REALDEED PROPTECH (DIFC) LTD – WHISTLEBLOWING POLICY (UAE | INDIA | UK)

Introduction

This Whistleblowing Policy outlines the governance framework, escalation procedures, and standards that RealDeed Proptech (DIFC) Ltd (“the Company” or “RealDeed”) follows to uphold uncompromised levels of integrity, transparency, ethical conduct, and professionalism across all jurisdictions in which it operates, including the United Arab Emirates, India, and the United Kingdom.

Although RealDeed operates as a tokenization issuer company not as a financial institution, broker, or virtual asset service provider the Company voluntarily adopts enhanced ethical and governance standards to safeguard its property tokenization, verification technologies, and internal operations against misconduct. This policy establishes a secure, confidential, and independent mechanism for employees, contractors, partners, clients, and other stakeholders to report unethical, illegal, suspicious, or inappropriate behaviour without fear of retaliation.

The purpose of this policy is to ensure that all concerns raised are addressed promptly, objectively, transparently, and with full confidentiality, while fostering a corporate culture rooted in honesty, accountability, and legal compliance. All stakeholders across RealDeed Group are encouraged to whistleblow where necessary and may expect timely acknowledgement, impartial investigations, and appropriate outcomes. This document outlines the structure for reporting, investigation, governance, and whistleblower protection.

Scope

This Whistleblowing Policy applies to all forms of misconduct, unethical behaviour, or procedural violations that may impact RealDeed, its employees, its clients, or its reputation. Covered categories include, but are not limited to:

Fraud

Any intentional act of deception that causes or may cause operational, financial, or reputational harm, including:

• Forging or manipulating Title or Sale Deeds

• Tampering with identity documents

• Fabricating or altering verification records

• Misrepresenting ownership or authority

• Manipulating internal logs, records, or blockchain metadata

  
  

Corruption

Misuse of authority or position for personal benefit, including:

• Bribery, inducements, or kickbacks

• Favouritism in property verification or approvals

• Collusion with third parties

• Abuse of system access rights

  
  

Harassment and Discrimination

Any conduct that contributes to an unsafe or hostile work environment:

• Sexual harassment or misconduct

• Bullying, intimidation, or threats

• Discrimination based on race, gender, age, religion, disability, nationality, or other protected traits

• Offensive, inappropriate, or abusive language

  
  

Safety & Technology Violations

Actions that compromise the security, safety, or integrity of RealDeed systems:

• Breaching cybersecurity protocols

• Mishandling or leaking sensitive data

• Unauthorized system access

• Negligence in verification or compliance tasks

• Failure to escalate document tampering or fraudulent identity attempts

  
  

Operational Misconduct

Behaviour contrary to internal rules or compliance obligations:

• Circumventing AML/KYC requirements

• Approving tokenization without valid documentation

• Misusing DIDIT verification systems

• Suppressing potential red flags or ignoring anomalies

  
  

Retaliation

Any negative action taken against an individual for reporting misconduct is strictly prohibited:

• Termination or demotion

• Threats, intimidation, or harassment

• Exclusion or unfair treatment

• Negative changes to roles, duties, or performance ratings

  
  

RealDeed maintains a zero-retaliation approach. Individuals who report concerns in good faith are protected at all times.

SECTION 1: PROHIBITED ACTIONS

RealDeed is committed to maintaining a safe, transparent, and ethically responsible work environment. The following actions are strictly prohibited:

1.1 Fraud or Corruption

RealDeed enforces a zero-tolerance position toward all forms of fraud or corruption, including:

Falsification of Records

• Altering or manipulating property verification records

• Tampering with digital logs or audit trails

• Forging signatures, seals, or stamps

• Modifying Title or Sale Deeds

  
  

Financial Misconduct

• Misappropriation or misuse of Company assets

• Behaviour designed to deceive internal controls

• Unauthorized approval of tokenization requests

  
  

Bribery and Improper Influence

• Offering, receiving, or soliciting anything of value to influence verification or approval decisions

  
  

1.2 Harassment or Discrimination

RealDeed prohibits behaviour that undermines respect, inclusivity, and equality within the workplace:

Sexual Harassment

• Unwelcome verbal, written, or physical conduct

• Inappropriate digital communication or remarks

  
  

Discrimination

• Unfair or biased treatment based on protected characteristics

• Exclusion or prejudiced decision-making

  
  

1.3 Safety, Technology, and System Violations

Employees must safeguard RealDeed’s systems, infrastructure, and data. Prohibited actions include:

• Bypassing cybersecurity controls

• Ignoring system access protocols

• Failing to escalate suspicious identity or document submissions

• Mishandling sensitive or confidential information

  
  

1.4 Market, Information, or Data Offences

Although RealDeed does not operate a trading or investment platform, the following remain prohibited:

• Unauthorised disclosure of Company-confidential information

• Misuse of internal information

• Suppression or manipulation of verification data or system logs

  
  

Compliance and Enforcement

Any employee or contractor found engaging in prohibited actions will face disciplinary measures, up to and including termination of employment or engagement. RealDeed maintains strict consistency and accountability in the enforcement of this policy.

SECTION 2: REPORTING MECHANISMS

RealDeed provides multiple secure and confidential channels for whistleblowers to report concerns.

2.1 Internal Reporting Channels

Dedicated Email (Confidential Access Only)

📧 support@realdeed.co

In-Person Reporting

Reports may be submitted directly to:

• MLRO

• Chief Executive Officer (for escalated cases only)

  
  

Anonymous Reporting

RealDeed supports anonymous submissions via:

• Encrypted online reporting forms

• Anonymous email services

• Third-party whistleblower tools (if implemented)

  
  

2.2 External / Third-Party Reporting

External stakeholders (including clients, developers, agents, and partners) may report concerns through:

• Website: www.realdeed.co

• Email: support@realdeed.co

• Postal mail (RealDeed DIFC office)

All reports are handled with confidentiality and procedural integrity.

SECTION 3: WHISTLEBLOWING GOVERNANCE

RealDeed has established a structured and impartial governance process for evaluating and resolving whistleblowing reports.

3.1 Impartial Investigations

Upon receiving a report:

1. A neutral Compliance Officer is designated to oversee the investigation.

2. All relevant evidence, documentation, and records are securely collected.

3. Interviews with involved parties or witnesses may be conducted.

4. The MLRO reviews the findings and provides formal recommendations.

5. Management determines the appropriate action or resolution.

Investigations must prioritise:

• Fairness

• Independence

• Confidentiality

• Whistleblower protection

  
  

3.2 Timelines and Transparency

RealDeed ensures timely review and communication:

• Acknowledgement of complaint: within 7 working days

• Investigation timeframe: within 30 working days (extendable if complex)

• Closing summary: provided to the whistleblower when appropriate

  
  

3.3 Conflict Resolution

For interpersonal or internal disputes, HR may provide mediation services.
Mediation will be:

• Neutral

• Objective

• Facilitated by trained personnel

  
  

3.4 Non-Retaliation Policy

RealDeed strictly prohibits any form of retaliation against individuals who:

• Report concerns in good faith

• Assist or participate in investigations

• Refuse involvement in unethical activities

Violators will be subject to disciplinary measures, including termination.

3.5 Confidentiality

RealDeed ensures:

• Strict confidentiality of whistleblowers’ identities

• Disclosure only where legally necessary

• Shared information limited to individuals required for the investigation

  
  

3.6 Disciplinary Measures

Depending on the severity of the violation, RealDeed may apply:

• Verbal or written warnings

• Formal reprimands

• Mandatory retraining

• Suspension or reassignment

• Restriction of system access

• Termination of employment or contract

• Blacklisting for future engagements

• Referral to law enforcement authorities (for criminal matters)