorities as provided by law.

11. Policy Review

Our Whistleblower Policy will be reviewed on a periodic basis to ensure that it remains in compliance with applicable laws and regulations and continues to align with our values and operational practices.

Your Voice Matters

We value your commitment to upholding the integrity of our organization. By speaking up when you observe potential violations, you help us to ensure a safe and ethical workplace for everyone. We appreciate your courage in coming forward and assure you that your reports will be treated seriously and with the utmost confidentiality and respect.

12. Contact Information

If you have any questions about this policy or need assistance in reporting, please contact:

Compliance Officer

Email: whistleblower@shantiresorts.com

Phone: +94 (XXX) XXXXXXX

Or contact [NAME OF REGULATORY BODY]