Whistleblower Policy for Rock & Art – Cultural Outreach LTD

1. Introduction

Rock & Art—Cultural Outreach LTD (“the Company”) is committed to conducting its business with honesty and integrity and in compliance with all applicable laws and regulations. As part of this commitment, the Company encourages employees, contractors, vendors, and other stakeholders to report any suspected violations of law, regulation, or Company policies, as well as unethical conduct or other wrongdoing. This Whistleblower Policy outlines the procedures for reporting concerns and protects whistleblowers from retaliation.

2. Scope

This Whistleblower Policy applies to all employees, contractors, vendors, consultants, and other stakeholders of Rock & Art – Cultural Outreach LTD.

3. Reporting Procedure

a. Any individual who becomes aware of suspected violations, misconduct, or unethical behaviour within the Company is encouraged to report such concerns promptly.

b. Reports can be made to any of the following channels:
i. Directly to the individual’s supervisor or manager.
ii. Human Resources department.
iii. Chief Compliance Officer.
iv. Anonymously through a designated hotline or online reporting system.

c. Reports should include specific details regarding the suspected violation, including dates, times, individuals involved, and any supporting evidence or documentation.

4. Confidentiality

a. The Company will handle all reports with the utmost confidentiality to the extent possible, consistent with the need to conduct a thorough investigation.

b. Only individuals directly involved in the investigation will have access to the information provided in the report.

5. Non-Retaliation

a. The Company prohibits retaliation against any individual who, in good faith, reports a suspected violation or cooperates in an investigation.

b. Retaliation includes but is not limited to, termination, demotion, harassment, or any adverse action taken against the whistleblower.

6. Investigation Procedure

a. Upon receipt of a report, the Company will promptly initiate an investigation by designated individuals or committees.

b. Investigations will be conducted impartially, thoroughly, and with respect for all parties involved.

c. Whistleblowers may be contacted for additional information or clarification during the investigation process.

7. Disciplinary Action

a. If an investigation confirms the existence of a violation, appropriate disciplinary action will be taken against the individuals involved, up to and including termination of employment.

b. Disciplinary action will be determined based on the severity of the violation and by Company policies and procedures.

8. False Reports

a. Knowingly making a false report or providing false information during an investigation violates Company policy and may result in disciplinary action, including termination of employment.

9. Compliance and Review

a. This Whistleblower Policy shall be communicated to all employees, contractors, vendors, and other relevant stakeholders.

b. The Policy shall be reviewed periodically to ensure its effectiveness and compliance with applicable laws and regulations.

c. Any updates or revisions to the Policy will be communicated to all stakeholders accordingly.

Rock & Art – Cultural Outreach LTD is committed to fostering a culture of integrity, transparency, and accountability. This Whistleblower Policy serves as a mechanism for individuals to report concerns and ensures that such reports are handled promptly, fairly, and with confidentiality. The Company encourages all stakeholders to utilize this Policy to help maintain a positive and ethical work environment.